Confined Space Entry Program
1.0 APPLICABLE DOCUMENTS
1.1 29 CFR Part 1910.146 "Permit-Required Confined Spaces"
1.2 ILHR 32, Subchapter VI, "Confined Spaces"
This standard establishes the minimum requirements to be taken when it is required that persons enter UW - La Crosse permit-required confined spaces such as tanks, tunnels, pits, ducts, chambers or utility manholes. Environmental Health and Safety maintains a list of permit required confined spaces identified at UW - La Crosse.
A safe and healthful campus environment shall be provided for all UW - La Crosse employees, students, guests and residents of the community. When engineering or administrative controls will not provide an acceptable level of protection, personal protective equipment will be provided to achieve safe working conditions.
4.1 ACCEPTABLE ENTRY CONDITIONS - conditions that must exist in a permit space to allow entry and to ensure that employees involved with a permit required confined space can safely enter and perform work.
4.2 ATTENDANT - an individual stationed outside the permit required confined space who had specific training and monitors the authorized entrants inside the space.
4.3 AUTHORIZED ENTRANT - employee who is authorized by UW-La Crosse to enter a permit required space.
4.4 BLINDED - absolute closure of a pipe, line, or duct by fastening across its bore a solid plate that completely covers the bore and can withstand the maximum upstream pressure.
4.5 CONFINED SPACE - a space that meets all the following criteria:
- is large enough to bodily enter and perform work;
- has limited means of entry and egress;
- is not designed for continuous employee occupancy; and
- has one of four hazardous characteristics (e.g., - hazardous atmosphere, engulfment, entrapment, or other safety/health hazard).
4.6 ENGULFMENT - surrounding and effective capture of a person by a liquid or finely divided solid substance.
4.7 ENTRY - a persons intentional passing though an opening into a permit required confined space.
4.8 ENTRY PERMIT - written or printed document provided by UW - La Crosse to allow and control entry into a permit space. This document must be returned to the Campus Environmental Health and Safety Office after expiration of the permit.
4.9 ENTRY SUPERVISOR - person responsible for:
- determining if acceptable conditions are present before entering a permit space;
- for authorizing entry;
- overseeing entry operations; and
- terminating entry.
4.10 HAZARDOUS ATMOSPHERE - an atmosphere that may expose employees to the risk of death, incapacitation, impairment of ability to self-rescue, injury, or acute illness.
4.11 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 individual's ability to escape unaided from a permit space.
4.12 ISOLATION - process by which a permit space is removed from service and completely protected against the release of hazardous energy or material into the space.
4.13 LOWER EXPLOSIVE LIMIT (LEL) - the lowest concentration of gas or vapor, expressed in percent by volume in air, that burns or explodes if an ignition source is present at room temperature.
4.14 LINE BREAKING - 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 death or serious physical harm.
4.15 OXYGEN DEFICIENT ATMOSPHERE - an atmosphere containing less that 19.5% oxygen.
4.16 OXYGEN ENRICHED ATMOSPHERE - an atmosphere containing more than 23.5 % oxygen.
4.17 PERMISSIBLE EXPOSURE LIMIT (PEL) - The airborne concentration of a hazardous material that must not be exceeded over a specified time or instantaneously. This value is established by the Occupational Safety and Health Administration (OSHA).
4.18 PERMIT-REQUIRED CONFINED SPACE - a confined space that has one or more of the following characteristics:
- contains or has a reasonable potential for hazardous atmospheres;
- contains a material that has the potential for engulfment;
- is internally configured so an employee could become trapped or asphyxiated by inwardly converging walls or a floor that slopes downward into a smaller cross-section; or
- contains any other recognized serious safety or health hazard.
4.19 PROHIBITED CONDITION - any condition in a permit space that is not allowed by the permit during the period when entry is authorized.
4.20 RESCUE SERVICE - personnel designated to rescue employees from permit spaces, from now on to mean the City of La Crosse Fire Department.
4.21 RETRIEVAL SYSTEM - equipment used for a non-entry rescue of persons from permit spaces.
4.22 TESTING - process by which hazards that may affect entrants of a permit space are identified and evaluated.
4.23 THRESHOLD LIMIT VALUE (TLV) - The airborne concentration of a hazardous material that must not be exceeded over a specified time or instantaneously. This value is established by the American Conference of Governmental Industrial Hygienists (ACGIH).
4.24 WELDING/CUTTING PERMIT - written authorization to perform operations that can provide a source of ignition (e.g., welding, cutting, burning, or heating) or a hazardous atmosphere.
5.1 Policy and Responsibility
All personnel who are part of an entry team have certain responsibilities as members. All practices established by this standard are expected to be retained and demonstrated by each member of the entry team.
5.2 Confined Space Entry Program
The Confined Space Entry Program consists of procedures to communicate the program requirements to all UW - La Crosse employees, as well as contractors. The program consists of the following elements:
- Confined Space Entry Requirements;
- Confined Space Entry Permit;
- Confined Space Entry Procedures and Techniques;
- Training Requirements for Entry Personnel; and
- Confined Space Rescue Procedures.
5.3 Entry Requirements, Procedures, and Techniques
The purpose of this program is to ensure the proper entry, work practices and exit from confined spaces.
5.3.1 Labeling Requirements
Where possible, each permit-required confined space should be labeled indicating that special precautions must be taken prior to entering the space. The signage for each space will read:
Enter by Permit Only.
Some variation will be allowed as long as the general message is clearly conveyed.
5.3.2 Personnel Requirements and Responsibilities
The following are the requirements for each member of the entry team.
- Know and recognize hazards that may be faced during entry.
- Be aware of behavioral effects of exposure to hazardous atmospheres.
- Maintain accurate counts and means to identify all entrants.
- Remain outside the space unless relieved by another qualified attendant.
- Monitor activities inside and outside space.
- Monitor status of entrants and initiate evacuation if: 1) prohibited conditions are detected; 2) present situation may endanger the entrant; or 3) attendant cannot effectively and safely perform duties.
- Know proper method of summoning rescue services before entry.
- Summon rescue services if needed.
- Establish and maintain a means of communication, via radio or telephone.
- Keep unauthorized persons out of entry space.
- Perform non-entry vertical rescues using a winch.
- Perform no other duties that may distract from the primary duties.
B. AUTHORIZED ENTRANT
- Know and recognize hazards that may be faced during entry.
- Obtain and properly use necessary personal protective equipment.
- Communicate as necessary with the attendant.
- Alert attendant when hazardous conditions are detected, identified or suspected.
- Exit the space immediately whenever: 1) ordered to do so by other members of the entry team; 2) warning signs/symptoms are identified; 3) prohibited conditions are identified; or 4) evacuation alarm is activated.
C. ENTRY SUPERVISOR
- Know and recognize hazards that may be faced during entry.
- Verify that all entries have been made on the permit.
- Verify that tests are completed and procedures and equipment are in place.
- Authorize entry to begin.
- Cancel permit when job is complete or unacceptable conditions arise.
- Know proper method of summoning rescue services before entry.
- Ensure that responsibilities are safely and effectively transferred.
- Ensure entrants have all necessary personal protective equipment.
5.3.3 Atmospheric Requirements Prior to Entry
Before entering, the following atmospheric conditions must be met:
- Oxygen level between 19.5% and 23.5%.
- Flammable gas, vapor, or mist below 10% of its LEL.
- Airborne combustible dusts which exceed their lower flammable limit. This limit is approximated as a condition in which dust obscures vision at a distance of 5 feet.
- Airborne hydrogen sulfide level below 10 parts per million (PPM).
- The lower of airborne hazardous substance concentrations specified as PEL’s or TLV’s.
- Concentrations below what is considered as IDLH.
Entry into a permit-required space will not be allowed if monitoring indicates deficiency in any of these categories. Respirators or a self contained breathing apparatus (SCBA) are not to be used to allow entry into deficient atmospheres. To achieve and maintain a safe atmosphere, it may become necessary to take some action to render the space safe for human occupancy. This may include:
- Isolation - precautions taken to prevent release of material and/or energy into the space. This can be achieved through blinding, blanking, disconnecting, lockout/tagout, or removal of incoming pipes or related energy sources.
- Ventilation - purging, inerting, flushing or otherwise ventilating the space with fresh air. The fresh air will displace the contaminated air allowing for safe entry. This can be accomplished by removing ports and openings or by mechanically ventilating the vessel.
- Verification - conditions within the permit space must remain acceptable throughout the duration of entry. UW-La Crosse will require all employees to wear oxygen/LEL meters while working in permit spaces. Verification may also be accomplished by using instruments or process/procedure knowledge.
- Separation - where there is a possibility of external hazards, the space may require barricades to protect the entrants from falling objects or from unauthorized entry.
5.3.4 Evaluation of the Hazards
Before granting entry, the entry supervisor should be aware of the following possible hazards specific to a particular permit-required confined space.
- Oxygen deficiency.
- Combustible, flammable or explosive atmospheres.
- Toxic gases or vapors.
- Physical hazards: 1. engulfment, 2. internal configuration, 3. moving parts or machinery.
- Corrosive chemicals.
Note: Before entry hazardous atmospheric conditions must be rendered harmless. Residual and physical hazards can be minimized by personal protective equipment. The entry supervisor should contact the Campus Environmental Health and Safety Office with any questions pertaining to entry.
5.3.5 Personal Protective Equipment (PPE)
When physical, chemical and/or biological hazards exist the space should be rendered safe for entry without the use of PPE. If this is not possible, the entry supervisor should make every effort to outfit the entrants with the appropriate gear. Most PPE is available through Campus Stores or the Physical Plant Stock Room. Contact the Campus Environmental Health and Safety Office with questions regarding the use of PPE.
Prior to entry each permit space must be sampled for the following atmospheric conditions in the listed order:
- Oxygen level (must be between 19.5% and 23.5%).
- Lower explosive limit (cannot exceed 10%).
- Hydrogen sulfide (cannot exceed 10 ppm).
- Other toxic gas levels.
Note: Oxygen level is sampled first because most combustible gas meters are oxygen dependent. Monitoring in an oxygen deficient atmosphere may result in erroneous readings. Combustible gases are sampled next because the threat of fire or explosion is both more immediate and more life threatening.
All initial monitoring will be done by the Campus Environmental Health and Safety Office. Sufficient advance notice should be given for monitoring to be performed. The Attendant, Authorized Entrant or Entry Supervisor will conduct continuous monitoring for oxygen, LEL and hydrogen sulfide throughout the entry.
A list of current monitoring equipment can be found in Appendix B, the UW-La Crosse Confined Space Entry Permit. All units are required to be calibrated every six (6) months. The calibration will be done by the Campus Environmental Health and Safety Office.
Each entry team is required to establish and maintain communication with its members during the course of work. In instances where distance or surrounding noise prohibit visual or audible communication, two-way radios will be used. Radio or telephone communication must be readily available to the attendant for emergencies. The attendant is responsible for establishing and maintaining a means of communication, via radio, telephone, or cellular telephone (for contractors).
5.3.8 Multiple Entrants
Multiple entrants may enter using the same attendant as long as the following conditions are met.
- All entrants are working on the same project.
- Visual or audible contact is maintained between entrants and attendant.
- For UW-La Crosse supervised entries involving UW - La Crosse employees and contractors, the attendant must be an employee of UW-La Crosse.
- All parties involved are from the same company or have the same supervisor. For example, UW-La Crosse employees will not serve as attendants for multiple turnkey contractor entry teams and vice versa.
Communication equipment only needs to be given to one entrant. However, if the entrants are at distances greater than what would allow for clear communication, the equipment will be provided to multiple entrants. This decision must be made by the entry supervisor before the commencement of work.
5.3.9 Authorization for Entry
Prior to entry, the entry team is required to notify Protective Services as to the location, time of entry, and number of personnel entering the permit-required space. The entry team must notify Protective Services when entry activities are complete.
5.3.10 Confined Space Permit Procedures
Confined space entry permits (see Attachment B) are required for entering any permit-required confined space. To obtain a permit, the entry supervisor must first confirm that work cannot be accomplished without entering the space. If work requires entry, a permit will be completed by the entry supervisor and the Campus Environmental Health and Safety office.
The entry supervisor must make all determinations regarding the safe entry into the space. The entry supervisor, following all requirements set forth in 5.3.2, will grant or refuse entry into the space after reviewing the monitoring results.
If entry is granted the completed permit will be posted or otherwise made readily accessible to all authorized entrants. All authorized entrants will review the permit, review rescue procedures and don any personal protective equipment before entering the space. The entry team will contact Protective Services before entering the space.
Permits are only valid up to eight (8) hours. Some exceptions may be granted with specific approval from the Campus Environmental Health and Safety Office.
The entry supervisor is required to terminate an entry or cancel the permit when the job is complete or a prohibited condition arises in the work area. Upon termination/cancellation, Protective Services must be notified that the entry team(s) has emerged from the space. The permit can then be mailed or delivered to the Campus Environmental Health and Safety Office. All permits will be retained for one (1) year.
5.3.11 Working in Streets
Work in confined spaces with entry from a street may proceed as long as the following conditions are met.
- An entry teams vehicle beacon light and/or four-way hazard flashers shall be activated upon arrival at the entrance to the confined space.
- An entry teams vehicle shall be parked in such a manner to not obstruct traffic, yet provide protection for the employees.
- Vehicle used by entry personnel shall be parked so that its exhaust does not enter the confined space.
- Traffic safety vests shall be worn.
- Easily visible traffic safety cones shall be placed around the entry team vehicle and manhole.
- A flag person should be added to the entry team if traffic flow is inhibited or based on the judgement of the entry supervisor. The flag person will not be the attendant.
5.3.12 Training Requirements for Confined Space Entry
Training will be provided to all employees who must enter confined spaces. Each employee will be provided with the understanding, knowledge, and skills necessary to carry out their duties as well as the functions of this program. Each employee will be trained in all aspects of entry responsibilities, including those of the attendant, entrant, and entry supervisor.
Initial training will be provided by the Campus Environmental Health and Safety Office. Refresher training will be performed by the employee's supervisor or designee. The training packet is available in the Campus Environmental Health and Safety Office on a check-out basis. Refresher training must be conducted under the following circumstances. When there is a change in permit space operations that presents a hazard about which an employee has not previously been trained. In addition, whenever the employer has reason to believe either that there are deviations from the permit space entry procedures or that there are inadequacies in the employee's knowledge or use of these procedures.
5.3.13 Confined Space Rescue
Rescue services will be provided by the La Crosse Fire Department. Protective Services will contact the La Crosse Fire Department to initiate the rescue procedure. Protective Services should be contacted via radio or telephone.
To facilitate rescue a full body harness and retrieval lines will be used for all entries where the use of such equipment does not create other potential hazards. Each member of the team will be trained in the proper operation of this piece of equipment.
In case of an emergency, the attendant will notify Protective Services and have information regarding the confined space readily available. This information includes, but is not limited to: time mishap occurred, number of affected entrants, possible hazards of the space, location and configuration of the space. If the entrant was working with a particular substance for which Material Safety Data Sheets (MSDS) were required, the MSDS must be made available to the treating health care professionals.
5.3.14 Contractor Coordination
All turnkey contract jobs requiring confined space entry will require submittal of the contractor's confined space entry plan before the commencement of work. All regulatory requirements of 1910.146 "Permit-Required Confined Spaces" will be followed by the contractor. The contractor must furnish all equipment required for entry.
As applicable, the Project Manager will inform the contractor of the UW-La Crosse Confined Space Entry Program and its requirements. Contractors are responsible for following all requirements set forth in this document. If any work requires the contractor's personnel to enter permit-required spaces, the contractor is required to obtain permits before entry. The Project Manager will inform the contractor of the hazards posed by the space and any notable experience with the space.
In instances where both UW-La Crosse employees and contractors are serving as entrants, UW-La Crosse will perform all duties prior to entry. In addition, UW-La Crosse will furnish communication equipment and personnel to serve as attendant and entry supervisor.
After completing all work in the confined space the project manager will debrief the contractor regarding the entry and identify any hazards encountered or created during the job. Details of any problems will be forwarded to the Campus Environmental Health and Safety Office.
5.3.15 Annual Review of Confined Spaces
The UW-La Crosse Confined Space Entry Program will be reviewed annually to determine its effectiveness. Utilizing canceled permits and other available information the Campus Environmental Health and Safety office will determine if:
- additional hazards have been identified within a given space;
- additional measures should be taken to protect the entrants;
- additional spaces should be included within the program; and
- some locations can be removed from the program.
The Confined Space Entry Standard is effective immediately. All University of Wisconsin-La Crosse employees shall fulfill their responsibilities as designated within this written standard.