University of Arkansas at Little Rock
Policy Name: Confined Space Program
Policy Number: LR 701.8
Effective Date: August 5, 2009
Most Recent Review Date:
The purpose of the UALR Confined Space Program is to set procedures that will ensure workers’ safe entry into confined spaces and permit-required confined spaces to perform routine tasks associated with their employment. This procedure is designed to provide the minimum safety requirements in accordance with the Occupational Safety and Health Administration’s (OSHA) Confined Space Standard, 1910.146.
A confined space is defined as any location that has limited openings for entry and egress, is not intended for continuous employee occupancy, and is so enclosed that natural ventilation may not reduce air contaminants to levels below the threshold limit value (TLV). Examples of confined spaces include: manholes, stacks, pipes, storage tanks, trailers, tank cars, pits, sumps, hoppers, and bins. Entry into confined spaces without proper precautions could result in injury, impairment, or death due to:
- An atmosphere that is flammable or explosive.
- Lack of sufficient oxygen to support life.
- Contact with or inhalation of toxic materials.
- General safety or work area hazards such as steam or high pressure materials.
III. ASSIGNMENT OF RESPONSIBILITY
In administering this Confined Space Program, UALR will:
- Monitor the effectiveness of the program.
- Provide atmospheric testing and equipment as needed.
- Provide personal protective equipment as needed.
- Provide training to affected employees and supervisors.
- Provide technical assistance as needed.
- Preview and update the program on at least an annual basis or as needed.
B. Program Manager
The Environmental Health and Safety Office (EHS) is responsible for managing the Confined Space Program, and shall:
- Ensure that a list of confined spaces at all UALR work sites is maintained.
- Ensure that canceled permits are reviewed for lessons learned.
- Ensure training of personnel is conducted and documented.
- Coordinate with outside responders.
- Ensure that equipment is in compliance with standards.
- Ensure that the EHS officer(s) or department supervisor in charge of confined space work shall:
- Ensure requirements for entry have been completed before entry is authorized.
- Ensure confined space monitoring is performed by personnel qualified and trained in confined space entry procedures.
- Ensure a list of monitoring equipment and personnel qualified to operate the equipment is maintained by the Safety and Occupational Health Office.
- Ensure that the rescue team has simulated a rescue in a confined space within the past twelve (12) months.
- Know the hazards that may be faced during entry, including the mode (how the contaminant gets into the body), signs or symptoms, and consequences of exposure.
- Fill out a permit.
- Determine the entry requirements.
- Require a permit review and signature from the authorized entry supervisor.
- Notify all involved employees of the permit requirements.
- Post the permit in a conspicuous location near the job.
- Renew the permit or have it reissued as needed (a new permit is required every shift).
- Determine the number of attendants required to perform the work.
- Ensure all attendant(s) know how to communicate with the entrants and how to obtain assistance.
- Post any required barriers and signs.
- Remain alert to changing conditions that might affect the conditions of the permits (i.e., require additional atmospheric monitoring or changes in personal protective equipment).
- Change and reissue the permit, or issue a new permit, as necessary.
- Ensure periodic atmospheric monitoring is done according to permit requirements.
- Ensure that personnel doing the work and all support personnel adhere to permit requirements.
- Ensure the permit is canceled when the work is done.
- Ensure the confined space is safely closed and all workers are cleared from the area.
C. Entry Supervisors
The EHS officer(s) or department supervisor(s) shall serve as the entry supervisor(s), and shall be qualified and authorized to approve confined space entry permits. The entry supervisor(s) shall be responsible for:
- Determining if conditions are acceptable for entry.
- Authorizing entry and overseeing entry operations.
- Terminating entry procedures as required.
- Serving as an attendant, as long as the person is trained and equipped appropriately for that role.
- Ensuring measures are in place to keep unauthorized personnel clear of the area.
- Checking the work at least twice a shift to verify and document permit requirements are being observed (more frequent checks shall be made if operations or conditions are anticipated that could affect permit requirements).
- Ensuring that necessary information on chemical hazards is kept at the work site for the employees or rescue team.
- Ensuring a rescue team is available and instructed in their rescue duties (i.e., an onsite team or a prearranged outside rescue service).
- Ensuring the rescue team members have current certification in first aid and cardiopulmonary resuscitation (CPR).
The EHS officer(s) or department supervisor(s) shall function as an attendant(s) and shall be stationed outside of the confined workspace. The attendant(s) shall:
- Be knowledgeable of, and be able to recognize potential confined space hazards.
- Maintain a sign-in/sign-out log with a count of all persons in the confined space, and ensure all entrants sign in and out.
- Monitor surrounding activities to ensure the safety of personnel.
- Maintain effective and continuous communication with personnel during confined space entry, work, and exit.
- Order personnel to evacuate the confined space if he or she:
- Observes a condition which is not allowed on the entry permit.
- Notices the entrants acting strangely, possibly as a result of exposure to hazardous substances.
- Notices a situation outside the confined space which could endanger personnel.
- Notices a hazard within the confined space that has not been previously recognized or taken into consideration.
- Must leave his or her work station.
- Must focus attention on the rescue of personnel in some other confined space that he or she is monitoring.
- Immediately summon the rescue team if crew rescue becomes necessary.
- Keep unauthorized persons out of the confined space, order them out, or notify authorized personnel of an unauthorized entry.
E. Rescue Team
The rescue team members shall:
- Complete a training drill using mannequins or personnel in a simulation of the confined space prior to the issuance of an entry permit for any confined space and at least annually thereafter.
- Respond immediately to rescue calls from the attendant or any other person recognizing a need for rescue from the confined space.
- In addition to emergency response training, receive the same training as that required of the authorized entrants.
- Have current certification in first aid and CPR.
F. Entrants/Affected Employees
Employees who are granted permission to enter a confined space shall:
- Read and observe the entry permit requirements.
- Remain alert to the hazards that could be encountered while in the confined space.
- Properly use the personal protective equipment that is required by the permit.
- Immediately exit the confined space when:
- They are ordered to do so by an authorized person.
- They notice or recognize signs or symptoms of exposure.
- A prohibited condition exists.
- The automatic alarm system sounds.
- Alert attendant(s) when a prohibited condition exists and/or when warning signs or symptoms of exposure exist.
The UALR EHS office shall provide training so that all employees whose work is regulated by this Confined Space Program acquire the understanding, knowledge, and skills necessary for the safe performance of their duties in confined spaces.
A. Training Frequency
The Environmental Health and Safety Office shall provide training to each affected employee:
- Before the employee is first assigned duties within a confined space.
- Before there is a change in assigned duties.
- When there is a change in permit space operations that presents a hazard for which an employee has not been trained.
- When the UALR EHS officer(s) or department supervisor(s) has reason to believe that there are deviations from the confined space entry procedures required in this program, or that there are inadequacies in the employee’s knowledge or use of these procedures.
The training shall establish employee proficiency in the duties required in this program, and shall introduce new or revised procedures, as necessary, for compliance with this program.
B. General Training
All employees who will enter confined spaces shall be trained in entry procedures. Personnel responsible for supervising, planning, entering, or participating in confined space entry and rescue shall be adequately trained in their functional duties prior to any confined space entry. Training shall include:
- Explanation of the general hazards associated with confined spaces.
- Discussion of specific confined space hazards associated with the facility, location, or operation.
- Reason for, proper use, and limitations of personal protective equipment and other safety equipment required for entry into confined spaces.
- Explanation of permits and other procedural requirements for conducting a confined space entry.
- A clear understanding of what conditions would prohibit entry.
- Procedures for responding to emergencies.
- Duties and responsibilities of the confined space entry team.
- Description of how to recognize symptoms of overexposure to probable air contaminants in themselves and co-workers, and method(s) for alerting the attendant(s).
Refresher training shall be conducted as needed to maintain employee competence in entry procedures and precautions.
C. Specific Training
- Training for atmospheric monitoring personnel shall include proper use of monitoring instruments, including instruction on the following:
- Proper use of the equipment.
- Calibration of equipment.
- Sampling strategies and techniques.
- Exposure limits (PELs, TLVs, LELs, UELs, etc.).
- Training for attendants shall include the following:
- Procedures for summoning rescue or other emergency services.
- Proper utilization of equipment used for communicating with entry and emergency/rescue personnel.
- Training for emergency response personnel shall include:
- Rescue plan and procedures developed for each type of confined space that is anticipated to be encountered.
- Use of emergency rescue equipment.
- First aid and CPR techniques.
- Work location and confined space configuration to minimize response time.
D. Verification of Training
Periodic assessment of the effectiveness of employee training shall be conducted by EHS. Training sessions shall be repeated as often as necessary to maintain an acceptable level of personnel competence.
V. IDENTIFICATION OF HAZARDS AND EVALUATION OF CONFINED SPACES
The Environmental Health and Safety Office shall ensure a survey of the work site is conducted to identify confined spaces. This survey can be partially completed from initial and continuing site characterizations, as well as other available data (i.e., blueprints and job hazard analyses). The purpose of the survey is to develop an inventory of those locations and/or equipment at UALR that meet the definition of a confined space. This information shall be communicated to personnel, and appropriate confined space procedures shall be followed prior to entry. The initial surveys shall include air monitoring to determine the air quality in the confined spaces. The potential for the following situations shall be evaluated by EHS:
- Flammable or explosive potential.
- Oxygen deficiency.
- Presence of toxic and corrosive material.
B. Hazard Reevaluation
The Environmental Health and Safety Office shall identify and reevaluate hazards based on possible changes in activities or other physical or environmental conditions that could adversely affect work. A master inventory of confined spaces shall be maintained. Any change in designation of a confined space will be routed to all affected personnel by EHS.
C. Pre-Entry Hazard Assessment
A hazard assessment shall be completed by EHS prior to any entry into a confined space. The hazard assessment should identify:
- The sequence of work to be performed in the confined space.
- The specific hazards known or anticipated.
- The control measures to be implemented to eliminate or reduce each of the hazards to an acceptable level.
No entry shall be permitted until the hazard assessment has been reviewed and discussed by all persons engaged in the activity. Personnel who are to enter confined spaces shall be informed of known or potential hazards associated with said confined spaces.
D. Hazard Controls
Hazard controls shall be instituted to address changes in the work processes and/or working environment. Hazard controls must be able to control the health hazards by eliminating the responsible agents, reduce health hazards below harmful levels, or prevent the contaminants from coming into contact with the workers.
The following order of precedence shall be followed in reducing confined space risks.
Engineering controls are those controls that eliminate or reduce the hazard through implementation of sound engineering practices. Ventilation is one of the most common engineering controls used in confined spaces. When ventilation is used to remove atmospheric contaminants from a confined space, the space shall be ventilated until the atmosphere is within the acceptable ranges. Ventilation shall be maintained during the occupancy if there is a potential for the atmospheric conditions to move out of the acceptable range. When ventilation is not possible or feasible, alternate protective measures or methods to remove air contaminants and protect occupants shall be determined by EHS prior to authorizing entry.
When conditions necessitate and can accommodate continuous forced air ventilation, the following precautions shall be followed:
- Employees shall not enter the space until the forced air ventilation has eliminated any hazardous atmosphere.
- Forced air ventilation shall be directed to ventilate the immediate areas where an employee is or will be present within the space.
- Continuous ventilation shall be maintained until all employees have left the space.
- Air supply or forced air ventilation shall originate from a clean source.
Work Practice (Administrative) Controls
Work practice (administrative) controls are those controls which eliminate or reduce the hazard through changes in the work practices (i.e., rotating workers, reducing the amount of worker exposure, and housekeeping).
Personal Protective Equipment (PPE)
If the hazard cannot be eliminated or reduced to a safe level through engineering and/or work practice controls, PPE should be used. EHS shall determine the appropriate PPE needed by all personnel entering the confined space, including rescue teams. Personal Protective Equipment (PPE) that meets the specifications of applicable standards shall be selected in accordance with the requirements of the job to be performed.
VI. ENTRY PERMITS
The Confined Space Entry Permit is the most essential tool for assuring safety during entry in confined spaces with known hazards, or with unknown or potentially hazardous atmospheres. The entry permit process guides the supervisor and workers through a systematic evaluation of the space to be entered. The permit should be used to establish appropriate conditions. Before each entry into a confined space, an entry permit will be completed by EHS. The Environmental Health and Safety Office will then communicate the contents of the permit to all employees involved in the operation, and post the permit conspicuously near the work location. A standard entry permit shall be used for all entries.
A. Key Elements of Entry Permits
A standard entry permit shall contain the following items:
- Space to be entered.
- Purpose of entry.
- Date and authorized duration of the entry permit.
- Name of authorized entrants within the permit space.
- Means of identifying authorized entrants inside the permit space (i.e., rosters or tracking systems).
- Name(s) of personnel serving as attendant(s) for the permit duration.
- Name of individual serving as entry supervisor, with a space for the signature or initials of the entry supervisor who originally authorized the entry.
- Hazards of the permit space to be entered.
- Measures used to isolate the permit space and to eliminate or control permit space hazards before entry (i.e., lockout/tagout of equipment and procedures for purging, ventilating, and flushing permit spaces).
- Acceptable entry conditions.
- Results of initial and periodic tests performed, accompanied by the names or initials of the testers and the date(s) when the tests were performed.
- Rescue and emergency services that can be summoned, and the means of contacting those services (i.e., equipment to use, phone numbers to call).
- Communication procedures used by authorized entrants and attendant(s) to maintain contact during the entry.
- Equipment to be provided for compliance with this Confined Space Program (i.e., PPE, testing, communications, alarm systems, and rescue).
- Other information necessary for the circumstances of the particular confined space that will help ensure employee safety.
- Additional permits, such as for hot work, that has been issued to authorize work on the permit space.
B. Permit Scope and Duration
A permit is only valid for one shift. For a permit to be renewed, the following conditions shall be met before each reentry into the confined space:
- Atmospheric testing shall be conducted and the results should be within acceptable limits. If atmospheric test results are not within acceptable limits, precautions to protect entrants against the hazards should be addressed on the permit and should be in place.
- The EHS shall verify that all precautions and other measures called for on the permit are still in effect.
- Only operations or work originally approved on the permit shall be conducted in the confined space.
A new permit shall be issued, or the original permit will be reissued if possible, whenever changing work conditions or work activities introduce new hazards into the confined space. EHS shall retain each canceled entry permit for at least one (1) year to facilitate the review of the Confined Space Entry Program. Any problems encountered during an entry operation shall be noted on the respective permit(s) so that appropriate revisions to the confined space permit program can be made.
I. ENTRY PROCEDURES
When entry into a confined space is necessary, either the Entry Supervisor or EHS may initiate entry procedures, including the completion of a confined space entry permit. Entry into a confined space shall follow the standard entry procedure below.
A. Prior to Entry
The entire confined space entry permit shall be completed before a standard entry. Entry shall be allowed only when all requirements of the permit are met and it is reviewed and signed by an entry supervisor. The following conditions must be met prior to standard entry:
- Affected personnel shall be trained to establish proficiency in the duties that will be performed within the confined space.
- The internal atmosphere within the confined space shall be tested by the entry supervisor with a calibrated, direct-reading instrument.
- Personnel shall be provided with necessary PPE as determined by the entry supervisor.
- Atmospheric monitoring shall take place during the entry. If a hazardous atmosphere is detected during entry:
- Personnel within the confined space shall be evacuated by the attendant(s) or entry supervisor until the space can be evaluated by EHS to determine how the hazardous atmosphere developed.
- Controls shall be put in place to protect employees before reentry.
B. Opening a Confined Space
Any conditions making it unsafe to remove an entrance cover shall be eliminated before the cover is removed. When entrance covers are removed, the opening shall be promptly guarded by a railing, temporary cover, or other temporary barrier that will prevent anyone from falling through the opening. This barrier or cover shall protect each employee working in the space from foreign objects entering the space. If it is in a traffic area, adequate barriers shall be erected.
C. Atmospheric Testing
Atmospheric test data is required prior to entry into a confined space. Atmospheric testing is required for two distinct purposes: (1) evaluation of the hazards of the permit space, and (2) verification that acceptable conditions exist for entry into that space. If a person must go into the space to obtain the needed data, then Standard Confined Space Entry Procedures shall be followed. Before entry into a confined space, the EHS officer(s) or entry supervisor shall conduct testing for hazardous atmospheres. The internal atmosphere shall be tested with a calibrated, direct-reading instrument for oxygen, flammable gases and vapors, and potential toxic air contaminants, in that order.
Testing equipment used in specialty areas shall be listed or approved for use in such areas by EHS. All testing equipment shall be approved by a nationally recognized laboratory, such as Underwriters Laboratories or Factory Mutual Systems.
The atmosphere of a confined space should be analyzed using equipment of sufficient sensitivity and specificity. The analysis shall identify and evaluate any hazardous atmospheres that may exist or arise, so that appropriate permit entry procedures can be developed and acceptable entry conditions stipulated for that space. Evaluation and interpretation of these data and development of the entry procedure should involve a technically qualified professional (i.e., consultant, certified industrial hygienist, registered safety engineer, or certified safety professional).
A confined space that may contain a hazardous atmosphere shall be tested for residues of all identified or suspected contaminants. The evaluation testing should be conducted with specified equipment to determine that residual concentrations at the time or testing and entry are within acceptable limits. Results of testing shall be recorded by the person performing the tests on the permit. The atmosphere shall be periodically retested (frequency to be determined by EHS to verify that atmospheric conditions remain within acceptable entry parameters.
The atmosphere of the confined spaces shall be considered to be within acceptable limits when the following conditions are maintained:
- Oxygen: 19.5 percent to 23.5 percent.
- Flammability: less than 10 percent of the Lower Flammable Limit (LFL)
- Toxicity: less than recognized American Conference of Governmental Industrial Hygienists (ACGIH) exposure limits or other published exposure levels [i.e., OSHA Permissible Exposure Limits (PELs) or National Institute of Occupational Safety and Health (NIOSH) Recommended Exposure Limits (RELs)].
D. Isolation and Lockout/Tagout Safeguards
All energy sources that are potentially hazardous to confined space entrants shall be secured, relieved, disconnected, and/or restrained before personnel are permitted to enter the confined space. Equipment systems or processes shall be locked out and/or tagged out as required by the UALR Lockout/Tagout Program [which complies with OSHA’s 29 CFR 1910-147 and American National Standards Institute (ANSI) Z244.1-1982, Lockout/Tagout of Energy Sources] prior to permitting entry into the confined space. In confined spaces where complete isolation is not possible, EHS shall evaluate the situation and make provisions for as rigorous an isolation as practical. Special precautions shall be taken when entering double-walled, jacketed, or internally insulated confined spaces that may discharge hazardous material through the vessel’s internal wall.
Where there is a need to test, position, or activate equipment by temporarily removing the lock or tag or both, a procedure shall be developed and implemented to control hazards to the occupants. Any removal of locks, tags, or other protective measures shall be done in accordance with the UALR Lockout/Tagout Program.
E. Ingress/Egress Safeguards
Means for safe entry and exit shall be provided for confined spaces. Each entry and exit point shall be evaluated by EHS to determine the most effective methods and equipment that will enable employees to safely enter and exit the confined space.
Appropriate retrieval equipment or methods shall be used whenever a person enters a confined space. Use of retrieval equipment may be waived by EHS if use of the equipment increases the overall risks of entry or does not contribute to the rescue. A mechanical device shall be available to retrieve personnel from vertical confined spaces greater than five (5) feet in depth.
F. Warning Signs and Symbols
All confined spaces that could be inadvertently entered shall have signs identifying them as confined spaces. Signs shall be maintained in a legible condition. The signs shall contain a warning that a permit is required before entry. Accesses to all confined spaces shall be prominently marked.
VIII. EMERGENCY RESPONSE
A. Emergency Response Plan
EHS shall maintain a written plan of action that has provisions for conducting a timely rescue of individuals within a confined space, should an emergency arise. The written plan shall be kept onsite where the confined space work is being conducted. All affected personnel shall be trained on the Emergency Response Plan.
B. Retrieval Systems and Methods of Non-Entry Rescue
Retrieval systems shall be available and ready when an authorized person enters a permit space, unless such equipment increases the overall risk of entry, or the equipment would not contribute to the rescue of the entrant. Retrieval systems shall have a chest or full-body harness and a retrieval line attached at the center of the back near shoulder level or above the head. If harnesses are not feasible, or would create a greater hazard, wristlets may be used in lieu of the harness. The retrieval line shall be firmly fastened outside the space so that rescue can begin as soon as anyone is aware that retrieval is necessary. A mechanical device shall be available to retrieve personnel from vertically confined spaces more than five (5) feet deep.
Source: Environmental Health and Safety
Approved By: Environmental Health and Safety Committee, Aug. 5, 2009
Custodian: EHS Committee