Policy No: 2031 Responsible Office: Safety & Environmental Compliance Last Review Date: 05/27/2020 Next Required Review: 05/27/2021
Confined Space Entry Policy
The purpose of this policy is to specify minimum requirements for assuring safe entry of Confined Spaces and to assign responsibility for implementation and enforcement.
This policy applies to Finance & Administration, Executive VP and the USA Health Division employees as well as any person, either University employee, or outside contractor employee, who enters Confined Spaces on any of the University of South Alabama Campuses.
Confined Space: A space which has limited opening for entry and exit, or unfavorable natural ventilation which could allow accumulation of dangerous materials or in which an oxygen deficiency might exist. HVAC Units and Cooling Towers will have signage posted if excluded from Confined Space Permit process.
- Storage Tanks;
- Evacuation Holes;
- Elevator Pits;
- Exhaust Ducts;
- Dust Collectors;
- Utility Pits/Chases;
- Large Pipes.
Confined Space Entry: Is defined as when any part of the body of the worker breaks the plane of the opening to the Confined Space and is not limited to full body entry.
4. Policy Guidelines
4.1 Areas of Concern
Confined Space entry procedures shall be followed when work is performed in a tank, vessel, silo, vault, pit or open-topped space more than five feet deep or any other enclosed space that is not designed for continuous employee occupancy and which has at least one of the following characteristics:
- Contains an actual or potentially hazardous atmosphere or other safety or health hazard;
- Makes quick escape difficult (i.e. prevent egress in a normal walking position);
- Restricts entry for the rescue operations.
A Confined Space entry permit is required to authorize entry into a Confined Space. A sample copy of the required permit is shown as an attachment to this rule.
4.2.1 A Confined Space entry permit/checklist must be filled out by the responsible person coordinating the project or who is responsible for the maintenance of this site.
4.2.2 Only those who have been trained in the areas described in this policy by the University shall sign the Confined Space entry permit.
4.2.3 A thorough review of the checklist must be completed at the job site by the project coordinator. The signed permit, along with special precautions to be followed, must be provided to and discussed with those persons who will enter the Confined Space.
4.2.4 It shall specifically state exactly when the permit will begin and expire.
NOTE: For NO reason will the permit extend into the following shift or day without being reissued and approval.
4.2.5 The approved permit shall be posted in close proximity to the Confined Space entry. Also, a sign stating that a “Confined Space Entry is in Progress” shall be posted in close proximity to the Confined Space.
4.2.6 The project coordinator shall retain each canceled entry permit for at least one (1) year.
Persons who are required to work in Confined Spaces or in support of those working in Confined Spaces (attendants or helpers) shall be trained and receive instructions in the following areas:
- Nature of the work to be performed;
- Emergency Confined Space entry and exit procedures;
- Use of entry and emergency equipment.
4.4 Preparation of Confined Space Prior to Entry
4.4.1 Removal of Residual Materials
Residual materials in the Confined Space shall be removed before work is started. Sludge or encrustation shall be removed to as large an extent as possible before entry.
An exception can be made only if low levels of hazardous materials are involved and the employee is totally isolated from exposure to any harmful residual from the materials/hazards created by it (i.e. suffocation hazard of partially filled tanks, crusty hazards of materials caked on top/sides of the space). Exceptions are to be considered on a case-by-case basis.
In cases where the residual material is flammable, or presents a potential health and/or toxicity hazard, an entry shall not be permitted until the concentration of vapors/gases are below the “Immediately Dangerous to Life and Health” (IDLH) levels as established by NIOSH/OSHA. The IDLH levels are published in the NIOSH/OSHA Pocket Guide to Chemical Hazards. See the Department of Safety and Environmental Compliance’s web site under Resource Links or the NIOSH web site.
If the IDLH level is not listed in the guide, the concentration of flammable vapors/gases must not be above the “Short Term Exposure Level” (STEL).
4.5.1 The Confined Space must be purged to ensure fresh air prior to entries using a mechanical air blower or exhauster that is the same for service in the specific environment.
Exceptions to 4.5.1 can occur in cases where it is not practical to ventilate the area because the residual materials cannot be removed. In such cases, the Self-Contained Breathing Apparatus (SCBA) or continuous airline \ respirators must be worn. (This exception does not apply when residual material is flammable).
4.5.2 Thorough purging is best accomplished by carefully choosing the best location of the suction and discharge of the exhaust blower/exhauster. Locate the blower suction and discharge at the opposite ends of the Confined Space or attach a flexible duct to the exhauster suction and extend it to a remote part of the space when only a single opening is available.
4.5.3 The rate and volume of fresh air purging is to be determined by the nature and quantity of the residual material and the size and configuration of the Confined Space.
4.5.4 The discharge of the purged air must be located where it will not present a flammability/toxicity hazard.
4.5.6 If gas-driven, Venturi type blowers (exhausters) are used, either the air will be exhausted or the driving gas shall meet Compressed Gas Associate Grade D specifications.
All pipelines, which are intended to discharge a hazardous material into the Confined Space, must be isolated from the Confined Space as follows:
4.6.1 Where practical, each pipeline shall be physically disconnected from the space or unit, and blind flanges installed and tagged on the live end of the pipe. All blind flanges are to be of materials that are corrosion resistant and must be rated for the line pressure, per ASME specifications.
4.6.2 If the requirements of 4.6.1 are not practical, acceptable isolation may be achieved by installing slip blanks between flanges in the pipeline upstream of the line’s entry into the unit, but as close as possible to the piping entrance.
4.6.3 If 4.6.1 and 4.6.2 are not possible or practical, and the materials are not hazardous, isolation may be achieved by locking and tagging two valve in series in the closed position and providing an open bleed line between the valves with a visible discharge (DOUBLE BLOCK AND BLEED).
Exceptions above are city water below 100 PSIG and 130E F (54E C) and plant air below 30 PSIG and 54E C. For those materials, locking out a valve and tagging is sufficient isolation.
4.6.4 If 4.6.1, 4.6.2, and 4.6.3 are all totally impractical, the pipelines should be re-engineered to permit compliance or an alternate plan for safe isolation should be developed and approved by the person responsible for signing off on the Confined Space entry permits.
All electrically controlled moveable equipment (agitators, storage tank pumps, elevator motor, fans, and other energized equipment) that could cause injury if energized, shall be deactivated and locked and tagged in the OFF position, in accordance with the University’s Lockout Tagout Procedures-Policy.
4.8 Moveable Equipment Drives
In addition to LOCKOUT and where practical, it is recommended that any moveable equipment drives have the drive belt physically disconnected or the electric motor leads are disconnected.
4.9 Atmospheric Testing
The atmospheric testing described below shall be performed on all Confined Spaces before entry.
4.10 Flammable gases, vapors or mists:
A flammable gas test shall be testedusing an appropriate meter calibrated as per the manufacturer’s recommendations and qualitatively tested before each use. Concentrations of gases, vapors, or mists will not exceed ten percent of its lower explosive level (LEL).
An oxygen test for deficiency and enrichment shall be performed using an appropriate meter before entering ANY Confined Spaces. The sample shall be taken at representative points within the unit. The oxygen concentration must be in the range of 19.5% to 23.5% before entry is permitted.
4.10.2 Additional Contaminants:
When the Confined Space has contained material that is toxic by inhalation, the Confined Space must be tested by analyzing a grab sample taken at a representative point. This testing shall be performed using direct-reading instruments (i.e. Draeger tubes, etc.) Results shall be such that persons will not be exposed to concentrations above those specified by industry standards.
4.10.3 Ambient Temperature:
Consideration shall be given to assuring a Confined Space is neither excessively hot nor cold. Engineering controls, administrative controls or personal equipment controls shall be implemented to counteract the hazard (decreasing order of preference).
4.11 Respiratory Protection Requirement
4.11.1 If the atmosphere in a Confined Space is a potential health hazard and/or toxic, personnel entering the Confined Space must wear an open circuit, positive pressure, full-facepiece airline respirator or a full-facepiece SCBA.
4.11.2 If the atmosphere in a Confined Space is below the IDLH level, personnel entering a Confined Space must wear, as a minimum requirement, PAPR (Positive Air Purified Respirator) and check all O2 levels.
4.11.3 Negative pressure air-purifying respirators SHALL NOT be worn for Confined Space entry if the atmosphere is hazardous.
4.11.4 For welding or gas cutting operations in a Confined Space, personnel shall wear the same respiratory protection as in 4.11.1.
4.11.5 Airline respiratory protection may be exempted in areas that are open top with adequate general ventilation and if the Confined Space does not contain any materials hazardous to health.
4.11.6 In areas with limited access, respirators may be exempted, providing all three of the following conditions exists:
- The vessel is free of any potentially hazardous materials;
- Welding or gas cutting is not being performed;
- Mechanical ventilation is provided.
4.11.7 Breathing air in cylinders for use with airline respirators and/or SCBA apparatus must meet or exceed Grade D requirements as outlined in the Compressed Gas Association Standards.
4.11.8 All respiratory protection equipment must be NIOSH/OSHA approved for the service for which it is being used.
4.12 Electrical Appliance
4.12.1 Lighting equipment for Confined Space entry shall be powered by a 12-volt electrical system. If a 110-volt system is preferred, a ground fault interrupter must be connected to the electrical system outside of the Confined Space.
4.12.2 All electrical systems must be an approved type for the location and hazards.
4.12.3 If powered electrical tools are used in a Confined Space, a ground fault interrupter must be connected to the electrical system outside of the Confined Space.
4.13 Emergency Response Equipment
4.13.1 A full body harness and D-ring shall be properly fitted to each person entering an enclosed Confined Space. A lifeline shall be attached to the body harness extending out to the primary exit to the attendant, who shall be located as close as possible to permit safe removal of the individual.
4.13.2 Where rescue is to be accomplished by lifting the person vertically, mechanical hoisting equipment shall be provided directly above entry opening (for purposes of hoisting the person by the lifeline), mounted either on overhead structures (capable of supporting the weight of the person) or on a detachable pulley support frame. The equipment shall be such that a rescue team can readily lift the person.
4.13.3 A continuous supplied air respirator shall be located near the attendant ready for immediate use.
4.14 Exit Capabilities
Before entry, the means of exiting shall be determined. Any special precautions for entry or exit must be taken clearly specified on the permit checklist. Each case must be evaluated separately.
4.15 Attendants and Rescue Teams
4.15.1 All Confined Space operations shall require a qualified attendant for personnel in the unit. The attendants’ primary function is to assure continued safe work in the Confined Space throughout the duration of the job and to call for rescue aid if assistance is required.
4.15.2 A qualified attendant may pass tools but shall have no other job that will take his/her attention away from the person(s) in the Confined space (i.e. attendant must not walk to a vehicle parked away from the personnel in the Confined Space to get tools, etc.).
4.15.3 A qualified attendant must be trained in the duties assigned to Confined Space entry and rescue. Training records should be kept of file for five years.
4.15.4 A qualified attendant shall be required to wear a body harness and have a separate lifeline and air-supplied breathing apparatus at the job site.
4.15.5 A qualified attendant shall maintain either constant observation of person(s) in Confined Space, maintain constant radio, or voice contact with the employee in the Confined Space.
4.15.6 A qualified attendant shall provide constant surveillance of the work and protective equipment associated with the Confined Space entry.
4.15.7 A qualified attendant shall visually observe the continuous gas and oxygen monitor. If an alarm is activated, the qualified attendant shall notify the individual in the Confined Space to abort the entry.
4.15.8 Whenever an emergency condition requires the immediate removal of a person, the qualified person shall:
- Summon aid immediately by activating a previously agreed to alarm/notification plan;
- Perform rescue work from OUTSIDE the Confined Space.
AT NO TIME SHALL AN INDIVIDUAL ENTER THE CONFINED SPACE UNTIL ADDITIONAL ASSISTANCE ARRIVES AT THE SCENE.
4.15.9 When performing rescue work the qualified attendant must wear and use self- contained breathing apparatus and/or positive pressure airline respirator, have a lifeline attached to his/her harness and another trained person outside the area before entry.
4.15.10 For every location involved in Confined Space entry, a rescue team shall be assigned and trained to provide quick and effective first aid, CPR and rescue. This requirement may be accomplished with University staff or outside personnel (Mobile Fire-Rescue or EMS).
4.16 Burning Inside Confined Spaces
4.16.1 All standard procedures required for burning or hot work as per University regulations shall be followed.
4.16.2 Additionally, flammable vapor tests shall be conducted frequently. If the monitor indicates flammability concentrations in the Confined Space other than zero, welding or other burning will be stopped immediately and will resume only after an investigation shows that it is safe to do so.
4.16.3 Where welding or burning will take place inside a unit, NIOSH/OSHA approved continuous airline respirators or positive pressure self-contained breathing apparatus shall be required for all persons inside the unit.
4.16.4 Welding or burning shall not be done if flammable dusts are present in the Confined Space or in the air around the Confined Space.
4.17 Other Hazardous Work in Confined Space
If it is necessary to perform other hazardous work inside the Confined Space, the nature of the job, the hazards and the necessary safety precautions shall be thoroughly evaluated on a case- by-case basis. The person responsible for approving the project shall clearly describe the precautions effectively to all those who will do the work.
4.18 Equipment and Tools
4.18.1 Tools shall be in good condition and proper for the use intended.
4.18.2 For entry into metal confine spaces, all portable electric equipment must have ground fault circuit interrupters installed at the electrical outlet or the supply voltage shall be 12-volt or less.
4.18.3 When there is the possibility of flammable liquids or gases being present, any electrical tools or equipment must be explosion proof or intrinsically safe.
4.18.4 If there is a possibility of flammable liquids or gases being present, any electrical tools or equipment must be explosion proof or intrinsically safe.
4.18.5 Good illumination within the Confined Space shall be provided.
4.18.6 Cylinders of compressed gases must not be taken into a Confined Space. Exempt from the rule are cylinders that are part of a self-contained breathing apparatus or resuscitation equipment.
4.19 Personal Protective Equipment
4.19.1 Normal requirements for proper personal protective equipment apply for Confined Space entry.
4.19.2 All personal protective equipment requirements must be designated on the permit form, and fully explained to the persons involved in the Confined Space.
4.20 Completion of Work
4.20.1 When work has been completed in a Confined Space, the responsible coordinator signing the Confined Space permit shall verify the following:
- All personnel, equipment and materials have been removed from the Confined Space;
- Locks and tags have been removed from all valves and piping and disconnected lines secured;
- Personnel working in the Confined Space have removed all electrical equipment locks and tags;
- All openings have been secured for normal operations;
- Housekeeping has been completed;
- The supervisor shall retain each cancelled entry permit for at least one (1) year;
- Any problem encountered during an entry operation shall be noted on the pertinent permit so that appropriate revision to the permit space program can be made.
4.20.2 After all items have been completed, the responsible coordinator can remove his/her lock from the main deactivation point and make the equipment ready for service.
4.20.3 Emergency stand-by equipment shall be replaced and made ready for service.
4.21 Equipment Design
4.21.1 All new equipment large enough to accommodate entry shall be designed with a minimum 24-inch diameter manhole.
4.21.2 All new equipment layouts, which will require Confined Space entry, shall be designed with facility isolation in mind.
This policy is enforced by Safety and Environmental Compliance Department. Non-compliance may result in suspension of associated activities and/or projects. Contractors' failure to comply may require removal from University property and potential ineligibility for future bids. University faculty and staff will be subject to disciplinary action per Faculty Handbook or Staff Employee Handbook, respectively.
7. Related Documents
Confined Space Permit link: