Confined Space Program

          

Confined Space Program                                                                                                                                                              

Table of Contents:                                       

(Click on hyperlinks below to skip to the areas of interest.)                                                             Printable pdf

1.0 Introduction.

1.1 Policy / Applicability.

1.2 Definitions.

1.3 Roles & Responsibilities When Conducting a Confined Space Entry.

2.0 Confined Space Entry – Program Implementation.

2.1 Identification of Confined Spaces.

2.2 Confined Space Entry Hazards and Their Controls.

2.2.1 Monitoring Equipment.

2.2.2 Entry Hazards and Controls.

2.2.3 Other Hazards and Their Controls.

2.3 Confined Space Rescue.

3.0 Confined Space Entry Procedures.

3.1 Administrative Procedures.

3.2 Confined Space Permit.

3.3 General Entry Requirement.

3.4 Specific Entry Procedures.

4.0 Training Requirements.

5.0 Record Keeping Requirements.

6.0 References.

APPENDIX A – Confined Space Map - Parnassus.

APPENDIX B – Confined Space Inventory

APPENDIX C – Approved Confined Space Rescue Contractors.

APPENDIX D – Confined Space Evaluation

APPENDIX E – Confined Space Permit.

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1.0 Introduction

Personnel entering or working in confined spaces may encounter a number of potentially serious hazards that can result in injury or death. These hazards include insufficient oxygen to support life, flammable atmospheres, toxic gases, engulfment & entrapment hazards, or electrical & mechanical hazards.  Many of these hazards, especially atmospheric hazards, are not visible or detectable by odor.  Failure to recognize and control hazards associated with confined spaces is the primary cause of fatal injuries.  The second most-frequent cause of fatal injuries in confined spaces is inadequate or incorrect emergency response or attempted rescue. Attempted rescues are usually a spontaneous reaction and often lead to multiple fatalities.

This program complies with Cal/OSHA and Federal OSHA regulations for practices and procedures to protect workers from the hazards associated with entry into permit- required confined spaces. The criteria set forth are the minimum safety requirements for confined space operations at UC San Francisco (UCSF).

 

1.1 Policy / Applicability

Entry into any confined space, regardless of the operation (construction, telecommunication, utility, etc.), must occur in accordance with this program.

This program applies to anyone who enters a confined space owned by UCSF or on UCSF property, irrespective of their affiliation with the University.

See APPENDIX D for Confined Space Evaluation form

See APPENDIX E for Confined Space Entry Permit

 

1.2 Definitions

Atmospheric Monitoring — The quantitative analysis of a confined space environment to identify a potentially hazardous atmosphere.

Attendant — A trained individual stationed outside one or more confined spaces who monitors authorized entrants and performs attendant’s duties assigned in the permit space program.

Bump Test — A functional check of a direct-reading “4-gas meter” instrument used for atmospheric monitoring.

Calibration —A laboratory or bench-top resetting of alarm points, spans and zeros according to manufacturer’s specifications.

Confined Space —A space that: Is large enough and configured so a worker can bodily enter and perform assigned work; has limited or restricted means for entry or exit; and is not designed for continuous human occupancy.

Direct-reading instrument – A broad term used to describe various multi-gas detectors and 4-gas meters. Direct-reading instruments permit real-time or near real-time measurements of oxygen levels, flammability limits, and toxic gas levels.

Engulfment — The surrounding and overwhelming of a person by finely divided particulate matter or liquid.

Entrant —Any employee who is trained and authorized to enter a confined space.

Entry - Any action by which a person passes through an opening into a permit-required confined space. Entry is considered to have occurred as soon as any part of the entrant’s body breaks the plane of an opening into the confined space.

Entry Permit - The written authorization for entry under defined conditions into a confined space for a stated purpose during a specified time.

Entry Supervisor - 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, and for terminating entry as required by this program

Hazardous Atmosphere — An atmosphere presenting a potential for death, disablement, injury, or acute illness from one or more of the following causes:

  • Oxygen concentration below 19.5 percent or above 23.5 percent;
  • Flammable gas, vapor, or mist in excess of 10 percent of its lower explosive limit (LEL);
  • An airborne combustible dust at a concentration that meets or exceeds its LEL or LFL;
  • An atmospheric concentration of any toxic substance greater than the permissible exposure or other predetermined limit

Hot Work Permit —The written authorization to perform “hot work” operations such as riveting, welding, cutting or burning, or heating that could provide a source of ignition.

Limited or restricted means of egress – A space is considered having limited or restricted means of egress if the overall characteristics of the space could hinder an entrant's ability to exit or be rescued in a hazardous situation. The entrant must be able to walk upright and unimpeded to safety. The following are considered a limited or restricted means of egress:

  • Ladders
  • Temporary, movable, spiral, or articulated stairs
  •  Access doors or horizontal portals which an entrant must crouch, crawl, kneel, stoop, or bend to exit

Lower Explosive Limit (LEL) —The lowest concentration of flammable or combustible vapor or dust which can be ignited by a spark or flame. Also referred to as “Lower Flammable Limit” (LFL).

Non-Permit Confined Space —A space that meets the criteria for a confined space but does not contain or have the potential to contain any atmospheric of physical hazards capable of causing death or serious physical harm.

NRTL – Nationally Recognized Testing Laboratory – An independent testing laboratory that certifies the quality and reliability of many different kinds of electrical equipment and instrumentation. An example of an NRTL is “Underwriters Laboratory” (UL). Federal OSHA maintains a current list of all accepted NRTLs on the OSHA website [https://www.osha.gov/dts/otpca/nrtl/].

Permit-Required Confined Space —A 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 the 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, such as water, slippery floors, unstable walls, spiders, rodents, etc.

Qualified Person —A person who is trained to recognize the hazards of confined spaces and how to evaluate those anticipated hazards.

Vault - A room (including manholes) of fire-resistant construction, primarily used to house

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1.3 Roles & Responsibilities When Conducting a Confined Space Entry

Entry Team

An entry team is required for all entries into a permit-required confined space. No one ever enters a confined space as a solo operation.  At minimum, the entry team will consist of one attendant and one entrant who both must be physically present throughout the entire confined space entry. The entry supervisor who signs the permit may perform the duties of the attendant or the entrant.

Attendant

An attendant is a trained individual stationed outside one or more confined spaces to monitor authorized entrants and perform attendant duties assigned in this program.

Attendants may be assigned to monitor more than one permit space provided the duties described in this section can be effectively performed for each permit space monitored.

The attendant must:

  • Know the hazards that may be encountered by entrants during entry, including information on the mode, signs/symptoms, and consequences of all potential hazard-exposures
  • Understand how to operate and interpret all direct-reading instruments used for atmospheric monitoring and ensure equipment is properly calibrated and bump tested
  • Continuously maintain an accurate count of authorized entrants in the permit space
  • Remain physically present outside the permit space during entry operations until relieved by another attendant
  • Communicate with authorized entrants as necessary to monitor entrant status and to alert entrants of the need to evacuate the space
  • Monitor activities inside and outside the space to determine if it is safe for entrants to remain in the space
  • Order the authorized entrants to evacuate the permit space immediately if:a prohibited condition is detected the behavioral effects of hazard exposure in an authorized entrant is detected a situation arises outside the space that could endanger the authorized entrants; or the attendant can no longer effectively and safely perform these required duties while an entry is in process.
  • Summon rescue and other emergency services as soon as the attendant determines that authorized entrants may need assistance to escape from permit space hazards
  • Perform non-entry rescues when required
  • Perform no other duties that might interfere with the attendant's primary duty to monitor and protect the authorized entrants while an entry is in process
  • Wear required PPE

In addition, the attendant is responsible for keeping unauthorized persons from entering the permit space. If an unauthorized person approaches a permit space when an entry is underway, the attendant must:

  • Warn the unauthorized persons that they must stay away from the permit space;
  • Advise the unauthorized persons that they must exit immediately if they have entered the permit space; and
  • Inform the authorized entrants and the entry supervisor if unauthorized persons have entered the permit space.

 

Entrant

An entrant is an employee who is trained and authorized to enter a confined space. The entrant must:

  • Know the hazards that may be faced during entry, including information on the mode, signs/symptoms, and consequences of all potential hazard-exposures.
  • Understand how to operate and interpret all direct-reading instruments used for atmospheric monitoring and ensure equipment is properly calibrated and bump tested
  • Communicate with the attendant as necessary to enable the attendant to monitor the status of the entry and entrant.
  • Not enter a space until it has been deemed safe for entry
  • Alert the attendant whenever:
    • The entrant recognizes any warning sign or symptom of exposure to a dangerous situation
    • or The entrant detects a prohibited condition.
  • Exit from the permit space as quickly as possible whenever:
    • An order to evacuate is given by the attendant or the entry supervisor,
    • The entrant recognizes any warning sign or symptom of exposure to a dangerous situation
    • The entrant detects a prohibited condition, or
    • An evacuation alarm is activated.
  • Fully understand all procedures, safeguards, and emergency egress and/or rescue procedures associated with the entry.
  • Follow all safe work procedures.
  • Notify the entry supervisor when hazards exist that were previously unknown, or that have not been corrected.
  • Notify the entry supervisor if they are ill or on medication that could affect their ability to self-evacuate
  • Wear all required PPE.

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Entry Supervisor

The entry supervisor is responsible for ensuring the safety of all personnel who enter or work in a confined space. The entry supervisor is usually a Lead, Supervisor or Manager, but may delegate authority to qualified and authorized competent personnel. An entry supervisor may oversee more than one confined space entry at a time and is not required to remain at the entry location unless fulfilling the role of attendant.

The duties of the entry supervisor may be passed from one individual to another during an entry operation, as long as it is noted on the permit and all entrants and attendants are immediately notified.

The Entry Supervisor must:

  • Know the hazards that may be faced during entry, including information on the mode, signs or symptoms, and consequences of all potential hazard exposures
  • Understand how to operate and interpret all direct-reading instruments used for atmospheric monitoring and ensure equipment is properly calibrated and bump tested
  • Verify acceptable conditions are present at a permit space where entry is planned.
  • Ensure entrants and attendants are properly trained and qualified to perform all assigned duties.
  • Inspect the work area, tools, and equipment prior to authorizing entry into a space
  • Ensure appropriate guards, barriers, or other means to protect the entry party and attendants from local vehicle and pedestrian traffic hazards and to protect non-entering personnel
  • Ensure all entrants and attendants have proper PPE
  • Coordinate rescue with off-campus agencies, as necessary.
  • Ensure the means (i.e., telephone, radio, etc.) for summoning the rescue team are operable, on hand, or easily accessible.
  • Ensure all hazards are eliminated (e.g., valves are isolated, locked out, and blinded or blanked) prior to authorizing entry into the space
  • Conduct a pre-entry briefing with all entrants and attendants which covers the information on the entry permit
  • Endorse the entry permit to allow entry to begin
  • Transfer the duties of the entry supervisor to another qualified supervisor during the course of the entry operations and ensure that the new supervisor signs or initials the entry permit when the transfer is complete.
  • Revoke the entry permit, terminate the entry, and secure the site when becoming aware of a hazardous, prohibited or unexpected condition.
  • If at any time a permit is revoked, the entry supervisor must contact EH&S.

EH&S will assist in determining what conditions are acceptable for re-entry.

 

Departments

For the purpose of this program, “department” is a comprehensive term that describes the owner (whomever has administrative control) of the confined space. Ownership may fall to a specific shop within a trades group, the building coordinator, department safety coordinator (DSC), or Principal Investigator (PI).

The department has the following responsibilities:

  • Understand and document all hazards associated with confined space entry operations
  • Post signs and secure the space.
  • Inform EH&S if they have a confined space that has not been classified and/or identified on the Confined Space Inventory.
  • Notify EH&S if the ownership of the confined space changes, or if the space is decommissioned, so EH&S can update the inventory.
  • Maintain all equipment associated with confined space entry, including direct- reading instruments for atmospheric monitoring, harnesses, tripods, fans, blowers, radios, etc.
  • Provide personal protective equipment (PPE) based upon a documented hazard analysis
  • Ensure personnel working in or around confined spaces receive training in accordance with this program.
  • Produce and retain copies of the Entry Permits

 

Contractors

For contract work that involves entry into a permit space, the Project Manager must:

  • Inform the contractor that the workplace contains confined-space permit spaces and that permit space entry is allowed only through compliance with this program and Cal/OSHA regulations
  • Provide the contractor with all available information regarding permit space hazards and entry operations
  • Ensure the contractor has a permit space program that includes provisions for atmospheric testing and monitoring, hazard control (ventilation, EI-LOTO, Hot Work, etc.), rescue, communication, and specific entry procedures.
  • Debrief the contractor at the conclusion of the entry operations regarding the permit space program followed and regarding any hazards confronted or created in permit spaces during entry operations.

For contract work that involves entry into a permit space, the Contractor must:

  • Follow all applicable Cal/OSHA (or equivalent) standards.
  • Obtain any available information regarding permit space hazards and entry operations from the Project Manager
  • Coordinate entry operations with the Project Manager if UCSF personnel will be working in or near permit spaces
  • Inform the Project Manager of the permit space program that the contractor will follow and of any hazards confronted or created in permit spaces, either through a debriefing or during the entry operation.

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EH&S

The Office of Environment, Health and Safety (EH&S) must:

  • Maintain the master Confined Space Inventory for the campus.
  • Conduct periodic inspections of permit spaces and audits of permits to ensure departments are meeting the requirements of this program.
  • When feasible, conduct the confined space classification survey.
  • Advise departments with purchasing equipment, developing calibration schedules, and hazard mitigation
  • Provide training to affected personnel
  • Assist departments with implementing the provisions of this program

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2.0 Confined Space Entry – Program Implementation

 

2.1 Identification of Confined Spaces

A space must meet the following three criteria to be defined as a confined space:

  1. It is large enough and configured so a worker can bodily enter and perform assigned work;
  2. It is not designed for continuous human occupancy; and
  3. It has limited or restricted means for entry or egress.

If the confined space meets the above three criteria, but has no potential or actual hazards, it is a non-permit confined space.

A confined space becomes permit-required if it 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 the 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.

Examples of a recognized serious safety hazard could be the potential for falling objects, unstable walls, slippery work surfaces, unknown structural integrity, poor lighting, mechanical, thermal, radiological or electrical hazards.  Possible health hazards include bird feces, venomous insects, rodents, and microbial agents. These examples are not exhaustive.

It is the responsibility of the supervisor of entrants to ensure that an evaluation is performed on a confined space prior to entry. This evaluation shall be documented and available to EH&S staff if requested.

 

2.2 Confined Space Entry Hazards and Their Controls

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2.2.1 Monitoring Equipment

Appropriate and Approved Monitoring Equipment

Prior to purchasing any direct reading equipment for the purpose of atmospheric monitoring during confined space entry, EH&S may be contacted for guidance and information. Ensure the monitoring device is adequate for use in the intended environment and meets required standards of safety as determined by an appropriate Nationally Recognized Testing Laboratory (NRTL).

It is the responsibility of the owner-department to maintain their monitoring equipment and written standard operating procedures for its use.

Calibration of Monitoring Equipment

Monitoring equipment used to evaluate confined spaces must be calibrated according to the manufacturer’s instructions. Frequency of calibration varies by equipment make and model.  Calibration may be done in-house or may involve sending the equipment back to the manufacturer for a professional service.

EH&S can assist with developing a calibration schedule in accordance with the manufacturer recommendations at no cost to owner-departments. The owner- department incurs all costs associated with calibration, maintenance and repair of their monitoring equipment.

Bump Test

Prior to a multi-gas meter’s use each day, alarm functions must be verified by users who perform a functional test called a “bump test”.  Bump testing involves exposing the meter to a “span gas” containing concentrations in excess of the lowest alarm set-point for each sensor and verifying the alarm operation.

Bump testing may also involve exposing the meter to a gas with a known concentration and comparing the readings on the meter. However, bump testing is not the same as calibrating your meter. Even if the reading on the meter is the same as the gas’s concentration, it does not technically validate the accuracy of the instrument.

Failure of Monitoring Equipment

Any monitoring equipment that is not currently calibrated, fails calibration, or fails the bump test, must be removed from service until it is repaired and the calibration or bump test is successfully accomplished.

Atmospheric Monitoring

Some permit-required confined space entries may require additional atmospheric monitoring, either continuously or at specified intervals, to ensure safe conditions are maintained. Many operations may produce or cause release of hazardous concentrations of toxic or flammable vapors, such as sludge removal, cleaning operations, or the application of paints, epoxies, solvents, etc. The frequency and type of monitoring are dependent upon the hazards of the space and the nature of the operations; therefore, no single rule can be established for all operations. The entry supervisor (with assistance from the EH&S as necessary) must establish the frequency and type of tests for atmospheric monitoring and must enter these requirements on the entry permit.

EH&S requires continuous monitoring of oxygen levels and flammable vapor levels, as well as toxicity levels of all anticipated contaminants within the permit-required confined space.

Use the Confined Space Evaluation Form found in APPENDIX D to aid in your determination.

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2.2.2 Entry Hazards and Controls

Communication

During permit-required confined space entry, two-way communication between the entrant and attendant must be maintained at all times. If communication cannot be sustained by voice/sound, a series of pre-arranged hand signals or rope tugs should be used.

Only explosion-proof or intrinsically safe communication equipment (radios, cell phones, etc.) may be used where flammable or explosive atmospheres are present. Equipment must be accredited by an NRTL, such as Underwriters Laboratories.

NOTE: If it is not possible for one attendant to maintain communications with each entrant because of the entrant’s work station in the space, the supervisor will make other arrangements to ensure the attendant is continuously aware of the location and condition of any entrant who is out of direct communication range. This must be noted on the entry permit.

Noxious Atmosphere and Ventilation

Ventilation can be an effective means of controlling a hazardous atmosphere in a confined space. Control of atmospheric hazards through forced air ventilation does not constitute elimination of the hazards. Ventilation is a hazard control.

The term “ventilating” is often used synonymously with “purging” or “flushing”; however, purging and flushing refer to the processes of removing the initial hazardous atmosphere by displacement.

There are many factors to consider when ventilating a confined space, such as:

  • The level and type of atmospheric contamination
  • The size and shape of the space
  • Access to the space and availability of electrical power
  • Source of clean air
  • Nature of work to be done inside the space

These variables will all help determine the volume of air that needs to be exhausted (or the number of air changes per period of time) and the length of time to ventilate. This will then determine the equipment needed - fan (blower or ejector), the motor speed and size, power source or generator, length of duct-work, if a directional device is needed, etc. Contact EH&S to assist in these determinations.

 

2.2.3 Other Hazards and Their Controls

Chemicals

Use caution when working with chemicals within a confined space. Ensure there is adequate ventilation to facilitate the removal of toxic gases or vapors.  Continuous air monitoring with a direct-reading instrument should be used when there is the potential to create a hazardous atmosphere.

For permit-required confined spaces, indicate the chemicals used on the entry permit.

Energy Isolation – Lockout/Tagout (EI-LOTO)

All energy sources that are potentially hazardous to confined space entrants must be secured, relieved, disconnected and/or restrained before personnel are permitted to enter the space.  If entry into the space is required for energy isolation, safe work procedures must be developed and they must be noted on the Confined Space Inventory.  Refer to the UCSF EL-LOTO program on the EH&S website for more information.

Heat

If the temperature inside a confined space exceeds 85 degrees Fahrenheit, or there are environmental risk factors for heat illness, a combination of engineering controls, administrative controls and/or PPE must be utilized to reduce the risk of heat illness. These controls are outlined below.

UCSF Personnel are not authorized to work in confined spaces where the heat index (a single value that takes both temperature and humidity into account) exceeds 115 degrees Fahrenheit after engineering controls have been implemented.

Heat - Engineering controls:

  • Use general ventilation to dilute the hot air inside a confined space with cooler air brought in from  the outside using a portable exhaust systems.
  • Air treatment, air cooling or air conditioning differs from ventilation because it reduces the temperature of the air by removing the heat or humidity. This method uses portable blowers with built-in air conditioning or chillers.
  • Guard surfaces that generate or radiate heat, such as pipes, with insulation or shielding blankets, either permanently or for the duration of the confined space entry operation.

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Heat - Administrative controls:

  • Acclimatize entrants.
  • Implement a work/rest schedule.
  • Replace fluids by drinking small amounts of cool (not cold) water frequently, like one cup every 20 minutes. Ample supplies of water should be provided close to the work area. While some commercial fluid-replacement drinks (e.g., Gatorade) contain salt or “electrolytes”, this is not necessary.
  • Reduce the physical demands by reducing physical exertion such as excessive lifting, climbing, or digging with heavy objects. Spread the work over more individuals, use relief workers or assign extra workers.
  • Provide recovery areas such as air-conditioned enclosures and rooms and provide intermittent rest periods with water breaks.
  • Reschedule hot jobs for the cooler part of the day, and routine maintenance and repair work in hot areas should be scheduled for the cooler seasons of the year.
  • Monitor workers who are at risk of heat stress.

Heat - Personal Protective Equipment (PPE):

  • Cooling ice vests, though heavy, may accommodate as numerous ice packets and last over two hours.
  • Wetted clothing, such as terry cloth coveralls, is an inexpensive option when there is good airflow.

Hot Work

All Hot Work operations within a confined space, non-permit or permit-required, must follow the provisions of UCSF’s Hot Work Permit Program. Refer to the UCSF Hot Work Permit program on the EH&S website for more information.

In addition, whenever oxygen-consuming equipment (plumbers' torches or furnaces, welders and plasma cutters, etc.) are used in a confined space, measures must be taken to ensure ventilation is provided to maintain oxygen levels between 19.5 – 23.5% and to remove exhaust fumes and gases.  Continuous air monitoring using a direct- reading instrument is required.

Standing Water

Water can be a hazard to entrants. Even a few inches of water could cause an employee to drown if they become trapped or fall face-down.  Small amounts of water could also obscure tripping hazards or make it difficult to retrieve a dropped tool. Stagnant water is filled with anaerobic bacteria that can produce hydrogen sulfide (H2S) gas and/or may be a health concern.  All water needs to be pumped or drained so no more than two inches remain prior to entry.  No exposed electrical conductors are permitted in wet environments.

Electrical Equipment

Appropriate electrical equipment or systems must be used in locations where there is potential for electrical shock.  This includes all fans, blowers, tools, lighting, communications and test equipment.

Equipment should have protection such as ground fault circuit interrupters (GFCI), assured grounding systems by use of 3-prong electrical plugs, double insulation (for small powered hand-tools), and/or low voltage systems. Equipment must be certified by an NRTL. Only explosion-proof or intrinsically safe may be used in spaces with the potential for a combustible atmosphere.

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2.3 Confined Space Rescue

Two-thirds of all confined space fatalities occur among would-be rescuers. It is critical to follow the safe entry and work practices outlined in this program to prevent the need for rescue. NEVER enter a space to rescue someone. If a rescue becomes necessary, always assume that the space is deadly until proven otherwise.

There are three methods of rescue from a confined space: self-rescue, non-entry rescue, and entry rescue. The method of rescue depends on factors such as the physical configurations of the space, the work being performed, the external environment, and the foreseeable emergency.

All entries into a permit space must involve a non-entry rescue setup.  All authorized entrants into permit spaces are required to wear a full body harness and retrieval lines, unless it is determined that the retrieval equipment would increase the overall risk of entry or would not contribute to the rescue operation.

Emergency Rescue Methods:

 

Self-Rescue

Self-rescue means the entrant exits the space under their own power, regardless of whether they are attached to a retrieval line. Self-rescue is always preferred. It provides the entrant with the best chance of escaping and allows the entrant to escape quicker than having to wait for rescue. Also, self-rescue does not endanger anyone else.

Self-rescue is best for permit spaces where:

  • The physical configuration of the space is such that the entrant can normally exit without the assistance of a mechanical lifting device (by using a ladder, stairs, scaffold, etc.).
  • The potential for hazardous atmosphere is very low.
  • The entrant is in communication with the attendant and can see and/or hear the order to evacuate the moment it is given.

Self-rescue may also be the better option for spaces that have horizontal entry portals in restricted diameters (less than 24” or too small to allow a rescuer to enter wearing an SCBA) or obstructed internal configurations (pipe structures, baffles).

 

Non-Entry Rescue

If self-rescue is not possible, non-entry rescue is the next best approach. Non-entry rescue can begin as soon as an evacuation order is given or it becomes clear the entrant cannot aid in their own evacuation. Like self-rescue, non-entry rescue does not endanger anyone else and does not require another person entering the space.

Non-entry rescue is best for spaces that have:

  • A vertical entry.
  • An unobstructed internal configuration.
  • An external area that can support a tripod or davit.

Non-entry rescue uses a retrieval system which consists of a support structure (tripod or davit) or anchor with a mechanical lifting device, a retrieval line or rope, and a chest or full-body harness. A manually operated device should be used. If a powered (electric, pneumatic, hydraulic) lifting device is used, then it should be equipped with a slip clutch or similar device to stop motion against a preset resistance and a back-up manual mode of operation. Mechanical lifting devices must have a mechanical advantage sufficient enough for an attendant to easily lift the entrant (including any attached tools and equipment) the entire distance of the space without getting fatigued.

 

Entry Rescue

Entry rescue involves rescuers entering the space to retrieve the entrant and/or provide the victim with emergency assistance such as CPR, first aid, and supplemental air. Rescuers usually wear a Self-Contained Breathing Apparatus (SCBA) or a supplied air respirator (SAR). Entry rescue may be the only solution for spaces that have obstructed internal configurations or other elements that do not allow for relatively free movement in and out of the space.

Employees at UCSF are not trained in and do not perform entry rescue.  An outside certified emergency rescue vendor must be set-up onsite prior to entering the space. A list of approved local vendors who can provide this rescue service for your operations is available in APPENDIX C.

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3.0 Confined Space Entry Procedures

 

3.1 Administrative Procedures

Classification of Confined Spaces

A hazard evaluation must be conducted by a qualified person for each confined space with the purpose of classifying the space as non-permit or permit-required prior to every confined space entry. Contact EH&S for assistance and training in classifying confined spaces for your operations.

Confined Space Survey and Inventory

A qualified person must conduct a survey of operations to identify confined spaces as defined by this program. The purpose of the survey is to develop an inventory of those locations and/or equipment which meet the definition of a confined space so that signage warning of the confined-space hazard are installed, personnel may be made aware of the confined space and appropriate procedures developed for each confined space prior to entry.

Once a confined space is classified as non-permit or permit-required, the information is entered into UCSF’s Confined Space Inventory. EH&S maintains the master Confined Space Inventory.  The inventory is updated whenever a confined space is added, deleted or the conditions of the space change.

It is the responsibility of all departments at UCSF to inform EH&S if they have a confined space that has not been classified and/or identified on the Confined Space Inventory.

EH&S will use the inventory to conduct inspections of spaces and evaluations of permits to ensure departments are meeting the requirements of this program.

Other Hazardous Spaces

Telecommunication Manholes

If telecommunication work is performed in a permit-required confined space, entry must occur in accordance with this program.

If telecommunications field work is performed on or with underground lines in a manhole or unvented vault that does not meet the definition of a confined space, the following steps must be taken:

  1. When covers are removed, promptly guard all manholes, vaults and street openings by a railing, temporary cover, or other suitable temporary barrier which is appropriate to prevent an accidental fall through the opening and to protect employees working in the manhole from foreign objects entering the manhole.
  2. Test the atmosphere in accordance with the “Pre-Entry Atmospheric Testing” guidelines (section 3.3), prior to entry. Do not enter the space until an oxygen deficiency, toxic or flammable atmosphere is corrected.
  3. Continuously monitor the atmosphere using an approved, calibrated, direct- reading instrument.
  4. Supply continuous fresh air by mechanical means in accordance with “Ventilation” section of this program if:
  • combustible or explosive gas vapors have been initially detected (even if subsequently reduced to a safe level),
  • a toxic gas or oxygen deficiency is found (even if subsequently reduced to a safe level),
  • organic solvents are used in the work procedure,
  • open flames or torches are used in the work procedure (also, see UCSF’s Hot Work Program on the EH&S website), or
  • the manhole or vault is located in that portion of a public right-of-way open to vehicular traffic exhaust and/or exposed to a seepage of gas or gases.

If telecommunication work is performed in a manhole that does not meet the definition of a confined space but contains a recognized serious safety or health hazard, a person with basic first-aid training must be immediately available to render assistance.

Elevator pits can be bodily entered and are not designed for continuous occupancy, which meet two of the three criteria of a confined space classification. The third criterion, limited or restricted means of entry and egress, determines whether the space is considered a confined space. Deep elevator pits that have a standard door at the base of the pit are not considered restrictive to enter or exit and therefore do not meet the definition of a confined space.  Elevator pits that need a ladder for exit are considered confined spaces.

To be classified as a permit-required confined space, the elevator pit must meet the first three criteria for a confined space and have an additional hazard, such as the potential for a hazardous atmosphere. If an elevator pit is in a public area of an occupied or residential building and shares the ambient air of the area, the potential for a hazardous atmosphere is rare. As such, atmospheric hazards do not generally need to be addressed beyond the initial evaluation and classification of the space.

The predominant hazards - mechanical and electrical - stem from elevator-related equipment. Consequently, while most pits may not contain a potential atmospheric hazard, elevator pits generally are permit-required confined spaces by virtue of their associated electrical and/or mechanical hazards.

If an elevator pit is permit-required, workers must follow the appropriate safe-entry procedures. If it is possible to completely de-energize and lockout/tagout the elevator equipment without entry into the pit, and there is no potential or actual atmospheric or other hazards, the space may be reclassified as a non-permit space. However, if entry into the pit is necessary to verify that the hazards have been eliminated (such as using a test instrument to verify electrical circuit de-energization), permit-required confined space entry procedures need to be followed until the hazards are eliminated.

Following industry best practice, activating the elevator access key switch and pit stop switch before entering the pit will suffice as isolating the elevator. If the pit does not have a pit stop switch, lockout/tagout procedures must be implemented. For deep pits that have an upper and lower pit stop switch, the lower stop switch must be turned to the off position once the pit is entered.

Electrical Utility Work

If electrical utility operations are preformed within underground vaults that meet the definition of a permit-required confined space, entry must occur in accordance with this program.

Exception: An underground vault listed on the Confined Space Inventory as not having a potential or actual hazardous atmosphere may be entered for routine work without an entry permit, attendant or rescue team. For the purpose of this program, routine work is defined as non-invasive, low hazard activities such as inspection, meter or dial reading, housekeeping, and other similar work.

Utility Tunnel System

The utility tunnel system, also referred to as the steam tunnels, are an area on UCSF’s campus that does not meet the traditional definition of a confined space based on the criterion “limited or restricted means of egress.” EH&S, the Campus Fire Marshall, and the Fire Department have made this determination in concurrence with Cal/OSHA Consulting.   The determination is based on some of following variables:

  • dimensions of doorways, stairs and hatches
  • the location of the exits
  • the distance an employee must travel to safely egre
  • nature of work being performed
  • internal configurations of the space
  • physical hazards

These spaces are listed as “hazardous environments” on the Confined Space Inventory.

Notification / Posting Signs

Warning signs must be posted on all permit-required confined spaces which workers, other employees or the public could inadvertently enter. Use a permanently mounted sign stating “DANGER — PERMIT-REQUIRED CONFINED SPACE, DO NOT ENTER” or a commercially available equivalent. Permit spaces where personnel cannot inadvertently enter, such as those protected by heavy manhole covers which require tools to remove, need not have signage posted.

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3.2 Confined Space Permit

A Confined Space Permit is a document that certifies safe entry conditions are met, safe entry procedures are developed / followed, and must be used for all entries into permit- required confined spaces.

The entry permit identifies at a minimum:

  • The location and type of space to be entered
  • Date, time and authorized duration
  • Purpose for the entry & work to be performed
  • Members of the entry team, including names of all entrants
  • Monitoring Equipment Used
    1. Instrument Serial Number
    2. Date of Last Calibration
  • Atmospheric test results
    1. Oxygen Level
    2. Carbon Monoxide (CO)
    3. Flammability (Lower Explosive Limit)
    4. Temperature
  • Possible hazards and hazard control methods
    1. EI-LOTO
    2. Ventilation, etc.
  • Communication methods
  • Potential rescue procedures / equipment needed
  • Other hazard controls or safe-work procedures
    1. Hot work
    2. Heat control, etc.

The Entry Supervisor is responsible for filling out the entry permit. The permit is essentially a pre-entry checklist. Once the space is deemed safe for entry, the Entry Supervisor signs the permit and entry into the space may commence. The permit must be posted in a conspicuous location near the entrance of the confined space and must remain there during the duration of the entry.

A sample entry permit can be found in Appendix E of this document. Contractor or 3rd Party confined space entry permits may be used, but must meet or exceed the requirements of this program.

Upon completion of all work inside the permit-required confined space, the entry supervisor will cancel the entry permit by recording the end time. Completed / cancelled entry permits are kept as long as the confined space exists by the owner-department of the confined space. Cancelled entry permits must be presented to EH&S or compliance regulators during safety-audits as evidence of the department’s safe-management of the confined space.

The Confined Space Permit can be found in APPENDIX E.

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3.3 General Entry Requirement

Every confined space must be considered a “Permit Required Confined Space” until evaluated, reclassified or proven otherwise.

Pre-Entry Briefing for Permit-Required Entry

The Entry Supervisor must conduct a pre-entry briefing with the entrant(s) and attendant(s) prior to entry into a permit space. The purpose of the briefing is to ensure the entrant(s) and attendant(s) are aware of their roles and responsibilities and relay all pertinent safety-information to the Entry Team prior to entry.

The briefing must cover:

  • the potential hazards of the space
  • control measures
  • signs and symptoms of exposure
  • prohibited conditions
  • communication methods
  • rescue procedures
  • safe-work rules

It is recommended that the entry supervisor uses the entry permit as a guide for the pre-entry briefing.

Pre-Entry Atmospheric Testing

The internal atmosphere of a permit space must be tested with a calibrated direct- reading instrument to ensure the environment is safe for entry. Atmospheric hazards, such as oxygen deficiency and flammable or toxic gases, can occur from the materials or processes inside the space or the effects of the external environment must be considered.

Acceptable safe-entry atmospheric levels of life-sustaining air are:

  • Oxygen (O2): Oxygen content between 19.5% and 23.5%.
  • Lower Explosive Limit (LEL): The concentration of any type of flammable gases and vapors must be less that 10% of the LEL (usually indicated as <10% LEL).
  • Other toxic gases and vapors:
    1. Carbon Monoxide (CO):  Carbon Monoxide levels below 50 parts per million(ppm).
    2. Hydrogen Sulfide (H2S):  Hydrogen Sulfide levels below 5 parts per million(ppm).

NOTE: Most multi-gas or 4-gas meters are capable to test for these hazards. Contact EH&S if you need to test for additional toxic gases, vapors or fumes (e.g. aromatic hydrocarbons, ammonia, carbon dioxide).

 

Procedures for Pre-Entry Atmospheric Testing

Ensure the direct-reading instrument is charged, calibrated and bump tested. Follow all manufacturers’ recommendations for use, which may include validating levels for fresh air (20.8% O2, 0% LEL, 0 toxic gases), zeroing the meter, etc.

  1. Begin by testing the air around the space, just near the entry portal. If these readings are acceptable, remove the entry cover or lid (if applicable).
  2. Insert the gas-meter-probe into the portal and test the air inside the portal (about a four foot radius), WITHOUT entering the space (any body part crossing the entrance-plane).
  • If the readings are unacceptable for entry:
  1. If the space is listed on the Confined Space Inventory as able to be ventilated using mechanical forced air ventilation - follow PM, SOP or appropriate pre-arranged procedures for ventilating the space.
  2. If the space is not listed on the Confined Space Inventory as able to be ventilated using mechanical forced air ventilation – halt operations, secure the space (close the cover or lid), and contact EH&S.
  • If the readings received in #2 are acceptable for entry, continue to sample in layers of approximately four feet (for vertical spaces), until the entire space has been tested and the levels are confirmed safe BEFORE entry. Testing the atmosphere in layers allows for the detection of lighter- and heavier-than-air gasses.
  • For permit spaces that are horizontally deep: the entrant may begin entry once acceptable levels are confirmed within a four foot radius of the entryway, but continue to sample in increments of approximately four feet horizontally until the entire working area has been cleared. Be sure to sample the air above and below the entrant’s breathing zone in order to detect lighter- and heavier-than-air gasses.

NOTE: For each test, allow enough time for the air to be drawn up into the sensors and register a reading. This is especially important when using long sample probes and tubes. Record all monitoring results on the Entry Permit.

All entrants must be provided an opportunity to observe the pre-entry atmospheric testing.

Ventilation

When it’s determined that ventilation must be used, follow these guidelines when selecting / installing / using ventilation:

Ventilation Safe Guidelines:

  • Select a fan with the capacity to quickly and efficiently replace the air within the space.
  • Use reliable, grounded power.
  • Ensure fresh air is drawn from a source away from atmospheric contaminates, such as idling vehicles or portable electric-generators.
  • Position exhaust so air is sufficiently dissipated as to avoid recirculation or endangering others outside the space.
  • If continuous forced air ventilation is to be used while an entrant is in the space:

o The entrant may not enter the space until the ventilation has eliminated any hazardous atmosphere as confirmed by gas-meter readings.

o Direct air as to ventilate the immediate areas where the entrant is or will be present within the space.

o Continue to ventilate until all entrants have left the space.

o The atmosphere must be continuously monitored to ensure ventilation remains adequate. 

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Evacuation Procedures

Entrants must evacuate the space whenever:

  • An order to evacuate is given by the attendant or the entry supervisor,
  • The entrant recognizes any warning sign or symptom of exposure to a dangerous situation,
  • The entrant detects a prohibited condition, or
  • An evacuation alarm is activated.

In the event of a potential exposure, the entrant will report to the Occupational Health for evaluation.

Report all events requiring evacuation to EH&S. EH&S will assist in determining the cause of the event, prevention & mitigation strategies, and procedures for reentering or reclassifying the space.

 

Rescue / Retrieval Procedures

The attendant (or person designated to operate the winch) will immediately begin retrieval procedures whenever:

  • The order to evacuate is given and the entrant cannot or does not self-rescue.
  • There is questionable non-movement of the entrant.
  • The entrant does not respond to communication and cannot be located visually.

Exception: If the worker is disabled due to an injury not related to exposure (i.e., a fall or structural collapse) and attempting to remove the worker may cause additional harm, the attendant will NOT ENTER the space and will call 911. The attendant should explain to the 911 dispatcher that they are having a confined space entry emergency, so the response team is prepared and has sufficient gear for an entr`1y rescue. NEVER enter a confined space to rescue an injured entrant, even if the atmosphere readings are okay. In the event of a potential exposure, the entrant will report to the Occupational Health for evaluation.

Report all events requiring evacuation to EH&S. EH&S will assist in determining the cause of the event, prevention & mitigation strategies, and procedures for re-entering or reclassifying the space.

 

3.4 Specific Entry Procedures

There are three specific types of confined space entries that are allowed under this program.  They are:

  • Entry into Non-Permit Required Confined Spaces,
  • Entry into Permit-Required Confined Spaces, and
  • Entry into Permit-Required Confined Spaces under alternate procedures. Below are detailed procedural instructions for each type of entry.

 

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Entry into Non-Permit Required Confined Spaces

A Non-Permit Required Confined Space does not meet the definition of a permit-required confined space, meaning there is no actual or potential hazardous atmosphere or no serious safety or health hazard. All confined space entries require a Confined Space Evaluation prior to entry, regardless of previous classification. Once the space is confirmed to be Non-Permit Required, entry may continue without a permit, entry team or rescue set-up.

Provide pedestrian, vehicle, or other barriers as necessary to protect entrants from external hazards and passersby from the working area.

Personnel who enter non-permit confined spaces must wear appropriate PPE and follow all safe work practices.

The Confined Space Evaluation can be found in APPENDIX D.

 

Entry into Permit-Required Confined Spaces

Entry into a permit-required confined space requires an entry permit, an appropriate rescue system, and an entry team, as outlined in this program.

 

Before entry into a permit space:

  • Organize, inspect, and test all tools and equipment needed to make the space safe for entry (direct-reading instruments, fans, blowers, LOTO equipment) and all tools and equipment used during entry (harnesses, tripods, radios, PPE).
  • Coordinate with off-campus rescue teams, if necessary.
  • Set up pedestrian, vehicle, or other barriers to protect entrants from external hazards and passersby from the working area
    • If a permit-space has an entrance cover or lid, conditions making it unsafe to remove the cover must be eliminated before the cover is removed. When entrance covers are removed, the opening must be promptly guarded.
  • Test the internal atmosphere in accordance with the “Procedures for Pre-Entry
  • Atmospheric Testing” section of this program
  • Eliminate all hazards by applying appropriate controls (EI-LOTO, pumping out water, purging, ventilating) and take measures to ensure hazards remain eliminated during entry
  • Assemble non-entry rescue setup
  • Confirm that acceptable entry conditions are present inside the space
  • Conduct a pre-entry briefing
  • Fill out the entry permit and post a signed copy outside the space

During entry, all members of the entry team must perform their duties as described in the Entry Team section of this program and follow all established safe-work rules.

When the entry has concluded, the space must be secured and permit must be canceled.

 

Entry into a Permit-Required Confined Space under Alternate Entry Procedures

Under certain conditions, an employer may use alternate procedures for worker entry into a permit required space. For example, if an employer can demonstrate with monitoring and inspection data that the only hazard is an actual or potential hazardous atmosphere that can be made safe for entry using continuous forced air ventilation, the employer may be exempted from some requirements, such as permits and attendants. However, even in these circumstances, the employer must test the internal atmosphere of the space for oxygen content, flammable gases and vapors, and the potential for toxic air contaminants before any employee enters it. The employer must also provide continuous ventilation and verify that the required measurements are performed before entry.

 

A permit-required space may be entered under alternate procedures if:

  • The only hazard posed by the permit space is an actual or potential hazardous atmosphere; and
  • Continuous forced air ventilation alone is sufficient to maintain the permit space safe for entry; and
  • All other hazards (mechanical, electrical, etc.) within the space can be eliminated without entry into the space; and

As with any confined space, conditions making it unsafe to remove an entrance cover must be eliminated before the cover is removed. When entrance covers are removed, the opening must be promptly guarded by a railing, temporary cover, or other temporary barrier that will prevent an accidental fall through the opening and that will protect entrants from foreign objects entering the space.

Before an employee enters the space, the internal atmosphere must be tested with a calibrated direct-reading instrument for oxygen content, flammable gases and vapors, and potential toxic air contaminants, in that order and according to the “Procedures for Pre-Entry Atmospheric Testing” section of this program. All entrants must be provided an opportunity to observe the pre-entry testing.

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If continuous forced air ventilation is used:

  • An employee may not enter the space until the forced air ventilation has eliminated any hazardous atmosphere;
  • The forced air ventilation must be so directed as to ventilate the immediate areas where an employee is or will be present within the space and must continue until all employees have left the space;
  • The air supply for the forced air ventilation must be from a clean source and may not increase the hazards in the space (for example, ensure the air intake is not in the vicinity of idling vehicles or portable electric-generators).

 

Ventilation Safe Guidelines:

  • Select a fan with the capacity to quickly and efficiently replace the air within the space.
  • Use reliable, grounded power.
  • Ensure fresh air is drawn from a source away from atmospheric contaminates, such as idling vehicles or portable electric generators.
  • Position exhaust so air is sufficiently dissipated as to avoid recirculation or endangering others outside the space
  • If continuous forced air ventilation is to be used while an entrant is in the space:
    • The entrant may not enter the space until the ventilation has eliminated any hazardous atmosphere.
    • Direct air as to ventilate the immediate areas where the entrant is or will be present within the space.
    • Continue to ventilate until all entrants have left the space.
    • The atmosphere must be continuously monitored to ensure ventilation remains adequate.

The atmosphere must be continuously monitored using a direct-reading instrument in order for an employee to enter a permit space under alternate procedures, regardless of the pre-entry atmospheric readings and irrespective of continuous fresh air ventilation. This can most easily be accomplished by having the employee wear a multi-gas or 4- gas meter.

There may be no hazardous atmosphere within the space whenever any entrant is inside. If a hazardous atmosphere is detected during entry, all entrants must leave the space immediately and contact EH&S. EH&S will assist in evaluating the space to determine how the hazardous atmosphere developed and implement measures to protect employees from the hazardous atmosphere before any subsequent entry takes place.

Any employee who enters permit spaces under alternate entry procedures must:

  • Be trained in the provisions of this program
  • Be aware of the possible hazards faced with entry into the space
  • Wear proper PPE
  • Understand how to operate and interpret the direct-reading instruments used in atmospheric monitoring
  • Follow all safe-work practices
  • Sign their name to the Entry Permit prior to entering the space.

Use the Confined Space Permit (Appendix E), when entering a permit-required confined space under alternate entry procedures. The Entry Permit must be posted at the entrance of the space at all times while entry is underway.

When the entry has concluded, the space must be secured and permit must be canceled.

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Reclassification of a Permit-Required Confined Space to a Non-Permit Confined Space

If a permit-required confined space presents no potential or actual atmospheric hazards, it is possible for the permit space to be reclassified as a non-permit confined space.

 

Reclassification can take place in two ways:

1.   If the space is listed on UCSF’s Confined Space Inventory as not having the potential for a hazardous atmosphere and all other hazards (electrical, mechanical, etc.) can be eliminated without entry into the space, the permit space may be reclassified as a non-permit confined space for as long as the non-atmospheric hazards remain eliminated.

For example, entry needs to be made into a water tank to repair a valve. While water is in the tank, the space is classified as permit-required because of the engulfment hazard.  The water is drained and the inlet pipes are blocked without entering the tank, thereby eliminating the hazard.  Entry can now be made under non-permit conditions.

2.  The space is listed on UCSF’s Confined Space Inventory as not having the potential for a hazardous atmosphere, but entry needs to be made into the permit- space to eliminate the hazards. Such entry must first be made under permit conditions. If testing and inspection during that entry demonstrate that the hazards within the permit space have been eliminated, the permit space may be reclassified as a non-permit confined space for as long as the hazards remain eliminated.

 

4.0 Training Requirements

 

Non-Permit Confined Spaces

Any personnel who enter a non-permit confined space must be trained in the provisions of this program as it applies to non-permit spaces. They must also be thoroughly trained in safe-work practices, hazard identification and hazard control.

Any person using a direct-reading instrument for atmospheric monitoring while entering a non-permit space must receive hands-on training in the interpretation of data, operation, calibration, function testing, and basic maintenance of the equipment.

Permit-Required Confined Spaces

Any personnel who enter a permit-required confined space, regardless of whether the space is reclassified or entered under alternate procedures, must be trained in the provisions of this program as it applies to permit spaces. In addition, personnel who perform duties as a member of the Entry Team must be trained as followed:

Attendant

The Attendant must be trained in:

  • Their duties and responsibilities as described in the Entry Team section of this program
  • Hazard recognition and controls as applicable to permit spaces
  • Use of personal protective equipment (PPE)
  • Non-entry rescue
  • Entry procedures and entry permits
  • Interpretation of data, operation, calibration, function testing, and basic maintenance of all direct-reading equipment used in atmospheric monitoring

 

Entrants

Entrants must be trained in:

  • Their duties and responsibilities as described in the Entry Team section of this program
  • Hazard recognition and controls as applicable to permit spaces
  • Proper use of personal protective equipment (PPE)
  • Self-rescue and non-entry rescue procedures
  • Entry procedures and entry permits
  • Interpretation of data, operation, calibration, function testing, and basic maintenance of all direct-reading equipment used in atmospheric monitoring

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Entry Supervisor

The Entry Supervisor must be trained in:

  • Their duties and responsibilities as described in the Entry Team section of this program
  • Hazard recognition and controls as applicable to permit spaces
  • Selection and use of personal protective equipment (PPE)
  • Non-entry rescue
  • Entry procedures and entry permits
  • Interpretation of data, operation, calibration, function testing, and basic maintenance of all direct-reading equipment used in atmospheric monitoring
  • Duties of the Entrant and Attendant

For entries that will use retrieval systems for non-entry rescue, employees must receive annual hands-on training removing simulated victims from actual or representative confined spaces that have openings and portals like the types from which rescue is to be performed, using the actual retrieval equipment.

 

Retraining

For both permit and non-permit spaces, retraining must be provided whenever:

  • There is a change in duties*
  • There is a change in the classification of a confined space*
  • There is a change in the hazards of a space*
  • An inspection reveals retraining would improve the safety of confined space operations
  • A deviation from procedure reveals retraining would improve the safety of confined space operations
  • An employee demonstrates deficiencies or inadequacies in their knowledge of confined space operations or procedures
  • If the employee has not been previously trained in the specifics

 

5.0 Record Keeping Requirements

 

Each department is responsible for maintaining their own records. Records include:

  • Cancelled Entry permits
  • Training records (to include tailgates, monthly safety meeting minutes, etc.)
  • Calibration, maintenance and bump test records of equipment

 

Retention

Retain all entry permits for two years. If a permit was revoked for any reason, or a hazardous or abnormal condition occurred during an entry, that permit must be retained for five years.

Retain all training records for ten years after employees have retired or left University employment.

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6.0 References

 

29 Code of Federal Regulations 1910.146 Permit-required Confined Spaces

American National Standards Institute, ANSI/ASSE Z117.1-2009 Safety Requirements for Confined Spaces

 

California Code of Regulations, Title 8, Chapter 4. Division of Industrial Safety:

§2943. Work on or in Proximity to Underground High-Voltage Cables, Conductors or Equipment

§5156 - §5159 Confined Spaces

§8616. Underground Lines

 

California Department of Industrial Relations, Cal/OSHA Consultation Service, Training and Education Unit, Confined Space Guide, May 2012

 

OSHA Letter of Interpretation October 27, 1995 Mr. Edward A. Donoghue [Donoghue Associates Inc.] Code and Safety Consultant to NEII

 

Confined Space Emphasis Program http://www.dir.ca.gov/dosh/Confined_Space_Emphasis_Program.html