S-001,_Confined_Space.pdf

WATER SERVICES DEPARTMENT

POLICIES & PROCEDURES

DEPARTMENT RECORD NUMBER:

S-001

FUNCTION

ALL

SUBJECT

Confined Space Policy

EFFECTIVE DATE

June 22, 2023

REVIEW DATE

May 22, 2023

PAGE

I. Purpose

A. Precautions will be implemented before entering a Confined Space or Permit Required Confined Space (Permit Space). These include the following: air quality monitoring;

determination of safety procedures applicable to the space; assessment of chemicals for possible health risks; emergency rescue plans and procedures; provision for appropriate PPE and tools, and adequate training.

B. A confined space is a space 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 human occupancy under normal operating conditions.

C. A Permit Space is any confined space that has 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 Authorized Entrant (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 small cross-sectioning, or contains any other recognized serious safety or health hazard.

II. Responsibilities

A. Management will:

1. Be responsible for the application of this confined space program in their area of responsibility.

2. Provide resources necessary to ensure full compliance with this program.

3. Ensure consultation with affected employees and their authorized representatives on the development and implementation of all aspects of this Permit Space program.

4. Make available to affected employees and their authorized representatives all program, procedure, training, forms, and other documents for this Permit

Space program.

B. Site Managers and Supervisors will:

1. Be accountable for the application and maintenance of this program in their work area.

2. Establish methods for the availability and distribution of Confined Space and Retrieval equipment.

3. Ensure a Confined Space Evaluation is available for review prior to entry.

4. Ensure all employees are trained on this program.

5. Ensure completion of and adherence to all requirements set within the WSD Confined

Space Exchange of Information Form.

C. Safety Staff will:

1. Develop and maintain this program.

2. Coordinate delivery of Confined Space training.

3. Provide guidance and interpretation for this program.

4. Conduct routine audits of the Confined Space Program.

D. The Entrant will:

1. Know all hazards faced by entry.

2. Know the proper use of equipment.

3. Maintain effective communication with the Attendant.

4. Alert the Attendant when prohibited conditions are identified.

5. Exit from the Permit Space as quickly as possible when:

a. Any order to evacuate is given.

b. Signs or symptoms of exposure to hazards are apparent.

c. Evacuation alarm is activated.

E. The Attendant will:

1. Be responsible for only one entry operation at a time.

2. Have the ability to identify hazards faced by entry.

3. Be aware of possible physical or behavioral effects of hazard exposure.

4. Maintain an accurate count of all authorized Entrants and their locations.

5. Maintain effective communication with Entrant(s).

6. Monitor for hazards inside and outside of space.

7. Order Entrant(s) to evacuate space when:

a. When conditions change.

b. Prohibited conditions are detected.

c. Entrant(s) exhibit signs or symptoms of hazard exposure.

d. Hazards outside the space are detected.

e. The Attendant cannot perform their duty effectively.

8. Immediately summon rescue services to assist Entrant(s) escape from hazardous conditions.

9. Warn entrants and supervisors of the unauthorized entrant(s).

Remove unauthorized entrant(s) from the Permit Space immediately.

10. Perform non-entry rescue.

11. Perform no additional duty that might interfere with the Attendant role.

12. Remain outside Permit Space for the duration of entry unless relieved by another authorized Attendant

F. The Entry Supervisor will:

1. Know all hazards faced by entry.

2. Be aware of possible physical or behavioral effects of hazard exposure.

3. Verify all appropriate information on the Entry Permit.

4. Verify all atmospheric tests and monitoring have been performed.

5. Ensure procedures and equipment specified by the Entry Permit are in place.

6. Endorse the Entry Permit with signature and date.

7. Terminate entry when prohibited conditions occur.

8. Close out the Entry Permit when entry operations are complete.

9. Verify rescue services are available and means of summoning are operable.

10. Ensure operations are consistent with the Entry Permit and acceptable conditions are maintained.

III. Evaluation, Classification, and Documentation of Confined Spaces

A. Each WSD division will perform an initial evaluation of all potential Confined Spaces.

1. Confined space evaluation will be conducted by supervision and Safety Staff. Safety

Staff will consult with affected employees or their authorized representatives regarding these evaluations.

2. All confined space evaluations will be documented on a WSD Confined Space Evaluation Form.

3. All confined space evaluations will be readily accessible to all affected employees in hard copy onsite, on the Safety website, or on Work Order Asset Management

(WAM).

B. Confined Spaces will be reevaluated prior to entry if new hazards are introduced or identified.

C. Members of an entry team or their authorized representatives may request a reevaluation of a space in their presence if they have a specific reason to believe the initial evaluation may not be adequate.

D. Each Permit Space will be identified with signage that states, “Danger – Permit Required Confined Space, Do Not Enter.”

E. Permit Spaces will only be reclassified as a Confined Space under the following conditions:

1. All Confined Space reclassification entry procedures will be conducted in collaboration with Safety Staff or designee and in consultation with all members of the entry team or their authorized representatives.

2. All Confined Space reclassifications will be documented on the WSD Confined Space Entry Permit.

3. Reclassification from Permit Space to a Confined Space without Permit Entry.

a. The space poses no actual or potential atmospheric hazards.

b. All other hazards are eliminated without entry.

c. The space can now be reclassified.

d. If new hazards are identified, employees will immediately leave the space and conduct a Permit entry until hazards are eliminated and a new WSD Confined Space Entry Permit is completed.

4. Reclassification from a Permit Space to a Confined Space with Permit Entry

a. The space poses no actual or potential atmospheric hazards.

b. All other hazards are eliminated with Permit entry, and testing or inspection verifies elimination.

c. The space can now be reclassified.

d. If new hazards are identified, employees will immediately leave the space and conduct a Permit entry until hazards are eliminated and a new WSD Confined Space Entry Permit is completed.

e. Enter under an Entry Permit to reintroduce hazards within space.

F. Alternate Entry procedures will only be used under the following conditions:

1. The only hazard is an actual or potentially hazardous atmosphere.

2. A study of the hazardous atmosphere will be conducted in collaboration with Safety

Staff to verify that existing ventilation is sufficient to maintain safe entry.

3. The study is documented and available to the entry team or their authorized representatives.

4. Assessed forced air ventilation is used to maintain safe entry.

5. Atmospheric monitoring is conducted by the employee before and during entry.

IV. Training

A. Safety Staff will require prior to entry activity the following training to ensure proficiency related to all aspects of this policy:

1. Confined Space Training, course code WSCSRR

2. First/Aid CPR

B. Retraining will occur when:

1. There is a change in assigned duties.

2. Change in operations creates new hazards.

3. Deviation from the program is identified due to a lack of knowledge.

4. Program and procedures are revised.

V. Confined Space Entry Procedures

A. Signage All Permit Spaces will be identified with signage that states, “Danger – Permit Required Confined Space, Do Not Enter.”

B. Equipment and Supplies The following equipment and supplies will be provided and maintained:

1. Multi-gas monitor

2. Ventilation equipment (Local Exhaust Ventilation)

3. Retrieval equipment

4. Communication devices

5. Personal protective equipment

6. Lighting

7. Ladders

C. Required Documentation Prior to Permit Entry

1. All members of the entry team will establish roles (Entry Supervisor, Entrant and

Attendant) and review or assist with the completion of the WSD Confined Space Entry Permit prior to entry.

2. The WSD Confined Space Entry Permit will be maintained at the entry point and readily available to all entrant(s).

3. Entry will be immediately terminated upon identification of any Imminent Danger to Life and Health (IDLH) condition encountered but not identified on the Entry Permit prior to entry.

4. Any unforeseen IDLH condition encountered will be documented on the Entry Permit and promptly reported to Safety Staff.

5. Upon completion of entry, Entry Supervisors will account for all Entrants, secure the space from reentry, close out the Entry Permit and submit to Safety Staff for review and one-year retention.

6. Entry Permits will identify the time required to complete the task and not exceed one work shift.

D. Hazardous Atmosphere

1. All multi-gas monitors will be calibrated every thirty (30) days by an assigned Safety

Staff.

2. All multi-gas monitors will be bump tested/checked before each use or within a 24-hour Period.

3. Any substance within a space that could lead to atmospheric hazards will be ventilated, flushed, purged, or made inert.

4. Before entry into any Confined Space, Permit Space, Alternate Entry or Reclassified

Space, the entry team will use a multi-gas monitor to determine levels of oxygen, flammable gases and vapors, and toxic air contaminants.

5. Periodic atmospheric testing will be conducted by the entry team at a maximum of 15-minute intervals. The results will be documented on the Entry Permit.

6. All members of the entry team or their authorized representatives will be provided the opportunity to observe pre-entry testing if requested.

7. Atmosphere within the space will be continuously monitored during entry by the entry team.

8. If a hazardous atmosphere is detected during entry, the entry team will ensure:

a. All Entrants leave the space immediately.

b. The space is reevaluated to determine how the hazardous atmosphere developed.

c. Controls are established to protect employees before any subsequent entry takes place.

9. Forced air ventilation will be used to prevent an accumulation of hazardous atmospheres.

10. Continuous forced air ventilation will:

a. Eliminate hazardous atmosphere prior to entry.

b. Ventilate the immediate area where the employees are working.

c. Continue until all employees have left the space.

d. Draw from a clean source that does not create other hazards.

E. Hot Work When performed in a Confined Space, Hot Work that creates hazards such as sparks, flames, heat, or other ignition sources will have controls that are identified on the WSD Hot Work Permit.

F. Fall Protection When an entrance cover or similar device is removed and creates a fall hazard, employee protection, such as an attendant, barrier, guardrail, or harness will be utilized.

G. Rescue and Emergency Services

1. Methods for retrieval, rescue, and emergency services will be established during the initial evaluation of spaces and documented on the WSD Evaluation Form.

2. Non-entry retrieval will be performed by WSD personnel.

3. Entry rescue will only be performed by an established emergency service.

4. The City of Phoenix Fire Department (COP Fire) provides WSD confined space rescue and emergency services.

a. WSD will provide COP Fire information as required by 1910.146 on all confined spaces.

b. WSD will provide access to confined spaces as requested by COP Fire to develop appropriate rescue plans and practice rescue operations.

5. Non-entry Retrieval

a. All personnel who perform non-entry retrieval will be trained in the following:

• First/Aid CPR.

• Assigned rescue duties and methods, as defined in training.

b. All necessary personal protective equipment for non-entry retrieval will be provided.

c. A tripod, davit, or similar device combined with a harness over the Permit Space will be used to retrieve employees when:

• The space exceeds 5 feet in depth.

• The system is effective for retrieval.

• The system does not create hazards.

6. Entry Rescue and Emergency Services

a. 911 Rescue Services

• For routine entry into confined spaces with recognized hazards and established controls, a 911 call will be used to summon rescue and emergency services.

• The entry team will provide the space Evaluation, Entry Permit, Safety Data Sheet(s) and other pertinent information to emergency services upon arrival.

b. Stand-by Rescue Team

• When Confined Space evaluations identify hazards that are very serious or difficult to control, a COP Fire stand-by rescue team will be established on site.

• WSD Divisions utilizing stand-by rescue services will follow all requirements within the WSD Confined Space Rescue Stand-by Agreement.

H. Contractor Communication and Coordination

1. An exchange of the following information will take place between WSD and each contractor prior to work in Confined Spaces:

a. A copy of the WSD Confined Space Program.

b. A copy of the Contractor’s Confined Space Program.

c. A signed WSD Exchange of Information Form.

d. A copy of the WSD Confined Space Evaluation Form applicable to the Confined

Space.

e. Any job hazard analysis or standard operating procedures associated with the space.

2. Contract Personnel will establish their own Entry Permit and coordinate entry for their own employees on projects that do not include WSD staff.

3. Contractors will provide the following information to their designated point of contact

(WSD Staff) after each Permit entry:

a. Any hazards confronted or created.

b. Copies of closed out Entry Permits.

c. If requested, a written debrief to explain the contractor’s confined space program, experience during entry operations, and any hazards confronted or created during a Permit

d. Divisions will submit copies of all contractor Entry Permit information to Safety Staff Section.

4. Multi-Employer Entry

a. Coordination between WSD and contract entrants will be established and maintained to ensure equal protection for all entrants.

b. Contract personnel may enter a WSD-controlled confined space under a WSD

Entry Permit to bid on projects, conduct inspections, and participate in facility tours.

c. WSD personnel may enter a contractor-controlled confined space under a contractor’s Entry Permit to conduct audits and inspections.

d. Shared use of confined space equipment and supplies is permitted when inspected for defects and coordination ensures equal protection for all parties.

e. Each party is responsible for the health and safety of their own employees.

VI. Program Audit and Review

A. Divisions will review annually the following documents to ensure that all hazards are identified and controlled:

B. WSD Confined Space Evaluation Forms C. WSD Confined Space Entry Permits D. Affected employees or their representatives will participate in the annual document review.

E. Safety Staff will conduct an annual audit of the WSD Confined Space Program and correct any deficiencies found or reported.

VII. Definitions

Acceptable Entry Conditions are conditions that must exist in a Permit Space to allow entry and to ensure that employees involved with a Permit entry can safely enter into and work within the space.

Affected Employee is an employee whose job requires him/her to participate in confined space entry activities.

Alternate Entry are procedures that can be used when the only hazard in a Permit Space is an atmospheric hazard that can be controlled or eliminated through continuous forced air ventilation. The employer must demonstrate the continuous forced air ventilation is sufficient by means of monitoring and inspection data.

Attendant is an individual stationed outside the Permit Space who monitors the Entrants and who performs all Attendant's duties assigned in the employer's Confined space program.

Authorized Entrant (Entrant) is an employee who is authorized by the employer to enter a Permit Space.

Authorized Representative is the employee’s designated representative or the employee’s other official representative where no union exists.

Blanking or Blinding is the absolute closure of a pipe, line, or duct by the fastening of a solid plate (such as a spectacle blind or a skillet blind) that completely covers the bore and that is capable of withstanding the maximum pressure of the pipe, line, or duct with no leakage beyond the plate.

Bodily Enter is the action by which a person passes through an opening into a Permit Space. Entry includes ensuing work activities 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.

Confined Space is a space large enough and so configured that an employee can bodily enter and perform assigned work, has limited or restrictive means for entry or exit, and is not designed for continuous human occupancy under normal operating conditions.

Double Block and Bleed is the closure of a line, duct, or pipe by closing and locking or tagging two in- line valves and by opening and locking or tagging a drain or vent valve in the line between the two closed valves.

Eliminate Hazards is the process of removing the hazard from the Confined Space or Permit Space. It is the most effective way to reduce the risk of exposure because the hazard is no longer present. It is the preferred way to control a hazard and should be used whenever possible.

Emergency is any occurrence (including any failure of hazard control or monitoring equipment) or event internal or external to the Permit Space that could endanger Entrants.

Engulfment is the surrounding and effective capture of a person by a liquid or finely divided (flowable) solid substance that 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 is the action by which a person passes through an opening into a Permit Space.

Entry includes ensuing work activities 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.

Entry Permit is the written or printed document that is provided by the employer to allow and control entry into a Permit Space and that contains the information specified in paragraph (f) of this section.

Entry Supervisor is the person responsible for determining if acceptable entry conditions are present at a Permit Space where entry is planned, for authorizing entry and overseeing entry operations. An Entry Supervisor also may serve as an Attendant, as long as that person is trained and equipped as required by this section for each role they fulfill. Also, the duties of Entry Supervisor may be passed from one individual to another during the course of an entry operation.

Hazardous Atmosphere is an atmosphere that may expose employees to the risk of death, incapacitation, and impairment of ability to self-rescue (that is, escape unaided from a Permit Space), injury, or acute illness.

Hot Work is 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) is 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 Permit Space.

Inerting is the displacement of the atmosphere in a Permit Space by a noncombustible gas (such as nitrogen) to such an extent that the resulting atmosphere is noncombustible.

Line Breaking is the intentional opening of a pipe, line, or duct that is or has been carrying flammable, corrosive, or toxic material, an inert gas, or any fluid at a volume, pressure, or temperature capable of causing injury.

Limited or Restricted Egress is any space where an occupant must crawl, climb, twist, be constrained in a narrow opening, follow a lengthy path or otherwise exert unusual effort to enter or leave, or where the entrance may become sealed or secured against opening from inside.

Oxygen Deficient Atmosphere is an atmosphere containing less than 19.5 percent oxygen by volume.

Oxygen Enriched Atmosphere is an atmosphere containing more than 23.5 percent oxygen by volume

Permit-Required Confined Space (Permit Space) is any confined space that has 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, or contains any other recognized serious safety or health hazard.

Prohibited Condition is any condition in a Permit Space that is not allowed by the Entry Permit during the period when entry is authorized.

Reclassification is a process that allows a Permit Space with no potential atmospheric hazard to be reclassified to Confined Space, if all hazards can be eliminated as defined within this policy.

Reintroduce Hazards is to reestablish a hazardous condition or source of danger within the Permit Space.

Rescue Service is the personnel designated to rescue employees from Permit Spaces.

Retrieval System is 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 Permit Spaces. The retrieval system must be available, meaning that the Entrant's retrieval line is attached to a mechanical device so that rescue can begin as soon as the rescuer becomes aware that rescue is necessary.

Testing is the process by which the hazards that may confront Entrants of a Permit Space are identified and evaluated. Testing includes specifying the tests that are to be performed in the Permit Space. Testing enables employers both to devise and implement adequate control measures for the protection of authorized Entrants and to determine if acceptable entry conditions are present immediately prior to, and during, entry

Troy Hayes, Director Water Services Department