RFP_5000_BYS3046_ATT_2_v1.pdf

CONFINED SPACE

PROGRAM

City of Austin Department of Aviation (DOA)

Prepared For:

City of Austin Department of Aviation (DOA) 2716 Spirit of Texas Drive Austin, TX 78719

Prepared By:

TRC Environmental Corporation 505 East Huntland Dr.

Austin, TX 78752

ATTACHMENT 2

i

TABLE OF CONTENTS

Section 1.0 Purpose and Scope

Section 2.0 Regulatory Background

2.1 Definitions

Section 3.0 Duties and Responsibilities

3.1 DOA Confined Space Office

3.2 DOA Supervisors

3.3 DOA Designated Employees

3.4 Affected DOA Employees

3.5 DOA Tenants and Utility Corridor Owners

3.6 Controlling Contractor

Section 4.0 Program Elements

4.1 Identification and Classification of Confined Spaces

4.2 Confined Space Reclassification

4.3 Changes in Space Use or Configuration

4.4 Preventing Unauthorized Entry

4.5 Confined Space Entry Procedures

4.5.1 Pre-entry Requirements

4.5.2 Emergency Preparedness

4.5.3 Entry Operations

4.5.4 Post-Entry Review Meetings

4.6 Alternate Entry Procedures

Section 5.0 Employee Training

Section 6.0 Document Control and Program Evaluation

Appendix A – Permit-Required Confined Space Inventory

Appendix B – Confined Space Map

Appendix C – Confined Space Entry Permit

Appendix D – DOA Tenant and Utility Corridor Owner Confined Space Entry Minimum Requirements

Section 1.0 Purpose and Scope

The purpose of this document is to establish consistent procedures to (1) prevent unauthorized entry into permit-required confined spaces (PRCS or permit space), (2) identify and evaluate permit-required confined space hazards, and (3) implement the means, procedures, and practices necessary for safe entry operations at Austin-Bergstrom International Airport. Adherence to the requirements of this procedure will help ensure that risk to employees from the hazards posed by confined spaces is minimized or eliminated.

This document serves as the City of Austin Department of Aviation’s (DOA) Permit-Required and Non-

Permit Required Confined Space Entry Program. This Program covers all DOA employees and DOA

Contractors that are not part of the DOA Capital Improvement Program (CIP) who enter confined spaces and contains the practices and procedures for their safe entry. Confined space entry located within a utility corridor, project limits of a DOA CIP project, tenant lease area or other third party controlled areas will be managed under their own PRCS program that, at a minimum, meets the requirements of this

Program and the requirements under the Occupational Safety and Health Administration (OSHA) regulations for permit-required confined spaces codified in Title 29 of the Code of Federal Regulations (29

CFR), Part 1910, Subpart J, Section 146 (29 CFR 1910.146) and/or 29 CFR Part 1926, Subpart AA, Sections 1201 through 1213 (29 CFR 1926.1201 to 1926.1213).

This Program addresses the following elements:

Implementation of measures necessary to prevent unauthorized entry;

Identification and evaluation of hazards before entry;

Development of safe operating procedures for entry operations; and, Distribution, maintenance, and proper use of entry equipment at no cost to employees.

The objectives of this Program are to:

Prevent illnesses or injuries related to entry and/or work in permit-required confined spaces;

Identify the DOA Permit System for confined space entry including preparation, use, and cancellation of permits. The Permit System includes outside contractors who must have proof of their own program, permit entry system, training and safety equipment;

Identify and classify confined spaces on the DOA campus, determine their hazards, and address the reclassification of spaces; and, Identify the necessary steps for entry into confined spaces including monitoring and equipment that may be required.

Section 2.0 Regulatory Background

The Occupational Safety and Health Administration (OSHA) standards 29 CFR 1910.146 and 29 CFR

1926.1201-1213 require identification of confined spaces in the workplace; evaluation of the spaces;

prohibition of unauthorized access to permit-required spaces; and development of a confined space entry permit program to be implemented and available at the worksite of the permit-required spaces.

Working in a permit-required confined space requires that employers prepare a permit in a standardized format, through which the employer identifies all conditions to evaluate to ensure safe entry. Under the entry permit program, the employer shall include the following information:

Hazard Identification – Identify and evaluate each hazard of the permitted spaces, including determination of severity.

Hazard Control – Establish the means, procedures, and practices by which the permitted spaces can be entered safely.

Permit System – Establish a written permit system for the proper preparation, issuance, and implementation of entry permits.

Employee Information – Indicate that signs shall be posted near permitted spaces to notify employees what hazards may be present and that only authorized individuals may enter the permitted spaces.

Prevention of Unauthorized Entry – Identify measures such as training or posting signs and barriers to prevent unauthorized employee entry, as necessary.

Employee Training – Describe training provided to employees so that attendants, authorized entrants, and entry supervisors in charge of entry can work safely in and around the permitted space.

Equipment – Discuss means by which to provide, maintain, and ensure the proper use of the equipment necessary for safe entry, including testing, monitoring, communication, and personal protective equipment.

Rescue – Identify procedures and equipment to rescue entrants from permitted spaces and ensure they are implemented and provided.

Protection from External Hazards – Describe pedestrian, vehicle, or other barriers used to protect entrants from external hazards.

Duty to Other Employers – Discuss procedures to implement when an employer, such as a contractor, plans to send employees into a permitted space that is under the control of another employer (host employer). The host employer provides the contractor with all available information on permitted space hazards, on efforts to comply with this standard, and on any other workplace hazards, safety rules, and emergency procedures of which the contractor needs to be aware of in order to comply with this standard.

The regulatory requirements for confined spaces apply to any space that meets all of the following conditions:

Is large enough, and so configured that an employee can bodily enter and perform assigned work;

Has limited or restricted means for entry or exit; and, Is not designed for continuous employee occupancy.

Examples of confined spaces include, but are not limited to: pipes, ducts, mixers, tanks, vessels, pits, vaults, manholes, conduits, wells, stacks, tunnels, shafts, chillers, steam condensers, boiler drums, incinerators, scrubbers, sewers, storm drains, water mains, lift stations, cesspools, digesters, silos, hoppers, sludge gates, air receivers/preheaters, turbines, coffer dams, bunkers, storage bins, compartments, filter or process equipment, equipment housings, penthouses, and any potentially hazardous storage, mixing, or process areas.

Requirements for permit-required confined space (permit space) apply to confined spaces that have one or more of the following characteristics:

Contains or has a potential to contain a hazardous atmosphere

Contains a material that has the potential for engulfing an entrant

Has an internal configuration such that an entrant could be trapped or asphyxiated by inwardly converging walls, or by a floor which slopes downward and tapers to a smaller cross-section

Contains any other recognized, serious safety or health hazard

2.1 Definitions

Attendant – an individual stationed outside one or more permitted spaces who monitors the authorized entrants and who performs all attendant's duties assigned in the employer's permitted space program.

Authorized entrant – an employee who is authorized by the employer to enter a permitted space.

Competent Person – one who is capable of identifying existing and predictable hazards in the surroundings or working conditions which are unsanitary, hazardous, or dangerous to employees, and who has authorization to take prompt corrective measures to eliminate them.

Controlling Contractor – the Host Employer with the overall responsibility for construction at the worksite. Note: If the controlling contractor owns or manages the property, it is both a controlling employer and a host employer.

DOA Capital Improvement Program – construction projects that are delivered through the City of Austin

Capital Contracting Office that include contract language that the contractor is the Host Employer for the limits of construction. See Appendix D for requirements.

DOA Contractor – hired company that performs services under the direction of the Department of

Aviation and could enter DOA controlled portions of Austin-Bergstrom International Airport. For example, a networking company that is contracted by the DOA to pull fiber through manholes on airport property.

DOA Tenant – company that has a lease agreement with the City of Austin Department of Aviation that includes defined occupancy space limits on airport property or within a DOA maintained building.

Employer - contractor or subcontractor within the meaning of OSHA and 29 CFR 1910/1926.

Engulfment – the surrounding and effective capture of a person by liquid or finely divided (flowable) solid substance can be aspirated to cause death by filling or plugging the respiratory system or that can exert enough force on the body to cause death by strangulation, constriction, or crushing.

Entry Employer – any employer who decides that an employee it directs will enter a permit space.

Entry supervisor – the person (such as the employer, foreman, or crew chief) responsible for determining if acceptable entry conditions are present at a permitted space where entry is planned, for authorizing entry and overseeing entry operations, and for terminating entry as required by this section.

Note: An entry supervisor also may serve as an attendant or as an authorized entrant, as long as that person is trained and equipped as required by this section for each role he or she fills. Also the duties of the entry supervisor may be passed from one individual to another during the course of an entry operation.

Entry permit – (permit) the written or printed document that is provided by the employer to allow and control entry into a permitted space.

Entry – the action by which a person passes through an opening into a permit-required confined space.

Entry includes work activities performed in that space and is considered to have occurred as soon as any part of the entrant’s body breaks the plane of an opening into the space. Reaching into the space with a tool is not considered entry.

Host Employer – the employer that owns or manages the property where the construction work is taking place.

Note: If the owner of the property on which the construction activity occurs has contracted with an entity for the general management of that property, and has transferred to that entity the information specified in

§ 1926.1203(h)(1), OSHA will treat the contracted management entity as the host employer for as long as that entity manages the property. Otherwise, the owner of the property is the host employer. In no case will there be more than one host employer.

Hazardous atmosphere – an atmosphere that may expose employees to the risk of death, incapacitation, impairment of ability to self-rescue (that is, escape unaided from a permitted space), injury, or acute illness. Such hazards, can be presented by one or more of the following:

Flammable gas, vapor, or mist dust in excess of 10 percent of its lower flammable limit (LFL)

Airborne combustible dust at a concentration that meets or exceeds its LFL

Atmospheric oxygen concentrations below 19.5 percent (oxygen deficient) or above 23.5 percent

(oxygen enriched)

Atmospheric concentrations of any substance in excess of their permissible dose or exposure limit published within Subpart G or Subpart Z of the regulation.

Hot work permit – the employer's written authorization to perform operations (for example, riveting, welding, cutting, burning, and heating) capable of providing a source of ignition.

Immediately dangerous to life or health (IDLH) – any condition that poses an immediate or delayed threat to life or that would cause irreversible adverse health effects or that would interfere with an individual's ability to escape unaided from a permitted space.

Non-Permitted space – is a confined space that does not contain and has no potential to contain any hazard capable of causing death or serious injury.

Retrieval system – the equipment (including a retrieval line, chest or full-body harness, wristlets, if appropriate, and a lifting device or anchor) used for non-entry rescue of persons from permitted spaces.

Utility Corridor – a defined horizontal and/or vertical space on airport property that is dedicated to third party utilities (e.g., electrical, communication, computer, etc.). Each utility owns, maintains and operates their infrastructure located in utility corridors on airport property. The DOA does not own or maintain this infrastructure. The utility corridor is similar to a utility easement.

Section 3.0 Duties and Responsibilities

3.1 DOA Confined Space Office

This Program is coordinated through the DOA Confined Space Program Manager. This position is responsible for maintaining this Program. The DOA Confined Space Office will be available to answer specific questions about the Program and interpretations of its content.

The DOA Confined Space Office will periodically audit work operations and documentation using canceled permits to evaluate the overall effectiveness of the confined space entry program and ensure that employees participating in entry operations are protected from permitted space hazards. The DOA

Confined Space Office will also have the following responsibilities with respect to this program:

Maintain a current list of identified confined spaces is attached to this program as found in

Appendix A;

Classify confined spaces as "permit-required”; until confined space is temporarily reclassified as non-permit required;

Provide training on confined space hazards and entry procedures to those who may enter confined spaces;

Inform contractors and other non-DOA employees of the location of DOA controlled confined spaces;

Approve DOA contractor Confined Space Program;

Approve DOA tenant Confined Space Program when the tenant is entering a confined space outside of their lease area;

Approve DOA CIP construction contractor Confined Space Program;

Provide instruction to personnel on the proper selection and use of equipment required for confined space entry under this program including the appropriate air monitoring equipment, respiratory protection, and personal protective equipment (PPE);

Supply adequate storage and maintenance of all equipment except personal respirators;

Conduct work site inspections to review compliance with confined space entry procedures;

Maintain records of equipment maintenance, entry permits, air monitoring results, and employee training; and, Inform employees who may enter a permitted space by posting danger signs and by providing training of the existence and location of the space, and the danger posed by entry into the space.

3.2 DOA Supervisors

Supervisors with designated employees are responsible for implementing the program and making it available to employees. Supervisors will have the responsibility for the following, with respect to this program:

Identify and report job areas and locations that are or may be confined spaces and ensure all permit required confined spaces are posted;

Coordinate PRCS entries with DOA Confined Space Office;

Identify personnel who will take part in the entry of a permit-required confined space;

Ensure training on confined space hazards and entry procedures for rescue teams and to those who may enter confined spaces;

Ensure their contractors are complying with the DOA Confined Space Entry Program;

Ensure the DOA Confined Space Office has approved each contractor’s Confined Space

Program;

Confirm instruction has been provided to personnel on the proper use of equipment required for confined space entry;

Provide and maintain equipment that is used to enter confined spaces for rescue teams and to those who may enter confined spaces;

Conduct work site inspections to review compliance with confined space entry procedures;

Evaluate Rescue Teams/Service to ensure they are adequately trained and prepared;

Maintain records of equipment maintenance, entry permits, air monitoring results, and employee training; and, Take the necessary measures to prevent unauthorized entrance (i.e., entry without a permit, etc.)

into permitted spaces and report any previously un-identified hazards associated with confined spaces.

3.3 DOA Designated Employees

Employees involved in a permit-required confined space entry will be designated as an entrant, an attendant, or an entry supervisor. The roles and responsibilities of these designations vary and are described in Section 4.5. All employees who enter and work with/near confined spaces shall be responsible for the following:

Comply with the confined space entry procedures contained herein and with those procedures stipulated by their supervisor;

Store, clean, and maintain equipment used for confined space entry;

Report any deficiencies or malfunction of equipment to their supervisor or DOA Confined Space

Office;

Understand emergency procedures in case of an accident in a confined space;

Under no circumstances enter a confined space that is suspected of having a non-respirable atmosphere, even to rescue a fellow employee;

Participating in the development and implementation of the Confined Space Entry Program; and, Must be trained in permitted confined space (CS) entry and awareness. OSHA 10 & 30 hour training does not constitute confined space training.

3.4 Affected DOA Employees

DOA employees that work in divisions in which their daily work activity may require the interaction with a confined space or permit-required confined space will be trained to recognize permit-required confined spaces, associated signage and will receive awareness training on the hazards associated with confined spaces. The DOA also expects all other property lease holders, contractors, and other parties operating confined spaces within DOA property boundaries to train their employees to recognize permit-required confined spaces, associated signage, and will receive awareness training on the hazards associated with confined spaces.

3.5 DOA Tenants and Utility Corridor Owners

DOA Tenants and Utility Corridor Owners working in or near confined spaces are required to meet the required Duties and Responsibilities outlined in Section 3.0 as they apply to their operations. The DOA

Confined Space Office will have the authority to review all operations conducted by DOA Tenants and

Utility Corridor Owners including their contractors. DOA Tenants and Utility Corridor Owners requiring entry into confined spaces outside of their lease hold or utility corridor will require DOA Confined Space

Office approval.

3.6 Controlling Contractor

The Controlling Contractor acknowledges and agrees that the DOA, Tenant or Utility Corridor Owner is temporarily transferring management and control of the worksite to the Contractor for the purpose of constructing the Project. The Contractor‘s responsibilities to manage the work includes the responsibility to manage the worksite property for purposes of compliance with 29 CFR 1926 Subpart AA. To the best of DOA’s knowledge and belief, DOA has provided the following information in the plans and specifications and/or other Contract Documents: (i) the location of each known confined space, (ii) the hazards or potential hazards in each space or the reason it is a permit space; and (iii) any precautions that the Owner or any previous contractor has implemented for the protection of employees in the permit space. This transfer will result in the Contractor being both the host employer and the controlling contractor for this portion of the work.

3.7 DOA Contractors

DOA contractors or other non-DOA employees may enter permitted spaces under DOA control to perform work. Coordination of entry operations must occur when sites have multi-employer entries to avoid endangerment of employees. When contractors or other non-DOA employees enter DOA controlled permit confined spaces, the DOA Confined Space Office or designated authority is responsible for informing them of the DOA Permit-Required Confined Space Entry Program. Contractors or other non-

DOA employee is responsible for complying with this program as well as their own Permit-Required

Confined Space Entry Program.

It is the responsibility of DOA to ensure that they:

Approve DOA contractor confined space program;

Approve DOA contractor or other non-DOA employee entry into any DOA controlled confined space;

Confirm DOA contractors or other non-DOA employees are informed that the workplace contains permitted spaces, that they must follow a permitted space entry program per OSHA Standard

29CFR1910.146 and that they must use an authorized permit for entry;

Apprise DOA contractors or other non-DOA employees of the elements, including the hazards identified and the experience with the space making it a permitted space;

Inform DOA contractors or other non-DOA employees of the precautions or procedures implemented for protection of employees in or near permitted spaces;

Ensure that all activities of multi-employer operations are coordinated; this includes mandatory participation in the pre-entry review meeting and post-entry debriefing; and, Debrief the contractor at the conclusion of the entry regarding the DOA permitted space program followed and any hazards confronted or created in space(s) during entry operations.

All DOA contractors or other non-DOA employees performing permitted space entry are required to:

Obtain existing condition of confined space information from DOA;

Develop and follow their own PRCS Entry Program that is at least as stringent as the DOA

Program and approved by the DOA Confined Space Office;

Receive approval from DOA Confined Space Office prior to any entry;

Coordinate entry operations with others working in or near permitted spaces;

Submit Employees Confined Space Training Documents to the DOA Confined Space Office;

Submit their entry permit and atmospheric testing results to DOA Confined Space Office; and, Prevent entry of contractors or other non-DOA employees into a DOA controlled confined space without prior written approval from the DOA.

3.8 DOA Maintained Elevators and Escalators

All contractors and other non-DOA employees are responsible for the following when performing work on elevators and escalators that may include entries into a confined space:

Provide a Confined Space Entry Program to the DOA Confined Space Office along with confined space training certificates for those designated to manage and enter the confined spaces;

Provide lock out/tag out procedures to the DOA Building Maintenance Division before work begins. These procedures must be accepted before performing the work;

Develop and provide a preventative maintenance schedule to DOA Building Maintenance

Division;

Schedule work with the airport maintenance team at least 4 days in advance, including confined space entries. Provide notice to DOA Building Maintenance staff for any unscheduled or emergency repairs. All repairs activities must include the presence of an attendant while the work is being completed and a review of repairs with Maintenance staff once completed; and, Coordinate between the elevator service and repair companies and the host employer with respect to the initial evaluation of the pit space for compliance with the PRCS Program. This will include obtaining the necessary hazard information from the host employer to allow the elevator company to evaluate or reevaluate the elevator pit space, if available.

While most pits may not contain a potential atmospheric hazard, elevator pits generally are permit-required confined spaces by virtue of the electrical-mechanical hazard(s). Where the electrical-mechanical hazard(s) can be eliminated, and where there are no potential or actual atmospheric or other hazards, the pit can be [re-classified] and rendered non-permit required spaces by employing the procedures specified in paragraph 1910.146(c)(7). All testing and documentation must be provided to

DOA Confined Space Manager and Building Maintenance Manager for reclassifying a permit required confined space.

Section 4.0 Program Elements

4.1 Identification and Classification of Confined Spaces

Prior to entering a confined space, a competent person must confirm the classification of the confined space as either a (1) permit-required confined space, or (2) a non-permit confined space. The DOA has evaluated the facility to identify most permit-required confined spaces. See Appendix A for a current list of known permitted spaces.

Properly trained and supervised DOA employees, tenants, and contractor personnel may enter confined spaces as part of their service or repair activities. These spaces primarily consist of manholes, utility corridors, storm water gathering systems, grease traps, elevator shafts, construction trenches, boiler vessels, conveyor belt systems, and above ground storage tanks (ASTs). Affected employees will be notified of permit-required confined spaces via posted danger signs that include information on the existence, location, and hazards of each space.

In the case of DOA contracted employees on site for DOA authorized confined space activities, the DOA must provide the contracted employees with the location of each known permit-required confined space, known or potential hazards in each space and all precautions that have been implemented for the protection of employees. DOA Tenants and their approved contractors must operate as their own controlling contractor for confined space and permit-required confined space entries operated within the boundaries of their leaseholds and must maintain their own confined space program and recordkeeping.

When these entities enter confined spaces outside of their lease hold, the DOA will serve as the controlling contractor and all other entities will adhere to the DOA confined space program unless their confined space program is shown to be more rigorous. All confined space activities conducted on DOA controlled property, which excludes tenant lease holds and DOA CIP project limits, should be communicated and cleared by the DOA Confined Space Office before proceeding.

DOA CIP projects will have a controlling contractor that is contractually required to obtain the host employer’s information about the permitted confined space hazards and previous entry operations. This information must be provided to each entity entering a permitted space and any other entity at the worksite whose activities could foreseeably result in a hazard in the permitted space.

The CIP controlling contractor will submit their Confined Space Program for approval by the DOA

Confined Space Office prior to starting construction. The approved program will be implemented by the controlling contractor for the duration of the project. The DOA Confined Space Office will inspect program implementation and records periodically. Records are to be maintained on-site at all times.

Utility owners that are entering confined spaces within a formal utility corridor or utility easement will be classified as the controlling contractor and be responsible for managing their own Confined Space

Program.

The entry employer must obtain related entry information from the controlling contractor and inform the controlling contractor of their permitted space program.

The controlling contractor and the entry employer must coordinate entry operations when:

More than one entity performs permitted space entry at the same time; and/or, Entry is performed at the same time that any activities that could foreseeably result in a hazard in the permitted space.

The controlling contractor must debrief each entity that entered a permitted space regarding the permitted space program that was followed and any hazards encountered or created in the permitted space(s) during entry operations.

4.2 Confined Space Reclassification

A permit-required confined space may be reclassified as a non-permit confined space by a competent person under the following conditions:

If the space poses no actual or potential atmospheric hazards and all physical hazards are permanently eliminated or isolated through engineering controls without entry (forced air ventilation does not constitute elimination/isolation); and, Testing and inspection during an authorized entry demonstrate the hazards were eliminated without requiring continuous forced air ventilation.

In the event of reclassification, the basis for determining that all hazards in the space were eliminated or isolated must be documented and certification of the space reclassification shall contain the date, location of the space and the signature of the person making the determination.

In certain, specific conditions, the employer may allow alternate procedures to enter a space under non-permit conditions.

These conditions include documentation that:

All physical hazards in the space have been eliminated/isolated through engineering controls, leaving only actual/potential hazardous atmosphere as a hazard;

Continuous forced air ventilation is used to maintain safe entry; and, The space is continuously monitored, unless there is supporting data that demonstrates this is unnecessary.

If hazards arise within a permitted space that has been declassified to a non-permitted space, each employee must exit the space. Prior to re-entry, the space must be reevaluated to determine if it must be reclassified as a permitted space.

4.3 Changes in Space Use or Configuration

When there are changes in the use and configuration of a non-permit confined space that might increase the hazards to entrants, the space is to be reevaluated and, if necessary, reclassified as a permit-required confined space. Any changes should be brought to the attention of the DOA Confined Space Office for

DOA controlled property.

4.4 Preventing Unauthorized Entry

For each specific location containing a permit-required confined space, the following measures are to be implemented as necessary to prevent unauthorized employee entry:

Affected employees will be informed through safety training about the characteristics, presence, and location of permitted spaces;

Permitted spaces will be identified with danger signs;

Contractors and visitors will be informed as to the presence of and hazards associated with confined spaces, as appropriate; and, Affected employees will be trained on how to identify confined spaces.

4.5 Confined Space Entry Procedures

This Program is designed to prevent unauthorized entry into permit-required confined spaces, identify and evaluate hazards, and establish procedures and practices for safe entry including testing and monitoring conditions on DOA controlled property. The program requires an attendant to be stationed outside permitted spaces during entry; includes procedures to summon rescuers and prevent unauthorized personnel from attempting rescue; and a system for preparing, issuing, using, and canceling entry permits. All other entities operating within the ABIA boundaries that include or may include permit confined space entry within their contracted or leased portion of the airport property must develop and maintain their own PRCS Program to be followed when operating within the boundaries of their property.

The DOA will periodically audit contractor and leaseholder PRCS plans and plan recordkeeping to ensure the plans are being adhered to.

The following means, procedures, and practices necessary for safe permit-space entry operations have been implemented as part of the DOA’s PRCS.

4.5.1 Pre-entry Requirements

A. Notifications

Prior to the start of a permit-required confined space entry operation on DOA controlled property, both the

DOA Confined Space Office (or designated representative and the DOA departmental supervisor/manager must be notified of the proposed entry.

B. Pre-Entry Review Meeting

Prior to entering a permit-required confined space, the entry supervisor must conduct a pre-entry review meeting with all persons involved in the operation, including employees and contractors. The pre-entry review meeting must, at a minimum, discuss the following topics:

Hazards associated with the space;

The method of communication to be used between the entrants and the attendants;

How emergency services are summoned;

The use of required equipment; and, The specific duties and responsibilities of each of the participants.

C. Isolating the Permitted space

All hazardous energy sources associated with permitted spaces that may expose entrants to potential injury must be isolated and locked out and/or tagged out prior to entry. Due to the inherent hazards associated with confined space entries, preference shall be given to isolating the space utilizing standard lockout/tagout procedures.

D. External Hazards

Barriers to prevent pedestrian and/or vehicle traffic must be provided as necessary to protect entrants from external hazards.

E. Means of Egress

If possible, a ladder should be provided in all confined spaces deeper than the employee's shoulders.

The ladder shall be secured and not removed until all employees have exited the space. In addition, a mechanical device shall be available to retrieve personnel from all vertical type permitted spaces more than 5 feet deep.

F. Lighting

The lighting used should be a minimum of 20 foot-candles, or 20 feet of unobstructed vision, and must meet the classification rating for the area in which it is to be used. All lighting used should be intrinsically safe and rated for use in explosive atmospheres.

G. Atmospheric Monitoring

Prior to entering a confined space, the atmosphere must be tested to determine if acceptable entry conditions exist before entry is authorized to begin. Atmospheric testing must be performed on the same date and time as the entry and prior to entry. To the extent feasible, entry conditions should be continuously monitored in work areas and include provisions for an early-warning system when non-isolated engulfment hazards are present. The tests and monitoring should be conducted in permitted spaces as necessary to determine if acceptable entry conditions are being maintained during entry operations.

Employees or their designated representative shall be provided the opportunity to observe the testing of the space upon pre-entry and subsequent testing. Results of the tests must be maintained with the permit and made available to all employees participating in the entry project and/or their designated representatives.

A person who has been properly trained shall conduct the atmospheric monitoring using equipment that has been calibrated in accordance with the equipment manufacturer’s instructions. The type and frequency of atmospheric monitoring will be determined by the person conducting the tests and must be stated on the permit. When conducting tests for atmospheric hazards, oxygen tests shall be conducted first, then combustible gases and vapors, followed by toxic gas/vapor tests. The tests are conducted in order to ensure that test instruments function properly since an oxygen deficient atmosphere may adversely affect the test results.

Acceptable Entry Conditions

For entries by personnel, the following values are to be considered acceptable atmospheric entry conditions:

Oxygen Level 19.5% - 23.5%

Flammables <10% of the lower explosive limit (LEL)

Toxic (CO) < 35 parts per million (ppm)

Toxic (H2S) <10 ppm

The Entry Supervisor must be contacted for instructions and/or approval if these values cannot be achieved.

Note: If monitoring indicates that the lower explosive limit exceeds 10 percent in the space and the entry

Supervisor has approved entry, all tools must be non-sparking, only low-voltage explosive-proof lights may be used, and all equipment must be intrinsically safe. Atmospheres above 50% LEL must NOT be ventilated due to explosion hazard.

The air should be tested at several levels within the space as gases may settle into layers. Continuous air monitoring may be required if the atmosphere can change, such as during welding, painting, descaling, chemical cleaning, or working with sewers. Continuous air monitoring is recommended for all entries, with readings verified every 10-15 minutes. A secondary monitor may be worn by one or more entrants as an added precaution.

Re-testing is required should an extended break occur or if new hazards are introduced.

Re-testing may also be requested by an authorized entrant or attendant who suspects that conditions have changed or that the initial evaluation of the space was not adequate.

Any testing that indicates conditions outside of the defined safe entry levels listed on the entry permit will require further evaluation of the space. The Entry Supervisor must be made aware of this situation and consulted prior to continuing with the entry. The use of ventilation or personal protective equipment, such as respirators may be required to continue. There must be no entry into this type of confined space without approval by the Entry Supervisor.

If ventilation is to be used to eliminate conditions of a hazardous atmosphere, ensure that the space is ventilated before starting work in the confined space, and for the duration of the work is to be performed in the space. Where air-moving equipment is used to provide ventilation, chemicals shall be removed from the vicinity to prevent introduction of fumes or vapors into the confined space. Vehicles shall not be left running near confined space work or near air-moving equipment being used for confined space ventilation.

H. Purging, Inerting, Flushing, or Ventilating Permitted spaces

All permit entry spaces are thoroughly purged, inerted, flushed, and/or ventilated as necessary to ensure the elimination and/or control of all hazards which may cause entrants injury and /or illness. The minimum length of time to ventilate a space before it is considered safe must be calculated and must meet the OSHA standard of at least 20 complete air volume changes of the space per hour or one complete air volume change every 3 minutes. The minimum amount of time the space should be ventilated prior to air testing and entry should be determined using the formula below.

I. Written Entry Permit

No task(s) involving entry into a permitted space may begin until an appropriate Confined Space Entry

Permit (see Appendix B) is issued. A written confined space entry permit must be completed for each permit-required confined space entered at any of the DOA facilities. An Entry Supervisor shall initiate the permit. The permit will be completed by the personnel involved in the entry and must be approved by the

Entry Supervisor before personnel will be permitted to enter the confined space. Approval by the Entrant

Supervisor will be documented through their review and signature on the permit.

The permit shall be valid only for the performance of the work identified, and for the location and time specified. Permits must be reissued at the beginning of each workday or each work shift.

The permit shall be considered void if work in the confined space causes unanticipated changes within the space, or changes in the work scope or duration occur.

The permit must be posted at the entry portal, and copies shall be placed in the project site file and retained for a minimum of three years. Upon project completion, these records will be forwarded and kept by the DOA Confined Space Office.

Volume of Space ________cubic feet

Ventilation device flow rate ________CFM X 20 (# of air changes) = _________minutes

The following requirements must be recorded on the entry permit:

Permitted space to be entered, purpose of the entry, and date and authorized duration of the entry permit;

Names of authorized entrants (or suitable tracking system);

Attendants' name(s);

Entry supervisor's name and signature, including original authorizing supervisor;

Identify and evaluate the hazards of the space;

Measures used to isolate the space and to eliminate or control the space hazards, internally and externally, before entry;

Purge, inert, flush or ventilate the permitted space as necessary to eliminate or control atmospheric hazards;

Specify acceptable entry conditions (see Section 4.5.1 G) and verify that conditions are acceptable throughout the duration of the authorized entry;

Results of initial and periodic tests accompanied by the names or initials of the testers and time of the tests;

Available rescue and emergency services and how to summon them;

Communication procedures used by entrants and attendants to maintain contact during entry and rescue requirements;

Equipment, such as personal protective equipment, alarm systems and rescue equipment, to be provided;

If respirators are required, all persons entering the confined space must show proof of respirator fit testing;

Any other pertinent information necessary to ensure entrant safety; and, All completed Entry Permits are to be submitted to the DOA Confined Space Office.

Additional permits, such as hot work, which have been issued to authorize work in the space are to be attached to the posted entry permit. Permits shall be cancelled once the activities requiring entry have been completed, when a new hazard arrives that requires reevaluation of the space, or at the end of a work shift (i.e., 8 hours).

4.5.2 Emergency Preparedness

A. Rescue Service Responsibilities

A Rescue Service within a 30-minute response to the site must be available for any permit-required entry, including failed non-entry rescue. All emergency response personnel should be trained on the work location and confined space configuration to minimize response time. If the entry is into a space that might possibly contain an IDLH situation, at least one assigned rescuer must be on stand-by at the portal for the duration of the entry. Unauthorized personnel will not be permitted to attempt rescue within permit-required spaces.

The entry supervisor cannot rely on the local fire department to provide this service without first contacting the fire department, verifying response times, and confirming their acceptance of their role in writing (see page 3 of Appendix B).

The supervisor must also confirm that the rescue service is in compliance with the following conditions:

The rescue service shall ensure that each member of the team is provided with and is properly trained to use the personal protective equipment and rescue equipment necessary for making rescues from permitted spaces.

The rescue service has a rescue plan for each type of confined space that is anticipated to be encountered.

Each member of the rescue service shall be trained to perform the assigned rescue duties in a time frame appropriate for the identified hazards. Additional training for rescue team members should also include:

o Semi-annual drill and simulation training;

o Authorized entrant training; and, o First aid and CPR

The rescue service team agrees to notify the DOA immediately if they become unavailable.

The supervisor will also be responsible for providing the rescue team with information on the hazards they may confront when they arrive on scene and with access to all permitted spaces in order to develop appropriate rescue plans and practice rescue operations.

B. Non-Entry Rescue

To facilitate non-entry rescue, retrieval systems or methods shall be used whenever an authorized entrant enters a permitted space, unless the retrieval equipment would increase the overall risk of entry or would not contribute to the rescue of the entrant.

Retrieval systems shall meet the following requirements:

Each authorized entrant shall use a chest or full body harness, with a retrieval line attached at the center of the entrant's back near shoulder level, or above the entrant's head;

Wristlets may be used in lieu of the chest or full body harness if the employer can demonstrate that the use of a chest or full body harness is infeasible or creates a greater hazard and that the use of wristlets is the safest and most effective alternative;

The other end of the retrieval line shall be attached to a mechanical device or fixed point outside the permitted space in such a manner that rescue can begin as soon as the rescuer becomes aware that rescue is necessary;

A mechanical device shall be available to retrieve personnel from vertical type permitted spaces more than 5 feet deep; and, All personnel, the entrant, the attendant, and the supervisor MUST be properly trained on the use of the PPE retrieval equipment.

If an injured entrant is exposed to a substance for which a Safety Data Sheet (SDS) or other similar written information is required to be kept at the worksite, the SDS or written information shall be made available to the medical facility treating the exposed entrant.

4.5.3 Entry Operations

A. Attendants

At least one attendant is required outside the permitted space for the duration of the authorized entry operation. All attendants should be designated by their employer or employer supervisor prior to conducting any confined space entry activities. All attendants are required:

To know the hazards that may be faced during entry, including information on the mode, signs or symptoms, and consequences of an exposure;

To be aware of possible behavioral effects exposure to potential hazards might cause;

To continuously maintain an accurate count of entrants in the permitted space and ensure a means to accurately identify authorized entrants;

To remain outside the permitted space during entry operations until relieved by another attendant.

Once properly relieved, attendants may participate in other activities (such as entry);

To frequently communicate with entrants, to monitor entrant status, and alert entrants of the need to evacuate;

To monitor activities inside and outside the space to determine if it is safe for entrants to remain and order the entrants to immediately evacuate if:

o The attendant detects a prohibited condition, detects entrant behavioral effects of hazard exposure, or detects a situation outside the space that could endanger the entrants;

and/or, o The attendant can no longer effectively and safely perform all the attendant duties;

To summon rescue and other emergency services as soon as the attendant determines that entrants need assistance to escape the permitted space hazards;

To take the following action when unauthorized person’s approach or attempt to enter a permitted space while entry is underway:

o Warn the unauthorized persons that they must stay away from the confined space;

o Advise the unauthorized persons that they must exit immediately if they have entered the space; and, o Inform the authorized entrants and the entry supervisor if unauthorized persons have entered or attempted to enter the permitted space;

To perform non-entry rescues as specified by the rescue procedure and entry supervisor; and, To remain focused on the entry and entrants and eliminated any distractions that would interfere with the duty to monitor and protect the entrants.

If multiple spaces are assigned to a single attendant, the written permit program must include the means and procedures to be used in case of emergency response. Attendants should not attempt entry or non-entry rescue operations if they have not been properly trained in those operations.

B. Entrants

All entrants must be authorized by the entry supervisor to enter permitted spaces; have received the required training; use the proper equipment and PPE; as well as review and understand the entry procedures and permit requirements. The following duties are required for each entrant:

Know the hazards that may be encountered during entry, including information on the mode, signs or symptoms, and consequences of a potential exposure;

Confirm that pre-entry preparations have been completed;

Properly use the equipment required for safe entry;

Communicate with the attendant frequently to enable the attendant to monitor the status of the entrants and to enable the attendant to alert the entrants of the need to evacuate the space, if necessary;

Alert the attendant whenever the entrant recognizes any warning sign or symptom of exposure to a dangerous situation, or any prohibited condition is detected; and, Exit the permitted space as quickly as possible whenever the attendant or entry supervisor gives an order to evacuate the permitted space, the entrant recognizes any warning sign or symptom of exposure to a dangerous situation, or the entrant detects a prohibited condition.

Entrants from other employers working in the same confined space as DOA personnel will coordinate their activities with the DOA Entry Supervisor prior to entry.

C. Entry Supervisors

Entry supervisors are responsible for the overall permitted space entry and must coordinate all entry procedures, tests, permits, equipment, and other relevant activities. All entry supervisors should be designated by their employer or employer supervisor prior to conducting any confined space entry activities. The following entry supervisor duties are required:

Know the hazards involved with the work and the signs, symptoms, and consequences of exposure;

Ensure that all necessary resources (equipment, training, hazard information, etc.) are available to provide a safe work environment for the employees;

Ensure affected third parties, DOA and confined space controlling contractors have been notified;

Assure that entry procedures and any permit specified testing are in compliance with the permit, this program, and any other site safety documents, or OSHA regulations;

Verify that rescue services (e.g., Aircraft Rescue and Fire Fighting Chief…