Confined Space

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rev 6/2013

Table of Contents
I.     Purpose
II.    Definitions
III.   Confined Spaces on Campus/Authorized Employees
IV.   Identifying Permit Required Confined Space Hazards
V.    Equipment
VI.   Procedures for Working in a Non-Permit Required Confined Space
VII.  Procedures for Working in a Permit Required Confined Space
VIII. Emergency Procedures
IX.   Contractor Entry
X.    Training
XI.   Records
XII.  Annual Program Review

I. Purpose

This Program is designed to identify and control potential hazards of working in confined spaces on campus by establishing procedures for confined space entry in compliance with 29 CFR 1910.146, OSHA Permit Required Confined Space Standard.

II. Definitions

A Confined Space is a space that has all of the following characteristics:

  • is large enough and so configured that a person can bodily enter and perform assigned work
  • has limited or restricted in its means of entry or egress
  • is not designed for continuous occupancy

A Permit Required Confined Space is a confined space that has one or more of the following characteristics:

  • contains or has the potential to contain a hazardous atmosphere
  • contains a material with the potential to engulf someone who enters the space
  • has an internal configuration that might cause an entrant to be trapped or asphyxiated by inwardly converging walls or by a floor that slopes downward and tapers to a smaller cross section,
  • contains any other recognized serious safety or health hazard, examples include:
    • fall hazards
    • unguarded machinery
    • extreme hot or cold
    • live steam pipes
    • gas lines
    • electrical hazards
    • combustion sources
    • hazards introduced to the space (e.g., welding, chemical use)

Entry means any part of the entrant’s body breaking the plane of an opening into a confined space.

III. Confined Spaces on Campus/Authorized Employees

A. Non-Permit Required Spaces

A Non-Permit required confined space is a confined space that does not contain, or have the potential to contain, any hazard capable of cause death or serious physical harm. Examples may include interiors of HVAC units, certain air plenums, attics, and some building crawl spaces. 

Entry into Non-Permit required spaces requires atmospheric testing prior to and during entry to ensure the space is, and remains, free of atmospheric hazards.   General work safety practices must be adhered to including use of barrier as needed to ensure the safety of others in the area.

Areas that have been classified as Non-Permit, may be reclassified as Permit-Required if hazards are being introduced to the space (e.g., welding, chemical use) or unusual conditions have changed the hazards of the space (e.g., water infiltration).

B. Permit Required Confined Spaces

Entry into Permit Required Confined Spaces requires that a valid Entry Permit be in place. Requirements for Entry Permits are detailed in section VI.

Examples of Permit Required confined spaces on campus include:

Boilers: waterside and fireside
Hot water tanks at the Central Heating Plant and in campus buildings
Manholes: any space accessed by lifting a manhole cover
Mechanical Crawl Spaces: e.g., Carr, Kendade, Shattuck, Williston Library, Mary Lyon, Pratt, Torrey and Betty Shabazz
Elevator Pits and Shafts
Certain Attics: e.g., Dwight

Facilities Management maintains a list of all Permit Required confined spaces on campus and ensures that spaces are identified by signs or, in the case of manholes, on a map posted at the Otto Kohler Building and the Central Heating Plant.

C. Authorized Employees

No employee that has not been trained under the confined space program will enter any confined space or serve in any other capacity in support of entry (e.g., attendant, entry supervisor). Trained employees in the following Facilities Management trades are authorized to participate in entries: Plumbing, HVAC, Electrical, Central Heating Plant.

The following Facilities Management employees are authorized as Permit Required Entry Supervisors: Associate Director and Chief Engineer, Plumbing Supervisor, Electrical Supervisor, HVAC and Central Heating Supervisor, or his/her designee.

IV. Identifying Permit Required Confined Space Hazards

A. Hazardous Atmosphere

The following parameters are used to define a "Hazardous Atmosphere"

Atmospheric oxygen concentration below 19.5 percent or above 23.0 percent.

At 16% most people will show signs of respiratory distress, light-headedness, mental confusion. Above 23% the risk of fire and explosion increases rapidly.

Flammable gas, vapor, or mist more than 10 percent of its LEL.

LEL is the Lower Explosion Limit (also sometimes known as the Lower Flammability Limit, LFL). It is the lower concentration in air at which ignition can occur. The UEL is the Upper Explosion Limit above which ignition will not occur. The flammable range is the range between the LEL and UEL.

Carbon Monoxide more than 35 parts per million.

Carbon monoxide is the most common cause of chemical poisoning deaths. It is a chemical asphyxiant that prevents blood from transporting oxygen. The alarm level of 35 ppm is the 8-hour time weighted average OSHA Permissible Exposure Limit.

Hydrogen sulfide more than 10 parts per million.

Hydrogen sulfide is toxic and explosive. The LEL is 4% and the UEL is 44%. The 8-hour OSHA Permissible Exposure Limit is 10 ppm. The Immediately Dangerous to Life and Health (IDLH) concentration is 300 ppm. Hydrogen sulfide has a distinct odor that can be detected at 0.0002 ppm. The toxic effects are, however, on the nervous system; the nerve responsible for smell quickly becomes fatigued, therefore, odor, or lack of odor, should not be used as a warning sign. Eye and nasal irritation are more persistent.

Airborne combustible dust at a concentration that meets or exceeds its LFL.

(approximately a dust that obscures vision at a distance of 5 feet or less).

B. Other Confined Space Hazards

  • engulfment including potential for rising water, sewage, or landslide
  • configuration/entrapment (spaces that narrow or have obstructions that might cause a person to become stuck)
  • fall Hazards of 6 feet or more
  • unguarded machinery or mechanical hazards such as rotating or moving mechanical parts
  • extreme temperatures including either high or low atmospheric temperature in the space or hot objects in the space
  • live steam lines
  • gas lines with valves or other devices that could release gas if they fail
  • electrical hazards including exposed electrical voltages more than 120 volts
  • combustion sources due to potential for combustion gases
  • introduced hazards such as welding or chemical use

V. Equipment

Two Industrial Scientific M40 four gas (oxygen, flammable gas, carbon monoxide, and hydrogen sulfide) meters are available for testing confined spaces. Basic instructions for the meter are included at the end of this Program. The meters are:

  • stored at Central Heating Plant
  • only available to employees trained under this Program
  • signed out including: employee name, date, time, and location of use
  • maintained by the Facilities Management Systems Inspector

The meters are kept in a M-Cal station for charging, calibration and bump testing.

Barriers, air blower, retrieval tripod and other confined space equipment are also kept at the Central Heating Plant.

Kendade mechanical room is equipped with escape breathing apparatus, for use to immediately exit the area should the refrigerant release alarm sound. These respirators are inspected and maintained by the Facilities Management Systems Inspector.

VI. Procedures for Working in a Non-Permit Required Confined Space

Only employees who have completed training for this Program are authorized to enter a non-permit required confined space. 

A. Pre-Entry

  1. Pick-up test equipment and a Confined Space Entry Permit at the Central Heating Plant. Perform a bump test on the meter by holding the BUMP button for 2 seconds. A passed bump test is indicated by a flashing green light. A failed bump test is designated by a flashing red light. If the bump test fails, the meter required calibration or repair and cannot be used. Record the bump test and removal of the test equipment on the Instrument Log.
  2. Complete the following pre-entry tasks
    • gather required equipment
    • erect pedestrian and/or vehicular barriers as needed
    • eliminate any condition that makes it hazardous to open the space
    • open the space
    • without entering the space, make a visual inspection for potential hazards
    • without entering the space, test for atmospheric hazards using the test meter and record the results
  3. Determine if the space needs to be reclassified. If any level of atmospheric contaminant is detected or any other hazard is detected, the space must be reclassified as a Permit Required Confined Space.

B. Entry

Assuming the space remain classified as Not-Permit Required, enter the space continuing to do atmospheric testing while in the space and complete the needed task.

If atmospheric or other hazards develop while in the space, exit immediately and reclassify as Permit Required.

C. Entry Termination

After the necessary work is complete, remove all tools, exit the space, and secure the entry point from unauthorized entry.

VII. Procedures for Working in a Permit Required Confined Space

Only employees who have completed training for this Program are authorized to enter a confined space or serve as an attendant. An attendant is required for all work in permit required confined spaces

A. Pre-Entry

  1. Pick-up test equipment and a Confined Space Entry Permit at the Central Heating Plant. Perform a bump test on the meter by holding the BUMP button for 2 seconds. A passed bump test is indicated by a flashing green light. A failed bump test is designated by a flashing red light. If the bump test fails, the meter required calibration or repair and cannot be used. Record the bump test and removal of the test equipment on the Instrument Log.
  2. Complete the following pre-entry tasks
    • identify the Entry Supervisor and complete Section 1 of the Entry Permit
    • gather required equipment
    • erect pedestrian and/or vehicular barriers as needed
    • eliminate any condition that makes it hazardous to enter the space
    • open the cover or other closure device
    • without entering the space, make a visual inspection for potential hazards without entering the space, test for atmospheric hazards using the test meter and record the results. 
    • implement controls to, such as lockout/tagout to isolate identified hazards
    • obtain a Hot Works Permit if applicable
    • if the space is a sewer pit, a hazard will be introduced (e.g., hot work operations, or chemical use), or a hazardous atmosphere is detected, a forced ventilation system must be setup
      • care must be taken to insure that the air intake to the ventilation system is safe from contamination and that the ventilation is directed toward the employee's work area in the confined space.
      • if ventilation is required, set up ventilation and retest atmosphere (acceptable results must be sustained for at least 10 minutes prior to entry)
    • for all vertical entries, the retrieval system (tripod and harness) must be used
    • ensure a communication system for summoning emergency assistance is available
    • complete Section 2 of the Entry Permit
    • entry supervisor reviews
  3. Rescue Services Notification

    During regular office hours, prior to entry, entrants must notify the Facilities Management Office of the entry location and estimated entry time and duration of entry. The Office with notify South Hadley Fire District #2. After hours, the Entry Supervisor is responsible for notifying South Hadley Fire District #2.

B. Entry Permit

After Section 2 of the Entry Permit is Complete, the Entry Supervisor reviews the permit information and site conditions and either issues an Entry Permit or determines that additional testing or precautions are needed and supervises those efforts. If the Entry Supervisor determines that the space cannot be safely entered, the Entry Permit is denied and the space cannot be entered.

C. Entry

For all entries, the meter must be carried in to the confined space by one of the entrants, or operated remotely by the attendant during the entire entry. 

Record all entrant entries and exits and changes in attendant in Section 4 of the Entry Permit. The Entry Permit must remain on-site throughout the entry. 

Should the test equipment sound a warning alarm during entry all employees must exit the space immediately and the entry is terminated. Record the Termination for Cause in Section 4 of the Entry Permit. Prior to reentry a new Entry Permit must be issued.

If additional action is needed to control hazards once the space is entered, take that action immediately upon entry.

The escape respirator must be carried into the Kendade mechanical crawl space.

D. Entry Termination

After the necessary work is complete, remove all tools, exit the space, and secure the entry point from unauthorized entry.                                            

If the space is being ventilated, all employees must leave the confined space before the ventilation system is turned-off. 

Complete Section 5 of the Entry Permit and give the Permit to the Entry Supervisor for review.

E. Duties of the Attendant

  • maintains an accurate count and identification of authorized entrants in the space
  • remains outside the space during entry until relieved by another  attendant
  • monitors conditions inside and outside the space
  • maintains communication with entrants
  • notifies entrants to leave the space if conditions become hazardous or if entrants show signs of overexposure to hazardous conditions

VIII.  Emergency Procedures

The College has an agreement with South Hadley Fire District #2 for emergency rescue services. Should rescue services be required or other health emergency occur, immediately contact Campus Police (ext. 1911, 538-2304) to request services.

IX. Contractor Entry

If Mount Holyoke College hires a contractor for work in a confined space the following tasks should be performed:

  1. All contracts for work to be done in a space identified by the College as a confined space will include the explicit requirement that the work be done according to a confined space program meeting the requirements of 29 CFR 1910.146.
  2. The College must tell the supervisor of any known hazards in the space and provide the contact information for South Hadley Fire District #2 so that the contactor can give pre-entry notification and call for emergency services if needed.
  3. Contractors must supply their own equipment and make their entry record or permit available upon request.
  4. The supervisor for that work area will inform the contractor of:
    • any known hazards in the space
    • results of any testing done to detect these hazards
    • procedures in use to control any potential hazards
  5. If both College employees and a contractor will be entering a space College procedures will be used for college employee entry and contractor procedures for contractor employee entry. An attendant may be shared if s/he is aware of College emergency notification procedures.

X. Training

Employees will be trained:

  • at the start of this Program
  • after that time for new and transferred employees before entering a confined space or serving in any other capacity under this program
  • if the annual review finds the need for additional training
  • when changes in the Program, test equipment, or list of confined spaces warrant additional training

The training program will consist of:

  • the hazards associated with working in confined spaces
  • a review of the Mount Holyoke College Confined Space Program and the OSHA Permit-Required Confined Space Standard
  • how to complete the Instrument Log, and Confined Space Entry Permit
  • how to use the atmospheric test equipment
  • how to use other program equipment (barriers, communication equipment etc., escape respirator)
  • procedures for confined space entry
  • emergency procedures

XI. Records

For Permit Required Entries the Entry Permit will be kept at the work site. After completion of the entry these documents will be completed and given to the Entry Supervisor for review. 

Completed Permits will be maintained in a separate program file in the Facilities Management Office. The Instrument Log will be maintained at the Central Heating Plant as part of the sign-out procedure. Instrument calibration records are kept on the Instrument Log. The Instrument Log will be collected annually and added to the program file for that year at the Facilities Management Office. 

All Permits, Instrument Logs, and other program records will be kept for at least one year after their annual review.

Training records will be kept in the Environmental Health & Safety Office.

XII. Annual Program Review

Once a year, the Facilities Management Associate Director (or his designee) will review the Confined Space Entry Program. The review will include at least the following procedures:

  • reviewing the records for the past year for completeness and adherence to the written Program
  • determining the need for Program modification or training
  • determining the need for new equipment
  • determining whether additional spaces should be classified as Permit Required Confined Spaces or whether identified spaces can be removed from the Program

Industrial Scientific M40 Multi-Gas Monitor Basic Operating Instructions
Confined Space Entry Permit