Confined Spaces

The purpose of this Confined Space Program is to establish a safe working procedure for the employees of this facility and to ensure the protection of all employees from the hazards associated with confined space entry. This program will describe reasonable and necessary policies and procedures for management and employees to follow during confined space entry.

Responsibilities

Management: It is the responsibility of management to reduce the need for confined entry and/or to eliminate whenever possible all confined space hazards in order to reclassify permit-required spaces to a non-permit confined space. Whenever confined space entry is necessary, management shall make sure all provisions of this document are to be followed. Management shall provide the proper protective equipment when such equipment is necessary to protect the safety of all employees. They are responsible for the establishment and review of a confined space entry program.

Management/Supervisor: Supervisor shall be responsible for the following:

Identify and report job areas and locations that are or may be confined spaces.
Classify confined spaces as permit required or non-permit required.
Identify personnel who will enter confined spaces.
Identify the personnel under their supervision to wear respirators.
Provide detailed instructions and training on confined hazards and entry procedures.
Provide instructions on proper use of equipment required for confined space entry.
Maintain equipment that is used to enter confined spaces.
Conduct work site inspections.
Maintain records of equipment maintenance and employee training.
Inform employees who may enter permit-confined space by posting danger signs and by training.
Issuance and cancellation of entry permit.
Identify and evaluate the hazards of permit space before employees enter them.

Employees: It is the responsibility of the employee to follow all given policies and procedures. He shall also report any deficiencies or malfunction of equipment, understand emergence procedures, and under no circumstance enter a confined space, even to rescue an employee.

Contractor: If an outside contractor is hired to perform work within a permit-required confined space, management and contractor shall work closely together to insure proper entry procedures. Management shall:

Inform the contractor that the area in question is a permit-required confined space.
Review the permit-required confined space program followed by the contractor.
Inform the contractor of the hazards identified within the space and any past experience with the space.
Inform the contractor of any precautions or procedures that have been implemented for the protection of employees in the permit-confined space where contractors personnel will be working.
Debrief the contractor at the end of the work to identify hazards discovered or created in the permit-required confined space during the operations.

Identifying Confined Spaces

Recognition is an important aspect of making a safe entry into a confined space. Not all confined spaces will be considered permit-required confined spaces and being able to identify the difference between the two is important. A site evaluation shall be conducted in order to determine if any spaces are considered to be a confined space or a permitrequired confined space. A confined space is any space that has the following:

It is large enough or so configured that an employee cannot easily enter to perform his or her job duties.
It has limited or restricted means for entry or exit. Confined space openings are limited primarily by size and location. Some confined spaces may have large openings such as a pit. Entrance and exit may be required from top, bottom, or side having to access the work area by ladder.
It is not designed for continuous employee occupancy. Most confined spaces are not designed for employees to enter and work on a routine basis. They may be designed to store a product, enclose materials and process, or transport product or substance. The danger associated with entry may come from chemicals or physical hazards within the space.

A non-permit confined space is space that poses no actual or potential atmospheric hazards and if all the hazards within the space are eliminated without entry into the space. Examples of some non-permit required confined spaces might include attics, walk-in freezers or refrigerators, and some building crawl spaces.

Permit Required Confined Space

A permit-required confined space is a confined space that is potentially hazardous. A permit-required space 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 that slopes downward and tapers to a smaller cross section.
Contains any other recognized serious safety or healthy hazard such as but not limited to:
- fall hazards
- unguarded machinery
- extreme heat or cold
- steam pipes or chemical lines
- hazardous noise levels
- electrical hazard
- potentially hazardous levels of dust

Management/supervisors are directly responsible for ensuring the safety of their employees. It is their responsibility to evaluate potentially hazardous spaces within their facility and areas to ensure that the proper precautions are taken for safety. This includes clearly marking permit-required confined space, training the employee, and ensuring proper entry procedures are followed. No employee shall be sent on a job that could potentially involve work in a confined space unless they have been properly trained.

Reclassification to A Non-Permit Confined Space

If it is necessary to enter the permit space, management should try to eliminate hazards. If testing and inspection during the entry demonstrates that the hazard within the permit space has been eliminated, the permit space may be reclassified as a non-permit confined space for as long as the hazard remains eliminated.

Identifying Permit Space Hazards

Once a space has been classified as confined, the hazards that may be present within the confined space must be identified. Confined space hazards can be grouped into the following categories:

Oxygen-deficient atmospheres
Flammable atmospheres
Toxic atmospheres
Mechanical and physical hazards

Every confined space must be evaluated for these four types of hazards. The three types of atmospheric hazards are often the most difficult to identify since they might not be detected without the assistance of a gas monitor.

Oxygen-Deficient Atmosphere: the normal atmosphere is composed of approximately 21% oxygen and 79% nitrogen. An atmosphere containing less than 19.5% oxygen shall be considered oxygen deficient. The oxygen level inside a confined space may be decreased as the result of either consumption or displacement. There are a number of processes that consume oxygen in a confined space. Oxygen is consumed during combustion of flammable materials, as in welding, cutting, or brazing. A more subtle consumption of oxygen occurs during bacterial action, as in the fermentation process. Oxygen can also be consumed during chemical reactions such as in the formation of rust on the exposed surfaces of a confined space. The number of people working in a confined space and the amount of physical activity can also influence oxygen consumption.

Flammable Atmosphere: Flammable atmosphere are generally the result of flammable gases, vapor, dust mixed in certain concentrations with air, or an oxygen-enriched atmosphere are those atmosphere that contain an oxygen concentration greater than 22%. An oxygen-enriched atmosphere will cause flammable materials such as clothing and hair to burn violently when ignited.

Combustible gases or vapors can accumulate within a confined space when there is inadequate ventilation. Gases that are heavier than air will accumulate in the lower levels of a confined space. The work being conducted in a confined space can generate a flammable atmosphere. Work such as spray painting, coating, or the use of flammable solvents for cleaning can result in the formation of an explosive atmosphere. Welding or cutting with oxyacetylene equipment can also be the cause of an explosion in a confined space and shall not be allowed without a hot work permit. Oxygen and acetylene hoses may have small leaks in them that could generate an explosive atmosphere. The atmosphere shall be tested continuously while any hot work is being conducted within the confined space.

Toxic Atmosphere: Toxic atmosphere may be present within a confined space as the result of one or more of the following:

A product stored in a confined space can be absorbed by walls, giving off a toxic vapor when removed or when cleaning the residual materials. The product can also produce toxic vapors that will remain in the atmosphere due to poor ventilation.
Toxic atmosphere can be generated as the result of work being conducted inside the confined space. Example of such work includes things like welding or brazing, painting or scraping, sanding, etc. Many of the solvents used for cleaning and/or degreasing produce highly toxic vapors.
Toxic fumes produced by processes near the confined space may enter and accumulate in the confined space. For example, if a confined space is lower than the adjacent area and the toxic fume is heavier than air, the toxic fume may settle into the confined space.

Mechanical and Physical Hazards: Rotating and/or moving mechanical parts or energy sources can create hazards within a confined space. All rotating or moving equipment such as pumps, process lines, electrical sources, etc., within a confined space must be identified. Physical factors such as heat, cold, noise, vibration, and fatigue can contribute to accidents.

Safe Entry Practices

All confined spaces shall be classified as either a Permit-Required confined space, or a Non-Permit confined space. Nonpermit confined space is a space that does not present a real potential hazard. All employees shall be made aware of these spaces through training.

Written Permit: The permit system procedures for all personnel entering permit-required confined spaces are the responsibility of the management/supervisor in charge.

The permit system will document the following:

The signature of the authorized entry personnel
Time duration for the permit.
Termination procedures.

The entry permit must identify the following:

The identity of the space to be entered
Purpose of entry
Date and duration of the permit
Authorized entrant(s)
The name of the attendant(s)
The name of the entry supervisor
Identification of Hazards (must be specific)
Isolation measures
Acceptable entry conditions
The results of initial and periodic testing
Rescue and Emergency procedures
Communications procedures
Equipment used
Additional permits requirements (hot work-welding)
Any other information that may be relevant to the safety of employees.

Atmospheric Monitoring: Atmospheric monitoring is used to determine if the space contains or has the potential to contain a hazardous atmosphere. Atmospheric testing evaluates the hazard of the permit space and then verifies acceptable entry conditions for entry into that confined space exit.

The atmosphere of a confined space should be analyzed using equipment of sufficient sensitivity and specificity to identify and evaluate any hazardous atmospheres that may exist or arise, so that appropriate entry procedures can be developed and acceptable entry conditions can be made for that space. A minimum of three tests should be performed to identify atmospheric hazards in confined space. These tests must be performed in the following sequence:

oxygen content
flammability
toxicity

Verification testing of the atmosphere of a permit space which may contain a hazardous atmosphere should be tested for residue at entry and make sure they are within the range of acceptable entry conditions. Measurement of values for each atmospheric parameter should be made for at least the minimum response time of the test instrument specified by the manufacturer.

To ensure that the atmospheric testing equipment is functioning properly, the user shall perform the following three operations:

Inspection
Calibration
Function Test
If any of the alarms sound, exit the space immediately.

Ventilation of Confined Space: Ventilation is one of the most effective means of controlling hazardous atmospheres in confined space. In this procedure, clean air replaces contaminated air by natural or forced ventilation. When ventilating a confined space, the following factors must be taken into consideration:

Volume of air: This determines the capacity of the blower or ejector.
Type of atmosphere: This will determine the type of blower used and the length of time needed to ventilate until it is safe for people to enter the space
Access to space: This determines how to get the ventilating air into and out of the space
Power requirements and availability: This will influence the power source and fan motor size
Source of clean air: This is necessary to ensure adequate ventilation
Length of time ventilation is needed: This is determined by the type of contaminant and the work that is to be done in the space
Type of work to be done: This determines whether local exhaust ventilation or general ventilation is required

Ventilation Guide

Select fan with a capacity to quickly replace the air in the space. Limitations are typically posted on the fans housing.
Use reliable, grounded electrical power.
Eliminate any hazardous atmosphere. Exhaust toxic and flammable air, supply fresh air when oxygen-deficient.
Provide constant circulation of fresh air while space is occupied:
- Natural ventilation is allowable only on non-permit entry.
- Direct high-velocity supply ventilation to mix the air throughout the space.
- Capture contaminants during hot work or cleaning with solvents by using additional local exhaust.
- Pure oxygen is not fresh air. Never use bottle oxygen for ventilation.
Arrange ductwork to ensure safety.
Monitor the air to ensure ventilation is keeping the air safe to breathe.

Employee Duties

Duties of Authorized Entrants:

Know the hazards that may be faced during entry.
Recognize the signs and symptoms of hazard exposure
Understand the consequences of hazardous exposure.
Use equipment properly.
Communicate with the attendant.
Alert the attendant of hazards.
Exit the permit space quickly when required.

Duties of Attendant:

Know entry hazards.
Know behavioral effects of exposure.
Maintain accurate entrant identification.
Remain outside the permit space.
Communicate with entrants.
Monitor entry activities.
Summon rescue and emergency services.
Prevent unauthorized entry.
Perform non-entry rescue.

Duties of Entry Supervisor:

Know the potential hazards during entry and work.
Determine if acceptable entry conditions are present at a permit space where entry is planted.
Terminate entry.
Verify that rescue services are readily available or the means for summoning them are operable.
Remove unauthorized individuals who enter or try to enter the permit space during entry and work.
Determine that entry and work operations remain consistent with entry permit terms and that acceptable entry conditions are maintained.

Conclusion of Entry: The lead worker will determine when the entry operations have been completed. The permit space will be closed and the permit canceled. The lead worker will write “Permit Closed” with the date, time and signature. Reentry into the permit space will only be allowed after following all aspects of this program.

Measures to Prevent Unauthorized Entry: If a permit-required confined space is located within this facility, management shall inform employees of the existence of such a space by posting a warning sign which reads:

DANGER, PERMIT-REQUIRED CONFINED SPACE, DO NOT ENTER

When posting of warning signs is not feasible, permit-required confined spaces shall be identified by other equally effective means such as by training.

Emergency Response

To facilitate pre-entry rescue, retrieval system or other methods shall be used whenever an authorized entrant enters a permit space, unless the retrieval equipment would increase the overall risk of entry or would not contribute to the rescue of the entrant. Retrieval system shall meet the following requirements:

A. 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.

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

C. If an injured entrant is exposed to a substance for which a MSDS or other similar written information is required to be kept at the worksite, the MSDS or written information shall be made available to the medical facility treating the exposed entrant.

D. The facility shall contact its local Fire Department/Emergency Rescue to inform them that they will be designated as the outside rescue team. They shall be made aware of the hazards they may confront when called on to perform rescues. Facilities shall provide the Fire Department/Emergency Rescue with access to all permit spaces from which rescue may be necessary so that they can develop appropriate rescue plans and practice rescue operations.

Training

Employees involved with permit-confined space work will be trained to assure the knowledge, understanding, and skills necessary for the safe performance of their duties. Management and supervisors will be trained in the identification and evaluation of confined space hazards and the proper precautions to be taken to assure safe entry and work in confined spaces. Employees entering confined spaces will be trained in the hazards and potential hazards involved and how to protect themselves from the hazards. They will be trained to never enter a confined space until a permit has been authorized to enter. Attendants will be trained in their duties and responsibilities and the action to be taken in the event of an emergency.

Initial and annual training refresher courses must be completed.

1. Initial training must be provided to each affected employee:

Before the employee is assigned confined space duties.
Before there is a change in assigned duties.
When there is a change in permit space operations.
Whenever management feels that there are inadequacies in the program or training.

2. Annual Training:

Annual training must be accomplished for all affected employees on a refresher and review basis.

3. Training documents must contain each trained employees name, signature and date of training. Management/supervisor shall be responsible for the following:

Identifying confined spaces.
Identifying hazards within a confined space.
Document that all training requirements for a specific confined space entry have been met by signing the pre-entry authorization space on the entry permit
Obtaining and maintaining all equipment necessary to complete the confined space entry.
Terminating the entry and canceling the permit.

The person(s) authorized to enter a confined space shall be responsible for and receive training in the following:

1. The knowledge of hazards that may be faced during entry, including symptoms and consequences of the exposure.

2. Proper use of equipment:

Atmospheric testing and monitoring equipment.
Ventilating equipment needed to obtain acceptable entry condition.
Communication equipment necessary to maintain contact with the attendant.
Personal protective equipment as needed.
Rescue and emergency equipment as needed.
Any other equipment necessary for safe entry into and rescue.

3. How and when to communicate with attendant as necessary.

4. Alert the attendant whenever:

The entrant recognizes any warning sign or symptom of exposure.
The entrant detects a prohibited condition.

5.Exiting the permit space as quickly as possible whenever:

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

Person authorized to perform duties as attendant shall be responsible for and receive training in the following:

Knowing the hazards that may be faced during entry.
Continuously maintaining an accurate count of authorized entrants in the permit space.
Remain outside the permit space during entry operation.
Attempting non-entry rescue if proper equipment is in place and the rescue attempt will not present further hazards to the entrant or attendant.
Communicating with authorized entrants as necessary to monitor entrant’s status and to alert entrants of the need to evacuate the space when conditions warrant.
Monitoring activities inside and outside the space to determine if it is safe for entrants to remain in the space and ordering the authorized entrants to evacuate the permit space immediately under any of the following conditions:
- If the attendant detects a prohibited condition.
- If the attendant detects the behavioral effects of a hazardous exposure.
- If the attendant detects a situation outside the space that could endanger the authorized entrant.
- If the attendant cannot effectively and safely perform all the duties required by this program.
Summoning rescue and other emergency services when necessary.
Perform no duties that might interfere with the attendant’s primary duty to monitor and protect the authorized entrants.

****The following Confined Space Program is provided only as a guide to assist employers and employees in complying with the requirements, as well as to provide other helpful information. It is not intended to supersede the requirements of the OHSA standard. An employer should review the standard for particular requirements which are applicable to their individual company. A feedyard shall add information relevant to their particular facility in order to develop an effective, comprehensive program.

The plan shall be signed by the operator or other signatory authority and shall be made available to all company and contract employees.

CONFINED SPACE AREA DESCRIPTIONS AND HAZARDOUS ANALYSIS

Each facility shall perform a workplace analysis to determine if any space fits the criteria for a permit required confined space. Based on a walk through analysis of the work place, both permit and non-permit confined spaces have been identified and their hazards evaluated.

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CONFINED SPACE ENTRY PROCEDURE CHECKLIST/PERMIT

DATE: _____

REASON FOR ENTRY: ______________________________________

SPACE TO ENTER: ________________________________________

EMPLOYEES: _____________________________________________

Supervisor present at entry _____________________________

Note: If there is a crew change or shift change, this checklist must be completed again before entry.

Air Quality:

% oxygen prior to entry, at least 20%
Oxygen to be monitored continuously
No pesticides, flammables, sewer gas, or other potentially hazardous odors known/suspected
Note: Work cannot proceed until confirmed safe for entry
Mechanical ventilation needed
Ventilation
- Natural: doors, vents, inspection ports, etc. opened
- Mechanical: fan if needed to maintain air quality

Safety Equipment Inspected and Free of Defects:

Safety Harness
Hoist Mechanism
Lifeline
Other, specify

Personal Protective Equipment to be Used:

Respirator, specify type
Gloves
Eye/face protection
Other, specify

General Practices:

Employees trained in procedure(s).
Communication methods, signals, etc. understood
Emergency procedures understood
Symptoms of oxygen deficiency explained
Appropriate equipment locked out, tagged, blocked, bled or otherwise secured against unwanted movement
Duties of safety observer(s) explained
Appropriate lighting and tools provided

Work Site Conditions

Bin Entry:

If entry and exit is made with rope or chain ladder, additional personnel are on hand to pull employee out of bin if necessary
The distributor(s) feeding the bin has been blocked so that material is not accidentally run into the bin
Inspect bin to ensure that there is no suspended or lodged material above the work area. Employees are not permitted to work in bins under these conditions
Everyone understands that the safety harness and lifeline must be used, and that they must be put on before entry and may not be taken off until the employee is out of the bin. Lifeline will be kept tight at all times
At least two observers will be present at all times (More if more than one person is entering the bin)

Tank, Vessel, Equipment Entry:

Equipment secured against unwanted movement, blocked, bled
Material/liquid level low enough not to constitute a hazard
Safety line needed. If no, why?
Possible entrapment hazard. If so, list

CONFINED SPACE TRAINING

Date of Employee Training __________

Topics Discussed:

Initial and annual training refresher courses must be completed.

Initial training must be provided to each affected employee:
- Before the employee is assigned confined space duties
- Before there is a change in assigned duties
- When there is a change in permit space operations
- Whenever management feels that there is inadequacies in the program or training
Annual Training:
- Annual training must be accomplished for all affected employees on a refresher and review basis
Training documents must contain each trained employee’s name, signature and date of training

Management/supervisor shall be responsible for the following:

Identifying confined spaces
Identifying hazards within a confined space
Document that all training requirements for a specific confined space entry have been met by signing the pre-entry authorization space on the entry permit
Obtaining and maintaining all equipment necessary to complete the confined space entry
Terminating the entry and canceling the permit

Confined Spaces

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