St. Olaf College

Confined Space Entry


Policy and Procedures Manual





Section 1
INTRODUCTION





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Section 1
INTRODUCTION




OVERVIEW



  • A. The National Institute of Occupational Safety and Health (NIOSH) defines Confined Space as "any space which, by design, has limited openings for entry and exit; unfavorable natural ventilation which could contain or produce dangerous air contaminants, and which is not intended for continuous employee occupancy.

  • B. The Occupational Safety and Health Administration (OSHA) in 1926.21 "Safety training and education" paragraph 5, sub-paragraph ii, defines Confined Space as "any space having a limited means of egress, which is subject to the accumulation of toxic or flammable contaminants or has an oxygen deficient atmosphere. Confined or enclosed spaces include, but are not limited to, storage to, storage tanks, process vessels, bins, boilers, ventilation or exhaust ducts, sewers, underground utility vaults, tunnels, pipelines, and open top spaces more than 4 feet deep such as pits, tubs, vaults, and vessels." OSHA 1926 is the construction industry standard.

  • C. OSHA 1910.146(a) (23), the general industry standard, defines Confined Space Entry as "A permit-required confined space (permit space) means an enclosed space which:
    • 1. Is large enough and so configured that an employee can bodily enter and perform assigned work.

    • 2. Has limited or restricted means for entry or exit, (some examples are tanks, vessels, silos, storage bins, hoppers, vaults, pits and diked areas);

    • 3. Is not designed for continuous human occupancy, and has one or more of the following characteristics:


      • a. Contains or has a known potential to contain a hazardous atmosphere;

      • b. Contains a material with the potential for engulfment of the entrant;

      • c. Has an internal configuration such that an entrant could be trapped or asphyxiated by inwardly converging walls or a floor which slopes downward and tapers to a smaller cross-section;

      • d. Contains any other recognized safety or health hazard."


  • D. The exact number of workers killed and injured each year in confined-space accidents is unknown. The NIOSH criteria document on confined spaces lists a study that reviewed 20,000 accident reports filed over a three-year period. Analysis of those reports showed that 234 deaths and 193 injuries were linked to 276 confined-space incidents. An OSHA report summarizing an in-house review of inspection case files showed that 173 fatalities resulted from 122 confined-space accidents.

  • E. Employees assigned to work in confined spaces are not the only people at risk. A NIOSH study conducted in 1986 suggests that more than half of those killed in confined spaces were rescuers. In some cases, as many as four would-be rescuers were killed in a single accident.

  • F. The practices and procedures which St. Olaf College follows when doing confined space entry are designed to protect you from the hazards of entry into and working in this environment. Never short cut these safe work practices.

  • G. You should know and remember that work-related accidents in confined spaces usually result in serious injury or death.



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PERMIT ENTRY CONFINED SPACE



  • A. Definition:

    • 1. Permit entry confined space means an enclosed space which:

      • a. Is large enough and laid out in such a way that a worker could enter and perform work; and

      • b. Has limited means of entry and exit such as a storage bin, hopper, vault, pit, or diked area; and

      • c. Is not designed for continuous occupancy by the worker, and

      • d. Has one or more of the following characteristics:

        • 1) Contains or may contain a hazardous atmosphere;

        • 2) Contains the potential for engulfment by loose particles;

        • 3) Has an internal layout such that someone entering could be trapped or asphyxiated by inwardly converging walls or a floor which slopes downward and tapers to a smaller cross-section; or

        • 4) Contains any other recognized serious safety or health hazard.


NOTE: Even the act of placing your face through the opening of a permit entry confined space is considered an "entry".


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EMPLOYER PROGRAM REQUIREMENTS
  • A. Regulations require St. Olaf College to establish a Confined Space Entry program which contains the following elements:

    • 1. Identifying each permit entry confined space and informing workers by sign, placard, training program or other effective means of it's location in order to prevent unauthorized entry.

    • 2. Providing a specific training program for workers who would be entering such spaces before they may be authorized to enter them.

    • 3. Making available all protective clothing and personal protective equipment necessary for safe entry into such places.

    • 4. Assuring the ready availability of rescue and safety related equipment or services, such as lifting or retrieval devices and others, necessary for the entry.

    • 5. To make non-entry rescues possible where entry would be into an atmosphere immediately dangerous to life or health or into an area where there is a risk of engulfment. This means that retrieval lines must be set up at the space. There must be adequate attachment points outside the confined space for tying-off or otherwise securing retrieval lines for all workers entering. If these lines themselves could become a hazard due to entanglement or if they otherwise cannot be used, then an equivalent method for rescue must be provided.

    • 6. Determining and evaluating the source of any atmospheric contamination found at the time of entry. If the severity of this hazard could increase while workers are in this space, then appropriate provision must be made for this.

    • 7. Providing an attendant for each entry where required.

    • 8. Establishing an entry permit system which is covered in the section on ENTRY PERMIT SYSTEM.



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ENTRY PERMIT SYSTEM



  • A. The college must develop, implement and use an entry permit system that includes written procedures for issuance of permits to enter permit entry confined spaces. These procedures must:

    • 1. Determine the permit entry confined spaces and identify them for workers to prevent unauthorized entry.

    • 2. Determine the actual and potential hazards associated with the space at the time of entry

    • 3. Assure that control measures used in the confined space are effective. This is done by appropriate testing.

    • 4. Provide appropriate vehicle and pedestrian guards, barriers or other means to protect the workers entering the confined space and the attendant(s) from local traffic hazards, and to protect non-entering workers from hazards arising from the confined space.

    • 5. Prepare a plan of emergency evacuation in conformance with CFR Section 1910.38(a).

    • 6. Identify by job title those persons who must sign the entry permit and the duties of each, including the person in charge of the entry.

    • 7. Provide for pre-planned emergency rescue.

    • 8. Define the role of the person deemed "competent person", or equivalent title, if such a person is part of your school's permit entry system.

    • 9. Provide an attendant for each entry, where applicable, and specify the duties of that attendant.

    • 10. Assure proper calibration of test and/or monitoring equipment.

    • 11. Assure that workers who participate in entry of a permit entry confined space in any capacity have been properly trained.



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ENTRY PERMIT AND CHECKLIST



  • A. Regulations require that the entry permit shall authorize entry

    • 1. only by authorized workers

    • 2. into a specific permit entry confined space

    • 3. for a specific purpose

    • 4. with entry by a specific shift or work crew for a period not to exceed 24 hours.


  • B. These Regulations would require the following items to be included on each entry permit;

    • 1. The minimum environmental conditions which are acceptable for entry and working in the space.

    • 2. A means for assuring and certifying that all pre-entry requirements have been met.

    • 3. The name or job title of the person authorizing or in charge of the entry.

    • 4. The name of the attendant. If the permit directs that more than one worker will rotate in the attendant position, this may be omitted. Also, this may be omitted if the entry falls under the classification of special permits and practices.

    • 5. The means for assuring that the in-plant rescue team is available. If your location has not formed an in-plant rescue team, then the permit must carry the means for assuring that predesignated outside assistance can be summoned. The College does not maintain an in-house rescue team. Dial 9-911 on any College telephone for the Northfield Rescue Squad.

    • 6. Any known hazards or those which could reasonably be expected to be present in the space.


  • C. The regulations would allow the following requirements to be covered by the permit or as an alternative, they may be covered by a checklist which is then attached to the permit:

    • 1. All means of isolation, cleaning, purging or bringing motion to rest has been done prior to entry to remove or control hazards identified in number 6. above.

    • 2. Describe any additional hazards that the activities of the workers in the space could be reasonably expected to generate. If any special work practices or procedures must be followed, they must be listed here.

    • 3. Any personal protective equipment that is necessary for the entry or rescue of the workers in the confined space, should be necessary.

    • 4. Any testing of the atmosphere in the space which must be done immediately prior to and during the entry period. The person(s) who are responsible for such testing must be listed unless special circumstances allow otherwise.

    • 5. If hot work will be necessary in the space, it must be authorized on the Entry Permit or a separate Hot Work permit must be attached to the entry permit. In this case, the issuance of the Hot Work permit is then noted on the entry permit itself.

    • 6. If the entry will be into an atmosphere which is actually or potentially immediately endangering to life or health, NIOSH approved positive pressure atmosphere supplying breathing apparatus or a positive pressure airline respirator equipped with a minimum of a 5 minute emergency escape bottle must be available at the point of the entry.



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