I. OVERVIEW AND OBJECTIVES A. This procedure shall address the identification of confined spaces, posting of confined spaces, control of hazards, completion of a confined space entry permit, and minimum precautions for persons prior to entry into confined spaces at the SDSU campus. The regulatory authority by which this standard is applied to the campus is cited in Title 8, California Code of Regulations, Sections 51565158, and the Code of Federal Regulations Subpart J 1910.146. This written program is available for inspection by employees and their authorized representatives. A copy of this written program including the attachments shall be located in each shop for review by employees who participate in confined space work tasks. B. This policy and procedure shall meet the safety standards set by Federal OSHA and Cal-OSHA and advocated by San Diego State University. Adherence to these procedures will minimize employees' risks of exposure to hazards associated with confined spaces. These include but are not limited to: 1. Spaces configured with restrictive work areas that are not designed for continuous employee occupancy. Examples of these types of spaces include but are not limited to: Silos, tanks, tunnels, vaults, manholes, vats, vessels, boilers, compartments, ducts, sewers, pipelines, pits, and bins. II. Oxygen deficient or oxygen rich atmospheres. An oxygen deficient atmosphere is an environment composed of an oxygen content of less than 19.5% content by volume of air. An oxygen rich atmosphere is an environment with a concentration of oxygen greater than 23.5% or containing flammable gases or vapors. These gases and/or vapors increase the potential for ignition or explosion from sparks, heat or a flame source. 3. Physical hazards such as heat or burns from heating pipes or lines, electrocution or shock from electrical lines or equipment, slips, trips, or falls, hazards associated with falling and protruding objects, and hazardous dust, steam, or toxic vapors. SCOPE A. 10/2009 2. The scope of application of this policy is meant to apply to all employees, contractors, inspectors, and all other persons entering an identified confined space at San Diego State University. No person may enter a permit required confined space without a confined space entry permit. Entry into non-permitted confined spaces can be made as long as the special procedures for entry into that space are followed. Contractors are responsible for their employees during work in confined spaces. 1 III. DEFINITIONS Detailed definitions are provided in Title 8, California Code of Regulations, Section 5157. A summary of applicable definitions is provided below. Alternate Entry Procedure: A procedure that may be used to enter a confined space if the only actual or potential hazard present in the space is atmospheric in nature, can be controlled by continuous forced air ventilation alone, will not become immediately dangerous to life and health (IDLH) if the mechanical ventilation should fail and documented data supports these findings. Attendant: The person responsible for monitoring workers inside the permit required confined space from outside the space. The Attendant conducts continuous monitoring for changes in potentially hazardous air contaminants. He/she remains in constant contact with workers inside the space and may stop a job and order workers out of the space if he/she believes a hazardous condition exists. The Attendant must never enter or leave the confined space opening, unless he/she is relieved by another Attendant, or upon completion of the job after workers have evacuated the space and closed the confined space opening. Authorized Entrant: The person authorized by the campus to enter a permit required confined space after receiving training. His/her task is to complete the job within the confined space and to be aware of all hazards associated with work within the space. Confined Space: Has limited means of entry and exit (for example manholes and vaults), Is large enough and configured so that an employee can bodily enter and perform assigned work, and Is not designed for continuous employee occupancy. Confined Space Entry Permit: A written document that is provided by the employer to authorize and control entry into a permitted confined space. (Attachment C) Entry Supervisor: The person responsible for determining if acceptable entry conditions are present at a permit space where entry is planned, for authorizing entry and overseeing entry operations, and for terminating entry. Hazardous Atmospheres: An atmosphere that may expose employees to the risk of death, incapacitation, impairment of ability to self-rescue, injury, or acute illness resulting from one or more of the following: Flammable gas, vapor, or mist in excess of 10 percent of its lower flammable limit (LFL). Airborne combustible dust at a concentration that meets or exceeds its LFL. This may be approximated as a condition in which the dust obscures vision at a distance of 5 feet or less. Atmospheric oxygen concentration below 19.5 percent or above 23.5 percent. 10/2009 2 Atmospheric concentration of any radioactive or airborne contaminant substance that could result in an exposure greater than the dose limit or Permissible Exposure Level (PEL). Any other atmospheric condition that is immediately dangerous to life and health (IDLH). Immediately Dangerous to Life and Health (IDLH): Any condition that poses an immediate or delayed threat to life or that would cause irreversible adverse health effects or that would interfere with an individual’s ability to escape unaided from a confined space. Lower Flammable Limit (LFL): The minimum vapor concentration of a flammable liquid in air, below which flame propagation does not occur on contact with an ignition source. Non Permit Confined Space: A space that does not contain or, with respect to atmospheric hazards, have the potential to contain any hazard capable of causing death or serious physical harm. Oxygen Deficient Atmosphere: A space with air that has an oxygen concentration less than 19.5% by volume. Oxygen Enriched Atmosphere: A space with air that has an oxygen concentration greater than 23.5% by volume. Permit Required Confined Space: 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 that has the potential for engulfing Entrants, Has an internal configuration such that an Entrant could be trapped or asphyxiated by inwardly converging walls or by a floor that slopes downward and tapers to a smaller cross-section, or Contains any other recognized serious safety or health hazard. Testing: The process by which hazards that may confront Entrants of a permitted confined space are identified and evaluated. Toxic Atmosphere: A material in the air that will cause injury to an individual entering the space. Ventilation: A process used to control the atmospheric hazards of confined spaces by replacing unsafe air with clean, breathable air. 10/2009 3 IV. RESPONSIBILITIES A. B. C. 10/2009 Directors are responsible to: 1. Establish and institute the Confined Space Policy for their department. 2. Ensure that the policy is applied throughout the confined space work areas. Environmental Health and Safety (EH&S) is responsible to: 1. Prepare, develop, implement, maintain, and audit the written Confined Space Program for SDSU. 2. Coordinate with Physical Plant and TNS personnel to locate, identify, and post SDSU confined spaces. 3. Assist in coordination of training for Entry Supervisors, Attendants, and Authorized Entrants regarding procedures and protocols to be used during work in a confined space. 4. Work with Managers and Supervisors to ensure university employees comply with the Cal-OSHA requirements for entry into confined spaces. SDSU Employees including Physical Plant and Communications Services/ TNS Department are responsible to: 1. Identify personnel who are affected by this standard and ensure that they receive the required confined space entry and procedures training. 2. Provide information to EH&S on the type of work procedures and conditions within SDSU confined spaces when requested. 3. Identify tools, equipment, and sources of hazardous energy to be locked out or blocked off prior to entry into a confined space. 4. Maintain written procedures regarding administrative and engineering controls and standards to work in a confined space. 5. Fill out and issue the confined space permits and cancel the permits upon completion of the work. 6. Follow procedures and practices identified and established within this safety program. 7. Provide and maintain equipment that is needed for confined space entry, including but not limited to: atmospheric testing equipment, protective barriers, ventilation devices, and rescue equipment. 4 8. D. Ensure that all confined space entries are carried out according to the procedures specified in this document. Contractors are responsible to: 1. Comply with all Cal-OSHA regulations for entry into a confined space. 2. Take responsibility for their employees who enter confined spaces. 3. Train employees in the required confined space entry procedures. 4. Provide copies of their permits to EH&S upon request. E. F. 10/2009 Confined Space Entry Supervisor is responsible to: 1. Ensure that all persons involved in a confined space entry are properly trained and follow appropriate procedures. 2. Verify by checking that the appropriate entries have been made on the permit, that all tests specified by the permit have been conducted and that all procedures and equipment specified by the permit are in place before endorsing the permit and allowing entry. 3. Complete training and be aware of the hazards, effects of exposure to hazards, and signs or symptoms of exposure associated with the particular space being evaluated. 4. Complete the Confined Space Entry Permit. 6. Verify that rescue services are available and the means for summoning additional services are operable. 7. At intervals dictated by the hazards and operations performed within the space, determine whenever responsibility for a permit space entry operation is transferred that entry operations remain consistent with terms of the entry permit and that acceptable entry conditions are maintained. 8. Remove unauthorized individuals who enter or who attempt to enter the permit space during entry operations. 9. Terminate the entry and file cancelled permits properly. Confined Space Authorized Entrant is responsible to: 1. Be the only person who may enter a confined space. 2. Complete training and be aware of the hazards, effects of exposure to hazards, and signs or symptoms of exposure associated with the particular space being entered. 5 3. G. 10/2009 Stay in constant contact with the Attendant (sight, voice, or radio) during a permit required confined space entry to enable the Attendant to monitor Entrant status and to enable the Attendant to alert Entrants of the need to evacuate the space if required. The Entrant must alert the Attendant whenever: a. Entrant recognizes any warning signs or symptoms of exposure or b. Entrant detects a prohibited condition. 4. Properly use the appropriate safety equipment as specified on the Entry Permit. 5. Exit from the space when directed by the Attendant or Entry Supervisor, when Entrant feels that a hazardous condition exists, when Entrant recognizes any warning signs or symptoms of exposure, or when the evacuation alarm on the gas detector is activated. Confined Space Entry Attendant is responsible to: 1. Complete training and be aware of the hazards, effects of exposure to hazards, and signs or symptoms of exposure associated with the particular space being monitored. 2. Be aware of possible behavioral effects of hazard exposure in Authorized Entrants. 3. Work with the Entrant to obtain and install the required safety equipment for Permit Required Confined Space entries. 4. Monitor pedestrian barriers to protect Entrants from external hazards and prevent unauthorized persons from entering the space. 5. Monitor the atmosphere for hazardous condition changes such as air quality, dust, steam, heat sources, equipment, etc. within the confined space during the entry operation. 6. Remain in position (outside the permit space during entry operations) until relieved by another trained Attendant or the work in the space is complete and perform no duties that might interfere with monitoring and protecting the Entrant. 7. Ensure that all lock out/tag out measures, if applicable, remain in place. 8. Notify the Entrant and order an evacuation if a situation develops that could endanger the Entrant. 6 9. Take the following actions when unauthorized persons approach or enter a permit space while entry is underway: a. b. c. 10. Continuously maintain an accurate count of Authorized Entrants in the space and ensure that Authorized Entrants are identified appropriately. 11. Stay in constant communication with Entrant using either verbal communication, if the Entrant is in direct sight, or powered communication to monitor Entrant status and alert Entrant of the need to evacuate. If the powered communication equipment malfunctions, the Entrant must evacuate the confined space immediately and not reenter until a functional method of communication is available. 12. Monitor activities inside and outside of the space to determine if it is safe for Entrant to remain in the space and order the Authorized Entrant to evacuate the permit space immediately under any of the following conditions: a. b. c. d. V. If the Attendant detects a prohibited condition, If the Attendant detects the behavioral effects of hazard exposure in an Authorized Entrant, If the Attendant detects a situation outside the space that could endanger the Authorized Entrant, or If the Attendant cannot effectively and safely perform all the duties as listed in this section 13. Be trained in non-entry rescue. 14. Perform non-entry rescues and summon additional rescue and other emergency services as soon as it is determined that Authorized Entrants may need assistance to escape from permit space hazards. 15. Inform Work Control in the event that the Attendant must perform a nonentry rescue. GENERAL PRE-ENTRY REQUIREMENTS FOR CONFINED SPACES ON CAMPUS A. Space Determination 1. 10/2009 Warn the unauthorized persons that they must stay away from the permit space, Advise the unauthorized persons that they must exit immediately if they have entered the permit space, and Inform the Authorized Entrant and the Entry Supervisor if unauthorized persons have entered the permit space. EH&S, Physical Plant, and TNS work together to determine which types of spaces on campus are defined as “confined spaces.” A list of these types of spaces already identified at SDSU can be found as Attachment B. This 7 list includes general descriptions of spaces and specifies spaces that will always be considered “Permit Required Confined Spaces.” 2. B. All permit required confined spaces on campus will be considered “Permit Required” until pre-entry procedures determine otherwise. The only individuals authorized to designate a particular space as “Non Permit Required” or “Alternate Entry Procedure” are designated “Entry Supervisors." Refer to the Confined Space Evaluation section. Identification 1. Employees shall be informed of permit required confined spaces by posted signs including the information below or by another equally effective means. Information shall include the location and danger posed by the permit spaces. "DANGER” PERMIT REQUIRED CONFINED SPACE DO NOT ENTER 2. C. Permit information shall include work practice safety requirements and required safety equipment for each permit required confined space. Hazard Assessment 1. Before entry is made into a confined space hazardous conditions shall be assessed including: a. b. c. d. e. f. 10/2009 Controlled access of the area and confined space. Evaluation of space configuration. Evaluation of work to be done and materials to be used. Evaluation of atmospheric and other hazards. Determination of proper personal protective equipment required prior to entry into the confined space. Ensuring that equipment and/or hazardous energy sources have been disabled by Lock Out/Tag Out, Block & Bleed, Double Block & Bleed, etc. 2. The Confined Space Pre-Entry Checklist in the Confined Space Permit must be completed. 3. After a permit is issued by the Entry Supervisor, the permit required confined space work team, consisting of the Authorized Entrant and Attendant, can proceed to the job site. 8 D. Confined Space Evaluation Refer to the Confined Space Entry Decision Flow Chart (Attachment A). 1. The goal of the evaluation is to determine if Permit Required Entry Procedures or Alternate Entry Procedures will be used. 2. The Entry Supervisor may use Alternate Entry Procedures for entering a permit required confined space under the following conditions: a. b. c. d. e. 3. If all of the conditions in V.D.2. are met and the gas tests indicate that the atmosphere is non-hazardous with the use of continuous forced air ventilation, the space may be entered using Alternate Entry Procedures (Section VII.A). 4. If the potential for atmospheric hazards cannot be eliminated using ventilation, the space must be entered using Permit Required Entry Procedures. 5. A space classified as a permit required confined space may be reclassified as a non-permit confined space under the following conditions: a. b. 10/2009 The only hazard in the space is an actual or potential hazardous atmosphere. The potential atmospheric hazard can be eliminated and controlled through the use of continuous forced air ventilation. Previous and current atmospheric monitoring data verify that conditions a. and b. are correct and all testing results and monitoring data are documented, retained and made available to each employee who enters the space. If an initial entry into the permit space is necessary to obtain the data required for item c., the entry is performed in compliance with permit required confined space guidelines. Employees can safely enter and do work in the space. If the permit space poses no actual or potential atmospheric hazards and if all hazards within the space are eliminated without entry into the space, the permit space may be reclassified as a non-permit confined space for as long as the hazards remain eliminated. If it is necessary to enter the permit space to eliminate hazards, such entry shall be performed according to the procedures for entering a permit required confined space. If testing and inspection during that entry demonstrate that the hazards within the permit required space have been eliminated, the permit required space may be reclassified as a non-permit confined space for as long as the hazards remain eliminated. 9 E. The Confined Space Entry Permit 1. The Entry Supervisor shall review and issue confined space entry permits. The permit is required to confirm that all the proper steps and procedures as specified on the permit checklist for entering the confined space have been taken. 2. Each Authorized Entrant or their authorized representative shall be given the opportunity to observe the pre-entry testing and subsequent testing of confined spaces. 3. The permit is required to be displayed at each permit required confined space site. Information contained on the permit includes the following: a. b. c. d. e. f. g. h. i. (*) At the end of the job the permit is to be returned to the issuing Supervisor for filing. The files should be maintained for at least one year to provide an audit trail for parties reviewing the program. 5. The Entry Supervisor shall terminate entry and cancel the permit when: b. 10/2009 Item required for space entry only if necessary 4. a. F. Atmospheric testing and monitoring results Engineering and work place controls Rescue and emergency equipment Communication equipment Personal protective equipment Any additional permits required for the space (for example: Hot Works) * Space lighting equipment * Space ventilating equipment * Any other equipment necessary for safe entry and rescue from the permitted space. * The entry operations covered by the entry permit have been completed or A condition that is not allowed under the entry permit arises in or near the permit space. Personal Protective Equipment and Tools 1. All San Diego State University departments and contractors who may enter a confined space are responsible for the proper maintenance, inspection, and use of tools, equipment, and personal protective equipment. 2. Tools and equipment shall meet all Federal and State requirements. 3. Tools and equipment shall be checked prior to use in confined spaces. 10 4. Lighting must be intrinsically safe and/or explosion proof and recognized by Underwriters Laboratory. 5. Work involving the use of a source of ignition is prohibited within a confined space (or any adjacent space having common walls, floor, or ceiling with the confined space) that contains or is likely to develop oxygen enrichment or dangerous air contamination due to flammable and explosive substances. 6. Personal protective equipment shall include, but is not limited to: a. b. c. d. e. f. G. Training Requirements 1. No employees shall be involved in confined space work unless they have been trained in confined space entry and understand the provisions of this SOP. This includes Supervisors, Attendants, and Entrants. Each of these positions requires specific training related to their job duties. Students shall not be authorized to participate in confined space work. 2. Entry Attendants shall be trained and immediately available to perform non-entry rescues in permit required confined spaces and to contact Public Safety and outside rescue services personnel in the event of an emergency. Refresher training to review non-entry rescue shall be carried out. 3. Training shall be provided to each affected employee: a. b. c. d. 4. 10/2009 Head, eye, face, feet, hand, and hearing protection; Atmospheric testing devices; Protective clothing, safety belts, harnesses and lifelines; Intrinsically safe lighting, ventilation equipment, and tools; Respiratory protection equipment; Intrinsically safe compressed gas cylinders. Before the employee is first assigned duties under this section, and Before there is a change in assigned duties, and Whenever there is a change in permit space operations that presents a hazard about which an employee has not been previously trained, and Whenever there is reason to believe that there are deviations from the permit space entry procedures or there are inadequacies in the employee’s knowledge or use of these procedures. Employees who participate as Supervisors, Attendants, and Entrants shall review basic confined space entry procedures and policy requirements annually. 11 H. 5. Due to the specialization of each trade, the immediate Supervisor is best qualified to coordinate specific confined space entry training. It is the immediate Supervisor's responsibility to coordinate the training in confined space entry and on the equipment necessary for the job. EH&S, at the Supervisor's request, will provide training assistance. 6. The training shall establish employee proficiency in the duties required and shall introduce new or revised procedures, as necessary, for compliance with this written program. 7. Training records are to be maintained by the Supervisor. Documentation that the training has been carried out shall include each employee’s name, the signatures or initials of the trainers, and the dates of the training. The documentation shall be available for inspection by employees and their authorized representatives. Monitoring for Toxic Atmospheres and Oxygen Deficiency Atmospheric Testing Procedures are to be conducted in the following manner: 1. The gas detector must be available prior to entering a confined space, calibrated per manufacturer’s recommendations, and in good working order. 2. Gas detectors must be checked and calibrated prior to each use. This includes: a. b. 10/2009 Inspection of the hoses, batteries, pump, sensors, and filters. Field testing using test gas cylinders containing known amounts of the substances being tested for in the space. 3. Sample the air quality of the confined space, for example a manhole, by slightly moving the lid or by testing the space through the hole in the lid before completely opening the space. This is a surface reading. 4. Lower the probe slowly into the space, allowing time for the instrument to detect atmospheric changes at different vertical heights in the space. Take meter readings approximately 3 feet from the surface, approximately 6 feet from the bottom, and approximately 3 feet from the bottom. 5. Measure in the following order a. Percent Oxygen b. Lower Flammable Limit for Flammable Gases and Vapors c. Carbon Monoxide d. Hydrogen Sulfide 6. Record measurements in the Confined Space Pre-Entry Checklist Atmospheric Check Section of the Confined Space Entry Permit (Section IV, 1). 12 7. If there is no indication from the meter that there is a problem with the confined space atmosphere, all required sections of the Confined Space Entry Permit have been completed, and the Entry Supervisor has signed the permit, workers may proceed into the space. 8. No source of ignition shall be introduced into the confined space until testing has verified that flammable gases are not present. 9. The gas detector shall be located near the Entrants and left on throughout the duration of the work in a Permit Required or Alternate Entry Procedure Confined Space. Results of environmental testing shall be documented at least hourly. Readings must be recorded in the Periodic Atmospheric Test Results Table (Section VI) of the Confined Space Entry Permit. 10. Whenever oxygen-consuming equipment (for example torches) is used in any confined space, continuous environmental testing must be performed. 11. If the following concentrations are noted at any time, discontinue operations, remove entry personnel, and ventilate the space until new test results are within the safe range and it is safe to enter. a. b. c. d. 12. VI. Evaluate work processes that will be carried out in the confined space to determine if any other harmful substances will be present or potentially present. If hazardous substances are potentially present, monitoring and appropriate personal protection must be implemented. Entrance into the confined space is not permitted under any circumstances until this has been addressed. SPECIFIC CONFINED SPACE ENTRY PROCEDURES A. 10/2009 Oxygen reading less than 19.5% or greater than 23.5% Combustible gas reading greater than 10% LFL H2S reading greater than 10 ppm CO reading greater than 25 ppm Entering a Permit Required Confined Space 1. If there is an option to enter the confined space from the side or top, always choose the side entry. 2. If the side entry is utilized, a safety belt with a line attached to the employee in the confined space will be secured outside the entry opening and manned by the Attendant. 3. If a top entry is utilized, the retrieval system must meet the requirements as specified in Section VI, C, 4 of this document. 13 B. C. Ventilating a Confined Space 1. Use one or more blowers to provide adequate ventilation for the space. 2. Ensure the ventilation air supply is from a clean source. 3. Allow enough time for blowers to clear the space before entering it. Air sampling must be performed and documented to verify acceptable atmospheric conditions prior to entering. 4. When required to provide adequate ventilation, the blowers must remain on during the entire entry into the confined space. If a blower fails, the Entrant must leave the space immediately. This applies to Permit Required and Alternate Entry Procedure confined spaces. 5. Whenever oxygen-consuming equipment is used, measures shall be taken to ensure adequate combustion air and exhaust gas venting. Emergency Rescue from Permit Required Confined Spaces 1. More employees are killed while attempting rescues than Entrants. Based on this information, emergency rescues within confined spaces must only be attempted by emergency medical personnel who are properly trained and have the proper rescue equipment. 2. Self-rescue is always the preferred rescue method. Authorized Entrants are informed about how to recognize their own symptoms of exposure to a dangerous atmosphere or when a prohibited condition is detected, based on the potential hazards and pre-entry checklists. This recognition allows Entrants to escape quickly without assistance. 3. All rescues attempted by SDSU personnel in permit required and alternate entry confined spaces will be Non-Entry Rescues. 4. Retrieval systems shall be used whenever an Authorized Entrant enters a permit space unless the retrieval equipment would increase the overall risk of entry or would not contribute to the rescue of the Entrant. If a harness and retrieval line are not used because they will increase the overall risk of entry, then the reason for not using the retrieval system must be approved by the Supervisor and documented on the permit. Retrieval systems shall meet the following requirements: a. 10/2009 Each Authorized Entrant shall use a chest or full body harness that suspends a person in the upright position with a retrieval line attached to a suitable point so that when rescued, the Entrant presents the smallest possible profile. The line shall be at least ½inch diameter and 2,000-pounds test. Suggestions for placement of the line include at the center of the Entrant’s back near shoulder level or above the Entrant’s head. Wristlets may be used in lieu of 14 b. c. d. D. the chest or full body harness if the use of a chest or full body harness is infeasible or creates a greater hazard and it can be demonstrated that the use of wristlets is the safest and most effective alternative. The other end of the retrieval line shall be attached to a mechanical device or fixed point outside the permit space in such a manner that rescue can begin as soon as the rescuer becomes aware that rescue is necessary. A mechanical hoisting device shall be available to retrieve personnel from vertical type permit spaces more than 5 feet deep. The hoisting device shall be positioned over the entry. The retrieval line, which is attached to the worker, shall be threaded through the hoist. 5. The Entry Supervisor shall know and specify how emergency medical personnel will be notified. For example, the Attendant will contact Work Control using the radio and Work Control will contact Public Safety and notify outside rescue services personnel, as listed on the Confined Space Entry Permit. The Attendant shall inform Work Control in the event that the Attendant must perform a non-entry rescue. 6. Review of non-entry rescue procedures shall be included as a part of refresher training for all employees who participate in non-entry rescue. 7. At least one person must be immediately available and CPR and First Aid trained during a permit required confined space entry. 8. If an injured Entrant is exposed to a substance for which a Material Safety Data Sheet or similar written information is required to be kept at the worksite, that MSDS or written information shall be made available to the medical facility treating the exposed Entrant. SDSU Obligations Regarding Contractors When employees of another employer perform work at SDSU that involves confined space entry, SDSU shall: 10/2009 1. Inform the contractor that the workplace contains permit spaces and entry is allowed only through compliance with a permit confined space program meeting the requirements of Title 8, California Code of Regulations, Sections 5156-5158, and the Code of Federal Regulations Subpart J 1910.146, 2. Apprise the contractor of the elements and hazards identified within the space, 15 E. VII. Apprise the contractor of any precautions or procedures that SDSU has implemented for protection of employees in or near the permit spaces where contractor personnel will be working, 4. Coordinate entry operations with the contractor when both SDSU personnel and contractor personnel will be working in or near permit spaces, and 5. Debrief the contractor at the conclusion of the entry operations regarding any hazards confronted or created in the space during entry operations. Program Review 1. Departments shall perform an annual review covering all entries performed during the 12-month period and results shall be available for all employees to review. EH&S shall review and update written procedures in this program annually. 2. Entry operations shall be reviewed when there is reason to believe that the measures taken under the permit space program may not protect employees and the program will be revised to correct deficiencies found to exist before subsequent entries are authorized. TYPES OF ENTRIES AND ASSOCIATED PROCEDURES A. 10/2009 3. Alternate Entry Procedures 1. Alternate entry procedures may be used based on the requirements in the Confined Space Evaluation Section of this document. 2. An Entry Supervisor, Entry Attendant, and Entrant shall be designated to participate when alternate entry procedures are used to enter a confined space. The Entry Supervisor does not need to be present during the entire confined space operation. 3. Any conditions making it unsafe to remove an entrance cover shall be eliminated before the cover is removed. 4. When the entrance cover is removed, the opening shall be promptly guarded using a railing, temporary cover, or other temporary barrier that will prevent a fall into the space and protect employees working in the space from objects entering the space. 5. If applicable to the site, traffic control shall be in place during entry procedures. 6. The air shall be tested for hazardous contaminants since the only hazard posed by the space is an actual or potential hazardous atmosphere. Before an employee enters the space, the internal atmosphere shall be 16 tested with a calibrated direct reading instrument. Pre-entry gas test results must be entered into the Confined Space Pre-Entry Checklist Atmospheric Check Section of the Confined Space Entry Permit (Section IV, 1). The following conditions must be tested in the order given: a. Oxygen content, b. Flammable gases and vapors, c. Potential toxic air contaminants. 7. There must be no hazardous atmosphere within the space whenever any employee is inside the space. The gas detector and alarm must be on throughout the entire entry procedure to test for the following contaminants: Oxygen content, lower flammable limit, carbon monoxide, and hydrogen sulfide. Readings must be recorded every hour. 8. The Entry Supervisor must verify that the space is safe for entry and that the pre-entry measures have been taken prior to employees entering the space. Written documentation is required and the following sections on the Entry Permit must be completed: I, II, III, IV (1, 5-7), V, VI, and VII. 9. Continuous forced air ventilation shall be used, as follows: a. b. c. d. e. 10. If the ventilation does not operate or if a hazardous atmosphere is detected during entry: a. b. c. 11. 10/2009 An employee may not enter the space until the hazardous atmosphere is eliminated and acceptable gas detector readings are documented. The forced air ventilation shall be directed as to ventilate the immediate areas where an employee is or will be present within the space and shall continue until all employees have left the space. The supply air shall be taken from a clean source and may not increase the hazards in the space. The ventilation shall be allowed to operate for at least 5 minutes prior to entering the space. The atmosphere within the space shall be tested and readings shall be documented to ensure that the continuous forced air ventilation is preventing the accumulation of a hazardous atmosphere. All Entrants must leave the space immediately. The space shall be evaluated to determine how the hazardous atmosphere developed. Measures shall be implemented to protect employees from the hazardous atmosphere before any subsequent entry takes place. If the Entrant becomes aware of a previously unrecognized hazard, he/she must immediately evacuate the space and the space must be reevaluated prior to reentry. 17 B. 10/2009 12. An effective means of communication shall be available for the Entrants to use at all times. Entrants must be trained in the appropriate use of powered communication equipment and the system shall be tested to confirm its effective operation. If the powered communication equipment malfunctions, the Entrants must evacuate the confined space immediately and not reenter until a functional method of communication is available. 13. Employees entering the confined space must have the opportunity to observe pre-entry testing and review the Confined Space Entry Permit containing pre-entry test results. 14. When work in the confined space is completed, the Entry Permit shall be kept on file for a minimum of 1 year. Permit Required Confined Space Entry Procedures 1. Entry into a permit required confined space requires an entry permit issued by the Entry Supervisor. 2. An Entry Supervisor, Entry Attendant, and Entrant shall be designated to participate in each Permit Required Confined Space Entry. In addition to the Entry Attendant, at least one other person needs to be available within sight or call in the event that the Entry Attendant requires assistance. The Entry Supervisor does not need to be present during the entire confined space operation. 3. All of the required safety equipment, based on the permit, must be on site and available. Equipment can include, but is not limited to, blowers, full body harness, retrieval line, rescue tripod, and traffic control systems. 4. Hazardous sources of energy that impact the work to be performed in a confined space must be identified and disconnected, tagged or locked out of operation. Please refer to the SDSU Lock Out/Tag Out Program. 5. When the entrance cover is removed, the opening must be promptly guarded using a railing, temporary cover, or other temporary barrier that will prevent a fall into the space and protect employees working in the space from objects entering the space. 6. If applicable to the site, traffic control must be in place during entry procedures. 7. A survey of the air in the confined space is required prior to entry. An atmospheric survey instrument shall be used to monitor the confined space for Oxygen content, lower flammable limit of any combustible gases that may be present, Carbon Monoxide, and Hydrogen Sulfide. If any other hazardous substances are potentially present, monitoring and appropriate personal protection must be implemented. Entrance into the 18 confined space is not permitted under any circumstances until this has been addressed. 10/2009 8. The pre-entry gas test results must be entered into the Confined Space Pre-Entry Checklist, Atmospheric Check Section of the Confined Space Entry Permit (Section IV, 1). The air must be continuously sampled and the results recorded in the Periodic Atmospheric Test Section of the Confined Space Entry Permit (Section VI) throughout the entire entry procedure. Refer to the Monitoring for Toxic Atmospheres and Oxygen Deficiency section of this document. 9. The Entry Supervisor shall complete and sign the Confined Space Entry Permit prior to Entrants going into the space. The following topics must be reviewed with the Attendant and Entrant prior to entry: permit conditions, entry precautions, and rescue procedures. 10. The Attendant shall verify that entry conditions are acceptable prior to entry, continuously monitor the portable gas detector, and record the readings every hour. 11. The Entrant must wear retrieval equipment during the entire entry operation. Retrieval systems shall be used whenever an Authorized Entrant enters a permit space unless the retrieval equipment would increase the overall risk of entry or would not contribute to the rescue of the Entrant. If a harness and retrieval line are not used because they will increase the overall risk of entry, then the reason for not using the retrieval system must be approved by the Supervisor and documented on the permit. Retrieval systems shall meet the requirements specified in Section VI, C, 4 of this document. 12. If the safety equipment fails or if the space becomes immediately hazardous, an immediate evacuation of the space shall be ordered. 13. An effective means of communication between the Attendant and Entrants shall be used at all times. Powered communication devices are required when Entrants are using respiratory protection equipment or whenever employees inside of the confined space are out of sight of the Attendant or unable to communicate verbally with the Attendant. Employees must be trained in the appropriate use of the powered communication equipment and the system shall be tested to confirm its effective operation. If the powered communication equipment malfunctions, the Entrants must evacuate the confined space immediately and not reenter until a functional method of communication is available. 14. After the job is complete, the Entry Supervisor shall cancel the permit and keep the completed permit on file for a minimum of one year. 15. In the event that a non-entry rescue is carried out, the Attendant must contact Work Control as soon as possible to report the situation. 19 C. Non-Permit Required Confined Space Entry Procedures 1. 10/2009 Entry into a Non-Permit required confined space is allowable if certain criteria are met that determine no actual or potential atmospheric hazards exist and if all hazards within the space are eliminated without entry into the space (Refer to Section V,D,5 of this document). A Confined Space Pre-Entry Checklist (Attachment D) shall be completed. If it is necessary to enter the permit space to eliminate hazards, the entry must be carried out according to permit required confined space entry procedures. If testing and inspection during that entry demonstrate that the hazards in the space have been eliminated, the permit space may be reclassified as a non-permit space for as long as the hazards remain eliminated. Following are the criteria that authorize entry into a non-permit confined space: a. The confined space shall be maintained in a safe condition for entry. b. A pre-entry hazard evaluation has determined that no atmospheric hazard or oxygen deficient environment exists and that there is no other hazard associated with the space. c. Documentation shall be available reclassifying it as a non-permit required confined space. d. An effective means of powered communication shall be available for Entrants to use at all times. Entrants shall be trained in the appropriate use of the powered communication equipment and the system shall be tested to confirm its effective operation. If the powered communication equipment malfunctions, the Entrants shall evacuate the confined space immediately and not reenter until a functional method of communication is available. e. Since an Entry Supervisor and Entry Attendant are not required, approved procedures shall be in place for maintaining communication with the Entrant to ensure the Entrant completes the work and exits the space safely. When working in manholes, crawl spaces, or any other confined spaces at least two employees must be present at the job site. f. When the entrance cover is removed, the opening shall be promptly guarded using a railing, temporary cover, or other temporary barrier that will prevent a fall into the space and protect employees working in the space from objects entering the space. g. If applicable to the site, traffic control shall be in place during entry procedures. 20 h. If any hazard is identified, the confined space shall become a permitted space and the employees shall immediately exit the space. The space shall be reevaluated prior to entry. i. It is important to realize that a non-permit required confined space might require reclassification based on the type of work to be performed. For example, an underground vault may be classified as non-permit required, however, if an employee will be applying a solvent within this space, it could be reclassified to a permit required confined space. All questions concerning this procedure or requests for further information should be directed to the Department of Environmental Health and Safety at 594-6778. 10/2009 21