The Louis Berger Group, Inc. has prepared this Confined Space Entry Policy for
This Confined Space Entry policy identifies minimum safety requirements to be followed while entering, exiting, and working in Confined Spaces.
The purpose of this Confined Space Entry policy is to identify procedural concerns and requirements regarding the health and safety of all BSC employees who will be working within Confined Spaces (permit and non-permit required). In addition, this policy establishes the requirement that contractors employed by BSC observe OSHA Confined Space entry requirements when working at the BSC campus. Furthermore, this policy serves as a reference to guide BSC environmental health and safety personnel in the development and implementation of plans and procedures for Confined Space Entry.
This Confined Space Entry Policy will provide the basis to identify Confined Spaces, implement an entry permit system, require testing for hazardous atmospheres, establish safety equipment and ventilation guidelines, and develop a Confined Space Entry training program.
This policy also will allow for the reduction of a Permit-Required Confined Space ("PRCS") to a "non-permit required Confined Space" ("NPRCS"), as long as established criteria (identified in this policy) have been met.
Definitions (per 29 CFR 1910.146)
Attendant- An individual stationed outside one or more permit spaces who monitors the authorized entrants and who performs all attendants duties assigned in the employers permit space program.
Authorized entrant- An employee who is authorized by the employer to enter a permit space.
Blanking or blinding- The absolute closure of a pipe, line, or duct by the fastening of a solid plate (such as a spectacle blind or a skillet blind) that completely covers the bore and that is capable of withstanding the maximum pressure of the pipe, line, or duct with no leakage beyond the plate.
Confined Space- A space that:
Double block and bleed- The closure of a line, duct, or pipe by closing and locking or tagging two in-line valves and by opening and locking or tagging a drain or vent valve in the line between the two closed valves.
Emergency- Any occurrence (including any failure of hazard control or monitoring equipment) or event internal or external to the permit space that could endanger entrants.
Engulfment- The surrounding and effective capture of a person by a liquid or finely divided (flowable) solid substance that can be aspirated to cause death by filling or plugging the respiratory system or that can exert enough force on the body to cause death by stangulation, constriction, or crushing.
Entry- The action by which a person passes through an opening into a PRCS. Entry includes ensuing work activities in that space and is considered to have occurred as soon as any part of the entrants body breaks the plane of an opening into the space.
Entry permit (permit)- The written or printed document that is provided by the employer to allow and control entry into a permit space and that contains the information specified in 29 CFR 1910.146(f).
Entry supervisor- The person (such as the employer, foreman, or crew chief) 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 section.
NOTE: An entry supervisor also may serve as an attendant or as an authorized entrant, as long as that person is trained and equipped as required by this section for each role he or she fills. Also, the duties of entry supervisor may be passed from one individual to another during the course of an entry operation.
Hazardous atmosphere- An atmosphere that may expose employees to the risk of death, incapacitation, impairment of ability to self-rescue (that is, escape unaided from a permit space), injury, or acute illness from one or more of the following causes:
NOTE: This concentration may be approximated as a condition in which the dust obscures vision at a distance of 5 feet (1.52 m) or less.
4. Any other atmospheric condition that is immediately dangerous to life or health
NOTE: For air contaminants for which OSHA has not determined a dose or permissible exposure limit, other sources of information, such as Material Safety Data Sheets that comply with the Hazard Communication Standard, section 1910.1200 of this Part, published information, and internal documents can provide guidance in establishing acceptable atmospheric conditions.
Hot work permit- The employers written authorization to perform operations (for example, riveting, welding, cutting, burning, and heating) capable of providing a source of ignition.
Immediately dangerous to life or health ("IDLH")- Any condition that poses an immediate or delayed threat to life or that would cause irreversible adverse health effects or that would interfere with an individuals ability to escape unaided from a permit space.
NOTE: Some materials hydrogen fluoride gas and cadmium vapor, for example may produce immediate transient effects that, even if severe, may pass without medical attention, but are followed by sudden, possibly fatal collapse 12-72 hours after exposure. The victim "feels normal" from recovery from transient effects until collapse. Such materials in hazardous quantities are considered to be "immediately" dangerous to life or health.
Inerting- The displacement of the atmosphere in a permit space by a noncombustible gas (such as nitrogen) to such an extent that the resulting atmosphere is noncombustible.
NOTE: This procedure produces an IDLH oxygen-deficient atmosphere.
Isolation- The process by which a permit space is removed from service and completely protected against the release of energy and material into the space by such means as: blanking or blinding; misaligning or removing sections of lines, pipes, or ducts; a double block and bleed system; lockout or tagout of all sources of energy; or blocking or disconnecting all mechanical linkages.
Line breaking- The intentional opening of a pipe, line, or duct that is or has been carrying flammable, corrosive, or toxic material, an inert gas, or any fluid at a volume, pressure, or temperature capable of causing injury.
Non-permit Confined Space ("NPRCS")- A Confined Space that does not contain or, with respect to atmospheric hazards, have the potential to contain any hazard capable of causing death or serious physical harm.
Oxygen deficient atmosphere- An atmosphere containing less than 19.5 percent oxygen by volume.
Oxygen enriched atmosphere- An atmosphere containing more than 23.5 percent oxygen by volume.
Permit-required Confined Space ("PRCS")- A Confined Space that has one or more of the following characteristics:
(4) Contains any other recognized serious safety or health hazard.
Permit-required Confined Space program (permit space program)- The employers overall program for controlling, and, where appropriate, for protecting employees from, permit space hazards and for regulating employee entry into permit spaces.
Permit system The employers written procedure for preparing and issuing permits for entry and for returning the permit space to service following termination of entry.
Prohibited condition- Any condition in a permit space that is not allowed by the permit during the period when entry is authorized.
Rescue service- The personnel designed to rescue employees from permit spaces.
Retrieval system The equipment (including a retrieval line, chest or full-body harness, wristlets, if appropriate, and a lifting device or anchor) used for non-entry rescue of persons from permit spaces.
Testing- The process by which the hazards that may confront entrants of a permit space are identified and evaluated. Testing includes specifying the tests that are to be performed in the permit space.
NOTE: Testing enables employers both to devise and implement adequate control measures for the protection of authorized entrants and to determine if acceptable entry conditions are present immediately prior to, and during, entry.
All BSC campus locations that are considered to be PRCS shall be identified as specifically as possible, including area or room, the building, and its specific address.
Entry into these spaces (including, but not limited to placing of head or face into the opening of a Confined Space) shall be subject to the provisions of this program.
Signage shall be posted on or as near as is practicable to each PRCS. The signs shall read:
PRCSs that cannot be labeled, because of adverse area or weather conditions, shall be identified with written communications, with reference to this policy, to all BSC personnel whose work may involve the direct use or entry of the PRCS.
The following PRCSs exist at BSC.
If entrance into an identified PRCS will never be necessary, access to the space will be prohibited. Appropriate warning signage shall be posted, or some other means to prevent access shall be provided.
Any person, (regardless of agency) working for BSC (i.e. outside company or contractor) shall follow an OSHA-compliant "Confined Space Entry Policy."
Whenever outside companies or contractors are working with BSC employees, the Confined Space policy used shall not be less stringent than the BSC policy.
Other Non-BSC Workers
Outside contractors are responsible for complying with OSHA Confined Space regulations. Contractors employed by BSC shall coordinate their own Confined Space procedures in accordance with the requirements of BSCs policy. Their contracts will specifically require the General Contractor to notify Facilities Management whenever Permit-Required Confined Space ("PRCS") access is required.
When it has been determined that entry into a PRCS will be necessary, the following agency(s) shall be notified:
A verbal notification of PRCS entry can be made. However, the notification shall be made not less than 24 hours prior to the start of work. A copy of the actual permits must then be sent to the appropriate departments for record keeping purposes. The departments are listed at the bottom of the actual permit.
Exception: Emergency evaluations/repairs are acceptable, however, Facilities Management and/or the Central Heating Plant must notified before entering a PRCS.
Outside contractors must notify Facilities Management and/or the Central Heating Plant before entering a PRCS. This notification allows the facilities department to notify the other necessary shops that may have knowledge of unsafe conditions within said PRCS.
Confined Space Survey
Each Confined Space shall be surveyed for hazards or potential hazards within. The survey shall be done by qualified persons who shall decide which spaces are to be designated PRCS or NPRCS. A "qualified person" shall be considered an individual qualified by training and experience who is authorized by the party conducting Confined Space Entry to make determinations with respect to confined spaces.
If identified as a PRCS, the Confined Space shall be labeled with appropriate signage, or shall be otherwise indicated.
Hazards shall be identified for each Confined Space.
The identification shall include:
Evaluations shall be performed by a qualified person. Each hazard (potential or known) shall be examined for:
-Who and how many people would be affected?
-How much energy could be released?
-How toxic are the chemicals used or found in place?
-What is the likelihood of injury, explosion or fire within the Confined Space?
-Steam-Electricity-Polychlorinated biphenyls ("PCBs")
-Block & Bleed
-Which agencies might be called for this Confined Space?
Bridgewater Department of Public Works
Bridgewater Fire Department
Central Heating Plant
BSC Police Department
In certain circumstances a "hazard re-evaluation" will be performed. Depending on the work being performed within a NPRCS (i.e., welding/cutting) a Confined Space will need to be re-evaluated.
When the need for such re-evaluation is determined, a qualified person shall conduct the "hazard evaluation" and "hazard identification" process.
When evaluating or re-evaluating a Confined Space atmosphere, the following shall be incorporated:
After evaluation by a qualified person, the atmosphere of the Confined Space shall be considered within the acceptable limits if the following air quality criteria are met:
Unsafe Atmosphere/Unacceptable Limits
No employee/Contractor Shall Enter Any Confined Space in which a hazardous atmosphere has been detected. Whenever testing, (by a qualified person), of the atmosphere indicates that levels of oxygen, flammability, or toxicity are not within acceptable limits, entry shall be prohibited until appropriate controls are implemented or appropriate personal protective equipment ("PPE") and training has been provided.
If Hazardous Gas (Toxic/Flammable) or Oxygen Deficiency/Enrichment is discovered, the space can be purged or force ventilated using intrinsically safe and explosion resistant equipment to eliminate or control atmospheric hazards. The area should then be re-monitored.
Whenever possible, forced ventilation shall be directed to ventilate the immediate areas where an employee is or will be present within the space and shall continue until the employees have left the space.
If forced ventilation is necessary, and is to be used, the initial and subsequent atmospheric tests of the Confined Space shall be performed with all ventilation equipment shut down for a significant period of time. (This is done to show hazardous and potentially hazardous conditions, should the ventilation system fail.)
After testing and documenting the results with the ventilation shut down, the ventilation system should then be turned back on. (The above steps are taken to ensure that contaminants are not being drawn into the Confined Space by the ventilation system, creating its own hazardous conditions(s)).
The following exceptions to the above will be made: Negative air ventilation (already permanently installed) can be used in lieu of forced ventilation provided that it shall not draw poor quality air into the Confined Space, and fresh air intake plenums for buildings on campus. Air supply for the forced air ventilation shall be from a clean source (i.e., not in close proximity to vehicle exhaust), and shall not increase the hazards within the Confined Space. When air quality testing shows that the atmosphere remains unsafe or unacceptable for entry, the entry permit shall be revoked and entry prohibited.The permit can be revoked by the attendant, supervisor, qualified personnel, Facility Safety Officer or any qualified person.
If hazardous gases or oxygen deficiency/enrichment is not indicated after re-testing, the Confined Space may be entered. This provides that continuous atmospheric testing is conducted and that forced ventilation is continuous throughout the work period.
If, during any entry, a hazardous atmosphere is detected:
Heating Plant immediately.
If there is a possibility that the Confined Space could become unacceptable, while personnel are working, procedures and equipment shall be provided including: tripod, safety harness, telephone or portable radios.
Permit-Required Confined Space
Confined Spaces at BSC that represent known or potential PRCSs include sewers, steam pits, electrical pits, steam pits, and underground vaults.
The PRCSs Program shall:
-Identification of acceptable entry conditions
-Isolating the PRCS
-Eliminating or controlling atmospheric hazards by purging, blanking, locking or tagging out, flushing inerting or ventilating
-Monitoring (periodically or continuously) of the PRCS as required by the qualified person. Provide the required equipment (intrinsically safe, as necessary) needed for proper set up, entry and breakdown of the Confined Space, such as:
Prior to entry, the PRCS permit shall be prepared and signed by the supervisor/project manager. In case of emergency, the permit can be signed by a qualified person. A sample Confined Space entry form is included as Appendix B.
The completed permit shall be made available to all entrants, occupants, and attendants by posting near the entry of the Confined Space. The length of time to be spent in the Confined Space shall be noted on the permit, and shall be strictly adhered to. The supervisor may need to terminate the permit if a condition arises, not covered for by the permit BSC shall create and maintain a file for all canceled, expired or completed entry permits, indefinitely. All the requirements of the permit shall have been met, before entry is made.
The entry permit shall identify:
PRCSs may include, but are not limited to:
Attendant(s) shall be stationed outside any Confined Space (PRCS/non-PRCS) The number of attendants that are required at any Confined Space shall be determined by a qualified person. It shall be the qualified persons responsibility to determine the manpower requirement(s) of the project:
For example: More than one attendant may be required if there is more than one entry to the Confined Space, and that the different entries are arranged in such a way that the distance between them may be greater than 20 feet. Attendants and the occupants within the Confined Space shall remain in constant two-way communication (i.e., person-to-person, radio, cellular phone).
Attendants shall also:
Should unauthorized person(s) approach or enter a Confined Space while entry is underway the attendant shall:
The occupant/entrant who will be entering the Confined Space shall make sure that the qualified person has evaluated/inspected the Confined Space, and that it was determined to be safe for entry.
The occupant shall make sure, before entry that all potential hazards have been identified and that serious hazards have been isolated. Isolation includes: de-energizing and locking/tagging out exposed electrical equipment; locking/tagging out exposed mechanical equipment; blanking, blinding, misaligning or removing sections of pipes, ducts, or a double block and bleed system, in accordance with 29 CFR 1910.147.
The occupant shall also make sure, before entry, that all appropriate Rescue Equipment has been made available, at the site. Whenever a worker is required to enter a PRCS, a full body harness may be required.
An attached retrieval line, secured outside the Confined Space should be utilized, but may not be required to be attached to the occupant/entrant, if the attachment may cause additional harm or hazard to the occupant/entrant. Retrieval lines must not be secured to any vehicle.
Mechanical hoisting equipment, i.e., tripod, retrieval line, and full body harness shall be set up to provide for emergency retrieval from a PRCS such as a pit or manhole.
The occupant/attendant/qualified person shall make sure that the appropriate forced air ventilation equipment and tubing has been positioned properly to provide continuous, forced air to the work area, in any Confined Space. The occupant/entrant shall make sure they have the necessary communication equipment for the type of work. The occupant/entrant should be familiar with the use and warnings of all monitoring equipment.
Appendix C contains an inventory of BSCs Confined Space entry equipment, including monitoring devices and other safety equipment.
Supervisor/Project Manager(s) Responsibility
The Supervisor/Project Manager for any Confined Space work shall ensure that the following criteria has been satisfied before work in the Confined Space is started. The Supervisor/Project Manager shall make sure that all shops involved, or having responsibility for the Confined Space being worked on, have been notified at least 24 hours in advance. A shorter period of advance notice may apply in emergency situations. This will allow the specific shop(s) to identify any possible hazards that they may be aware of, (i.e., asbestos, leaks, etc.), before work is initiated.
The Supervisor/Project Manager shall ensure that the necessary equipment has been made available and placed on site before work has begun. The Supervisor/Project Manager must ensure that each Confined Space to be entered shall have been properly assessed by a qualified person before entry is permitted.
If the qualified person finds the Confined Space unacceptable, the Supervisor/Project Manager shall make sure that no one enters the Confined Space until corrective measures have been made, and the qualified person has then permitted entry. The Supervisor/Project Manager shall make sure that the attendants, occupants/entrants have monitoring equipment in the Confined Space at all times, when necessary and that the occupant/entrants know what to do in case of alarm(s).
The Supervisor/Project Manager shall also make sure that the appropriate two-way communication equipment has been made available to the occupant/entrants at all times. The Attendant shall be equipped with communication equipment, in case of emergency. Facilities Management shall be made aware of any Confined Space work, so that they are prepared to listen specifically for emergency requests.
The Supervisor/Project Manager shall make sure that a proper American Conference of Governmental Industrial Hygienists ("ACGIH") work/rest ratio has been implemented for working in a Confined Space. This is done to avoid heat exhaustion or heat stroke, a life threatening illness. The Supervisor/Project Manager shall ensure that the occupants/entrant/attendant shall have plenty of drinking water and cups at the site, should heat and weather conditions warrant.
The Supervisor/Project Monitor shall ensure that all persons who will be working in Confined Space, PRCS or NPRCS, have been medically evaluated by their physician to ensure adequate health and safety for Confined Space entry. The Supervisor/Project Monitor shall enforce all appropriate provisions of this policy with the assistance of the Facilities Department and their respective department heads. Supervisors shall be monitoring worksites for compliance.
Materials such as asbestos, biological/radiological agents, and electricity and other energy present special hazards. If any of these types of hazards are to be encountered during work, Facilities Management or the Central Heating Plant must be notified and appropriate precautions taken before proceeding with the work.
Lock Out/Tag Out
Lock Out/Tag Out procedures (per 29 CFR 1910.147), when necessary shall be incorporated at all times to ensure the health and safety of all BSC personnel and outside contractors. In accordance with the different "isolation" procedures, a means of reducing hazards for health and safety reasons must be followed. (See "isolation" in the definition section of this policy.) If complete isolation is not possible, provisions shall be made to reduce any hazard, before work in a Confined Space is initiated. After locking or tagging out energy sources, the supervisor/project manager or entrant (whoever locks or tags out an energy source) shall make sure that all potential stored energy has been relieved and if necessary, blocked or otherwise secured for additional safety. This shall be done for the protection of workers in and around Confined Space areas as well as for those who might otherwise be using the now de-energized equipment.
Open flames, welding, cutting, soldering, brazing, general purpose electrical equipment, light sources, smoking material, or other spark or flame producing agents or devices other than explosive-resistant equipment, shall not be used in any Confined Space, until it has been demonstrated by approved test that a flammable vapor does not exist. Appropriate and sufficient portable fire extinguishers shall be readily available, and in good working order at the site.
13.3 Hot Works
Gas cylinders and work involving associated Hot Works require authorization before work in the Confined Space is started. BSC employees or outside contractors must obtain the necessary authorization from Facilities Management. When Hot Works (i.e., welding, cutting, soldering or brazing, etc.) are required in a Confined Space, adequate fresh air ventilation of at least 2,000 cubic feet per minute ("cfm") per welder shall be provided per 29 CFR 1910.252. Hot Works authorization must be acquired from Facilities Management, before such work in a Confined Space begins. Facilities Management shall be contacted if the 2,000-cfm rate per welder can not be obtained or maintained. Local exhaust, airline respirator, or self-contained breathing apparatus ("SCBA") may be necessary. Respirators and SCBAs require special training and other requirements.
In accordance with the Massachusetts State Fire Prevention Codes, 527 CMR 39:
General Safety Considerations
Ground Fault Circuit Interrupters ("GFCI"):
Guarding of Confined Spaces:
Personal Protective Equipment ("PPE"):
Protection from Vehicular Traffic:
The Confined Space Emergency Response Team ("CSERT") shall be made up of the following organizations for fast and effective rescue.
Should the CSERT team be necessary for a Confined Space rescue, the following procedures shall be followed:
The attendant, at the Confined Space shall notify Facilities Management and/or The Central Heating Plant by portable radio or cellular phone, identifying the site as accurately as possible. Facilities Management shall then notify Bridgewater Fire Department, the BSC Police and other appropriate staff, initiating the necessary response. BSC staff shall assist the Bridgewater Fire Department in any way possible. All members of the CSERT Unit shall be trained in accordance with this policy. BSC personnel must not attempt to perform a Confined Space rescue without the proper training and equipment to perform such a rescue.
Any BSC employee who is required to enter or supervise those entering or serve as an attendant for any entry into a Confined Space shall receive appropriate training. This training will assure that understanding, knowledge and skills necessary for safe performance of duties are acquired.
Initial training will be given to all affected employees and will be followed up with refresher training. Training will be conducted as necessary on any new procedures, before there is a change in assigned duties. When there is a change in Confined Space hazards, or when deficiencies become evident.
Training shall be made available through:
The above training aids will include, but is not limited to:
The Facilities Management Office shall maintain certification records of all employees trained and tested in Confined Space entry and operations. The list shall include the subjects, signature(s) of the trainer(s), attendees and dates of training. Appendix D contains a list of BSC personnel who have received Confined Space entry training.
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Last Modified: May 5, 2004