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Chapter 7: Permit Required Confined Space Entry Program

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Chapter 7: Permit Required Confined Space Entry Program

NOTE – ALL CONFINED SPACE PERMITS REQUIRE AT LEAST 24 HOURS NOTICE TO OEMS VIA E-MAIL AT SAFETY@UMW.EDU OR AT 540-654-2108.

Purpose

The purpose of this program is to inform employees, that UMW is complying with the OSHA Confined Space Standard, Title 29 Code of Federal Regulations 1910.146. We have determined that UMW needs written procedures for the evaluation of confined spaces, and where permit-required spaces are identified. This program applies to all work operations at UMW where employees must enter a permit-required confined space as part of their job duties.

OEMS has overall responsibility for coordinating Health and Safety programs at UMW. The shop supervisors have the overall responsibility for the Permit-Required Confined entry. Shop supervisors will review and update the program along with OEMS no less than annually.

Copies of the written program may be obtained from shop supervisors at the Physical Plant Facility, as well as the OEMS Offices located in Hamlet House.

Under this program, we identify permit-required spaces at the University, and provide training for our employees according to their responsibilities in the permit space. These employees receive instructions for safe entry into specific types of confined spaces, including testing and monitoring, appropriate Personal Protective Equipment, rescue procedures, and attendant responsibilities.

This program is designed to ensure that safe work practices are utilized during all activities regarding the permit space to prevent personal injuries and illnesses that could occur.

If, after reading this program, you find that improvements can be made, please contact OEMS or your shop supervisor. We encourage all suggestions because we are committed to creating a safe workplace for all our employees and a safe and effective permit-required confined space entry program. It is an important component of our overall safety plan. We strive for clear understanding, safe work practices, and involvement in the program from every level of involvement.

Definition of a Confined Space

A confined space as defined by OSHA is:

  1. A space large enough to be entered
  2. Has limited means of entry and exit
  3. Is NOT designed for continuous employee occupancy

Hazard Evaluation for Permit Spaces

To determine if there are permit-required confined spaces at UMW, OEMS has conducted a hazard evaluation on campus. This evaluation has provided the information necessary to identify the existence and location of permit-required confined spaces on our campus that must be covered by the Permit-Required Confined Space Entry Program. This written hazard evaluation is kept at Hamlet House in the OEMS Offices.

Preventing Unauthorized Entry

To provide a safe work environment and to prevent employees from accidentally entering a permit space, we have implemented the following procedures to inform all employees of the location, and danger posed by permit spaces at UMW. To inform employees of the existence of a permit space, we post all areas with applicable signs and notifications ensuring that unauthorized employees do not enter and work in permit spaces.

DANGER – PERMIT-REQUIRED CONFINED SPACE – DO NOT ENTER

Notification of OEMS

All Permit-Required Confined Space Entry requests must be made at least 24 hours in advance unless the entry is due to an emergency situation. If 24 hours’ notice is not given, OEMS has the right to refuse entry to the confined space. OEMS also has the right to terminate a request if conditions do not warrant entry.

Safe Permit Space Entry Procedures

The shop supervisor is the Entry Supervisor responsible for authorizing entry and issuing entry permits for work at UMW permit spaces. The file of permits and related documents are kept in the Confined Space Entry Logbook located in the OEMS Offices at Hamlet House. The procedures we follow for preparing, issuing, and canceling entry permits includes the following elements:

  1. Evaluate the need to enter such a space
  2. Contact shop supervisor and advise of necessity
  3. Shop supervisor will contact OEMS for evaluation and monitoring (O2, LEL, H2S, CO)
  4. Shop supervisor will generate Confined Space Permit
  5. All equipment will be staged and erected
  6. OEMS will contact Fredericksburg Fire Dept. and UMW Police Dept. to notify them of entry and location and activate standby conditions for rescue.
  7. OEMS will do air sampling evaluations, noting on permit findings, monitor serial #, calibration date.
  8. OEMS will verify all equipment in place and in good condition.
  9. Shop supervisor will verify Lock Out / Tag Out
  10. Shop Supervisor will assign an attendant
  11. Shop Supervisor will verify all paperwork to be valid and in order.
  12. Shop Supervisor will notify safety office upon completion of work
  13. Shop Supervisor will submit original copy of permit in Confined Space Entry Logbook located in the OEMS Office.
  14. Shop Supervisor will verify all entry personnel are out and in good health
  15. OEMS will notify Fredericksburg Fire Dept. and UMW Police Dept. upon Completion of tasks and area has been secured.

Pre-Entry Evaluation

To ensure the Health and Safety of UMW employees, before allowing authorized workers to enter a permit space, we evaluate conditions in that space to determine if the conditions are safe for entry. Any employee who enters the space, or that employee’s authorized representative, has the opportunity to observe the pre-entry and any subsequent testing. The authorized entrant or that employee’s representative also has the option of requesting a reevaluation of the space if they feel that the evaluation was not adequate.

UMW follows the procedures to evaluate each permit space before entry according to 1910.146(c)(5)(ii)(C). This includes testing the internal atmosphere with a calibrated direct-reading instrument for oxygen content, flammable gases and vapors, and potential toxic air contaminants. We also periodically test the atmosphere of the space to ensure that the continuous ventilation is preventing the accumulation of a hazardous atmosphere.

Certification

According to 1910.146(c)(5)(ii)(H), UMW verifies that the space is safe for entry and that the pre-entry measures required by 1910.146(c)(5)(ii) have been taken. A written certification that contains the date, location of the space, and signature of the person providing the certification will be visible during the time of actual entry. UMW is responsible for verifying these procedures. The certification is made before entry and is available to each employee entering the space.

According to 1910.146(c)(5)(iii), UMW documents the basis for determining that all hazards in a permit space have been eliminated, through a certification that contains the date, location of the space, and signature of the person making the determination. UMW is responsible for documenting this information. The certification is available to each employee entering the space.

Equipment

To ensure the safety and health of our employees, the University provides appropriate equipment to all employees who work in or near our permit required confined spaces. According to 1910.146(k)(3)(i), each authorized entrant will use a chest or full body harness, with a retrieval line attached at the center of the entrant’s back near shoulder level.

We maintain all equipment in excellent working condition, train the entrants in the correct usage of this equipment, and ensure that all equipment, including that used for personal protection, is used properly.

Duties – Authorized Entrants

Those persons who have completed the training and are authorized to enter our permit spaces (authorized entrants) are assigned specific duties and responsibilities which they must perform when they work in the permit space.

The elements covered in the training program for authorized entrants include:

  1. All personnel involved in the entry into a permit-confined space shall receive appropriate training.
  2. The requirements of this program and the conditions that must be met for entry into a confined space
  3. The conditions or work practices that may produce a hazard in a permit confined space that may require the space to be reevaluated.
  4. Hazard recognition including information on the mode, signs and symptoms and consequences of an exposure.
  5. The use of personnel protective equipment including rescue harnesses, respiratory equipment (only certified personnel) and so forth. Entry procedures and precautions to include:
    1. Maintaining communication with the attendant as necessary to enable the attendant to monitor status and to enable the entrants of the need to evacuate the space.
    2. Alerting the attendant whenever:
      1. The entrant recognizes any warning sign or symptom of exposure to a dangerous situation.
      2. The entrant detects a prohibited condition.
    3. Requirements to evacuate whenever so ordered by the entry supervisor or attendant, whenever the entrant recognizes any warning sign or symptom of exposure to a dangerous situation, if the entrant detects a prohibited condition, or whenever an evacuation alarm is activated.
    4. Emergency and non-entry rescue methods, and procedures for calling rescue services.

Duties – Attendants

Those persons who have completed the training and have been designated as permit space attendants are assigned specific duties and responsibilities, which they must perform in, permit space job duties.

Their duties and responsibilities include:

  1. Continuously maintain an accurate count of authorized entrants in the permit space and ensure that the means used to identify authorized entrants are accurate.
  2. Remain outside the permit space during entry operations until relieved by another attendant.
  3. Communicate with authorized entrants as necessary to monitor entrant status and to alert entrants of the need to evacuate the space.
  4. Monitor activities inside and outside the space to determine if it is safe for entrants to remain in the space and orders the authorized entrants to evacuate the permit space immediately under any of the following conditions:
    1. If the attendant detects a dangerous condition,
    2. If the attendant detects behavioral effects of a hazard exposure with the authorized attendants,
    3. If the attendant detects a situation outside the space that could endanger the authorized entrant
    4. If the attendant cannot effectively and safely perform the requirements of this section.

The elements covered in the training program for permit space attendants includes:

  1. Training detailed above as an authorized entrant as well as the following training.
  2. Hazards that may be faced during entry.
  3. Possible behavior effects of hazard exposure in authorized entrants.

Duties – Entry Supervisors

Those persons who have completed the training and have been designated as permit space entry supervisors are assigned specific duties and responsibilities which they must perform in permit space job duties. Their duties and responsibilities and training are to include:

  1. Know the hazard(s) that may be faced during entry, including information on the signs or symptoms and consequences of exposure. This information will be contained on the Permit-Confined Space permit form for the space in question.
  2. Verify, by checking that the appropriate entries have been made on the permit and that all air monitoring has been performed as well as all procedures followed and equipment in place as specified before endorsing permit.
  3. Terminate the entry and cancel the permit when the operations covered by the entry permit have been completed or a condition that is not allowed under the entry permit arises in or near the permit space.
  4. Verify with the UMW Safety office that rescue services are available and that the means for summoning them are operable
  5. Remove unauthorized entrants from the space/area
  6. Upon completion of tasks notify OEMS
  7. File original permit with OEMS into Confined Space Logbook
  8. Make a copy for shop records

The entry supervisor shall receive training as for attendants above, and additional training as required to evaluate confined space hazards.

Training Program

Every employee at UMW who faces the risk of confined space entry is provided training so that each designated employee acquires the understanding, knowledge, and skills necessary for the safe performance of the duties assigned to them. OEMS conducts the permit-required confined space training. All training related materials, documents, and signed certificates are kept at the OEMS Office located in Hamlet House.

New employees are always trained before their initial assignment of duties. When changes occur in permit-required confined space areas, additional training will be provided. Training will also be re-evaluated upon request of any involved employee as requested. Upon successful completion the permit-required confined space training program, each participant receives a wallet card which they sign verifying that they understand the material presented, and that they will follow all policies and procedures regarding permit space entry.

Rescue and Emergency Services

UMW utilizes Fredericksburg Fire Department to perform rescue and emergency services in the event of a confined space incident. To familiarize this service with our facility and emergency needs, we provide access to all permit spaces from which rescue may be necessary so the rescue team can develop appropriate rescue plans and practice rescue operations. We also inform the rescue team of the hazards they may confront when called on to performs rescue at the site.

Multiple Employer Entry Procedures

When outside contractors enter our facility to perform work in permit spaces, we coordinate entry and work operations. All contractors and subcontractors will follow all applicable and preceding requirements while performing duties at the University.

Post-Operations Procedures

Upon completion of work in a permit space, we follow these procedures to close off the space and cancel the permit:

  1. Contact OEMS for final closure
  2. OEMS will notify rescue of completion and termination of support.
  3. All barriers and warnings will be removed
  4. Covers, doors and closures will be secured
  5. Signs re-hung at entry point for notification

Review of Procedures

To ensure that all employees participating in entry operations are protected from permit space hazards, UMW reviews the Permit-Required Confined Space Entry Program on a regular basis. We use the retained canceled permits from the past 12 months within one year after each entry and revise the program as necessary. UMW performs a single annual review covering all entries performed during a 12-month period. If no entry is performed during a 12-month period, no review will be performed.

Enforcement

Constant awareness of and respect for permit-required confined space entry hazards, and compliance with all safety rules are considered conditions of employment. Supervisors, OEMS, and the Department of Human Resources reserve the right to issue disciplinary warnings to employees, up to and including termination.

Emergency Management and Safety