DISTRIBUTION: B, E, G, H

NEXT REVIEW DATE: May, 1996

POSITION RESPONSIBLE FOR REVIEW: Director, Environmental Health & Safety

 

PURPOSE: To establish policy and procedures for work in a confined space.

BACKGROUND: Basic policies and procedures are outlined in referenced documents. This directive reiterates key and essential provisions and establishes departmental policies which are aimed at standardizing procedures and enforcement. The objective to be achieved is to ensure persons entering confined spaces are proceeding in a safe manner.

POLICY: FMS policy is to ensure compliance with the referenced standard.

PROCEDURES: The following procedures shall be followed for all entries into confined spaces:

1. Definitions: The following words and terms, when used in this directive, shall have the following meaning, unless the context clearly indicates otherwise.

1.1. "Attendant" means an individual with no other duties assigned other than to remain immediately outside the entrance to the confined space and who may render assistance as needed to employees inside the space.

1.2. "Blind" or "blinding" or "blanking" means the absolute closure of pipe, line, or duct, to prevent passage of any material (e.g., by fastening a solid plate or "cap" across the pipe).

1.3. "Confined space" means any space that (1) is large enough and so configured that an employee can enter to perform work, and (2) is not intended for continuous employee occupancy, and (3) has a limited or restricted means of entrance or egress and (4) and which is also subject to either the accumulation of an actual or potentially hazardous atmosphere as defined in this directive, or has a potential for engulfment as defined in this directive. Confined spaces generally include, but are not limited to, storage tanks, bins, boilers, ventilation or exhaust ducts, sewers, manholes, underground utility vaults, acid tanks, digesters, ovens, tunnels, and pipelines. Open top spaces more than 4 feet in depth such as pits, tubs, vaults, and vessels may also be confined spaces if the above criteria above are met.

1.4. "Engulfment" means the surrounding and effective capture of a person by finely divided particulate matter or liquid. There is a potential for engulfment when such particulate matter or liquid exists in the sufficient quantity or at a sufficient pressure to surround a person before normal exit can be effected.

1.5. "Entrant" means any employee who enters confined space.

1.6. "Entry" means any action resulting in any part of the employee's face breaking the plane of any opening of the confined space, and includes any ensuing work activities inside the confined space.

1.7. "Entry permit" means CMU's written authorization of employee entry into a confined space under defined conditions for a stated purpose for a specified time.

1.8. "Hazardous atmosphere" means an atmosphere presenting a potential for death, disablement, injury, or acute illness from one or more of the following causes:

1.8.1. A flammable gas, vapor, or mist in excess of 10% of its lower explosive limit (LEL).

1.8.2. An oxygen deficient atmosphere containing less than 19.5% oxygen by volume or an oxygen enriched atmosphere containing more than 23% oxygen by volume.

1.8.3. An atmospheric concentration of any substance listed in sub-part Z of 29 CFR Part 1910 standards above the listed numerical value of the permissible exposure limit (PEL).

1.8.4. A condition immediately dangerous to life or health as defined in this directive.

1.9. "Hot Work Permit" means the CMU official burning permit which authorizes an operation capable of providing a source of ignition.

1.10. "Immediately dangerous to life or health (IDLH)" means any condition that poses an immediate threat to life, or which is likely to result in acute or immediately severe health effects.

1.11. "Lockout or tag out" means placing locks or tags on the energy isolating device. Tags shall indicate that the energy isolated device shall not be operated until the removal of the tag by an authorized person. Consult REFERENCE 2.

1.12. "Qualified person" means a person who is trained to recognize the hazard(s) of the confined space and how to evaluate those anticipated hazards and shall be capable of specifying necessary control measures to assure work safety. The primary "qualified person" designee is a representative of EH&S.

1.13. "Rescue Team" means those persons properly trained prior to any confined space entry to perform rescues from confined spaces. CMU presently has no on-site rescue team and relies on the City of Pittsburgh Fire Department for rescue from confined spaces.

1.14. "Retrieval line" means a line or rope secured at one end to a worker's safety belt, chest or body harness, or wristlets with the other end secured to an anchor point or lifting device located outside the entry portal. The anchor point shall not be a motor vehicle. Retrieval lines must be of sufficient strength to remove an entrant when necessary.

1.15. "Zero mechanical state" means that the mechanical potential energy of all portions of the machine or equipment is set so that the opening of the pipe(s), tube(s), hose(s), or actuation of any valve, lever, or button will not produce a movement which could cause injury.

2. Preparation. Entry into a confined space shall not be made unless a qualified person has assured that the following procedures have first been completed. The primary "qualified person(s)" are staff representatives of EH&S. Results of any observations or tests shall be entered onto the official Confined Space Entry Permit.

2.1. All pumps or lines which may convey flammable, injurious or incapacitating substances into a space shall be disconnected, blinded, double blocked and bled, or effectively isolated by other means to prevent engulfment, the development of dangerous levels of air contamination, or oxygen deficiency within the space.

2.2. All fixed mechanical devices or equipment that are capable of causing injury shall be placed at zero mechanical state (ZMS) by using lockout/tag out devices designed for that purpose.

2.3. All confined spaces shall be emptied, flushed, or otherwise purged of flammable, injurious or incapacitating substances to the extent feasible. Initial cleaning should be done from outside the confined space.

2.4. Where the existence of a hazardous atmosphere is demonstrated by tests performed by the qualified person, the confined space shall be mechanically ventilated until the concentration of the hazardous substance(s) is reduced to a safe level, and ventilation shall be continued as long as the recurrence of the hazard(s) is possible.

3. Testing the Atmosphere. Testing for flammability, oxygen deficiency, and toxicity must be performed either by or under the direction of a qualified person from EH&S or other designated personnel prior to entry. Until the space is determined to be safe for entry, all testing shall be performed from outside the space. If entry is required to complete the testing before safe entry is ascertained, the proper respirator and PPE shall be worn by the person performing the tests.

3.1. Start testing with remote probe at vent holes, if present, or on the downwind side of slightly opened door, cover, or panel. This will determine the presence of lighter than air combustibles.

3.2. Remove the covers, access panels, or doors and from outside the structure, test for combustibles and oxygen content from the bottom to the top. Test near conduits, pipes or cables. Check around all irregular surfaces in the space. The head is to be kept outside the plane of the entrance. Test at exit ports when space is mechanically ventilated.

3.3. If oxygen is sufficient and combustible atmosphere is below 10% of LEL, test for toxic materials.

4. Pre-entry Procedures and Considerations

4.1. Ventilation - Select the method and the equipment to ventilate a confined space prior to entry based upon the size of the opening and space, the gases to be exhausted, and the source of make-up air.

4.2. Isolation or the removal of space from service must be accomplished by one or all of the following methods to ensure no release of hazardous energy could render the space unsafe for occupancy.

4.2.1. Locking out electrical sources at disconnect switches remote from the equipment, and identifying lockout status with appropriate tags.

4.2.2. Blanking and bleeding pneumatic hydraulic lines.

4.2.3. Disconnecting the belt and chain drives and mechanical linkages on shaft-driven equipment where possible. Tags must be used to identify the disconnect status.

4.2.4. Securing the mechanical moving parts within confined spaces with latches, chains, shocks, blocks, or other devices, and locking out.

4.3. Respiratory Protection - Air purifying respirators are not to be used in confined spaces where there is insufficient oxygen to support life or airborne toxic chemical levels exceed PELs or cannot be filtered by air purifying respirators. Supplied air respirators are required in these cases. All personnel assigned to wear respiratory protection must maintain Respiratory Protection Qualification Status (i.e., training and medical qualifications). See REFERENCE 4.

4.4. Attendants and Rescue Teams

4.4.1. Whenever it is necessary to enter a confined space which has been determined to have a potentially hazardous atmosphere, a trained attendant shall be assigned to remain on the outside of the confined space, while maintaining contact with those on the inside. The person shall have no other duties than to serve as attendant, shall know how and who to contact in an emergency, and shall initiate contact with emergency response agencies in case of emergency. The attendant shall not enter the space in the event of an emergency.

4.4.2. Properly trained rescue teams from the City of Pittsburgh Fire Department shall be alerted to be available where the confined space has been found to have an atmosphere which is immediately dangerous to life or health (IDLH).

4.4.3. CMU currently has no trained rescue teams and all rescue operations shall be conducted from outside the confined space using lifelines or retrieval harnesses, or by the trained Fire Department rescue team. CMU employees are forbidden to enter a confined space to perform rescue operations.

5. Entry Procedures

5.1. Training

5.1.1. All personnel working in confined spaces must be thoroughly trained in safe entry procedures. They shall have an understanding of their equipment and of all hazards (potential and actual). Training will be conducted or coordinated by a trained representative from EH&S.

5.1.2. Records shall be maintained of the most recent training program conducted. The records shall include date of training, training content, the instructor, and the employees trained.

5.1.3. The qualified person performing pre-entry testing shall provide a brief reminder training of potential and actual hazards, and procedures to follow by entrants and attendants. This shall be done immediately prior to entry.

5.2. Entry Permit

5.2.1. All work in confined spaces shall be delayed until a proper entry permit is filled out by the job supervisor and approved by EH&S (confined space entry permit form is attached).

5.2.2. Permit is issued following assurance that all appropriate precautions (e.g., atmospheric testing, ventilation, isolation) have been taken by the qualified person. Using the permit, the qualified person shall assure that all preliminary work is completed prior to entry, including the notification of affected personnel.

5.2.3. Permit is limited by date and time of issue/expiration, and shall never exceed one work shift.

5.2.4. If any hot work is to be performed in the confined space, a hot work permit shall be obtained and its presence noted on the entry permit.

5.2.5. Entrants shall be required to wear a lifeline or retrieval line, which shall be continually manned by the attendant. If visual or verbal communication is not feasible, an alternate means of communication (e.g., walkie talkies) shall be established prior to entry.

5.2.6. The original permit shall be posted at the job site and the copy shall be forwarded to EH&S. When the job is completed the original shall be returned to EH&S, as well.

 

RESPONSIBILITIES:

1. Director of Operations and Utilities is responsible for:

1.1. Obtaining necessary equipment including respirators, PPE, and life lines/winches.

1.2. Coordinating appropriate training through EH&S.

2. Supervisors are responsible for ensuring that work is not allowed in any area which may fall under provisions of this directive or referenced standard until all entry procedure requirements are met.

3. The Loss Prevention Manager is responsible for maintaining records of training, and for arranging for or delivering required training.

4. The Director of EH&S is responsible for providing a qualified person as Loss Prevention Manager, and for developing a method for certification of designated employees as qualified persons.

 

 

REFERENCES:

1. Current edition of Occupational Safety and Health (OSHA) standards for confined space entry (29 CFR 1910.146)

2. FMS Directive No. 304 (Lockout/Tagout)

3. Current edition of Subpart Z to OSHA's safety and health standards (29 CFR 1910)

4. FMS Directive No. 307 (Respiratory Protection Program)

 

CANCELLATION(S): None

SIGNATURE:

 

 

Edward A. Guida, PE, CIH

Director, Environmental Health & Safety

ATTACHMENT:

CMU Confined Space Entry Permit