Work in confined space presents unusual and severe hazards. Common tasks, such as welding, use of solvents and adhesives, live electrical work, or painting can quickly become lethal in a confined space. This policy addresses working safely in confined spaces. It includes initial identification and risk assessment of confined spaces, entry procedure development and approval, self-help, and emergency rescue.
Many fatalities occur because victims do not fully understand the threat of airborne hazards they cannot see, smell or feel. Additional fatalities occur when untrained persons enter unknown atmospheres to rescue fallen co-workers. Layton City recognizes the inherent dangers associated with confined space. In order to help minimize this danger, the Public Works Department will initiate a Confined Spaces Permit program in accordance with OSHA regulation Permit-Required Confined Space Entry, 29CFR1910.146. Entry into an identified Confined Space without following a defined procedure could expose a worker to a serious atmospheric or physical hazard.
No employee will be permitted to enter any permit required confined space that has or has had the potential for hazards related to atmospheric conditions (toxic, flammable, or asphyxiation), engulfment configuration, or any other recognized serious hazard, until all requirements of this program have been met and it can be done safely.
Confined spaces may be entered without the need for a written permit or safety attendant provided the space is determined NOT to be a permit required confined space, or, the space can be maintained in a safe condition for entry by mechanical ventilation alone.
All spaces shall be considered permit-required confined space until the pre-entry procedures demonstrate otherwise. Any employee required or permitted to pre-check or enter a confined space shall have successfully completed at least the training as required in this program.
Unsafe Acts and Omissions
- Failure to test the atmosphere in a confined space before entry.
- Failure to continuously monitor the atmosphere in a permit-required confined space.
- Failure to lock out hazardous fluids, mechanical equipment, and electrical power to equipment inside the confined space. It is not usually necessary to lock out sanitary or storm sewage in manholes when routine maintenance is being performed, however it may become necessary at the discretion of the Entry Supervisor depending on the circumstances.
- Failure to follow approved entry procedures.
- Failure to pre-plan rescue and retrieval efforts.
- Failure to use adequate respirators when needed.
Confined Space: Defined as an area which:
- Has adequate size and configuration for employee entry; and,
- Has limited or restricted means of entry or exit; and,
- Is not designed for continuous human occupancy.
These may include but are not limited to: vaults, water meter boxes, sanitary sewer manholes, storm sewer manholes, land drain manholes, sewer lift stations, storm sewer lift stations, water regulator boxes, water reservoirs, hot water heating and holding tanks, building waste water pumping tanks, steel water tanks, pits, vats, and ventilation and exhaust ducts.
Permit-Required Confined Space (PRCS): A confined space that has one or more of the following characteristics:
- Potential to contain a hazardous atmosphere (toxic, flammable, low oxygen, or any other recognized hazard).
- Material that has potential for engulfing an entrant.
- An internal configuration that could trap or asphyxiate an entrant such as inwardly converging walls or a floor that slopes downward and tapers to a smaller cross section.
- Any other recognized serious safety or health hazard.
All confined spaces shall be considered "permit-required" until the pre-entry procedures demonstrate otherwise.
Non-Permit-Required Confined Space (NPRCS): A space that meets the definition of a confined space but, which after evaluation, does not contain or have the potential to contain any hazard capable of causing death or serious physical harm.
Confined Space Entry Permit: The permit required by this policy to enter a permit-required confined space. It must be completed and signed prior to any entry into the confined space.
Entry: Confined space entry begins when any part of the employee's body breaks the plane of any opening of the confined space and continues until the employee exits the confined space.
Gas Detection: The testing and monitoring of the atmosphere prior to and during the time a Confined Space is occupied. Safe atmospheric conditions, as explained in this document, must be met in order for work to begin or continue within a confined space.
IDLH: Immediately Dangerous to Life or Health. Any condition that would pose an immediate or delayed threat to life, cause irreversible health effects, or interfere with an individual's ability to escape unaided from a permit space.
Isolation: A process of interrupting and/or disconnecting pipes, lines, and energy sources from the confined space. The space is removed from service, and complete protection from release of energy or substances into the space is provided.
Lower Explosive Limit/Lower Flammability Limit (LEL/LFL): The lowest percentage of a substance in the air that leads to fire or explosion.
- Hazardous Atmosphere
A hazardous atmosphere means an atmosphere that may expose employees to the risk of death, incapacitation, impairment of ability to self rescue (that is to escape unaided from a permit space), injury, or acute illness from one or more of the following causes:
- Presence of Toxic Gases: Equal to or greater than 10 ppm hydrogen sulfide, or 35 ppm carbon monoxide. If the presence of other toxic contaminants is suspected, specific monitoring programs will be developed.
- Oxygen Deficient Atmosphere: When the oxygen content is below 19.5 percent, it is too low to provide enough oxygen for a working person.
- Oxygen Enriched Atmosphere: Oxygen content above 23.5 percent causes combustible substances to burn more vigorously than in normal atmosphere. For instance, in an oxygen enriched atmosphere, a person's hair, clothing, and even skin will burn rapidly if ignited.
- Flammable Explosive Atmosphere: Flammable gases, vapors, or dusts are dangerous in concentrations above 10 percent of the lower flammable explosive limit.
- Toxic Atmosphere: Dangerous air contamination caused by toxic substance is the concentration immediately dangerous to life and health. This definition does not preclude the requirement to control the concentrations to below the permissible exposure limit for persons working without respiratory protection.
- Airborne Combustible Dust: At a concentration that exceeds its lower flammable limit (LFL), dust obscures vision at a distance of 5 feet or less.
- Immediately Dangerous to Life or Health (IDLH): Any other atmospheric condition that is considered immediately dangerous to life or health is considered a hazardous atmosphere.
Grains, dusts, powders, liquids, or slurries pose serious hazards to persons entering confined spaces. Persons engulfed in sawdust or grain cannot breathe and become asphyxiated in a very short time. Lifelines attached to an approved harness, mechanical lifting aids, and an alert safety attendant are needed to prevent deaths in this work environment.
- Electrical/Mechanical Hazards
Electrical power that could shock workers or move mechanical equipment must be locked or tagged out prior to entry into a confined space. Machinery that could move under the influence of gravity, spring loads, or other forces must be mechanically blocked or immobilized before work is started in confined space.
- Fall Hazards
Fall hazards are serious because it is difficult to retrieve an injured person from a confined space. Free-fall distance must be limited to 2 feet (0.61 meters) before the fall is arrested.
Confined Spaces Program Coordinator: The Public Works Director or his/her designee is responsible to oversee the Confined Spaces within Layton City. Specific duties include:
- Reviews and updates the confined space policy annually.
- Identifies all confined spaces within Layton City and completes a written inventory of all city owned confined spaces. Reviews and updates this list annually.
- Completes a written list of authorized tools and personal protective equipment for use in confined spaces.
- Ensures that the confined space policy, inventory, tool list and personal protective equipment list are on file with the Public Works Director, Assistant City Manager and Fire Chief.
- Designates entry supervisors.
- Trains all public works personnel involved with confined spaces at least annually. This includes entry supervisors, safety attendants and entrants. Keeps records of training.
- Establishes and coordinates emergency response procedures and training with Fire and Police Departments.
- Retains all canceled permits for one year for audit purposes.
Entry Supervisor: Entry Supervisors are designated by the Confined Space Program Coordinator and are usually the supervising employee in a work crew. All Entry Supervisors must be trained as indicated herein. An Entry Supervisor may be a supervisor, foreman, or lead worker. The Entry Supervisor has overall responsibility for the safety of all persons involved with entry operations into confined spaces under his or her control. This includes authorized entrants and safety attendants. In the event emergency rescue personnel are summoned, the Entry Supervisor shall cooperate fully with rescue services and allow the commanding officer to take charge of the rescue. Where a Confined Space 10 Minute Entry Permit is issued, the Entry Supervisor may also function as a Safety Attendant. Specific duties include:
- Authorizes entry into a confined space by completing and signing the appropriate Confined Space Entry Permit, approves procedures for entry, coordinates the efforts of all other key personnel.
- Ensures that all safety requirements identified in the safe entry procedure contained herein are met, that all atmospheric testing devices are properly calibrated and maintained according to manufacturers standards, that all required equipment is readily available, and that all persons involved in the entry are fully aware of their roles and responsibilities.
- Cancels the permit when the entry is complete and submits the permit to program coordinator who keeps the canceled permit for one year for audit purposes.
Safety Attendant: A trained employee designated by the Entry Supervisor who assists and monitors an Entrant from outside the confined space. The safety attendant must not be exposed to the same hazard as the entrants and must be trained, equipped, and physically able to render immediate and effective aid. Specific duties include:
- Remains outside the confined space but continually monitors the entrant(s).
- Keeps track of the number of people entering and leaving the confined space to avoid exposing rescue personnel to grave risks by searching for a person who has previously left the confined space.
- Sets up and maintains preventative measures or equipment to keep persons from falling into a confined space or obtaining unauthorized entry.
- Immediately notifies the entry supervisor if conditions change such as to alter the entry permit or if exterior conditions change so as to endanger the entrant(s) (such as weather) and advises the entrants to leave the confined space.
- Possesses a radio or some other equally effective means of notifying emergency personnel at all times. In the event of an emergency situation, immediately notifies Police Dispatch.
Authorized Entrant: An employee who is trained in working in and around confined spaces as described in this document.
Rescue Services: Layton City Fire Department. Call 911 for rescue.
* * * Procedures for Safe Entry into a Confined Space * * *
A written copy of this document shall be on the work site for the duration of the job.
The Entry Supervisor completes and approves the appropriate Confined Space Entry Permit prior to allowing entrance into a confined space. The Entry Supervisor does NOT allow entry into the confined space until any deficiencies found are corrected. This permit shall be kept at the job site for the duration of the job. The following is a list of procedures, precautions, and steps to be taken by the Entry Supervisor in reviewing and approving the Confined Space Entry Permit:
- The surrounding area must be surveyed to determine it to be free of hazards such as drifting vapors from tanks, piping or sewers; the Safety Attendant (or Entry Supervisor in the case of a 10 minute permit being issued) will stand-by until work is complete. The surrounding area shall be continuously surveyed by the Safety Attendant (or Entry Supervisor in the case of a 10 minute permit being issued) to avoid hazards.
- From the Supervisor's knowledge of industrial or other discharges, he/she determines whether the area is likely to remain free of air contaminants while occupied;
- The Entry Supervisor must be certified in the operation of the gas monitor to be used and see that a gas monitor functional test has been performed this shift on the gas monitor to be used. It is the responsibility of the Entry Supervisor to ensure that all atmospheric testing devices are properly calibrated before each use and maintained in accordance with the manufacturer's standards.
- It is determined by testing whether oxygen deficiency or enrichment and/or dangerous air contamination exist.
When testing atmospheric hazards, (1) test first for oxygen deficiency which should be no less than 19.5% by volume, but no greater than 23.5% by volume; (2) next, test for combustible gases and vapors - flammable vapor must be less than 10% of LEL/LFL; the oxygen content must be near 21% for results to be meaningful; (3) third, concentrations of toxic materials are to be less than TVL/PEL. Tests for toxic contaminants must be specific for the target toxin, therefore it is important to know the history of the confined space so proper tests can be performed. Part of hazard assessment is to identify all possible contaminants that could be in the confined space.
Oxygen content is measured before flammability is tested because rich mixtures of flammable gasses or vapors give erroneous measurement results. For example, a mixture of 90% methane and 10% air will test non-flammable because there is not enough oxygen to support the combustion process in the flammability meters. This mixture will not support life and will soon become explosive if ventilation is provided to the space. Before entry, spaces must be ventilated until both oxygen content and flammability are acceptable.
A direct read type gas monitor should be used. Testing devices should have routine certification maintenance performed to ensure proper functioning. Testing shall be performed by an Entry Supervisor who has successfully completed the gas detector training for the monitor he will use.
The atmosphere shall be continually monitored while the space is occupied. Continuous testing of the atmosphere in the immediate vicinity of the workers within the space shall be accomplished, or the confined space must be continuously vented while occupied. When venting the work area with a blower, allow ample time for air exchange. Exhaust shall be directed away from work areas.
The minimum parameters to be monitored are oxygen deficiency, lower flammable limit, carbon monoxide and hydrogen sulfide concentration. A written record of the pre-entry test results shall be made on the Entry Permit and kept at the work site for the duration of the job. Upon approval of the appropriate Confined Space Entry Permit, the Entry Supervisor certifies in writing, based on the results of the pre-entry testing, that all hazards have been eliminated. Affected employees shall be able to review test results. The most hazardous conditions shall govern when work is being performed in two adjoining, connecting spaces.
The workers shall immediately leave the permit space when any of the gas monitor alarm set points are reached as defined. Workers will not return to the area until an Entry Supervisor who has completed the gas detector training has used a certified gas detector to evaluate the situation and has determined it is safe to enter.
Whenever inert gases such as nitrogen are used to create an inert atmosphere to prevent ignition of flammable gases or vapors, no ignition source is permitted unless the atmosphere is kept below 10% of LEL/LFL. Ventilation is required before any entry to ensure the atmosphere is acceptable before an entry permit is issued. Testing the oxygen content must be done every 20 minutes, and written records of test results must be kept at the job site for the duration of the job.
If the confined space has contained hazardous substances, it is important for the confined space to be emptied and thoroughly flushed or purged before entry. In addition, where air sampling indicates a need, supplemental mechanical ventilation must be provided.
- All sources of hazards must be isolated from the confined space by blanking pipes and locking out and blocking electrical and mechanical hazards. This does not apply to sewer laterals or main line unless experience or knowledge of industrial use indicates there is a reasonable potential for contamination or air or engulfment into an occupied sewer.
All pumps and lines which may cause contaminants to flow into the space shall be disconnected, blinded, and locked out, or effectively isolated by other means to prevent development of dangerous air contamination or engulfment. Not all laterals to sewers or storm drains require blocking, however, where experience or knowledge of industrial use indicates there is a reasonable potential for contamination or air or engulfment into an occupied sewer, then all affected laterals shall be blocked. If blocking and/or isolation requires entry into the space, the provisions for entry into a permit-required confined space must be implemented. Lock and tag devices are required to withstand a 50-pound pull without failure. Devices used to block or restrain stored mechanical energy devices must be engineered for safety. Safety barriers separate workers from hazards that cannot be reasonably eliminated by other engineering controls. Required barriers must be identified by the Entry Supervisor.
- Rescue, emergency and first aid equipment shall be available outside the confined space. This includes a tripod or another suitable anchorage, hoisting device, harnesses, wristlets, ropes, blankets, first-aid kit, Stokes stretcher, and any other equipment that may be needed;
- Emergency and rescue services must be notified that a confined space entry is about to be made, except in the case of a confined space entry approved with a Ten (10) Minute Entry Permit.
- A work crew safety briefing must be provided to employees prior to working in or around confined spaces. This briefing covers all protective measures, emergency response plans and preparations, and each person's role and responsibilities at the start of each entry or shift change. The Entry Supervisor must perform a final inspection to ensure that all items required by the permit are in place before entry is made.
- Ground fault circuit interrupters (GFCI) must be used for all portable electrical tools and equipment in confined spaces because most workers will be in contact with grounded surroundings.
- The Entry Supervisor ensures that necessary Personal Protective Equipment (PPE) is available and used by employees working in and around confined spaces. Types of PPE to be considered include respirators (air purifying or air supplied), head/eye protection, hearing protection, fall protection, hand/foot protection, protective clothing, continuous personal monitor, portable shower/eyewash and rescue equipment. Rescue equipment is not required for meter reads and inspections authorized with a Ten Minute Entry Permit.
Harnesses and retrieval ropes must be worn by entrants and attached to a hoisting device unless they would increase hazards to the entrants or impede their rescue. All harnesses shall be of the type that suspends a person upright. Hoising devices with a minimum mechanical advantage of 4 to 1 must be provided for lifting workers out of the confined space.
Fall-protection equipment for confined spaces should be the chest-waist harness type to minimize injuries from uncontrolled movements when it arrests a worker's fall. This type of harness also permits easier retrieval from a confined space than a waist belt. Adjustable lanyards should be used to limit free fall to two feet before arrest.
Employees working in confined spaces that have last contained substances corrosive to the skin, or substances that can be absorbed by the skin, are required to wear appropriate protective clothing and equipment, unless the space has been decontaminated prior to entry.
An appropriate NIOSH approved respirator should be worn by Entrant(s) when needed. It is important to note that air purifying respirators cannot be used in an oxygen deficient atmosphere.
- If hot work is to be performed in the confined space, related hazards must be addressed and eliminated. Hot work involves the use of open flame torches, portable electric heaters, arc or flame welders, or other flame or spark producing devices.
Under no circumstances should an ignition source be introduced into a confined space until test measures have ensured that no flammable or explosive atmosphere exists or will occur during entry operations. Whenever combustion devices are used in a confined space, steps must be taken to ensure that combustion air is supplied, and combustion products are exhausted from the confined space. Hot work inside a confined space requires that an approved fire extinguisher and a person trained in its use be stationed in the confined space or in a suitable vantage point where he or she could effectively suppress any fire that might result from the work.
- Continuous verbal communications shall be maintained between the Entrant(s) inside the confined space and the Safety Attendant outside.
An effective means of communications between employees inside a confined space and the safety attendant must be used whenever conditions in the space require use of respirators or whenever entrants are out of sight of the safety attendant at any time. It is important that the communication system be tested before each use, and frequently thereafter, to ensure it is working properly.
- The number of Entrants should be kept to a minimum. To the extent practicable, provisions should be made to expedite entry and exit from a confined space.
- Confined spaces with top and side openings should be entered from the side whenever practicable.
- If circumstances dictate an interruption of the work, the permit space must be re-evaluated and a new permit must be completed.
- It shall be the responsibility of the Safety Attendant and the Entry Supervisor to notify responding emergency personnel of all conditions in and around the confined space if an emergency situation arises.
Emergency Rescue Procedures
- Call 911 emergency services.
- If possible, retrieve the victim with the tripod, lifeline and winch system and remove to a safe place.
- DO NOT ENTER or attempt to rescue a victim by entering a confined space, UNLESS:
- A trained Safety Attendant is standing by; AND
- You are trained and understand rescue procedures; AND
- You have the necessary Personal Protective Equipment, including self-contained breathing apparatus, and you have necessary rescue equipment.
Issuance of Required Permits
Entry into a Confined Space requires the issuance of one of two permits:
- A Confined Space Ten (10) Minute Permit must be issued by an Entry Supervisor whenever an authorized employee enters a Confined Space for ten (10) minutes or less to do a meter reading or quick inspection. Where 10 minute permits are issued, the Entry Supervisor may also function as the Safety Attendant. If the employee finds reasons to perform work beyond those of the initial entry or needs arise to remain longer than ten (10) minutes, the employee must exit the confined space and a full Confined Space Entry Permit must be issued, this requires the presence of an Entry Supervisor and a Safety Attendant. After completing each job, all permits must be submitted to the Program Coordinator. A Ten (10) Minute Permit shall not be used for any other purpose besides meter reading and inspections. Any additional work requires a full Confined Space Entry Permit.
- A Confined Space Entry Permit must be filled out and signed before any confined space work beyond a 10 minute meter read or inspection may begin. This permit must be signed by an Entry Supervisor. The permit must be displayed at the work site while the confined space is occupied. Each confined space permit is valid up to six (6) hours. If a job requires more than six (6) hours a new permit must be issued before work can proceed. If a confined space fails the atmospheric test a new permit must be filled out and the failed permit retained and submitted to the Program Coordinator. All permits are submitted to the Program Coordinator upon completion of assigned work.
Identification of Confined Spaces in the City
All confined spaces will be marked with an appropriate sign and/or all key employees will otherwise be advised of the existence of confined spaces, at least annually by the Program Coordinator, and will be reminded of who has access to those confined spaces. (i.e. sewer and water system) Confined spaces such as sewer manholes and water meter boxes need not be individually marked, but rather may be identified on a map.
Training of Employees
Training must emphasize preventing hazardous conditions during confined space entries and preparing for emergency response, both self-help and emergency rescue. The following training is required for all key employees (Entry Supervisors, Safety Attendants, Entrants, and Rescue Services):
Confined Space Entry Training
- Confined Space Entry Safety
- Personnel Policy 4301 (this policy)
- American Red Cross Cardio-Pulmonary Resuscitation (CPR) Course or equivalent;
- American Red Cross Advanced First Aid Course or equivalent.
- Training must be conducted annually and documented; employer certification of training must include the employee's name, signature or initials of trainer and dates of training; refresher training should be provided whenever an evaluation determines inadequacies in employee's knowledge.
- Training should emphasize that serious emergencies can develop quickly in confined spaces, and that trained personnel, pre-planned responses and pre-placed rescue equipment are important for immediate and effective action when emergencies occur;
- Training must include recognition of possible hazards in confined spaces and appropriate countermeasures. Training shall include lockout/tagout procedures to permit persons to work safely on de-energized equipment, without fear that the equipment will be re-energized while they are at work. Included with lockout/tagout, employees shall be instructed that lines and pipes that could carry flammable, toxic, or injurious substances into the confined space must be blocked by positive means, such as valves, to ensure that the atmosphere in the confined space is not contaminated or rendered inert. It is important that employees know how to recognize in themselves and others the early symptoms of oxygen deprivation or intoxication such as dizziness, slurred speech, drowsiness, weakness, clumsiness, behavioral changes and loss of balance. Training should emphasize the importance of immediate evacuation at the first sign that the atmosphere is not safe. Training in methods and equipment used in self-help is important.
- Training shall include the proper operation of safety and personal protective equipment, rescue equipment and communications equipment. These employees shall practice making a confined space rescue at least once every year by means of simulated rescue operations in which they remove actual persons from actual spaces or from representative confined spaces.
Red Cross CPR and First Aid Training
- Training for Entry Supervisors shall include certification in the proper operation, calibration and maintenance of atmospheric testing devices according to manufacturers standards.
Support courses such as Red Cross CPR and First Aid must be conducted in accordance with Red Cross certification requirements to keep certifications current.
Contract Work - Obligations
Layton City Obligations: Any contractors performing work that involves permit required confined space entry for Layton City will be informed of any job sites that contain such confined spaces and that entry is allowed only through compliance with a permit space program.
Contractor's Obligations: Contractors shall comply with the permit space requirements that apply to all employees as required by the Industrial Commission of Utah.