CONFINED SPACE ENTRY PROGRAM
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CONFINED SPACE ENTRY PROGRAM The purpose of this program is to inform interested persons, including employees, that Northern Clearing, Inc. is complying with the OSHA Confined Space Standard, Title 29 Code of Federal Regulations 1910.146. We have determined that certain field locations may need written procedures for the evaluation of confined spaces, and where permitrequired spaces are identified, we have developed and implemented a confined space awareness program. This program applies to all work operations at Northern Clearing, Inc. properties or specific field sites where employees must work near a permit-required confined space as part of their job duties. At Northern Clearing, Inc., it is our policy that we DO NOT ENTER permit-required confined spaces. The Health and Safety Director has overall responsibility for coordinating safety and health programs in this company, and is the person having overall responsibility for the Confined Space Program. The Health and Safety Director will review and update the program, as necessary. Copies of the written program may be obtained from the Health and Safety Director in the Corporate Office. Under this program, we rely on the Host client to identify permitrequired spaces at their Field Locations, and provide awareness training for our employees according to their responsibilities. Employees receive instructions for safe entry into the specific type of confined spaces, including testing and monitoring, appropriate personal protective equipment, rescue procedures, and attendant responsibilities. This program is designed to ensure that safe work practices are utilized during all activities regarding the permit space to prevent personal injuries and illnesses that could occur. If, after reading this program, you find that improvements can be made, please contact the Health and Safety Director. We encourage all suggestions because we are committed to creating a safe workplace for all our employees and a safe and effective permit-required confined space entry program is an important component of our overall safety plan. We strive for clear understanding, safe work practices, and involvement in the program from every level of the company. HAZARD EVALUATION FOR PERMIT SPACES To determine if there are permit-required confined spaces at the Host Client’s location, the owner of the location will conduct a hazard evaluation of the workplace. This evaluation will provide the information necessary to identify the existence and location of permit-required confined spaces in the workplace that must be covered by the Permit Required Confined Space Entry Program. This written hazard evaluation is kept in the Host Employer’s Offices or Control Rooms. If questions arise regarding the classification or definition of a “confined space” we will rely on OSHA 29 CFR 1910.146 Appendix A for assistance with these decisions.
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For confined spaces, typical signs or labels should read as follows: DANGER! PERMIT REQUIRED CONFINED SPACE DO NOT ENTER
PREVENTING UNAUTHORIZED ENTRY To provide a safe work environment and to prevent exposed employees from accidentally entering a permit space, we rely on the Host employer to have implemented the following procedures to inform all employees of the existence, location, and danger posed by permit spaces at their locations. To inform employees of the existence of a permit space, Host employers will use training, barrier tape, and labels, etc. To ensure that unauthorized employees do not enter and work in permit spaces, we inform our employees of the hazards at the start of work and rely on the Host to post warning labels/signs. In addition, a site-specific Attendant is available to insure this unauthorized entry does not take place. SAFE PERMIT SPACE ENTRY PROCEDURES The Host Employer will designate an Entry Supervisor responsible for authorizing entry and issuing entry permits for work in the permit spaces. The file of permits and related documents are kept in the Host’s Offices. The procedures that the Host is to follow for preparing, issuing, and canceling entry permits include the following elements listed in the Appendix. In addition, protection of the entrants form external hazards is also critical. Using barriers, barricades, and use of outside personnel control pedestrian hazards, vehicles, and other hazards. We will follow their instructions. PRE-ENTRY EVALUATION To ensure the safety and health of employees, before allowing authorized workers to enter a permit space, the Host or entry Company will evaluate conditions in that space to determine if the conditions are safe for entry. The procedures followed to evaluate each permit space before entry includes review of the hazards, review of the testing data, determination of rescue procedures, and establishment of the methods for communication and other specific data. Examples of these can be found in the Appendix. Based on the 1999 final rule amendment, the outside rescue service, if used, must be given the opportunity to examine the entry site prior to entry, to practice rescues, and have the opportunity to decline this assignment. This is required PRIOR to any entry. In addition, for IDLH entries, any rescue service selected must be on-site at all times during the entry. EQUIPMENT To ensure the safety and health of our employees, Northern Clearing, Inc. provides appropriate equipment to all employees who work near permit spaces. The equipment we provide to these employees will be determined on a case-by-case basis for the specific project, and based on Host employer requirements. We maintain all equipment in excellent working condition, re-train in the correct usage of this equipment, and ensure that all equipment, including that used for personal protection, is used properly. We follow the procedures to ensure our employees are using the appropriate equipment. 3
DUTIES: AUTHORIZED ENTRANTS Those persons who have completed the training and are authorized to enter permit spaces (authorized entrants) are assigned specific duties and responsibilities, which they must perform when they work in the permit space. Their duties and responsibilities are based on the specific reasons necessary for entry into the confined space, such as repair, cleaning, painting, or other matters for the specific site. This is included in the individual permit. They or their authorized representatives are given the opportunity to review all monitoring data and sign the permit prior to entry. In addition, they can request additional monitoring if they believe conditions have changed. The elements covered in the training program for the duties of authorized entrants are mentioned in this document. DUTIES: ATTENDANTS Those persons who have completed the training and have been designated as permit space attendants are assigned specific duties and responsibilities that they must perform in permit space job duties. They must remain on duty outside for the duration of the entry, or if relieved by another qualified attendant. Their duties and responsibilities include communication, observation, and direction of outside assistance, prevention of unauthorized entry and other items that may become necessary for the entry/exit. Typically, they will be assigned only one (1) permitrequired space to monitor. The elements covered in the training program for the duties of authorized attendants are mentioned in this document. DUTIES: ENTRY SUPERVISORS Those persons who have completed the training and have been designated as permit space entry supervisors are assigned specific duties and responsibilities that they must perform in permit space job duties. Their duties and responsibilities will be determined prior to entry and specified for each scenario; in general; however, their duties are included in the training program. TRAINING PROGRAM Every employee at Northern Clearing, Inc. who faces the risk of confined space is provided with awareness training so that each employee acquires the understanding, knowledge and skills necessary for the safe performance of the duties assigned to him or her. The Health and Safety Director, Host Employer, or Wisconsin Indianhead Technical College conducts our confined space awareness training. All training related materials, documents, and signed certificates are kept in the Corporate Office. All employees that are required to enter a confined space receive training for entry into these spaces. The criteria used to determine which employees must receive permitrequired confined space training are based on the specific work necessary and the specific craft of the employee. Specifically, the training received by job duty assignment includes:
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AUTHORIZED ENTRANTS – The opportunity to observe monitoring and review air monitoring results prior to entry, and sign off on the permit The hazards faced during entry and those that may arise during the entry work elements Proper use of the required equipment, including continuous ventilation and monitoring of the air The ability to request additional monitoring at any time they believe changes has occurred Methods of communications with the Attendant and other entrants, especially for evacuation Alerting the Attendant when: Entrant recognizes any warning signs or symptoms of exposure, or whenever Entrant detects a prohibited condition Exiting from the permit space as quickly as possible whenever: The Attendant or Supervisor issues an evacuation order The Entrant recognizes any warning sign or symptom of exposure An evacuation alarm is activated
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ATTENDANTS – The hazards faced during entry Awareness of possible behavioral effects of hazard exposure Maintenance of a continuous count of Entrants Remaining outside the permit space during the entry until relieved by another Attendant Communication with Entrants as necessary to monitor their status and to alert them to the possibility of evacuation Monitors activities inside and outside the space to determine if it is safe and orders evacuations immediately under any of the following conditions detected by the Attendant: a) Any prohibited condition b) Behavioral effects of hazard exposure in an Entrant c) A situation outside the space that could endanger the Entrants d) Performance of all required duties in a safe and effective manner Summon rescue and other emergency services as soon as it is determined the Entrants may need assistance to escape Take actions when unauthorized persons approach or enter a permit space while Entry is underway Perform non-entry rescues as specified by the employer’s rescue procedure Performs no other duties that might interfere with the primary duty to monitor and protect the authorized entrants Is responsible for multiple entries simultaneously.
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ENTRY SUPERVISORS – Know and understand the hazards that may be faced during the entry Verify that all tests specified on the permit have been conducted and that all procedures and equipment specified by the permit, including ventilation
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and monitoring, are in place when reviewing and before endorsing the permit and allowing entry to begin Terminate entry and cancel the permit Verify rescue services are available and that there are operable means to summons them. For IDLH conditions, these services must be on standby at the location Removes unauthorized individuals who enter or attempt to enter the permit space during operations Determines that entry operations remain consistent with entry permit terms and that acceptable conditions are maintained •
RESCUE AND EMERGENCY SERVICES The following requirements apply to employers who have employees enter permit spaces to perform rescue services: - Rescue personnel must be provided with and trained to use all equipment necessary, including PPE, for making rescue - Each member of the rescue service will be trained to perform assigned rescue duties. They will also receive the training required of Authorized Entrants under this plan - Each member of the rescue service will practice making rescues at least once every twelve (12) months - For IDLH entries, the rescue team must be on-site at all times
When a Host employer arranges to have persons other than their employees perform rescues, the Host employer will: - Inform the rescue service of the hazards they may face when called on to perform a rescue and - Provide the rescue service with access to all permit spaces from which rescue may be necessary to allow them to develop rescue plans, practice rescues, and decline to provide services as appropriate To facilitate non-entry rescues, retrieval systems or other methods will be used whenever an Authorized Entrant enters a permit space, unless this would increase risk or would no assist the rescue. The retrieval systems must meet the following: 1. Each Authorized Entrant will use a full body harness with retrieval line. Wristlets may be used in lieu of a harness if the employer can demonstrate that they are a safer, more effective alternative. 2. The other end of the retrieval line will be attached to a mechanical device or fixed point outside the permit space so that a rescue can begin as soon as it becomes necessary. If an injured Entrant is exposed to a substance for which a MSDS sheet or other similar written information is required, that sheet or written information will be made available to the medical facility treating the exposure. When we conduct the training, we use classroom and tail gate topics initially. The Host or Entrant Company will re-evaluate the conditions, the safety equipment, and the training as necessary. If they have reason to believe that an employee has deviated from
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a previously trained upon procedure or that their knowledge seems inadequate, they can verbally instruct the employee, retrain the employee, reprimand the employee, or even terminate the employee. This is also applicable to Northern Clearing, Inc. employees that do not follow our procedures or those of the Host facility client. Upon successful completion of Wisconsin Indianhead Technical College training, each participant receives a certificate which they sign verifying that they understand the material presented, and that they will follow all Company policies and procedures regarding permit space entry. RESCUE AND EMERGENCY SERVICES Northern Clearing, Inc. does not enter confined spaces, and therefore we do not need to worry about whom or what types of rescue services are available. This responsibility is left to the Host and the Entry Company to determine. MULTIPLE EMPLOYER ENTRY PROCEDURES We do not serve as outside contractors to knowingly perform work in permit-required confined spaces. If other contractors are present, we will share appropriate information with them. ROUTINE PERMIT REVIEWS Entry permits are reviewed by the entry Supervisor during the actual entry for the possibility of revision, should additional employee protection become necessary. Examples of items that will be looked at include any unauthorized entry into the confined space, a hazard that is not covered by the permit, if an injury or near miss occurs, or if an employee voices any complaint. POST-OPERATIONS PROCEDURES Upon completion of work in a permit space, Entrant companies and/or Hosts follow the procedures to close off the space and cancel the permit specified in Appendix A, or something similar to this Appendix.
ANNUAL PERMIT REVIEW PROCEDURES To ensure that all employees participating in entry operations are protected form permit space hazards, Northern Clearing, Inc. reviews the Confined Space Entry Program on a regular basis. Host employers use the retained canceled permits from the past 12 months within one year after each entry and revise the program as necessary. If no entry is performed during a 12-month period, no review will be performed. ENFORCEMENT Constant awareness of and respect for permit-required confined space entry hazards, and compliance with all safety rules are considered conditions of employment. Supervisors and individuals in management reserve the right to issue disciplinary warnings to employees, up to and including termination, for failure to follow the guidelines of this awareness program.
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APPENDIX A
SAMPLE – DETAILED PERMIT INFORMATION
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ANNUAL REVIEW OF THE PRCS PROGRAM EXAMPLE Date of this Review:_______________
Date of Last Review:______________
Name of Evaluator:_____________________
Title:___________________________
A. STATISTICAL EVALUATION ____Total number of permit entries since last review ____Total number of permits noting problems with the entry (if this is not 0, complete Section B) ____Number of personal interviews with Entry Supervisors ____Number of personal interviews with Attendants ____Number of personal interviews with Entrants ____Number of person reporting problems
B. PROBLEMS ENCOUNTERED (fill in all information about problems encountered during PRCS Entry; add to Section D). Were any problems encountered not corrected? ___ Yes Were any of the problems encountered dangerous to life or health? ___ Yes Were there any injuries reported? ___ Yes Were these injuries the result of a problem? ___ Yes If any of the answers above were yes, then some action must be listed below in section C.
___No ___No ___No ___No
C. SUGGESTED ACTIONS FOR PRCS PROGRAM Suggested Action
Assigned to:
Date Complete:
D. MANAGEMENT REVIEWS Evaluator:_____________________________________ Safety Director:_________________________________ Head of Organization:____________________________
Date:__________________ Date:__________________ Date:__________________
On this form fill in the information requested for any permit that has had any type of problem. Permit #:_______________ Permit Date:_______________ Problems Encountered:__________________________ Corrective Action:_________________________
_________________________________________ ____________________________________ _________________________________________ ____________________________________ _________________________________________ ____________________________________ Permit #:_______________ Permit Date:________________ Problems Encountered:_________________________ Corrective Action:_______________________
__________________________________________ ___________________________________ __________________________________________ ___________________________________ __________________________________________ ___________________________________ Permit #:_______________ Permit Date:________________ Problems Encountered:____________________________ Corrective Action:_______________________ _______________________________________________ _____________________________________ _______________________________________________ _____________________________________
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SAMPLE CONFINED SPACE CHECKLIST –
PRE-ENTRY (Per Section 1910.146 Appendix C (b)) Date & Time Issued:______________________ Date & Time Expires:__________________________ Project:_________________________________ Equipment to be worked on:_____________________ Project Supervisor:________________________ Work to be performed:_________________________
PRE-ENTRY (See Safety Procedures) 1. Atmospheric Checks: Time:_________________ Explosive:_____________
Oxygen:___________% Toxic:___________PPM
2. Source Isolation (no Entry): Pumps or lines blinded Pumps or lines disconnected or blocked
N/A ( ) ( )
Yes ( ) ( )
No ( ) ( )
3. Ventilation Modification: Mechanical Natural Ventilation only
( (
( (
( (
) )
) )
) )
4. Atmospheric check after isolation and ventilation Time:________________ Oxygen:____________% (Greater than 19.5%) Explosive_____________ Toxic:____________PPM (Less than 10PPM H2S) If conditions are in compliance with the above requirements, and there is no reason to believe conditions may change adversely, then proceed to the permit space pre-entry checklist. Complete and post with this permit. If conditions are not in compliance with the above requirements, or there is reason to believe that conditions may change adversely, proceed to the entry checklist portion of this permit.
ENTRY (See Safety Procedures) 1. Entry, standby, and backup persons: Successfully completed required training? Is the training current: 3. Equipment: Direct-reading gas monitor-tested Safety harnesses and lifelines for entry And standby persons Hoisting equipment Powered communications SCBAs for entry and standby persons Protective clothing All electric equipment listed Class1, Division 1, Group D and non-sparking tools
N/A ( ) ( )
Yes ( ) ( )
No ( ) ( )
( (
) )
( (
) )
( (
) )
( ( ( (
) ) ) )
( ( ( (
) ) ) )
( ( ( (
) ) ) )
(
)
(
)
(
)
3. Rescue Procedures:____________________________________________________________________________ ______________________________________________________________________________________ ______________________________________________________________________________________ We have reviewed the work authorized by this permit, and the information contained herein. Written instructions and safety procedures have been received and are understood. Entry cannot be approved if any
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parentheses are marked in the “No” column. This permit is not valid unless all appropriate items are completed. Permit and checklist Prepared by: (Supervisor)_____________________________________________ Approved by: (Unit Supervisor)__________________________________________________________ Reviewed by: (Confined Space Operations Personnel)________________________________________ ______________________________________________________________________________________
This permit is to be kept at the jobsite. Return job site copy to Safety Office following job completion.
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SAMPLE CONFINED SPACE CHECKLIST –
PRE-ENTRY Per Section 1910.146 Appendix C (b) Requirements: All confined spaces shall be considered permit-required spaces until the pre-entry procedures demonstrate otherwise. This permit must be completed before approval can be given to enter a permit-required confined space. This permit shall be kept at the job site for the duration of the job. If circumstances cause an interruption in the work or a change in the alarm conditions for which entry was approved, a new permit must be completed. Purpose: To assure workers that the space is free from hazardous or flammable gases, has sufficient oxygen, and that hazards have been assessed. Procedure: A confined space is either entered through an opening other than a door [such as a manhole or side port] or requires the use of a ladder or rungs to reach the working level and test results are satisfactory. This checklist must be filled out whenever the job site meets these criteria.
1. Are you certified in the operation of the gas monitor to be used? 2. Has a gas monitor functional test [Bump Test] been performed this shift on the gas monitor to be used? 3. Did you test the confined space prior to entry? 4. Did the atmosphere check as acceptable [no alarms given]? 5. Will the atmosphere be continuously monitored while the space is occupied? 6. Does your knowledge of industrial or other discharges indicate this area is likely to remain free of dangerous air contaminants while occupied? 7. Did your survey of the surrounding area show it to be free of hazards such as such as drifting vapor from tanks, piping, or sewers?
YES
NO
(
)
(
)
( ( (
) ) )
( ( (
) ) )
(
)
(
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(
)
(
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(
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(
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Contact:_______________________________________________________________________________ Phone:___________________ for personnel rescue by local fire department in the event of an emergency. Contact:_______________________________ Phone:__________________ for onsite medical attention.
Notice: If any of the above answers are “no” DO NOT enter the confined space. Contact your immediate supervisor. Project:________________________________________________________________________________ Lead Man Signature: __________________________________________ Date:______________________
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SAMPLE CONFINED SPACE ENTRY PERMIT Per Section 1910.146 Appendix C (b) Date & Time Issued:_____________________ Date & Time expires:______________________ Project:_____________________ Equipment to be worked on:____________________ Project Supervisor:_____________________ Work to be performed:____________________ [Bold denotes minimum requirements to be completed and revised prior to entry] Requirements Compl. Date Time Lock Out/De-energize/Tag-out ___ ___ ___ Lines Broken, Capped, Blanked ___ ___ ___ Purge/Flush/Vent ___ ___ ___ Ventilation ___ ___ ___ Breathing Apparatus ___ ___ ___ Standby Safety Personnel ___ ___ ___ Lighting [Explosion-Proof] ___ ___ ___ Respirators[s] [Air Purifying] ___ ___ ___
Requirements Compl. Date Time Full Body Harness/Belt ___ ___ ___ Emerg Esc Retrieval Equip ___ ___ ___ Lifelines ___ ___ ___ Secure Area[Post/Flag] ___ ___ ___ Resuscitator – Inhalator ___ ___ ___ Fire Extinguishers ___ ___ ___ Protective Clothing ___ ___ ___ Burning & Welding Permit ___ ___ ___
Note: Items that do not apply enter N/A in the blank.
[Record Continuous Monitoring Results Every 2 Hours] Continuous Monitoring to be taken Lower Flammable Limit Oxygen Carbon Monoxide Ammonia Hydrogen Sulfide Sulfur Dioxide Aromatic Hydrocarbon
Max. Permissible Entry Level [PEL] Under 10% 19.5% - 23.5% 35 PPM* 35 PPM* 15 PPM* - 10 PPM** 5 PPM* - 2 PPM** 5 PPM* - 2 PPM**
Initial Test ____ ____ ____ ____ ____ ____ ____
2 hrs __ __ __ __ __ __ __
4 hrs __ __ __ __ __ __ __
6 hrs __ __ __ __ __ __ __
8 hrs __ __ __ __ __ __ __
10 hrs __ __ __ __ __ __ __
*= Short-term Exposure limit = Employee can work in the area up to 15 minutes. **= 8 Hr. Time-Weighted Average. Employee can work in area 8 hours. Remarks:______________________________________________________________________________ ______________________________________________________________________________________ Gas Tester Name
Model No.
Type/Serial No.
Unit No.
Calibration
______________
________
____________
_______
_________
Safety Standby Person is Required for All Confined Space Work. Name:_______________________ Supervisor Authorizing Entry. Name:_____________________________________________________ Emergency Nos. Posted: Medical:_____________ Fire:______________ Safety:__________________ All Above Conditions Satisfied________________________________
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