TECHNICAL COMMITTEE ON Confined Space Safe Work Practices
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TECHNICAL COMMITTEE ON Confined Space Safe Work Practices AGENDA Second Draft Meeting St. Petersburg, FL April 7-9, 2015 8 AM-5 PM EDT* Continental Breakfast served each Am at 7:30 AM. Lunch provided on Day One only. *Meeting times subject to modification by the Chair 1. Welcome. Don English, Chair. 2. Introduction of Committee Members and Attendees. 3. Approval of Meeting Minutes (attached-April 7-10, 2014). 4. Revision Timeline for Document Revision (Fall 2015 cycle-attached). 5. Staff presentation. Nancy Pearce. Revision Process-Second Draft. NFPA Data Initiative. 6. Task group reports/Chapter Reviews and Review of Public Comments.(attached) 7. Task Group meetings (TBD as needed). 8. Other Business/Next Steps. 9. Schedule Next Meeting. 10. Adjourn. 03/09/2015 Nancy Pearce CNS-AAA Address List No Phone Confined Space Safe Work Practices Leslie D. English Chair 254 South Jackson Street Grove Hill, AL 36451 SE 3/1/2011 Adam C. Jones CNS-AAA Secretary Buechel Fire Protection District 4101 Bardstown Road Louisville, KY 40218 E 10/18/2011 CNS-AAA Rick Argudin Principal Capital Safety 5740 West Little York, Suite 179 Houston, TX 77091 M 07/29/2013 Edward K. Boring CNS-AAA Principal Hilton Head Island Fire Rescue 40 Summit Drive Hilton Head Island, SC 29926 International Association of Fire Chiefs Alternate: Rodney Foster E 10/20/2010 CNS-AAA Christopher S. Buehler Principal Exponent, Inc. 10850 Richmond Avenue, Suite 175 Houston, TX 77042 SE 03/03/2014 Louis A. Donsbach, Jr. CNS-AAA Principal US Steel Corporation One North Broadway, 91E2/TS 526 Gary, IN 46402-3101 U 10/18/2011 CNS-AAA Timothy R. Fisher Principal American Society of Safety Engineers 1800 East Oast Oakton Street Des Plaines, IL 60018-2187 SE 03/14/2014 Nicole Gorman CNS-AAA Principal ENERCON Services Nova Scotia 202 Brownlow Avenue, Unit D#100 Dartmouth, NS B3B 1T5 Canada M 08/11/2014 CNS-AAA Alfred W. Keiss Principal Med-Tex Services, Inc. 6940 State Road, Building E Philadelphia, PA 19135-1541 Alternate: Robert J. Masonis, Sr. SE 10/18/2011 Steven E. Kosch CNS-AAA Principal 3M Company 3M Cottage Grove, Building 143-01 Cottage Gove, MN 55016 M 03/07/2013 CNS-AAA Richard S. Kraus Principal API/Petroleum Safety Consultants 210 East Fairfax Street, Apt. 600 Falls Church, VA 22046-2909 American Petroleum Institute Alternate: William E. Moody U 3/4/2009 Edmund L. Lydon, Jr. CNS-AAA Principal Northeast Hospital Corporation 85 Herrick Street Beverly, MA 01915-1790 New England Healthcare Engineers Society Alternate: Danny J. Collins Glenn E. Mate Principal Guilford Fire Department, EMT-Local 4177 Fairfield Regional Fire School 584 Moose Hill Road Monroe, CT 06468 E 3/4/2009 Joseph R. Mathews L 3/4/2009 CNS-AAA Principal CNS-AAA Sprinkler Fitters Local 692 JATC 14004 McNulty Road Philadelphia, PA 19154 United Assn. of Journeymen & Apprentices of the Plumbing & Pipe Fitting Industry Alternate: Mark R. Ronecker U 08/09/2012 CNS-AAA 1 03/09/2015 Nancy Pearce CNS-AAA Address List No Phone Confined Space Safe Work Practices Glenn E. McGinley, II E 8/5/2009 Principal CNS-AAA Ohio Public Employment Risk Reduction Program 4448 Prairie Creek Lane Maumee, OH 43537-9020 Jim E. Norris Principal Bunge North America 11720 Borman Drive PO Box 28500 St. Louis, MO 63146-1000 National Oilseed Processors Association Bob A. Rusczek Principal Certified Safety and Health 11 Arbor Lane Wilbraham, MA 01095 Alternate: Adam J. Goodman David McLaughlin Principal Oregon OSHA PO Box 14480 Salem, OR 97309-0405 E 03/07/2013 CNS-AAA U 3/4/2009 Michael Palmer SE 08/09/2012 CNS-AAA Principal CNS-AAA EnSafe Inc. 308 North Peters Road, Suite 200 Knoxville, TN 37922 American Industrial Hygiene Assn/Confined Spaces Committee Alternate: Bayless L Kilgore SE 08/09/2012 James L. Tyler CNS-AAA Principal Vestas 1417 NW Everett Street Quad 4.09 Portland, OR 97209-2652 American Wind Energy Association Alternate: Michele Myers Mihelic U 10/28/2014 CNS-AAA Bob Vigdor M 03/07/2013 David Wagner Principal CNS-AAA Principal Tyco/Scott Safety Industrial Scientific Corporation 4320 Goldmine Road 1001 Oakdale Road Monroe, NC 28110 Oakdale, PA 15071 International Safety Equipment Association Alternate: Andrew Saunders M 10/27/2009 CNS-AAA Laura Hartline Weems SE 03/07/2013 Principal CNS-AAA Center for Toxicology and Environmental Health 5120 Northshore Drive North Little Rock, AR 72118 SE 08/09/2012 CNS-AAA Richard Wright Principal Wright Rescue Solutions, Inc. 2002 Tupelo Court Panama City, FL 32405 Alternate: Dennis M. O'Connell William H. Weems Principal Safe State Program University of Alabama PO Box 870388 Tuscaloosa, AL 35487 Alternate: Kenneth W. Oldfield SE 3/1/2011 Leonard A. Young, Jr. L 08/09/2012 CNS-AAA Principal CNS-AAA Massachusetts Water Resources Authority 90 Tafts Avenue Winthrop, MA 02150-3334 American Federation of State, County & Municipal Employees 2 03/09/2015 Nancy Pearce CNS-AAA Address List No Phone Confined Space Safe Work Practices John Zimlich, Jr. Principal Louisville Gas & Electric 16660 Dixie Highway Louisville, KY 40272 U 03/05/2012 Danny J. Collins CNS-AAA Alternate Northeast Fire Safety and Consulting PO Box 3025 Plattsburgh, NY 12901 New England Healthcare Engineers Society Principal: Edmund L. Lydon, Jr. Rodney Foster Alternate Midwest City Fire Department 8201 East Reno Midwest City, OK 73130 International Association of Fire Chiefs Principal: Edward K. Boring E 03/07/2013 Adam J. Goodman CNS-AAA Alternate S-E-A Limited 1110 Benfield Boulevard Millersville, MD 21108 Principal: Bob A. Rusczek Bayless L Kilgore SE 10/23/2013 Alternate CNS-AAA Ensafe Inc. 1148 College Street Bowling Green, KY 42101 American Industrial Hygiene Assn/Confined Spaces Committee Principal: Michael Palmer Michele Myers Mihelic Alternate American Wind Energy Association 1501 M Street NW, Suite 1000 Washington Dc, DC 20005-1769 Principal: James L. Tyler Dennis M. O'Connell Alternate Roco Rescue Inc. 26 Cobalt Lane Westbury, NY 11590 Principal: Richard Wright Robert J. Masonis, Sr. Alternate Newport Beach Fire Department (retired) 1686 Rice Canyon Road Fallbrook, CA 92028-8719 Principal: Alfred W. Keiss U 10/28/2014 CNS-AAA SE 03/03/2014 CNS-AAA SE 03/03/2014 CNS-AAA U 10/28/2014 William E. Moody CNS-AAA Alternate Air BP 150 West Warrenville Road Naperville, IL 60563-8473 American Petroleum Institute Principal: Richard S. Kraus U 08/11/2014 CNS-AAA SE 10/29/2012 Kenneth W. Oldfield CNS-AAA Alternate Alabama Fire College 7291 Gadsden Highway Trussville, AL 35173-1688 Principal: William H. Weems SE 08/11/2014 CNS-AAA Mark R. Ronecker L 07/29/2013 Alternate CNS-AAA Sprinkler Fitters 268 JATC 1544 South 3rd Street St. Louis, MO 63104 United Assn. of Journeymen & Apprentices of the Plumbing & Pipe Fitting Industry Principal: Joseph R. Mathews Andrew Saunders Alternate Honeywell Inc. 7004 NW 99th Way Tamarac, FL 33321 Principal: David Wagner M 03/07/2013 CNS-AAA 3 03/09/2015 Nancy Pearce CNS-AAA Address List No Phone Confined Space Safe Work Practices Nancy Pearce Staff Liaison National Fire Protection Association 1 Batterymarch Park Quincy, MA 02169-7471 1/11/2012 CNS-AAA 4 TECHNICAL COMMITTEE ON Confined Space Safe Work Practices MINUTES-First Draft Meeting Quincy, MA April 7-10, 2014 Attendees: Don English Rick Argudin Edward Boring Christopher Buehler* Aaron Duff Adam Goodman* Adam Jones Alfred Keiss Richard Kraus Edmund Lydon Glenn Mate Glenn McGinley* Jim Norris Dennis O'Connell Michael Palmer Mark Ronecker Bob Rusczek Andrew Saunders* Bob Vigdor David Wagner Laura Weems William Weems Richard Wright* Leonard Young John Zimlich Nancy Pearce Capital Safety Hilton Head Island Fire Rescue Exponent, Inc. Bristol-Myers Squibb Company S-E-A Limited Buechel Fire Protection District Med-Tex Services, Inc. API/Petroleum Safety Consultants Northeast Hospital Corporation Guilford Fire Department, EMT-Local 4177 Ohio Public Employment Risk Reduction Bunge North America Roco Rescue Inc. EnSafe Inc. Sprinkler Fitters 268 JATC Certified Safety and Health Honeywell Inc. Tyco/Scott Safety Industrial Scientific Corporation Ctr for Toxicology and Environmental Health Safe State Program Wright Rescue Solutions, Inc. Massachusetts Water Resources Authority Louisville Gas & Electric NFPA Staff Liaison AL TX SC TX NJ MD KY PA VA MA CT OH MO NY TN MO MA FL NC PA AR AL FL MA KY MA ASSE Z117.1 Committee Chair, ExOSHA ASSE Z 117.1, Hartford Steam Boiler Ill CT Guests Terry Krug Timothy Healey NFPA Staff Guests Guy Colonna Nancy Wirtes Joanne Goyette Eric Nette Lisa Yarussi *Adobe Connect 1. The meeting was called to order at 8:00 AM. Don English, Chair, welcomed the committee and explained how the meeting would be conducted over the next several days. Chapter task group chairs were asked to present a review of public inputs for the chapter with recommendations as to which suggested changes should be accepted and which should not. Don asked task group chairs to point out which public inputs were substantive and which were editorial in nature so that the Committee could focus on the review of substantive changes. He explained that the Committee would then be asked to vote on accepting the recommended changes for the chapter as a whole unless there was a controversial issue that required further discussion. Once all the chapter changes were accepted, the Committee would use the new chapter revisions as a basis for any additional changes to be made for the remainder of the meeting. 2. Committee members and attendees introduced themselves and their affiliation. Chris Dubay, VP of Codes and Standards welcomed the group and congratulated the Committee for getting the preliminary draft completed. Guests joining the meeting over the four days included many Quincy NFPA staff, Terry Krug, Chair of ASSE Z 117.1 (Day Two) and Timothy Healey, ASSE Z117.1 committee member (Day 4). 3. Meeting Minutes from Feb 11th, 2014 adobe connect/conference call were approved. 4. Nancy Pearce, NFPA Staff, reviewed the First Draft revision process and timeline with the Committee. Nancy also provided a PowerPoint summary of the requirements of the NFPA Manual of Style. 5. Before moving ahead with additional revision of the preliminary draft, Adam Jones, Committee Secretary, reviewed the basic document tenets with the committee and outstanding issues still to be decided by the committee for consistency throughout the document. Basic tenets already agreed upon included: Document will use the term confined space rather than permit required confined space Document should cover all confined spaces and all hazards independent of industry Document should be able to be used in other countries Document should not conflict with OSHA Permit Required Confined Space Standard or other existing, well recognized standards such as ASSE Z117.1 Document should in no cases be less stringent than OSHA 1910.146 so that NFPA 350 can be used to supplement OSHA’s requirements. Stricter recommendations are OK. All confined spaces should be “evaluated” prior to entry Still to be decided were issues such as: What should the initial evaluation format look like? Permit, other Should air monitoring be required for all spaces? What is the role of owner/operator, contractor vs. employer? Terminology needs to be consistent. Who issues the permit? Permit issuer versus Entry supervisor What terminology should be used throughout document? Gas versus Atmospheric monitoring What are acceptable atmospheric conditions for entry? After significant discussion it was decided that the initial evaluation for all confined spaces would be called a preevaluation form and that a permit would be required if any of the pre-evaluation answers indicated that a hazard or potential hazard existed. This pre-evaluation document would be part of the form used for the permit. It was also decided that air monitoring would be the default for pre-entry evaluation. However, verbiage would be added to explain that in cases where it is clear that a hazardous atmosphere would never exist (for example a ventilation duct which had been running that was shut off right before entry) there is an option for entering without pre atmospheric monitoring. It was decided that the term owner/operator would be used and defined for consistency throughout the document. The term entrant employer was also added and defined. It was also ultimately decided that the term permit issuer would be eliminated from the document and that all pre-entry evaluations and permits would be signed by the entry supervisor. It was also decided that a “gas tester” would use a “gas monitor” to perform “atmospheric monitoring”. The committee also decided that atmospheric conditions that were acceptable for entry would be O2 (19.5-22%), LEL (10%) and Toxics (half the acceptable exposure limit). The upper level oxygen limit of 22% will be used since there is nothing in nature that would cause oxygen levels to increase therefore the 22% is a trigger that should be used to determine the source oxygen. There was some discussion about the use of OSHA’s 23.5% which reportedly was based on allowable Grade D breathing air oxygen upper limits. It was noted that marine chemists have used 22% upper limit for many years. *Adobe Connect 6. Task group reports/Chapter review and review of Public Inputs. Task group chairs provided verbal or PowerPoint Presentations on the public inputs that were reviewed and which were recommended for incorporation into the next chapter draft. Recommended substantive changes were discussed and the full committee voted on the new chapter drafts. 7. Terry Krug, ASSE Z117.1 Chair addressed the committee on Day 2. He indicated that he understood that this was a “best practices” guide and not a standard and would like to see this document become a “How To” document to assist in compliance with various standards including OSHA 1910.146 and ASSE Z117.1. He indicated that he did not see any duplication or conflict with the ASSE document. Terry provided a number of comments and suggestions to the committee. These included: Should refine what the trigger is for a permit-What is a serious hazard? Refine and expand on inerting and requirements related to entry Add notes about bump testing to clarify that humidity (including breathing into the sensor) can lead to interferences) Clarify that SCBA is required for entry monitoring for unknown atmospheres Recommend that any oxygen level less than 20.9% be investigated. Recommend explanatory material for oxygen limits. Terry also provided notes from his review of the preliminary draft document for the chapter task groups to review. Terry stayed for the full day meeting and participated in committee discussions. 8. Nicole Gorman of Encon, a Canadian Wind Turbine company called in to the meeting to discuss the possibility of incorporating annex material on confined spaces in wind turbines into the document. Nicole presented the unique challenges dealing with wind turbine confined spaces and provided a draft outline of the issues for possible incorporation into the document. After lengthy discussion, the committee decided not to add annex material specific for any single industry at this time. The committee indicated that the intent of the document was to address the hazards of all confined spaces and hazards generically so that the document can apply to wind turbines as well as other more unique spaces. Nicole and the wind turbine industry will be asked to make comments to specific sections of the document at second draft if there are requirements that need to be clarified for their particular type of entry. 9. Casey Grant from the Research Foundation addressed the group on Day 3. Casey presented a fatality case he had been involved with a number of years ago where he believed that a confined space was involved. He also explained what the Research Foundation Code Fund could do to possibly assist the committee in their work as the document continues to develop. 10. Tim Healey, ASSE committee member, addressed the committee on Day 4. He indicated that he reviewed the modified chapter drafts that were emailed out so far and is pleased with the direction the committee is taking with the document being a guide and not a standard. Tim submitted several PIs that were reviewed and incorporated into the revised document. Tim stayed for the full day meeting and participated in committee discussions. 11. Nancy explained that the next meeting (second draft) would have to be scheduled after the comment closing date of November 14, 2014 of but before May 1, 2015. The committee generally agreed that the February March timeframe would work best for the meeting. Several options for meeting locations were discussed including Jacksonville, Fort Lauderdale, Dallas, New Orleans and San Antonio. A poll will be sent to the full committee on dates and locations later in the year. 12. Meeting was adjourned at 3:45 PM on April 10, 2015. *Adobe Connect 2015 FALL REVISION CYCLE *Public Input Dates may vary according to standards and schedules for Revision Cycles may change. Please check the NFPA Website for the most up‐to‐date information on Public Input Closing Dates and schedules at www.nfpa.org/document# (i.e. www.nfpa.org/101) and click on the Next Edition tab. Process Stage Public Input Stage (First Draft) Comment Stage (Second Draft) Dates for TC Dates for TC with CC Public Input Closing Date for Paper Submittal* Public Input Closing Date for Online Submittal (e‐PI)* Final Date for TC First Draft Meeting Posting of First Draft and TC Ballot Final date for Receipt of TC First Draft ballot Final date for Receipt of TC First Draft ballot ‐ recirc Posting of First Draft for CC Meeting Final date for CC First Draft Meeting Posting of First Draft and CC Ballot Final date for Receipt of CC First Draft ballot Final date for Receipt of CC First Draft ballot ‐ recirc Post First Draft Report for Public Comment 11/29/2013 1/3/2014 6/13/2014 8/1/2014 8/22/2014 8/29/2014 9/5/2014 11/29/2013 1/3/2014 3/14/2014 4/25/2014 5/16/2014 5/23/2014 5/30/2014 7/11/2014 8/1/2014 8/22/2014 8/29/2014 9/5/2014 Public Comment Closing Date for Paper Submittal* Public Comment Closing Date for Online Submittal (e‐PC)* Final Date to Publish Notice of Consent Standards (Standards that received no Comments) Appeal Closing Date for Consent Standards (Standards that received no Comments) Final date for TC Second Draft Meeting Posting of Second Draft and TC Ballot Final date for Receipt of TC Second Draft ballot 10/10/2014 11/14/2014 11/28/2014 10/10/2014 11/14/2014 11/28/2014 12/12/2014 12/12/2014 5/1/2015 6/12/2015 7/3/2015 1/23/2015 3/6/2015 3/27/2015 Final date for receipt of TC Second Draft ballot ‐ recirc Posting of Second Draft for CC Meeting Final date for CC Second Draft Meeting Posting of Second Draft for CC Ballot Final date for Receipt of CC Second Draft ballot Final date for Receipt of CC Second Draft ballot ‐ recirc Post Second Draft Report for NITMAM Review 7/10/2015 7/17/2015 4/3/2015 4/10/2015 5/22/2015 6/12/2015 7/3/2015 7/10/2015 7/17/2015 8/21/2015 10/16/2015 8/21/2015 10/16/2015 10/31/2015 11/10/2015 10/31/2015 11/10/2015 6/6‐9/2016 6/6‐9/2016 6/29/2016 8/4/2016 6/29/2016 8/4/2016 Process Step Tech Session Notice of Intent to Make a Motion (NITMAM) Closing Date Preparation Posting of Certified Amending Motions (CAMs) and Consent Standards (& Issuance) Appeal Closing Date for Consent Standards (15 days) SC Issuance Date for Consent Standards (10 days) Tech Session Association Meeting for Standards with CAMs Appeals and Appeal Closing Date for Standards with CAMs Issuance SC Issuance Date for Standards with CAMs Approved___ October 30, 2012 Revised____March 7, 2013____________ National Fire Protection Association Report 1 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 1-NFPA 350-2014 [ Global Input ] Inconsistency: 7.14 and 8.4.1 states Oxygen levels should be 19.5-22.0 % while the permit B.1 states 19.0-22.5%. OSHA 1910.146(b) states 19.5-23.5%. Statement of Problem and Substantiation for Public Comment Inconsistency: 7.14 and 8.4.1 states Oxygen levels should be 19.5-22.0 % while the permit B.1 states 19.0-22.5%. OSHA 1910.146(b) states 19.5-23.5%. Proposal: keep information as stated by OSHA 1910.146 (b) for acceptable Oxygen entry levels. Related Item First Revision No. 7-NFPA 350-2014 [Chapter 8] Submitter Information Verification Submitter Full Name: MATT BENNETT Organization: CHARTER COMMUNICATIONS Street Address: City: State: Zip: Submittal Date: Mon Sep 08 13:21:42 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 2 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 274-NFPA 350-2014 [ Section No. 1.1.1 ] 1.1.1 This guide is intended to provide information to help protect workers who enter confined spaces. Statement of Problem and Substantiation for Public Comment Clarification Related Item First Revision No. 1-NFPA 350-2014 [Chapter 1] Submitter Information Verification Submitter Full Name: TERRY W KRUG Organization: EXOSHA INC Street Address: City: State: Zip: Submittal Date: Thu Nov 13 17:04:08 EST 2014 12/12/2014 2:22 PM National Fire Protection Association Report 3 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 289-NFPA 350-2014 [ Section No. 1.1.1 ] 1.1.1 This guide is intended to provide information to protect workers who enter and work in confined spaces. Statement of Problem and Substantiation for Public Comment Encompass working in confined spaces as well as it is mentioned in other areas of the document. Related Item Public Input No. 1-NFPA 350-2013 [Section No. 1.1.1] Submitter Information Verification Submitter Full Name: Nicole Gorman Organization: ENERCON Services Nova Scotia Street Address: City: State: Zip: Submittal Date: Thu Nov 13 18:25:26 EST 2014 12/12/2014 2:22 PM National Fire Protection Association Report 4 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 92-NFPA 350-2014 [ Section No. 1.1.1 ] 1.1.1 This guide is intended to provide information to protect workers who enter confined , work inside of, and work outside of and adjacent to confined spaces. Statement of Problem and Substantiation for Public Comment this will encompass all of the activities listed in this chapter as well as those in all of the subsequent chapters of the proposed document Related Item Public Input No. 726-NFPA 350-2013 [Section No. 1.1.1] Submitter Information Verification Submitter Full Name: Richard Kraus Organization: API/Petroleum Safety Consultan Street Address: City: State: Zip: Submittal Date: Tue Sep 23 08:16:16 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 5 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 290-NFPA 350-2014 [ Section No. 1.1.4 ] 1.1.4 This guide provides information on how to understand confined space safety and safeguard personnel from fire, explosion, safety, and health hazards that are commonly associated with confined space entry and work . Statement of Problem and Substantiation for Public Comment The list with the word "safety" is hard to understand. I removed the word safety for that reason. I also added "and work" to help encompass the work that is being performed in a confined space as well. Related Item Public Input No. 2-NFPA 350-2013 [Section No. 4.3] Submitter Information Verification Submitter Full Name: Nicole Gorman Organization: ENERCON Services Nova Scotia Street Address: City: State: Zip: Submittal Date: Thu Nov 13 18:26:24 EST 2014 12/12/2014 2:22 PM National Fire Protection Association Report 6 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 252-NFPA 350-2014 [ Section No. 1.1.8 ] 1.1.8 This guide provides information regarding hazards adjacent to confined spaces that might affect the safe conditions necessary for entry and work in aconfined a confined space. Statement of Problem and Substantiation for Public Comment correct spacing aconfined Related Item First Revision No. 1-NFPA 350-2014 [Chapter 1] Submitter Information Verification Submitter Full Name: EMERY THOMAS Organization: CONOCOPHILLIPS Street Address: City: State: Zip: Submittal Date: Wed Nov 05 19:14:24 EST 2014 12/12/2014 2:22 PM National Fire Protection Association Report 7 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 292-NFPA 350-2014 [ Section No. 1.1.8 ] 1.1.8 This guide provides information regarding hazards adjacent to confined spaces that might affect the safe conditions necessary for entry and work in aconfined a confined space. Statement of Problem and Substantiation for Public Comment Space needed between "a" and "confined" Related Item Public Input No. 3-NFPA 350-2013 [Section No. 5.4] Submitter Information Verification Submitter Full Name: Nicole Gorman Organization: ENERCON Services Nova Scotia Street Address: City: State: Zip: Submittal Date: Thu Nov 13 18:31:15 EST 2014 12/12/2014 2:22 PM National Fire Protection Association Report 8 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 275-NFPA 350-2014 [ Section No. 2.3.1 ] 2.3.1 AIHA not AIAH Publications. American Industrial Hygiene Association, 3141 Fairview Park Drive, Suite 777, Falls Church, VA 22042. “Prevention through Design: Eliminating Confined Spaces and Minimizing Hazards.” AIHA Confined Spaces Committee. https://www.aiha.org/government-affairs/PositionStatements /PtD%20Conf%20Space%20AIHA%20-%20BOD%20Approved.pdf. Statement of Problem and Substantiation for Public Comment Incorrect spelling of AIHA Related Item First Revision No. 2-NFPA 350-2014 [Chapter 2] Submitter Information Verification Submitter Full Name: TERRY W KRUG Organization: EXOSHA INC Affilliation: ANSI Z117.1 Street Address: City: State: Zip: Submittal Date: Thu Nov 13 17:07:20 EST 2014 12/12/2014 2:22 PM National Fire Protection Association Report 9 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 276-NFPA 350-2014 [ Section No. 2.3.2 ] 2.3.2 ANSI Publications. American National Standards Institute, Inc., 25 West 43rd Street, 4th Floor, New York, NY 10036. ANSI/AIHA/ASSE Z10, Occupational Health and Safety Management Systems, 2012. ANSI Z49.1, Safety in Welding, Cutting, and Allied Processes, 2012. ANSI/ASSE Z 117.1, Safety Requirements for Confined Spaces, 2009. ANSI/ASSE Z590.3, Prevention Through Design: Guidelines for Addressing Occupation Hazards & Risks in the Design & Redesign Processes, 2011. ANSI/AIHA Z 244 Control of Hazardous Energy - Lockout/Tagout & Alternative Methods Statement of Problem and Substantiation for Public Comment Applicable additional ANSI standards on LOTO Related Item First Revision No. 2-NFPA 350-2014 [Chapter 2] Submitter Information Verification Submitter Full Name: TERRY W KRUG Organization: EXOSHA INC Affilliation: ANSI/ASSE Street Address: City: State: Zip: Submittal Date: Thu Nov 13 17:11:24 EST 2014 12/12/2014 2:22 PM National Fire Protection Association Report 10 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 93-NFPA 350-2014 [ Section No. 2.3.3 ] 2.3.3 API Publications. American Petroleum Institute, 1120 1220 L Street, NW, Washington, DC 20005-4070. API 653, Tank Inspection, Repair, Alteration, and Reconstruction, 2009. API 2003, Recommended Practice on Protection Against Ignitions Arising out of Static, Lightning, and Stray Currents, 2008. API 2009, Safe Welding and Cutting Practices in Refineries, Gasoline Plants, and Petrochemical Plants, 2002. API 2015, Requirement for Safe Entry and Cleaning of Petroleum Tanks, 2001. API 2016, Guidelines and Procedures for Entering and Cleaning Petroleum Storage Tanks, 2001. API 2027, Ignition Hazards and Safe Working Practice for Abrasive Blasting of Atmospheric Storage Tanks in Hydrocarbon Service, 2002. API 2201, Safe Hot Tapping Practices in the Petroleum & Petrochemical Industries, 2003. API 2202, Guidelines for Protecting Against Lead Hazard when Dismantling and Disposing of Steel from Tanks that Have Contained Leaded Gasoline, 1991. API 2207, Preparing Tank Bottoms for Hot Work, 2007. API 2217A, Guidelines for Safe Work in Inert Confined Spaces in the Petroleum and Petrochemical Industries, 2009. API 2219, Safe Operations of Vacuum Trucks in Petroleum Service, 2005. Statement of Problem and Substantiation for Public Comment editorial corrects address Related Item Public Input No. 216-NFPA 350-2013 [Chapter 2] Submitter Information Verification Submitter Full Name: Richard Kraus Organization: API/Petroleum Safety Consultan Street Address: City: State: Zip: Submittal Date: Tue Sep 23 08:27:34 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 11 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 295-NFPA 350-2014 [ Section No. 2.3.7 ] 2.3.7 Other Publications. Merriam-Webster’s Collegiate Dictionary, 11th edition, Merriam-Webster, Inc., Springfield, MA, 2003. Gabel, D., Hasit, Y., and Thompson, K., Design Considerations in Water, Wastewater, and Stormwater Utility Security, American Society of Civil Engineers (2008). CSA Z1006-10, Management of Work in Confined Spaces , 2010 edition. Statement of Problem and Substantiation for Public Comment Added the CSA standard for confined space work to help encompass other countries to provide a cohesive picture. Related Item Public Input No. 4-NFPA 350-2013 [Section No. 8.8.2.2] Submitter Information Verification Submitter Full Name: Nicole Gorman Organization: ENERCON Services Nova Scotia Street Address: City: State: Zip: Submittal Date: Thu Nov 13 18:39:44 EST 2014 12/12/2014 2:22 PM National Fire Protection Association Report 12 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 334-NFPA 350-2014 [ Section No. 2.4 ] 2.4 References for Extracts in Mandatory Sections. NFPA 51B, Standard for Fire Prevention During Welding, Cutting, and Other Hot Work, 2014 edition. ® ® NFPA 70 , National Electrical Code , 2014 edition. NFPA 77, Recommended Practice on Static Electricity, 2014 edition. NFPA 99, Health Care Facilities Code, 2015 edition. NFPA 302, Fire Protection Standard for Pleasure and Commercial Motor Craft, 2015 edition. NFPA 326, Standard for the Safeguarding of Tanks and Containers for Entry, Cleaning, or Repair, 2015 edition. NFPA 1006, Standard for Technical Rescuer Professional Qualifications, 2013 edition. NFPA 1026, Standard for Incident Management Personnel Professional Qualifications, 2014 edition. NFPA 1451, Standard for a Fire and Emergency Service Vehicle Operations Training Program, 2013 edition. NFPA 1521, Standard for Fire Department Safety Officer Professional Qualifications, 2015 edition. NFPA 1561, Standard on Emergency Services Incident Management System and Command Safety, 2014 edition. NFPA 1670, Standard on Operations and Training for Technical Search and Rescue Incidents, 2014 edition. Statement of Problem and Substantiation for Public Comment Section title referenced “Mandatory Sections” where this guideline does not have any Mandatory Sections, Although this normally works with the NFPA style, this section title should be modified as confusion to users will arise. Related Item First Revision No. 2-NFPA 350-2014 [Chapter 2] Submitter Information Verification Submitter Full Name: EMERY THOMAS Organization: CONOCOPHILLIPS Street Address: City: State: Zip: Submittal Date: Fri Nov 14 11:02:38 EST 2014 12/12/2014 2:22 PM National Fire Protection Association Report 13 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 296-NFPA 350-2014 [ Section No. 3.3.3 ] 3.3.3 Accidents. Unplanned events that result in injuries or damage that interrupts routine operations. Statement of Problem and Substantiation for Public Comment 3.3.2 and 3.3.3 are almost the exact same definition. Redundant to have both. Related Item Public Input No. 5-NFPA 350-2013 [Section No. 10.1.1] Submitter Information Verification Submitter Full Name: Nicole Gorman Organization: ENERCON Services Nova Scotia Street Address: City: State: Zip: Submittal Date: Thu Nov 13 18:45:34 EST 2014 12/12/2014 2:22 PM National Fire Protection Association Report 14 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 298-NFPA 350-2014 [ Section No. 3.3.4 ] 3.3.4 Adjacent Space. Those spaces in all directions from subject a confined space, including points of contact, internal and external, such as decks, sumps, floating roofs, secondary containment areas, interstitial spaces, under floors, supports, tank tops, and bulkheads. [326, 2015] Statement of Problem and Substantiation for Public Comment Removed subject space and replaced it with confined. It ensures the same terminology is used throughout the document. Related Item Public Input No. 6-NFPA 350-2013 [Section No. 10.1.2 [Excluding any Sub-Sections]] Submitter Information Verification Submitter Full Name: Nicole Gorman Organization: ENERCON Services Nova Scotia Street Address: City: State: Zip: Submittal Date: Thu Nov 13 18:46:45 EST 2014 12/12/2014 2:22 PM National Fire Protection Association Report 15 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 262-NFPA 350-2014 [ Section No. 3.3.5 ] 3.3.5 Administrative Controls (Work Practice Controls). Changes in work Work procedures such as written safety policies, rules, supervision, schedules, and training with the goal of reducing the duration, frequency, and severity of exposure to hazardous chemical situations. Statement of Problem and Substantiation for Public Comment Definition of administrative controls (work practice controls) starts with “Changes in work procedures such a safety policies, rules, … Remove “Changes in” not relevant to the definition. Related Item First Revision No. 16-NFPA 350-2014 [Chapter 3] Submitter Information Verification Submitter Full Name: EMERY THOMAS Organization: CONOCOPHILLIPS Street Address: City: State: Zip: Submittal Date: Mon Nov 10 18:21:16 EST 2014 12/12/2014 2:22 PM National Fire Protection Association Report 16 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 277-NFPA 350-2014 [ Section No. 3.3.5 ] 3.3.5 Administrative Controls (Work Practice Controls). Changes in work procedures such as written safety policies, rules, supervision, schedules, and training with the goal of reducing the duration, frequency, and severity of exposure s to hazardous chemical situations. hazards . ( this takes in account physical hazards like noise, ergonomic, vibration, etc). Statement of Problem and Substantiation for Public Comment This takes in account other hazards than chemical. Related Item First Revision No. 16-NFPA 350-2014 [Chapter 3] Submitter Information Verification Submitter Full Name: TERRY W KRUG Organization: EXOSHA INC Affilliation: ANSI/ASSE Street Address: City: State: Zip: Submittal Date: Thu Nov 13 17:23:37 EST 2014 12/12/2014 2:22 PM National Fire Protection Association Report 17 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 301-NFPA 350-2014 [ Section No. 3.3.5 ] 3.3.5 Administrative Controls (Work Practice Controls). Changes in work procedures such as written safety policies, rules, supervision, schedules, and training with the goal of reducing the duration, frequency, and severity of exposure to hazardous chemical situations. Statement of Problem and Substantiation for Public Comment Not sure why there was a focus on just chemical hazards. I removed the work chemical to broaden the scope of hazards. Related Item Public Input No. 7-NFPA 350-2013 [Section No. 10.1.2.1] Submitter Information Verification Submitter Full Name: Nicole Gorman Organization: ENERCON Services Nova Scotia Street Address: City: State: Zip: Submittal Date: Thu Nov 13 18:50:28 EST 2014 12/12/2014 2:22 PM National Fire Protection Association Report 18 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 278-NFPA 350-2014 [ Section No. 3.3.8 ] 3.3.8 Atmospheric Monitoring. The act of using a portable or fixed gas monitor to sample the atmosphere in or around a confined space to determine the level of hazardous, gaseous contaminants present. Statement of Problem and Substantiation for Public Comment Atmospheric monitoring can be fixed or portable. Related Item First Revision No. 16-NFPA 350-2014 [Chapter 3] Submitter Information Verification Submitter Full Name: TERRY W KRUG Organization: EXOSHA INC Affilliation: ANSI/ASSE Street Address: City: State: Zip: Submittal Date: Thu Nov 13 17:29:48 EST 2014 12/12/2014 2:22 PM National Fire Protection Association Report 19 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 279-NFPA 350-2014 [ Section No. 3.3.9 ] 3.3.9 Attendant. Person stationed immediately on the outside of the space, assigned to oversee and support entrants while they are in a confined space. (if this definition is left as is it could include an office personnel at a desk looking at a camera, or a person leaving the portal area to get some rope or gloves) Statement of Problem and Substantiation for Public Comment The attendant needs to be stationed immediately on the outside not 10 feet or more away from the portal. Related Item First Revision No. 16-NFPA 350-2014 [Chapter 3] Submitter Information Verification Submitter Full Name: TERRY W KRUG Organization: EXOSHA INC Affilliation: ANSI/ASSE Street Address: City: State: Zip: Submittal Date: Thu Nov 13 17:32:06 EST 2014 12/12/2014 2:22 PM National Fire Protection Association Report 20 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 302-NFPA 350-2014 [ Section No. 3.3.9 ] 3.3.9 Attendant. Person A competent person assigned to oversee and support entrants while they are in a confined space. Statement of Problem and Substantiation for Public Comment clarifies that an attendant should be a competent person. Related Item Public Input No. 8-NFPA 350-2013 [Section No. 10.1.2.2 [Excluding any Sub-Sections]] Submitter Information Verification Submitter Full Name: Nicole Gorman Organization: ENERCON Services Nova Scotia Street Address: City: State: Zip: Submittal Date: Thu Nov 13 18:54:23 EST 2014 12/12/2014 2:22 PM National Fire Protection Association Report 21 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 280-NFPA 350-2014 [ Section No. 3.3.11 ] 3.3.11 Bump Testing. A brief exposure of the gas monitors/sensors to to a level of specific gas above the sensor's alarm set point to verify sensor and alarm functionality, not as a measure of gas monitor/sensor accuracy. Statement of Problem and Substantiation for Public Comment The bump test gas needs to be at a concentration above the alarm set points. Related Item First Revision No. 16-NFPA 350-2014 [Chapter 3] Submitter Information Verification Submitter Full Name: TERRY W KRUG Organization: EXOSHA INC Affilliation: ANSI/ASSE Street Address: City: State: Zip: Submittal Date: Thu Nov 13 17:39:11 EST 2014 12/12/2014 2:22 PM National Fire Protection Association Report 22 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 263-NFPA 350-2014 [ Section No. 3.3.13 ] 3.3.13 Competent Person. One who is designated in writing and who is capable of identifying existing and predictable hazards in the surroundings or working conditions that are unsanitary, hazardous, or dangerous to employees, and who has authorization to take prompt corrective measures to eliminate them. Statement of Problem and Substantiation for Public Comment The definition of Competent Person recommend to remove “…designated in writing...” Related Item First Revision No. 16-NFPA 350-2014 [Chapter 3] Submitter Information Verification Submitter Full Name: EMERY THOMAS Organization: CONOCOPHILLIPS Street Address: City: State: Zip: Submittal Date: Mon Nov 10 18:28:53 EST 2014 12/12/2014 2:22 PM National Fire Protection Association Report 23 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 281-NFPA 350-2014 [ Section No. 3.3.13 ] 3.3.13 Competent Person. One who is designated in writing by the employer and who is capable of identifying existing and predictable hazards in the surroundings or working conditions that are unsanitary, hazardous, or dangerous to employees, and who has authorization to take prompt corrective measures to eliminate them. Statement of Problem and Substantiation for Public Comment The employer needs to specify in writing otherwise BaBa give permission. Related Item First Revision No. 16-NFPA 350-2014 [Chapter 3] Submitter Information Verification Submitter Full Name: TERRY W KRUG Organization: EXOSHA INC Affilliation: ANSI/ASSE Street Address: City: State: Zip: Submittal Date: Thu Nov 13 17:45:39 EST 2014 12/12/2014 2:22 PM National Fire Protection Association Report 24 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 305-NFPA 350-2014 [ Section No. 3.3.13 ] 3.3.13 Competent Person Supervisor . One who is designated in writing and who is capable of identifying existing and predictable hazards in the surroundings or working conditions that are unsanitary, hazardous, or dangerous to employees, and who has authorization to take prompt corrective measures to eliminate them. Statement of Problem and Substantiation for Public Comment It mentions that someone that can take prompt corrective measures. In most organizations, that is the Supervisor who has that authority. Related Item Public Input No. 9-NFPA 350-2013 [Section No. 10.1.2.2.1] Submitter Information Verification Submitter Full Name: Nicole Gorman Organization: ENERCON Services Nova Scotia Street Address: City: State: Zip: Submittal Date: Thu Nov 13 19:04:06 EST 2014 12/12/2014 2:22 PM National Fire Protection Association Report 25 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 306-NFPA 350-2014 [ Section No. 3.3.15 ] 3.3.15 Confined Space Rescue Service. The confined space rescue team designated by the owner/operator or entrant employer to rescue victims from within confined spaces, including operational and technical levels of industrial, municipal, and private sector organizations external service providers . Statement of Problem and Substantiation for Public Comment Aligns the terminology with the CSA standard on confined spaces. Related Item Public Input No. 10-NFPA 350-2013 [Section No. 10.1.2.2.2 [Excluding any Sub-Sections]] Submitter Information Verification Submitter Full Name: Nicole Gorman Organization: ENERCON Services Nova Scotia Street Address: City: State: Zip: Submittal Date: Thu Nov 13 19:06:30 EST 2014 12/12/2014 2:22 PM National Fire Protection Association Report 26 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 282-NFPA 350-2014 [ Section No. 3.3.19 ] 3.3.19 Engineering Controls. A method of eliminating or reducing exposure to a chemical or physical hazard through the use of engineered specially designed machinery or equipment. Statement of Problem and Substantiation for Public Comment Do not use the word defined in the definition. Related Item First Revision No. 16-NFPA 350-2014 [Chapter 3] Submitter Information Verification Submitter Full Name: TERRY W KRUG Organization: EXOSHA INC Affilliation: ANSI/ASSE Street Address: City: State: Zip: Submittal Date: Thu Nov 13 17:47:07 EST 2014 12/12/2014 2:22 PM National Fire Protection Association Report 27 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 335-NFPA 350-2014 [ Section No. 3.3.19 ] 3.3.19 Engineering Controls. A method of eliminating or reducing exposure to a chemical or physical hazard through design, elimination, alternate lower hazard design or the use of engineered machinery or equipment. Statement of Problem and Substantiation for Public Comment Provides a more complete and properly focused definition of "Engineering Controls" Related Item First Revision No. 16-NFPA 350-2014 [Chapter 3] Submitter Information Verification Submitter Full Name: EMERY THOMAS Organization: CONOCOPHILLIPS Street Address: City: State: Zip: Submittal Date: Fri Nov 14 11:29:41 EST 2014 12/12/2014 2:22 PM National Fire Protection Association Report 28 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 309-NFPA 350-2014 [ Section No. 3.3.21 ] 3.3.21 Entrant Employer. The person(s) or organization responsible for personnel under their employ who make entry into a specific confined space. Statement of Problem and Substantiation for Public Comment The word specific narrows the scope too much. Related Item Public Input No. 12-NFPA 350-2013 [Section No. 10.1.2.4] Submitter Information Verification Submitter Full Name: Nicole Gorman Organization: ENERCON Services Nova Scotia Street Address: City: State: Zip: Submittal Date: Thu Nov 13 19:11:48 EST 2014 12/12/2014 2:22 PM National Fire Protection Association Report 29 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 308-NFPA 350-2014 [ New Section after 3.3.22 ] Entry. When a person enters any bodily part into a confined space. Statement of Problem and Substantiation for Public Comment Defines entry and the fact that even if you put your hand in, your entering a confined space and should follow necessary procedures. Related Item Public Input No. 11-NFPA 350-2013 [Section No. 10.1.2.2.3.1(A)] Submitter Information Verification Submitter Full Name: Nicole Gorman Organization: ENERCON Services Nova Scotia Street Address: City: State: Zip: Submittal Date: Thu Nov 13 19:09:29 EST 2014 12/12/2014 2:22 PM National Fire Protection Association Report 30 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 283-NFPA 350-2014 [ Section No. 3.3.22 ] 3.3.22 Entry Supervisor. The person(s) responsible for overseeing entry operations for a given confined space (they may or may not be the competent person for the task) . Statement of Problem and Substantiation for Public Comment Needed for clarification because someone may ask if the entry supervisor is the competent person for rescue or selection of respirators. Related Item First Revision No. 16-NFPA 350-2014 [Chapter 3] Submitter Information Verification Submitter Full Name: TERRY W KRUG Organization: EXOSHA INC Affilliation: ANSI/ASSE Street Address: City: State: Zip: Submittal Date: Thu Nov 13 17:51:08 EST 2014 12/12/2014 2:22 PM National Fire Protection Association Report 31 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 310-NFPA 350-2014 [ Section No. 3.3.24 ] 3.3.24* Explosionproof. Referring to an apparatus enclosed in a case that is capable of withstanding an explosion of a specified gas or vapor that might occur within it and of preventing the ignition of a specified gas or vapor surrounding the enclosure by sparks, flashes, or explosion of the gas or vapor within and that operates at such an external temperature that a surrounding flammable atmosphere will not be ignited thereby. [70, 2014] Statement of Problem and Substantiation for Public Comment grammer correction Related Item Public Input No. 13-NFPA 350-2013 [Section No. 7.6.6] Submitter Information Verification Submitter Full Name: Nicole Gorman Organization: ENERCON Services Nova Scotia Street Address: City: State: Zip: Submittal Date: Thu Nov 13 19:13:13 EST 2014 12/12/2014 2:22 PM National Fire Protection Association Report 32 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 284-NFPA 350-2014 [ Section No. 3.3.28 ] 3.3.28 Gas Tester. Qualified person(s) responsible for operating a gas monitor and able to interpret results for atmospheric monitoring. Statement of Problem and Substantiation for Public Comment The atmospheric tester must be able to interpret results not just take the readings. Related Item First Revision No. 16-NFPA 350-2014 [Chapter 3] Submitter Information Verification Submitter Full Name: TERRY W KRUG Organization: EXOSHA INC Affilliation: ANSI/ASSE Street Address: City: State: Zip: Submittal Date: Thu Nov 13 17:53:48 EST 2014 12/12/2014 2:22 PM National Fire Protection Association Report 33 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 286-NFPA 350-2014 [ Section No. 3.3.32 ] 3.3.32 Hierarchy of Controls. A system used to minimize or eliminate exposure to hazards. Hazardous Atmosphere. An atmosphere that may expose employees to death, incapacitation, impairment of their ability to self rescue, injury from one of the following: Atmospheric oxygen < 19.5% or > 23.5%/volume Flammable gas or vapor > 10% LFL Any substance which has a published PEL and is over it's IDLH level of that substance Any other atmospheric condition that is IDLH Statement of Problem and Substantiation for Public Comment Hierarchy of controls is not a needed term. It should be substituted with Hazardous Atmosphere because it is discussed in many parts of the guide especially in the definition of permit space. Related Item First Revision No. 16-NFPA 350-2014 [Chapter 3] Submitter Information Verification Submitter Full Name: TERRY W KRUG Organization: EXOSHA INC Affilliation: ANSI/ASSE Street Address: City: State: Zip: Submittal Date: Thu Nov 13 18:05:54 EST 2014 12/12/2014 2:22 PM National Fire Protection Association Report 34 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 287-NFPA 350-2014 [ Section No. 3.3.34 ] 3.3.34 Hot Work. Any activity that creates a source of ignition, including, but not limited to, welding, cutting, open flames, frictional heat or sparks, smoking, operation of internal combustion engines and use of nonapproved and nonauthorized electrical equipment. .(unapproved electrical equip doesn't create a source of ignition, although it my be a potential) Statement of Problem and Substantiation for Public Comment Unapproved equipment does not create an ignition source by itself. It could under certain circumstances be an ignition source. We are defining Hot Work. Related Item First Revision No. 16-NFPA 350-2014 [Chapter 3] Submitter Information Verification Submitter Full Name: TERRY W KRUG Organization: EXOSHA INC Affilliation: ANSI/ASSE Street Address: City: State: Zip: Submittal Date: Thu Nov 13 18:16:48 EST 2014 12/12/2014 2:22 PM National Fire Protection Association Report 35 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 311-NFPA 350-2014 [ New Section after 3.3.35 ] IDLH. Immediately dangerous to life or health. Statement of Problem and Substantiation for Public Comment Important abbreviation. Maybe there should be a section just for abbreviations? For example; LEL, LFL, etc. Related Item Public Input No. 13-NFPA 350-2013 [Section No. 7.6.6] Submitter Information Verification Submitter Full Name: Nicole Gorman Organization: ENERCON Services Nova Scotia Street Address: City: State: Zip: Submittal Date: Thu Nov 13 19:16:34 EST 2014 12/12/2014 2:22 PM National Fire Protection Association Report 36 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 288-NFPA 350-2014 [ Section No. 3.3.36 ] 3.3.36 Inert Gas. A nonreactive, nonflammable, noncorrosive gas such as argon, nitrogen, and carbon dioxide. or nitrogen. (Carbon dioxide is not inert, it has a PEL and will increase a human's heart rate if elevated enough) Statement of Problem and Substantiation for Public Comment Carbon dioxide is not inert or non-reactive. It helps regulates the breathing rate and has a PEL. So argon and nitrogen are good examples of inert gasses. Related Item First Revision No. 16-NFPA 350-2014 [Chapter 3] Submitter Information Verification Submitter Full Name: TERRY W KRUG Organization: EXOSHA INC Affilliation: ANSI/ASSE Street Address: City: State: Zip: Submittal Date: Thu Nov 13 18:21:54 EST 2014 12/12/2014 2:22 PM National Fire Protection Association Report 37 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 291-NFPA 350-2014 [ Section No. 3.3.37 ] 3.3.37 Inerting. The displacement of gas or vapors and oxygen (air) using an inert gas to eliminate the possibility of a potentially hazardous or flammable atmosphere in a confined space. ( Delete hazardous because nitrogen is hazardous by lowering the oxygen levels) Statement of Problem and Substantiation for Public Comment Delete hazardous because nitrogen is hazardous by displacing the oxygen. Related Item First Revision No. 16-NFPA 350-2014 [Chapter 3] Submitter Information Verification Submitter Full Name: TERRY W KRUG Organization: EXOSHA INC Affilliation: ANSI/ASSE Street Address: City: State: Zip: Submittal Date: Thu Nov 13 18:29:00 EST 2014 12/12/2014 2:22 PM National Fire Protection Association Report 38 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 293-NFPA 350-2014 [ Section No. 3.3.39 ] 3.3.39* Job Hazard Analysis (JHA). A safety management risk assessment (RA) technique that is used to define and control the actual or potential hazards associated with any process, job, or procedure that has actual or potential hazards . Statement of Problem and Substantiation for Public Comment Clearer wording modifying hazards. Related Item First Revision No. 16-NFPA 350-2014 [Chapter 3] Submitter Information Verification Submitter Full Name: TERRY W KRUG Organization: EXOSHA INC Affilliation: ANSI/ASSE Street Address: City: State: Zip: Submittal Date: Thu Nov 13 18:33:45 EST 2014 12/12/2014 2:22 PM National Fire Protection Association Report 39 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 294-NFPA 350-2014 [ Section No. 3.3.41 ] 3.3.41 Lower Explosive Limit (LEL). The lowest volume concentration of a combustible gas flammable gas or vapor or combustible dust that when mixed with air will ignite creating a when ignited may create a fire or explosion. Statement of Problem and Substantiation for Public Comment To properly define LEL flammable vapor or gas needs to be mentioned along with combustible dust and you need the mixture with air to be correct and an ignition source hot enough to make the reaction occur. Just having all those elements present without an ignition source will not cause a fire or explosion. Related Item First Revision No. 16-NFPA 350-2014 [Chapter 3] Submitter Information Verification Submitter Full Name: TERRY W KRUG Organization: EXOSHA INC Affilliation: ANSI/ASSE Street Address: City: State: Zip: Submittal Date: Thu Nov 13 18:37:34 EST 2014 12/12/2014 2:22 PM National Fire Protection Association Report 40 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 297-NFPA 350-2014 [ Section No. 3.3.45 ] 3.3.45* Occupational Exposure Limit (OEL) . The maximum amount in air of a hazardous material that a worker should be exposed to for a given period of time, also known as permissible exposure limit ( PEL - OSHA), recommended exposure limit ( REL - NIOSH), and threshold limit value ( TLV - ACGIH). Statement of Problem and Substantiation for Public Comment The exposure limits must be in air and the abbreviations of the OEL is necessary for clarification. Related Item First Revision No. 16-NFPA 350-2014 [Chapter 3] Submitter Information Verification Submitter Full Name: TERRY W KRUG Organization: EXOSHA INC Affilliation: ANSI/ASSE Street Address: City: State: Zip: Submittal Date: Thu Nov 13 18:46:13 EST 2014 12/12/2014 2:22 PM National Fire Protection Association Report 41 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 303-NFPA 350-2014 [ Section No. 3.3.48 ] 3.3.48 Peak Value. The highest measured concentration of combustible or toxic gas components and the lowest measured level of oxygen as detected by , as indicated by a gas monitor. Statement of Problem and Substantiation for Public Comment Peak value is not the lowest level of oxygen. Change needed for clarification. Related Item First Revision No. 16-NFPA 350-2014 [Chapter 3] Submitter Information Verification Submitter Full Name: TERRY W KRUG Organization: EXOSHA INC Affilliation: ANSI/ASSE Street Address: City: State: Zip: Submittal Date: Thu Nov 13 18:54:28 EST 2014 12/12/2014 2:22 PM National Fire Protection Association Report 42 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 304-NFPA 350-2014 [ Sections 3.3.56, 3.3.57 ] Sections 3.3.56, 3.3.57 3.3.56 Rescue Attendant. A person who is qualified to be stationed outside a confined space to monitor rescue entrants, summon assistance, and perform non-entry rescues. 3.3.57 Rescue Entrant. A person entering a confined space for the specific purpose of rescue. Are these two definitions necessary? I think they confuse the reader and no other publication has them that I know of? Statement of Problem and Substantiation for Public Comment These two definitions need to be deleted. They are not necessary and add confusion to the role of the attendant and entrant. Related Item First Revision No. 16-NFPA 350-2014 [Chapter 3] Submitter Information Verification Submitter Full Name: TERRY W KRUG Organization: EXOSHA INC Affilliation: ANSI/ASSE Street Address: City: State: Zip: Submittal Date: Thu Nov 13 19:01:45 EST 2014 12/12/2014 2:22 PM National Fire Protection Association Report 43 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 340-NFPA 350-2014 [ Section No. 3.3.68 ] 3.3.68 Safety Officer. A member of the incident command staff responsible for monitoring and assessing safety hazards or unsafe situations and for developing measures for ensuring personnel safety. [1026, 2014] Statement of Problem and Substantiation for Public Comment Insert text as shown: A member of the incident command staff …. As the context of safety officer in this document is specifically related to an incident command function, and not a normal industrial safety officer (representative). Related Item First Revision No. 16-NFPA 350-2014 [Chapter 3] Submitter Information Verification Submitter Full Name: EMERY THOMAS Organization: CONOCOPHILLIPS Street Address: City: State: Zip: Submittal Date: Fri Nov 14 11:42:16 EST 2014 12/12/2014 2:22 PM National Fire Protection Association Report 44 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 307-NFPA 350-2014 [ New Section after 3.3.69 ] TITLE OF NEW CONTENT Serious Hazard. An existing or potential biological, chemical, mechanical, atmospheric, environmental or physical agent that has the potential to cause death, or serious physical or phychological harm. Statement of Problem and Substantiation for Public Comment This definition is needed to ensure the difference is made between a confined space and a permit space. A permit space is a confined space that contains or potentially could contain a serious hazard and without a definition the reader would not be able to make that distinction. Related Item First Revision No. 16-NFPA 350-2014 [Chapter 3] Submitter Information Verification Submitter Full Name: TERRY W KRUG Organization: EXOSHA INC Affilliation: ANSI/ASSE Street Address: City: State: Zip: Submittal Date: Thu Nov 13 19:06:47 EST 2014 12/12/2014 2:22 PM National Fire Protection Association Report 45 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 315-NFPA 350-2014 [ Section No. 4.1 ] 4.1* Identification and Documentation of Permit Required Confined Spaces. The owner/operator is responsible for evaluating and documenting confined permit spaces in the entire facility, including, but not limited to, detached buildings, structures, sewers and drainage, trenches, tanks, vessels, containers, tunnels, vaults, manholes, and property grounds to determine if there are confined spaces present that are configured so they could be entered by employees, contractors, the public, or visitors to the facility. (The Chapter title should also be changed to Identification of Permit Required Confined Spaces Within a Workplace. This evaluation of permit spaces is consistant with other standards and regulations and does not confuse the reader or put an extra burden that is not required by law) Statement of Problem and Substantiation for Public Comment This is very important concept to get right from the beginning. Every confined space meeting the definition does not require all the bells and whistles of a permit space. So the difference between a confined space and a permit space is the presence or potential of containing a serious hazard. So the identification of confined spaces that pose serious issues is the thrust of this guide as well as other standards including OSHA. If this guide does not label spaces and address their work activity gearing toward how other organizations have defined confined space and permit spaces it will confuse the reader thinking that all spaces that are confined spaces under the definition need all the requirements of the entire document, the reader would be overwhelmed. So lets be consistent with regulatory standards as much as possible and ensure we stay in line with existing standards like ANSI Z117.1 and define Permit spaces based on the existence or potential to contain serious hazards. My changes in this chapter reflect permit spaces. Related Item First Revision No. 3-NFPA 350-2014 [Chapter 4] Submitter Information Verification Submitter Full Name: TERRY W KRUG Organization: EXOSHA INC Affilliation: ANSI/ASSE Street Address: City: State: Zip: Submittal Date: Fri Nov 14 09:22:44 EST 2014 12/12/2014 2:22 PM National Fire Protection Association Report 46 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 316-NFPA 350-2014 [ Section No. 4.2 ] 4.2 Identification of Confined Permit Spaces During Construction. All construction activity should be evaluated to determine if confined spaces may be present or created at any time during various construction phases. If confined spaces are identified, these evaluations should be documented and managed in accordance with a confined space program. Statement of Problem and Substantiation for Public Comment Change from confined space to permit space to be consistent. Related Item First Revision No. 3-NFPA 350-2014 [Chapter 4] Submitter Information Verification Submitter Full Name: TERRY W KRUG Organization: EXOSHA INC Affilliation: ANSI/ASSE Street Address: City: State: Zip: Submittal Date: Fri Nov 14 09:30:53 EST 2014 12/12/2014 2:22 PM National Fire Protection Association Report 47 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 318-NFPA 350-2014 [ Section No. 4.2 ] 4.2 Identification of Confined Permit Spaces During Construction. All construction activity should be evaluated to determine if confined permit spaces may be present or created at any time during various construction phases. If confined spaces are identified, these evaluations should be documented and managed in accordance with a confined space program. Statement of Problem and Substantiation for Public Comment Change confined space to permit space. Related Item First Revision No. 3-NFPA 350-2014 [Chapter 4] Submitter Information Verification Submitter Full Name: TERRY W KRUG Organization: EXOSHA INC Affilliation: ANSI/ASSE Street Address: City: State: Zip: Submittal Date: Fri Nov 14 09:34:12 EST 2014 12/12/2014 2:22 PM National Fire Protection Association Report 48 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 94-NFPA 350-2014 [ Section No. 4.2 ] 4.2 Identification of Confined Spaces During Construction. All construction activity should be evaluated to determine if confined spaces may be present or created at any time during various construction phases. If confined spaces are identified, these evaluations should be documented and managed in accordance with a the applicable owner/operator's or contractor's confined space program. Statement of Problem and Substantiation for Public Comment there is a need to specify the applicable program...just saying "a program" is not specific enough Related Item Public Input No. 751-NFPA 350-2013 [Section No. 4.2] Submitter Information Verification Submitter Full Name: Richard Kraus Organization: API/Petroleum Safety Consultan Street Address: City: State: Zip: Submittal Date: Tue Sep 23 08:36:34 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 49 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 320-NFPA 350-2014 [ Section No. 4.3 ] 4.3 Determination of Confined Spaces needing a Permit . Spaces that should be evaluated to determine if they could be confined spaces permit spaces include those that have all three of the following characteristics, and contains or has the potential to contain a serious hazard : (1) Are large enough and so configured that a person can bodily enter and perform assigned work. (2) Have limited or restricted means for entry and exit. Any space that requires a ladder to access or requires a worker to crawl or contort his or her body to enter or exit could be considered a confined space restricted . Nonstandard staircases such as spiral stairs or ships ladders could also be considered to have limited access or restricted means of egress. Often, these spaces are located below grade or require descent into a space. There are also confined spaces, such as water tanks, HVAC systems, and wind turbines that are typically located aboveground. Other spaces, by virtue of the distance a worker would have to travel to exit the space in an emergency, may be considered to have limited means of exit. (3) Are not designed for continuous human occupancy. These are spaces where employees would not normally be assigned for work. They are spaces where a desk, computer, or phone would not be placed but that might need to be entered for nonroutine inspection, maintenance, or repair work. Utility vaults, crawl spaces, tanks, and below-grade structures are examples of spaces that typically are not designed for continuous human occupancy. There are also structures that might be confined spaces that need to be worked on internally during construction, such as a pipe or a tank that needs to be welded. (This last sentence does not reflect not designed for continuous occupancy) Statement of Problem and Substantiation for Public Comment This verbiage is consistent with previous recommendations and adds clarification.. Related Item First Revision No. 3-NFPA 350-2014 [Chapter 4] Submitter Information Verification Submitter Full Name: TERRY W KRUG Organization: EXOSHA INC Affilliation: ANSI/ASSE Street Address: City: State: Zip: Submittal Date: Fri Nov 14 09:35:06 EST 2014 12/12/2014 2:22 PM National Fire Protection Association Report 50 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 67-NFPA 350-2014 [ Section No. 4.3 ] 4.3 Determination of Confined Spaces. Spaces that should be evaluated to determine if they could be confined spaces include those that have all three of the following characteristics: (1) Are large enough and so configured that a person can bodily enter and perform assigned work. (2) Have limited or restricted means for entry and exit. Any space that requires a ladder to access or requires a worker to crawl or contort his or her body to enter or exit could be considered a confined space. Nonstandard staircases such as spiral stairs or ships ladders could also be considered to have limited access or restricted means of egress. Often, these spaces are located below grade or require descent into a space. There are also confined spaces, such as water tanks, HVAC systems, and wind turbines that are typically located aboveground. Other spaces, by virtue of the distance a worker would have to travel to exit the space in an emergency, may be considered to have limited means of exit. (3) Are not designed for continuous human occupancy. These are spaces where employees would not normally be assigned for work. They are spaces where a desk, computer, or phone would not be placed but that might need to be entered for nonroutine inspection, maintenance, or repair work. Utility vaults, crawl spaces, tanks, and below-grade structures are examples of spaces that typically are not designed for continuous human occupancy. There are also structures that might be confined spaces that need to be worked on internally during construction, such as a pipe or a tank that needs to be welded. (4) Usually contain hazardous material, environment or can trap personnel. Hazardous materials are usually the chemicals left in the confined spaces like explosive, corrosive ot toxic chemicals. Environemnt dangers Inlude but not limited to oxygen deficiency and explosive atmosphere referred by LEL. Trapping usually takes place by the structural change like exit closed from cave in or material inflow. Statement of Problem and Substantiation for Public Comment The proposed change would help clarify more about the definition of confined spaces and their determination. Related Item Public Input No. 67-NFPA 350-2013 [Section No. 6.3.2] Submitter Information Verification Submitter Full Name: Muhammad Ahmed Organization: British American Tobacco Street Address: City: State: Zip: Submittal Date: Thu Sep 11 15:16:08 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 51 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 321-NFPA 350-2014 [ Section No. 4.4 ] 4.4 Signs. Confined spaces Permit spaces should have posted signs, tags, or labels denoting them as confined spaces needing a permit and prohibiting unauthorized entry. In facilities with similar, recognizable or multiple, confined permit spaces, (such as storage tank facilities or workplaces with multiple manholes), the owner/operator may choose to identify such spaces with facility signage and/or identify the spaces in their written confined space programs in lieu of individual signs or labels. Signs, tags, or labels should have wording similar to the following: DANGER — PERMIT REQUIRED CONFINED SPACE DO NOT ENTER WITHOUT AUTHORIZATION Statement of Problem and Substantiation for Public Comment This language is necessary for consistency with permit spaces. Related Item First Revision No. 3-NFPA 350-2014 [Chapter 4] Submitter Information Verification Submitter Full Name: TERRY W KRUG Organization: EXOSHA INC Affilliation: ANSI/ASSE Street Address: City: State: Zip: Submittal Date: Fri Nov 14 09:42:36 EST 2014 12/12/2014 2:22 PM National Fire Protection Association Report 52 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 68-NFPA 350-2014 [ Section No. 4.4 ] 4.4 Signs. Confined spaces should have posted signs, tags, or labels denoting them as confined spaces and prohibiting unauthorized entry. In facilities with similar, recognizable or multiple, confined spaces, (such as storage tank facilities or workplaces with multiple manholes), the owner/operator may choose to identify such spaces with facility signage and/or identify the spaces in their written confined space programs in lieu of individual signs or labels. Signs, tags, or labels should have wording similar to the following: DANGER — CONFINED SPACE DO NOT ENTER WITHOUT AUTHORIZATION I think a universal sign of confined space be added in the standard that will be more useful and appealing to novice Statement of Problem and Substantiation for Public Comment More clarity will be available to against any unauthorized entrants Related Item Public Input No. 68-NFPA 350-2013 [Section No. 6.3.4 [Excluding any Sub-Sections]] Submitter Information Verification Submitter Full Name: Muhammad Ahmed Organization: British American Tobacco Street Address: City: State: Zip: Submittal Date: Thu Sep 11 15:28:30 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 53 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 323-NFPA 350-2014 [ Section No. 4.6.1 ] 4.6.1 Owner/operators should inform all individuals working in or around confined permit spaces of the potentially hazardous nature of confined permit spaces on their property, regardless of whether or not they are employees. Statement of Problem and Substantiation for Public Comment Changes for consistency. Related Item First Revision No. 3-NFPA 350-2014 [Chapter 4] Submitter Information Verification Submitter Full Name: TERRY W KRUG Organization: EXOSHA INC Affilliation: ANSI/ASSE Street Address: City: State: Zip: Submittal Date: Fri Nov 14 09:49:55 EST 2014 12/12/2014 2:22 PM National Fire Protection Association Report 54 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 324-NFPA 350-2014 [ Section No. 4.6.2 ] 4.6.2* Employers sending employees to a location where it is reasonably anticipated that they may work in or around confined permit spaces should make sure those employees know how to identify confined spaces and are aware of the hazards associated with them. Statement of Problem and Substantiation for Public Comment Consistency. Related Item First Revision No. 3-NFPA 350-2014 [Chapter 4] Submitter Information Verification Submitter Full Name: TERRY W KRUG Organization: EXOSHA INC Affilliation: ANSI/ASSE Street Address: City: State: Zip: Submittal Date: Fri Nov 14 09:52:05 EST 2014 12/12/2014 2:22 PM National Fire Protection Association Report 55 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 325-NFPA 350-2014 [ Section No. 5.1 [Excluding any Sub-Sections] ] The terms confined space, non-permit-required confined space, and permit-required confined space may cause confusion among employers and workers. To minimize such confusion, this guide uses only the term permit required confined space or permit space and makes provisions for identifying and evaluating the hazards of all confined spaces, requiring permits if hazards are identified . If those hazards are serious, then the space is labeled as a permit space . Statement of Problem and Substantiation for Public Comment This language clarified the confined space and permit space issues. Related Item First Revision No. 4-NFPA 350-2014 [Chapter 5] Submitter Information Verification Submitter Full Name: TERRY W KRUG Organization: EXOSHA INC Affilliation: ANSI/ASSE Street Address: City: State: Zip: Submittal Date: Fri Nov 14 10:00:34 EST 2014 12/12/2014 2:22 PM National Fire Protection Association Report 56 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 95-NFPA 350-2014 [ Section No. 5.1 [Excluding any Sub-Sections] ] The terms confined space, non-permit-required confined space, and permit-required confined space may cause confusion among employers and workers. To minimize such confusion, this guide uses only the term confined space and makes provisions for identifying and evaluating the hazards of all confined spaces, requiring permits for entry if hazards are identified. Statement of Problem and Substantiation for Public Comment specific to require permits for ENTRY when hazards are indicated Related Item Public Input No. 755-NFPA 350-2013 [Section No. 5.1 [Excluding any Sub-Sections]] Submitter Information Verification Submitter Full Name: Richard Kraus Organization: API/Petroleum Safety Consultan Street Address: City: State: Zip: Submittal Date: Tue Sep 23 08:43:24 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 57 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 312-NFPA 350-2014 [ Section No. 5.1.2 ] 5.1.2 Table 5.1.2 shows the terminology used in commonly referenced confined space entry documents such as 29 CFR 1910.146, ANSI/ASSE Z 117.1, API 2015, and API 2016, and how the terms relate to those given in this guide. Table 5.1.2 Terminology for Confined Space Entry in Various Standards and Documents Standard or Document 29 CFR 1910.146 29 CFR 1910.146 Term Used Term Used in NFPA 350 Comments Confined space Confined NFPA 350 uses the same definition as space OSHA for a confined space. Permit required confined space NFPA 350 does not distinguish between Confined permit required confined spaces and space confined spaces. All confined spaces with hazards need permits for entry. ANSI/ASSE Non-permit-confined space Z117.1 All confined spaces need pre-entry evaluation prior to entry. If no hazards Confined are identified and no hazards will be space introduced, then no permit will be required. 29 CFR 1910.146 Reclassification (downgraded) entry Not defined in NFPA 350. A confined Confined space with hazards that have been space eliminated after the pre-entry evaluation entry will not require a permit. 29 CFR 1910.146 Alternate procedures entry Not defined in NFPA 350. A confined space where all hazards have been evaluated and the only hazard is a Confined potentially hazardous atmosphere that space is being controlled with effective entry ventilation would be issued a permit for entry that contains restrictions requiring ventilation and continuous monitoring. API 2015 and 2016 Nonconfined space (a confined space that is no longer a confined space due to None reconfiguration) If a space does not meet all the specifications for a confined space, then it is not a confined space and NFPA 350 does not apply. NFPA 326 Nonconfined space (for purposes of tank entry, cleaning, or repair a space that previously was a confined space but no longer meets any of the requirements for None a confined space or a permit required confined space, such as a tank with a large door sheet cut into the side) If a space does not meet all the specifications for a confined space, then it is not a confined space and NFPA 350 does not apply. CSA Z1006-10 Confined space - a workspace that is fully or partially enclosed, is no designed or intended for continious human occupancy, and has limited or restricted Confined access or egress, or an internal Space configuration, that can complicate first aid, evacuation, rescue, or other emergency response services 12/12/2014 2:22 PM National Fire Protection Association Report 58 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Statement of Problem and Substantiation for Public Comment Included CSA definition of confined space. Related Item Public Input No. 14-NFPA 350-2013 [Section No. 7.6.6] Submitter Information Verification Submitter Full Name: Nicole Gorman Organization: ENERCON Services Nova Scotia Street Address: City: State: Zip: Submittal Date: Thu Nov 13 19:24:16 EST 2014 12/12/2014 2:22 PM National Fire Protection Association Report 59 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 326-NFPA 350-2014 [ Section No. 5.1.2 ] 5.1.2 Table 5.1.2 shows the terminology used in commonly referenced confined space entry documents such as 29 CFR 1910.146, ANSI/ASSE Z 117.1, API 2015, and API 2016, and how the terms relate to those given in this guide. Table 5.1.2 Terminology for Confined Space Entry in Various Standards and Documents Standard or Document 29 CFR 1910.146 Term Used Term Used in NFPA 350 Comments Confined space Confined space NFPA 350 uses the same definition as OSHA for a confined space. Permit required confined space Confined Permit space NFPA 350 does not distinguish between permit required confined spaces and confined spaces. All confined spaces with serious hazards need permits for entry. ANSI/ASSE Non-permit-confined space Z117.1 Confined space All confined spaces need pre-entry evaluation prior to entry. If no hazards are identified and no hazards will be introduced, then no permit will be required. 29 CFR 1910.146 Confined space entry Not defined in NFPA 350. A confined space with hazards that have been eliminated after the pre-entry evaluation will not require a permit. Confined space entry Not defined in NFPA 350. A confined space where all hazards have been evaluated and the only hazard is a potentially hazardous atmosphere that is being controlled with effective ventilation would be issued a permit for entry that contains restrictions requiring ventilation and continuous monitoring. 29 CFR 1910.146 Reclassification (downgraded) entry 29 CFR 1910.146 Alternate procedures entry API 2015 and 2016 Nonconfined space (a confined space that is no longer a confined space due to reconfiguration) None If a space does not meet all the specifications for a confined space, then it is not a confined space and NFPA 350 does not apply. NFPA 326 Nonconfined space (for purposes of tank entry, cleaning, or repair a space that previously was a confined space but no longer meets any of the None requirements for a confined space or a permit required confined space, such as a tank with a large door sheet cut into the side) If a space does not meet all the specifications for a confined space, then it is not a confined space and NFPA 350 does not apply. Statement of Problem and Substantiation for Public Comment This change helps to clarify previous recommendations. Related Item First Revision No. 4-NFPA 350-2014 [Chapter 5] 12/12/2014 2:22 PM National Fire Protection Association Report 60 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Submitter Information Verification Submitter Full Name: TERRY W KRUG Organization: EXOSHA INC Affilliation: ANSI/ASSE Street Address: City: State: Zip: Submittal Date: Fri Nov 14 10:11:05 EST 2014 12/12/2014 2:22 PM National Fire Protection Association Report 61 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 327-NFPA 350-2014 [ Section No. 5.3.2 ] 5.3.2 Permit. A permit should be issued by the entry supervisor for all confined spaces with containing or has the potential to contain serious hazards identified in accordance with Chapter 13. Statement of Problem and Substantiation for Public Comment Language adds clarification. Related Item First Revision No. 4-NFPA 350-2014 [Chapter 5] Submitter Information Verification Submitter Full Name: TERRY W KRUG Organization: EXOSHA INC Affilliation: ANSI/ASSE Street Address: City: State: Zip: Submittal Date: Fri Nov 14 10:28:58 EST 2014 12/12/2014 2:22 PM National Fire Protection Association Report 62 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 328-NFPA 350-2014 [ Section No. 5.4 ] 5.4 Entry Conditions. Entry into confined permit spaces by assigned qualified entrants should be permitted only after the entry supervisor has indicated that acceptable entry conditions (see, Section 5.5 and 5.6 ) have been met,and after a pre-entry evaluation has been performed and permit issued, if applicable. Statement of Problem and Substantiation for Public Comment Clarification and consistency Related Item First Revision No. 4-NFPA 350-2014 [Chapter 5] Submitter Information Verification Submitter Full Name: TERRY W KRUG Organization: EXOSHA INC Affilliation: ANSI/ASSE Street Address: City: State: Zip: Submittal Date: Fri Nov 14 10:31:52 EST 2014 12/12/2014 2:22 PM National Fire Protection Association Report 63 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 313-NFPA 350-2014 [ Section No. 5.5 ] 5.5 Basic Requirements and Considerations. Prior to entering a confined space, the following should be identified and evaluated: (1) All inherent, potential, introduced, and adjacent hazards of the confined space should be anticipated, identified, and evaluated in accordance with a written confined space entry program and guidance provided in Chapters 6 and 7. (2) All hazards should be eliminated, controlled, or mitigated in accordance with Chapters 8 and 9. (3) An authorized entry supervisor qualified in accordance with Chapter 11 should be assigned to oversee the work. (4) Only authorized entrantsqualified entrants qualified in accordance with Chapter 11 should be assigned to enter the space. (5) Anattendant An attendant qualified in accordance with Chapter 11 should be assigned for permit entries to attend during confined space entry and work . (6) If atmospheric monitoring is required, a gas testerqualified tester qualified in accordance with Chapter 11 should be assigned. (7) If ventilation is required, a ventilation specialistqualified specialist qualified in accordance with Chapter 11 should be assigned. (8) If energy sources are required to be isolated or controlled, anisolation an isolation specialist qualified in accordance with Chapter 11 should be assigned. (9) If required, qualified rescuers and/or services as well as appropriate rescue equipment should be available in accordance with Chapter 10. (10) Any other required permits, including, but not limited to, hot work, are issued. (11) A pre-entry evaluation and/or confined space entry permit should be issued and signed by the entry supervisor in accordance with Chapter 13. (12) A pre-entry meeting should be held with all personnel entering or working in or adjacent to the confined space to discuss the work to be performed, job requirements and assignments, actual and potential hazards, and methods of eliminating or controlling the hazards as listed in the conditions on the permit. A Job Hazard Analysis is an important tool to utilize before confined space entry. (13) Communication between the entrant and the attendant and the attendant and rescuer, if required, should be established in accordance with Chapter 8. (14) Permit entry should not occur until all conditions for entry established on the permit have been met. If conditions change the permit should be cancelled, operations ceased, and the entrant should immediately vacate the space. Statement of Problem and Substantiation for Public Comment Corrected minor mistakes. Included reference to JHA as they are important to use before confined space entry. Related Item Public Input No. 15-NFPA 350-2013 [Chapter 2 [Title Only]] Submitter Information Verification Submitter Full Name: Nicole Gorman Organization: ENERCON Services Nova Scotia Street Address: 12/12/2014 2:22 PM National Fire Protection Association Report 64 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... City: State: Zip: Submittal Date: Thu Nov 13 19:30:54 EST 2014 12/12/2014 2:22 PM National Fire Protection Association Report 65 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 329-NFPA 350-2014 [ Section No. 5.5 ] 5.5 Basic Requirements and Considerations. Prior to entering into a confined permit space, the following should be identified and evaluated: (1) All inherent, potential, introduced, and adjacent hazards of the confined space should be anticipated, identified, and evaluated in accordance with a written confined space entry program and guidance provided in Chapters 6 and 7. (2) All hazards should be eliminated,controlled,or mitigated in accordance with Chapters 8 and 9. (3) An authorized entry supervisor qualified in accordance with Chapter 11 should be assigned to oversee the work. (4) Only authorized entrantsqualified in accordance with Chapter 11 should be assigned to enter the space. (5) Anattendant qualified in accordance with Chapter 11 should be assigned for permit entries. (6) If atmospheric monitoring is required, a gas testerqualified in accordance with Chapter 11 should be assigned. (7) If ventilation is required, a ventilation specialistqualified in accordance with Chapter 11 should be assigned. (8) If energy sources are required to be isolated or controlled, anisolation specialist qualified in accordance with Chapter 11 should be assigned. (9) If required, qualified rescuers and/or services as well as appropriate rescue equipment should be available in accordance with Chapter 10. (10) Any other required permits, including, but not limited to, hot work are issued. (11) A pre-entry evaluation and/or confined space entry permit should be issued and signed by the entry supervisor in accordance with Chapter 13. (12) A pre-entry meeting should be held with all personnel entering or working in or adjacent to the space to discuss the work to be performed, job requirements and assignments, actual and potential hazards, and methods of eliminating or controlling the hazards as listed in the conditions on the permit. (13) Communication between the entrant and the attendant and the attendant and rescuer, if required, should be established in accordance with Chapter 8. (14) Permit entry should not occur until all conditions for entry established on the permit have been met. If conditions change the permit should be cancelled, operations ceased, and the entrant should immediately vacate the space. Statement of Problem and Substantiation for Public Comment Consistency Related Item First Revision No. 4-NFPA 350-2014 [Chapter 5] Submitter Information Verification Submitter Full Name: TERRY W KRUG Organization: EXOSHA INC Affilliation: ANSI/ASSE Street Address: City: State: 12/12/2014 2:22 PM National Fire Protection Association Report 66 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Zip: Submittal Date: Fri Nov 14 10:33:04 EST 2014 12/12/2014 2:22 PM National Fire Protection Association Report 67 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 96-NFPA 350-2014 [ Section No. 5.5 ] 5.5 Basic Requirements and Considerations. Prior to entering a confined space, the following should be identified and evaluated: (1) All inherent, potential, introduced, and adjacent hazards of the confined space should be anticipated, identified, and evaluated in accordance with a written confined space entry program and guidance provided in Chapters 6 and 7. (2) All hazards should be eliminated,controlled,or mitigated in accordance with Chapters 8 and 9. (3) An authorized entry supervisor qualified in accordance with Chapter 11 should be assigned to oversee the work. (4) Only authorized entrantsqualified in accordance with Chapter 11 should be assigned to enter the space. (5) Anattendant An attendant qualified in accordance with Chapter 11 should be assigned for permit entries. (6) If atmospheric monitoring is required, a gas testerqualified in accordance with Chapter 11 should be assigned. (7) If ventilation is required, a ventilation specialistqualified in accordance with Chapter 11 should be assigned. (8) If energy sources are required to be isolated or controlled, anisolation specialist qualified in accordance with Chapter 11 should be assigned. (9) If required, qualified rescuers and/or services as well as appropriate rescue equipment should be available in accordance with Chapter 10. (10) Any other required permits, including, but not limited to, entry, cold work, testing criteria and hot work are issued. (11) A pre-entry evaluation and/or confined space entry permit should be issued and signed by the entry supervisor in accordance with Chapter 13. (12) A pre-entry meeting should be held with all personnel entering or working in or adjacent to the space to discuss the work to be performed, job requirements and assignments, actual and potential hazards, and methods of eliminating or controlling the hazards as listed in the conditions on the permit. (13) Communication between the entrant and the attendant and the attendant and rescuer, if required, should be established in accordance with Chapter 8. Where there are internal obstructions or where the space is so configured that visual contact between the attendant and the entrant is not possilble at all times, other means such as video cameras, should be considered. (14) Permit entry should not occur until all conditions for entry established on the permit have been met. If conditions change the permit should be cancelled, operations ceased, and the entrant should immediately vacate the space. Statement of Problem and Substantiation for Public Comment item (5) editorial item (1) specifies other permits in addition to hot work Related Item Public Input No. 761-NFPA 350-2013 [Section No. 5.5] Submitter Information Verification Submitter Full Name: Richard Kraus Organization: API/Petroleum Safety Consultan 12/12/2014 2:22 PM National Fire Protection Association Report 68 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Street Address: City: State: Zip: Submittal Date: Tue Sep 23 08:46:27 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 69 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 314-NFPA 350-2014 [ Section No. 5.6 ] 5.6 Roles and Responsibilities. Every workplace that has one or more confined spaces that can be entered, as identified in Chapter 4,should have personnel assigned to perform the responsibilities of the following roles as applicable. The same person can hold many of these roles as long as safe conditions are not violated : (1) Owner/operator and/or entrant employer (2) Entrant (3) Attendant (4) Entry supervisor (5) Gas tester (6) Ventilation specialist (7) Rescuer (could be attendant for non-entry rescue) (8) Rescue team or rescue service (9) Standby worker (10) Isolation specialist Statement of Problem and Substantiation for Public Comment Lets the reader know that more than one person can have many roles. Related Item Public Input No. 16-NFPA 350-2013 [Chapter 2 [Title Only]] Submitter Information Verification Submitter Full Name: Nicole Gorman Organization: ENERCON Services Nova Scotia Street Address: City: State: Zip: Submittal Date: Thu Nov 13 19:39:20 EST 2014 12/12/2014 2:22 PM National Fire Protection Association Report 70 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 330-NFPA 350-2014 [ Section No. 5.6 ] 5.6 Roles and Responsibilities. Every workplace that has one or more confined permit spaces that can be entered, as identified in Chapter 4,should have personnel assigned to perform the responsibilities of the following roles as applicable: (1) Owner/operator and/or entrant employer (2) Entrant (3) Attendant (4) Entry supervisor (5) Gas tester (6) Ventilation specialist (7) Rescuer (could be attendant for non-entry rescue) (8) Rescue team or rescue service (9) Standby worker (10) Isolation specialist Statement of Problem and Substantiation for Public Comment Consistency. Related Item First Revision No. 4-NFPA 350-2014 [Chapter 5] Submitter Information Verification Submitter Full Name: TERRY W KRUG Organization: EXOSHA INC Affilliation: ANSI/ASSE Street Address: City: State: Zip: Submittal Date: Fri Nov 14 10:36:01 EST 2014 12/12/2014 2:22 PM National Fire Protection Association Report 71 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 97-NFPA 350-2014 [ Section No. 5.7.1 ] 5.7.1 Owners/operators, contractors and entrant employers should subcontractors should ensure that all employees who work in and around confined spaces have the necessary awareness, understanding, knowledge, and skills to safely perform their duties in or around confined spaces. Statement of Problem and Substantiation for Public Comment all employers, not just entrant employers, need to provide this Related Item Public Input No. 764-NFPA 350-2013 [Section No. 5.7.1] Submitter Information Verification Submitter Full Name: Richard Kraus Organization: API/Petroleum Safety Consultan Street Address: City: State: Zip: Submittal Date: Tue Sep 23 08:52:49 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 72 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 98-NFPA 350-2014 [ Section No. 5.7.2 ] 5.7.2 Owners/operators, contractors and entrant employers should subcontractors should ensure that all employees engaged in confined space operations have been educated, trained, and/or qualified as follows: (1) Before beginning initial work and/or duty assignments (2) Before assignment to a different type of work or duty other than initially assigned (3) Wherevera change occurs in operations, equipment, materials, procedures, guidelines, work assignment, or duties that creates or has the potential to create a hazard for which the employee has not been previously trained, educated, or qualified (4) Wherever an owner/operator and entrant employer has reason to believe an employee requires retraining or additional education due to inadequacies in the employee’s performance or skill or because the employee deviates from the confined space program permit requirements or procedures Statement of Problem and Substantiation for Public Comment applies to ALL employers, not just entrant employers Related Item Public Input No. 765-NFPA 350-2013 [Section No. 5.7.2] Submitter Information Verification Submitter Full Name: Richard Kraus Organization: API/Petroleum Safety Consultan Street Address: City: State: Zip: Submittal Date: Tue Sep 23 08:59:52 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 73 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 99-NFPA 350-2014 [ Section No. 5.8 ] 5.8 * Training Verification. Owners/operators, comtractors and entrant employers subcontractors should verify, in writing, that employees who work in and aorund confined spaces have been trained, educated, or qualified as required. The verification should contain the names of the employees;the means used to determine that the employees understand the specific requirements of the training or work to be performed; the signature, name, or initials of the trainer(s), educator(s) or qualifier(s); the specific subjects and content; and the date(s) the training, education, or qualification was completed, in accordance with Chapter 11. Statement of Problem and Substantiation for Public Comment applicable to all employers not just entrant employers Related Item Public Input No. 765-NFPA 350-2013 [Section No. 5.7.2] Submitter Information Verification Submitter Full Name: Richard Kraus Organization: API/Petroleum Safety Consultan Street Address: City: State: Zip: Submittal Date: Tue Sep 23 09:02:03 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 74 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 7-NFPA 350-2014 [ Section No. 6.1.4 ] 6.1.4 After all hazards have been identified and risks have been assessedappropriate assessed appropriate means to eliminate, control, or mitigate hazards should be implemented in accordance with Chapter 8. Statement of Problem and Substantiation for Public Comment Typo Related Item Public Input No. 350-NFPA 350-2013 [Section No. 11.4.4.1] Submitter Information Verification Submitter Full Name: Donald Raffo Organization: General Dynamics, Electric Boa Street Address: City: State: Zip: Submittal Date: Wed Sep 10 12:27:24 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 75 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 331-NFPA 350-2014 [ Section No. 6.2.1 ] 6.2.1 Intelligence Gathering. Hazard preplanning starts with the collection of information that could be useful prior to determining actual and potential hazards where when planning for confined space operations. This intelligence gathering includes, but is not limited to, review of any previous permits concerning that space or adjacent spaces , using previously prepared hazard surveys, preplans, schematics, blueprints, work orders, equipment guides, safety data sheets, manuals, control measures, and prior experience from previous entries and knowledge from workers familiar with the space. Identification and determination of probable hazards and an understanding of the operations and processes associated with the space may also be helpful. Statement of Problem and Substantiation for Public Comment Consistency. Related Item First Revision No. 5-NFPA 350-2014 [Chapter 6] Submitter Information Verification Submitter Full Name: TERRY W KRUG Organization: EXOSHA INC Affilliation: ANSI/ASSE Street Address: City: State: Zip: Submittal Date: Fri Nov 14 10:38:10 EST 2014 12/12/2014 2:22 PM National Fire Protection Association Report 76 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 347-NFPA 350-2014 [ Section No. 6.2.1 ] 6.2.1 Intelligence Gathering. Hazard preplanning starts with the collection of information that could be useful prior to determining actual and potential hazards where hazards when planning for confined space operations. This intelligence gathering includes, but is not limited to, using previously prepared hazard surveys, preplans, schematics, blueprints, work orders, equipment guides, safety data sheets, manuals, control measures, and prior experience from previous entries and knowledge from workers familiar with the space. Identification and determination of probable hazards and an understanding of the operations and processes associated with the space may also be helpful. Statement of Problem and Substantiation for Public Comment change “…where planning…” to … when planning… Related Item First Revision No. 5-NFPA 350-2014 [Chapter 6] Submitter Information Verification Submitter Full Name: EMERY THOMAS Organization: CONOCOPHILLIPS Street Address: City: State: Zip: Submittal Date: Fri Nov 14 12:01:09 EST 2014 12/12/2014 2:22 PM National Fire Protection Association Report 77 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 332-NFPA 350-2014 [ Section No. 6.2.2.1 ] 6.2.2.1 Engineering Controls. Some common engineering controls include, but are not limited to, the following: (1) Hazard-specific area and personal atmospheric testing and monitoring equipment (2) Area and local ventilation, inerting, or purging equipment, including vapor recovery equipment, if needed (3) Isolation and/or lockout/tag out devices and equipment (4) Hazardous material and waste collection, disposal, and/or containment equipment (5) Lighting equipment (6) Barricades and road blocks (7) Breathing-air supply and equipment (8) Decontamination stations and eye wash and showers (9) Appropriate ladders, tripods and rescue equipment including harnesses, lifelines, (10) Any special equipment such as GFCI, emergency generators, non-sparking tools, heat stress clothing and test equip (WBGT) Statement of Problem and Substantiation for Public Comment Added items to be more comprehensive. Related Item First Revision No. 5-NFPA 350-2014 [Chapter 6] Submitter Information Verification Submitter Full Name: TERRY W KRUG Organization: EXOSHA INC Affilliation: ANSI/ASSE Street Address: City: State: Zip: Submittal Date: Fri Nov 14 10:41:55 EST 2014 12/12/2014 2:22 PM National Fire Protection Association Report 78 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 333-NFPA 350-2014 [ Section No. 6.2.2.2 ] 6.2.2.2 Administrative Controls and Personal Protective Equipment . Some common administrative controls include, but are not limited to, the following: (1) Qualified personnel assigned for all identified tasks (2) Confined space, respiratory protection, isolation, hot/cold work, and other applicable programs, regulations, and industry standards (3) Hazardous and toxic exposure amounts and time limits (4) Personal and respiratory protection equipment (5) Designated areas for specific equipment, work, breaks, and nonrelated activities (6) Identified rescue personnel and/or services (7) Entry, hot work permit, and restrictions and limitations (8) Applicable regulatory permit requirements (9) Outside services needed such as cranes, waste disposal, and so on Statement of Problem and Substantiation for Public Comment Clarification of heading matching contents. Related Item First Revision No. 5-NFPA 350-2014 [Chapter 6] Submitter Information Verification Submitter Full Name: TERRY W KRUG Organization: EXOSHA INC Affilliation: ANSI/ASSE Street Address: City: State: Zip: Submittal Date: Fri Nov 14 10:50:36 EST 2014 12/12/2014 2:22 PM National Fire Protection Association Report 79 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 338-NFPA 350-2014 [ Section No. 6.3.2 ] 6.3.2 Hazard sources can be directly or indirectly associated with working in and around confined spaces. Indirect hazards are hazards that are not integral to, or are outside of, the space but can still affect it. Direct and indirect hazards include the following: (The three examples are direct and indirect hazards) (1) Those associated with confined spaces and inherently present in or around the space (2) The result of product(s) stored in or around the space (3) The result of processes taking place within or near the space Statement of Problem and Substantiation for Public Comment Examples of direct and indirect hazards. Related Item First Revision No. 5-NFPA 350-2014 [Chapter 6] Submitter Information Verification Submitter Full Name: TERRY W KRUG Organization: EXOSHA INC Affilliation: ANSI/ASSE Street Address: City: State: Zip: Submittal Date: Fri Nov 14 11:36:53 EST 2014 12/12/2014 2:22 PM National Fire Protection Association Report 80 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 339-NFPA 350-2014 [ Section No. 6.3.4.1.2 ] 6.3.4.1.2 Inherent hazards to be identified include,but are not limited to, the following: (1) Limited access into the space. Space for which ladders or scaffolding are needed to reach the portal, to enter and exit the space, or to perform work therein. Elevated spaces require different considerations for entry and rescue than those that are at ground level, including fall protection. (2) Size and shape of the portal. The restrictive nature of some portals makes access with certain types of PPE difficult or impossible or requires entrants to contort their bodies while entering or exiting. An elevated, open, unprotected edge or portal may create a fall hazard. (3) Size and shape of the space/vessel. Inwardly converging walls or a funnel-shaped discharge can entrap an entrant; congested or dark spaces can inhibit mobility or create slip, trip, and fall hazards. (4) Products or processes in the space. Chemicals, thermal stress, noise, steam, pressurization, mechanical equipment, operations, and other activities associated with the use of the space can create hazards. Disturbing product residue during entry or work can release a contaminant that produces a hazard not detected during pre-entry testing. (5) Fixed equipment within the space. Piping systems, conduits, ducts, machinery,pressurized lines, and fire suppression systems should be evaluated for potential hazards and locked out/tagged out, tested, gas-freed, and/or inerted if needed to reduce the risk. (6) Structural weaknesses due to rusting of iron, should be evaluated such as fixed ladders, floors, pipes and space supports prior to using them for anchoring or support. Statement of Problem and Substantiation for Public Comment Added structural weakness as a hazard. Related Item First Revision No. 5-NFPA 350-2014 [Chapter 6] Submitter Information Verification Submitter Full Name: TERRY W KRUG Organization: EXOSHA INC Affilliation: ANSI/ASSE Street Address: City: State: Zip: Submittal Date: Fri Nov 14 11:40:08 EST 2014 12/12/2014 2:22 PM National Fire Protection Association Report 81 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 341-NFPA 350-2014 [ Section No. 6.3.4.2.2 ] 6.3.4.2.2 Examples of introduced hazards include the following: (1) Atmospheric hazards. Ventilating a space may introduce contaminants from the following: (2) Sources outside the space via an ill-placed supply-air duct (3) Contaminated air drawn from internal combustion engine exhaust (4) Oxygen-deficient air drawn from another space or source (5) Product off-gassing captured by forced ventilation and contaminated adjacent areas (6) Chemical hazards. Products used in cleaning, abating, painting, or coating need to be checked for reactivity with other chemicals that might be present. Chemicals may produce hazardous vapors or gases and/or displace or consume oxygen due to the nature of the confined space. The applying and drying of flammable paints may cause an explosive atmosphere. (7) Compressed hazards. Compressed gas used for welding, cutting, inerting, hot work, or fire suppression systems pose a hazard due to their contents (e.g., toxic or flammable gases), ability to displace or enrich the atmospheric oxygen content (e.g., carbon dioxide fire extinguishing systems), and their potential to become a projectile if damaged. Compressed gas hoses, valves, and regulators should be thoroughly inspected, evaluated, and leak checked prior to being brought into a confined space. Due to the inherent risks, compressed gas cylinders (except SCBAs) should not normally be introduced into confined spaces. (8) Hot work. Hazardous atmospheres and flammable conditions created by hot work such as welding, cutting, grinding, drilling, and burning, which can produce fumes, release gases, deplete or enrich the space’s oxygen content, or produce an ignition source, such as sparks from the work or the tool itself , should be conducted following a hot work permit . (This was an incomplete sentence needing revision) (9) Electrical hazards. Electrical equipment that is not low voltage or intrinsically safe, lighting, power tools, and extension cords, can produce electrical shock, trip hazards, and ignition sources. Additional consideration should be given to unexpected sources of electrical energy/ignition source such as static electric discharge that may be generated by the use of airlines/pressure lines or even exhaust fans. GFCI protection should be considered when using AC power. (10) Slip, trip, and fall hazards. Ladders or scaffolding used to reach portals, gain entry, or access inside the space can produce slip, trip, fall, and entanglement hazards. Equipment, cables, hoses, tools, ventilation ducts and other items brought into the space may create slip, trip, and entanglement hazards. Statement of Problem and Substantiation for Public Comment Needed examples for clarification. Related Item First Revision No. 5-NFPA 350-2014 [Chapter 6] Submitter Information Verification Submitter Full Name: TERRY W KRUG Organization: EXOSHA INC Affilliation: ANSI/ASSE Street Address: City: 12/12/2014 2:22 PM National Fire Protection Association Report 82 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... State: Zip: Submittal Date: Fri Nov 14 11:46:39 EST 2014 12/12/2014 2:22 PM National Fire Protection Association Report 83 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 345-NFPA 350-2014 [ Section No. 6.3.4.2.2 ] 6.3.4.2.2 Examples of introduced hazards include the following: (1) Atmospheric hazards. Ventilating a space may introduce contaminants from the following: (a) Sources outside the space via an ill-placed supply-air duct (b) Contaminated air drawn from internal combustion engine exhaust (c) Oxygen-deficient air drawn from another space or source (d) Product off-gassing captured by forced ventilation and contaminated adjacent areas (2) Chemical hazards. Products used in cleaning, abating, painting, or coating need to be checked for reactivity with other chemicals that might be present. Chemicals may produce hazardous vapors or gases and/or displace or consume oxygen due to the nature of the confined space. (3) Compressed hazards. Compressed gas used for welding, cutting, inerting, hot work, or fire suppression systems pose a hazard due to their contents (e.g., toxic or flammable gases), ability to displace or enrich the atmospheric oxygen content (e.g., carbon dioxide fire extinguishing systems), and their potential to become a projectile if damaged. Compressed gas hoses, valves, and regulators should be thoroughly inspected, evaluated, and leak checked prior to being brought into a confined space. Due to the inherent risks, compressed gas cylinders should not normally be introduced into confined spaces. (4) Hot work. Hazardous atmospheres and flammable conditions created by hot work such as welding, cutting, grinding, drilling, and burning, which can produce fumes, release gases, deplete or enrich the space’s oxygen content, or produce an ignition source, such as sparks from the work or the tool itself. (5) Electrical hazards. Electrical equipment that is not low voltage or intrinsically safe, lighting, power tools, and extension cords, can produce electrical shock, trip hazards, and ignition sources. Additional consideration should be given to unexpected sources of electrical energy/ignition source such as static electric discharge that may be generated by the use of airlines/pressure lines or even exhaust fans. (6) Slip, trip, and fall hazards. Ladders or scaffolding used to reach portals, gain entry, or access inside the space can produce slip, trip, fall, and entanglement hazards. Equipment, cables, hoses, tools, ventilation ducts and other items brought into the space may create slip, trip, and entanglement hazards. Statement of Problem and Substantiation for Public Comment Perhaps too specific, but chapter 6 does not address radiological hazards from NORM or external nuclear gauges. Nuclear gauges should be part of the isolation process and verified independently. It may be beneficial to identify nuclear gauges as a potential hazard source due to their prevalence in the refining and chemical industries. Recommend to include this in the appropriate section(s). Related Item First Revision No. 5-NFPA 350-2014 [Chapter 6] Submitter Information Verification Submitter Full Name: EMERY THOMAS Organization: CONOCOPHILLIPS Street Address: City: State: 12/12/2014 2:22 PM National Fire Protection Association Report 84 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Zip: Submittal Date: Fri Nov 14 11:52:46 EST 2014 12/12/2014 2:22 PM National Fire Protection Association Report 85 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 356-NFPA 350-2014 [ Section No. 6.3.4.2.2 ] 6.3.4.2.2 Examples of introduced hazards include the following: (1) Atmospheric hazards. Ventilating a space may introduce contaminants from the following: (a) Sources outside the space via an ill-placed supply-air duct (b) Contaminated air drawn from internal combustion engine exhaust (c) Oxygen-deficient air drawn from another space or source (d) Product off-gassing captured by forced ventilation and contaminated adjacent areas (2) Chemical hazards. Products used in cleaning, abating, painting, or coating need to be checked for reactivity with other chemicals that might be present. Chemicals may produce hazardous vapors or gases and/or displace or consume oxygen due to the nature of the confined space. (3) Compressed hazards. Compressed gas used for welding, cutting, inerting, hot work, or fire suppression systems pose a hazard due to their contents (e.g., toxic or flammable gases), ability to displace or enrich the atmospheric oxygen content (e.g., carbon dioxide fire extinguishing systems), and their potential to become a projectile if damaged. Compressed gas hoses, valves, and regulators should be thoroughly inspected, evaluated, and leak checked prior to being brought into a confined space. Due to the inherent risks, compressed gas cylinders should not normally be introduced into confined spaces. (4) Hot work. Hazardous atmospheres and flammable conditions created by hot work such as welding, cutting, grinding, drilling, and burning, which can produce fumes, release gases, deplete or enrich the space’s oxygen content, or produce an ignition source, such as sparks from the work or the tool itself. (5) Electrical hazards. Electrical equipment that is not low voltage or intrinsically safe, lighting, power tools, and extension cords, can produce electrical shock, trip hazards, and ignition sources. Additional consideration should be given to unexpected sources of electrical energy/ignition source such as static electric discharge that may be generated by the use of airlines/pressure lines or even exhaust fans. (6) Slip, trip, and fall hazards. Ladders or scaffolding used to reach portals, gain entry, or access inside the space can produce slip, trip, fall, and entanglement hazards. Equipment, cables, hoses, tools, ventilation ducts and other items brought into the space may create slip, trip, and entanglement hazards. Statement of Problem and Substantiation for Public Comment Recommend including the terms “inerting” or “blanking” as a type of introduced atmospheric hazard and reference those terms to section 8.4.4. Related Item First Revision No. 5-NFPA 350-2014 [Chapter 6] Submitter Information Verification Submitter Full Name: EMERY THOMAS Organization: CONOCOPHILLIPS Street Address: City: State: Zip: Submittal Date: Fri Nov 14 15:46:51 EST 2014 12/12/2014 2:22 PM National Fire Protection Association Report 86 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... 12/12/2014 2:22 PM National Fire Protection Association Report 87 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 350-NFPA 350-2014 [ Section No. 6.3.5.2.1 ] 6.3.5.2.1* As electricity travels from its source and returns to that source, either through a wire, conductive material, or through the ground, it makes a complete circuit. If anything, such as a human body, comes in contact with the current-carrying wires and has lower resistance than the wire, electricity will follow the path of least is effectively grounded, electrocution is possible. Electricity follows all paths of resistance to ground not only the path of lease resistance. Statement of Problem and Substantiation for Public Comment Inaccurate statement regarding electrify follows the path of least resistance. Related Item First Revision No. 5-NFPA 350-2014 [Chapter 6] Submitter Information Verification Submitter Full Name: TERRY W KRUG Organization: EXOSHA INC Affilliation: ANSI/ASSE Street Address: City: State: Zip: Submittal Date: Fri Nov 14 12:05:25 EST 2014 12/12/2014 2:22 PM National Fire Protection Association Report 88 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 69-NFPA 350-2014 [ Section No. 6.3.5.2.1 ] 6.3.5.2.1* As electricity travels from its source and returns to that source, either through a wire, conductive material, or through the ground, it makes a complete circuit. If anything, such as a human body, comes in contact with the current-carrying wires and has lower resistance than the wire, electricity will follow the path of least resistance any path to ground . Statement of Problem and Substantiation for Public Comment Electricity will follow any path to ground, no only the path of least resistance. Electricity will flow in all parallel paths. Related Item First Revision No. 5-NFPA 350-2014 [Chapter 6] Submitter Information Verification Submitter Full Name: JAMES TYLER Organization: VESTAS Affilliation: American Wind Energy Association (AWEA) Street Address: City: State: Zip: Submittal Date: Thu Sep 11 17:46:55 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 89 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 8-NFPA 350-2014 [ Section No. 6.3.5.3 ] 6.3.5.3 Physical Hazards. These hazards include hazards other than mechanical or chemical that would cause harm to the body, including, but not limited to, noise, engulfment, falls, wet/slick surfaces, slip/trip hazards, lighting, radiation, vibration, and extremes of temperature and pressure. Entrapment hazards are where the shape or configuration of the vessel itself can exert enough force on the body to cause death by strangulation, constriction, or crushing and may include narrow cross sections, sloping floors, funneling configurations, or other internal configurations that can entrap. Physical hazards include explosion and fire hazards created by various chemical agents such as flammable liquids, paints, solvents, and methane, as well as combustible settled dust in excess of 1⁄32 in., and airborne concentrations that impair visibility to less than 5 ft are indicators of potential explosive conditions. Concentrations of explosive/flammable vapors that have reached their LEL /LFL lower explosive /flammable limit and have not exceeded their UEL/UFL Upper explosive/flammable limit are capable of explosion. There is no effective PPE for an explosive environment, control or elimination is recommended. Generally, atmospheres that have reached 10% of their LEL/LFL are considered hazardous and should require additional precautions and actions prior to entering a space. LFL/LEL is the lowest concentration of gas or vapor in air in which burning will take place. .(The use of LFL is also used throughout this document and is not defined. LEL is defined but in many cases has been replaced with LFL. Use of the terms should be consistent. Also, the discussion of respiratory protection is not needed under this section) Statement of Problem and Substantiation for Public Comment The use of LFL is used throughout this document and is not defined. LEL is defined but in many cases has been replaced with LFL. Use of the terms should be consistent. Also, the discussion of respiratory protection is not needed under this section. Related Item Public Input No. 350-NFPA 350-2013 [Section No. 11.4.4.1] Submitter Information Verification Submitter Full Name: Donald Raffo Organization: General Dynamics, Electric Boa Street Address: City: State: Zip: Submittal Date: Wed Sep 10 12:33:53 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 90 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 351-NFPA 350-2014 [ Section No. 6.3.5.5 ] 6.3.5.5* Atmospheric Hazards. NIOSH statistics indicate that atmospheric hazards are the most common cause of death in confined spaces. Oxygen deficiency and enrichment atmospheres are also hazardous. The normal amount of oxygen is 20.8 percent to 20.9 percent in the air. Where oxygen is lower than 20.8 percent, there may be a chemical or process consuming or displacing oxygen; where it is higher, there may be a source of oxygen being introduced to the space. Oxygen deficiency may lead to atmospheres that cannot sustain life and that may become immediately dangerous to life and health. Oxygen-enriched atmospheres greater than 22% oxygen may create a fire or explosion hazard. The following are the most common atmospheric hazards: (1) Oxygen deficiency (less than 20.8 percent), which may be caused by the following: (a) Oxygen displacement by other gases and vapors, such as inert gases or by evaporating liquids (b) Oxygen consumption through rusting metals (oxidation), combustion, respitory respiratory consumption by workers, or organic decay of aqeous molasses or oils drying of paints (c) Oxygen absorbtion, where oxygen molecules adhere to the surface od a of such as damp carbon a solid body (2) * Flammable/explosive atmospheres, which may be caused by the following: (3) Vaporization of flammable liquids (4) Byproducts of chemical reactions (5) Oxygen enrichment (greater than 22% oxygen) Concentration (a) LEL c oncentration of combustible dust (b) Methane from soil gases near a nearby landfill (6) Toxic atmospheres, which contain substances that are poisonous and may cause injury or death independent of oxygen concentration. The effect of contamination may be immediate (acute) or may be cumulative(chronic), taking substantial time for symptoms to affect entrants. (7) Hypobaric and hyperbaric conditions, which may be present in both extreme in both extreme s high and low altitudes and pressurized spaces may also affect air monitoring devices. (See also A.6.3.5.4.) Statement of Problem and Substantiation for Public Comment Clairification Related Item First Revision No. 5-NFPA 350-2014 [Chapter 6] Submitter Information Verification Submitter Full Name: TERRY W KRUG Organization: EXOSHA INC Affilliation: ANSI/ASSE Street Address: City: 12/12/2014 2:22 PM National Fire Protection Association Report 91 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... State: Zip: Submittal Date: Fri Nov 14 12:12:48 EST 2014 12/12/2014 2:22 PM National Fire Protection Association Report 92 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 9-NFPA 350-2014 [ Section No. 6.3.5.7 ] 6.3.5.7 Psychological Hazards. Confined spaces, restricted movement, excessive noise, and PPE restriction may create psychological hazards. Some entrants may easily become claustrophobic or stressed, which may cause them to hyperventilate and alter their ability to reason and make sound decisions. Entrants should be evaluated prior (by who) prior to entry to ensure they are capable of performing assigned duties and should be continuously monitored for psychological stress. Entrants exhibiting physiological stress should be denied entry or removed immediately. (Suggest this section be deleted. Not sure if a field person is capable of making psychological determinations) Statement of Problem and Substantiation for Public Comment Suggest this section be deleted. Not sure if a field person is capable of making psychological determinations. If so, then the person responsible for this determination should be defined. Related Item Public Input No. 350-NFPA 350-2013 [Section No. 11.4.4.1] Submitter Information Verification Submitter Full Name: Donald Raffo Organization: General Dynamics, Electric Boa Street Address: City: State: Zip: Submittal Date: Wed Sep 10 12:38:19 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 93 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 359-NFPA 350-2014 [ Section No. 6.4.1 ] 6.4.1 Following hazard identification, the entry supervisor should conduct an assessment to determine the actual and potential risks to entrants and other confined space workers.Risk assessment is a process in which the expected severity of illness, injury, or property damage that an identified hazard may cause is coupled with the probability of that level of hazard occurring. Risk assessment enables prioritization of resources and indicates whether or not a hazard needs to be eliminated to establish acceptable entry parameters. If the level of risk is greater than what is acceptable(as described in the owners / operators confined space program) , control measures should be determined by the entry supervisor to eliminate, control, or mitigate the risk to an acceptable level. Statement of Problem and Substantiation for Public Comment Guidance on whom should provide risk acceptance / tolerance criteria Insert text as noted: ……. the level of risk is greater than what is acceptable (as described in the owners /operator confined space program), control measures …… Acceptability of risk should be described in the owners/operators HSE programs and either included or referenced in the confined space program. Related Item First Revision No. 5-NFPA 350-2014 [Chapter 6] Submitter Information Verification Submitter Full Name: EMERY THOMAS Organization: CONOCOPHILLIPS Street Address: City: State: Zip: Submittal Date: Fri Nov 14 16:05:27 EST 2014 12/12/2014 2:22 PM National Fire Protection Association Report 94 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 352-NFPA 350-2014 [ Section No. 6.4.2 ] 12/12/2014 2:22 PM National Fire Protection Association Report 95 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... 6.4.2 The general steps needed to provide acceptable entry conditions include, but are not limited to, the following: (1) Investigate thoroughly. Using information in this guide, entry supervisors should conduct a thorough investigation of existing or potential hazards that could pose a danger to entrants and confined space workers. Entry supervisors should then ensure entry requirements are documented on permits and that entrants and workers know what the hazards are, where and when they may be located or expected, and what control measures are appropriate for each hazard. (2) Conduct a hazard evaluation to determine the risks. Entry supervisors should develop hazard scenarios that describe the environment, possible exposures, actions, or events that could precipitate a hazard, and the outcome should the hazard occur. Hazard scenarios should determine what can go wrong, how the event may occur, what the consequences may be, and how likely the event is to happen. Consideration should also be given to the entry supervisors and entrants themselves, because their level of training, experience, and use of PPE can contribute to or create hazards in and around confined spaces. For example, wearing chemical protective clothing to prevent skin contact for an extended period of time in a hot environment may create heat stress hazards. (3) * Assess and evaluate risks. Entry supervisors should conduct a risk assessment to evaluate the hazards. This assessment can be quantitative, semiquantitative, or qualitative based on the needs of the situation and the identified hazards. Examples include performing air monitoring in the space (e.g., for oxygen levels, flammability, and toxic chemicals) and performing a visual inspection to determine if there are physical hazards. There are numerous methods for conducting risk assessments; one such method is outlined in ANSI/AIHA Z10-2012, Occupational Health and Safety Management Systems. (4) Prioritize the risks. The entry supervisor should prioritize and note which of the hazards pose the highest risk and focus on controlling or eliminating those first. (5) Determine control measures. Entry supervisors should know it is always best to eliminate hazards wherever possible regardless of the probability or severity of the hazard. If that is not feasible, the next best strategy is to use engineering controls to reduce exposures. Engineering controls include, but are not limited to,local exhaust ventilation to remove contaminants, general dilution ventilation to supply fresh air to the space, and substitution of materials so that chemicals are not introduced or produced during work in the space. Other types of control measures include administrative controls and PPE. Administrative controls include such measures as posting ; employee rotation to control toxic exposure, noise exposures or heat stress by administratively restricting time in the space, posting warning signs on confined spaces; ensuring , ensuring that personnel are trained how to identify, evaluate, and control hazards; and developing and implementing appropriate confined space, isolation, hot work, and other safety programs.PPE should be used when engineering and administrative controls are not sufficient to reduce or eliminate the hazards as PPE does not reduce or remove the hazard. (See also, Chapter 8.) (6) Verify control measures. Entry supervisors should ensure that the control measures chosen do not introduce additional hazards that have a higher level of risk or change the risk. For example, if ventilation ducts block the exit for entrants, it may be determined that the risk of not having the ventilation outweighs the risk posed by the blocked exit. (7) Determine if the level of risk is acceptable. Entry supervisors should determine if the risk has been reduced to an acceptable level,as determined by the organization or the supervisor, with the control measures chosen. For example, the risk assessment might conclude that a complicated, redundant ventilation system is required for entry. A facility in-house confined space entry team might conclude they are uncomfortable and unfamiliar with implementing such a system and determine that they will not complete the entry; instead, they conclude the risk is too great and decide to not conduct entry operations choosing instead to hire a professional contractor. (8) Implement and train. After the controls are implemented, entry supervisors should ensure that personnel involved in the entry operations are informed of the hazards, risk assessment determinations, specific control measures,and if the those control measures may pose a hazard. (9) Institute ongoing assessment. Entry supervisors should ensure that the identification and evaluation of hazards is an on-going process as conditions often change in a confined space due to inherent, introduced, and adjacent hazards. Entry supervisors should conduct regular visual and atmospheric monitoring of the space to ensure conditions do not change. Personnel should be aware that changing conditions may indicate the need to evacuate the space and re-evaluate it. 12/12/2014 2:22 PM National Fire Protection Association Report 96 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Statement of Problem and Substantiation for Public Comment Clarification. Related Item First Revision No. 5-NFPA 350-2014 [Chapter 6] Submitter Information Verification Submitter Full Name: TERRY W KRUG Organization: EXOSHA INC Affilliation: ASSE Street Address: City: State: Zip: Submittal Date: Fri Nov 14 12:27:46 EST 2014 12/12/2014 2:22 PM National Fire Protection Association Report 97 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 358-NFPA 350-2014 [ Section No. 6.4.2 ] 12/12/2014 2:22 PM National Fire Protection Association Report 98 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... 6.4.2 The general steps needed to provide acceptable entry conditions include, but are not limited to, the following: (1) Investigate thoroughly. Using information in this guide, entry supervisors should conduct a thorough investigation of existing or potential hazards that could pose a danger to entrants and confined space workers. Entry supervisors should then ensure entry requirements are documented on permits and that entrants and workers know what the hazards are, where and when they may be located or expected, and what control measures are appropriate for each hazard. (2) Conduct a hazard evaluation to determine the risks. Entry supervisors should develop hazard scenarios that describe the environment, possible exposures, actions, or events that could precipitate a hazard, and the outcome should the hazard occur. Hazard scenarios should determine what can go wrong, how the event may occur, what the consequences may be, and how likely the event is to happen. Consideration should also be given to the entry supervisors and entrants themselves, because their level of training, experience, and use of PPE can contribute to or create hazards in and around confined spaces. For example, wearing chemical protective clothing to prevent skin contact for an extended period of time in a hot environment may create heat stress hazards. (3) * Assess and evaluate risks. Entry supervisors should conduct a risk assessment to evaluate the hazards. This assessment can be quantitative, semiquantitative, or qualitative based on the needs of the situation and the identified hazards. Examples include performing air monitoring in the space (e.g., for oxygen levels, flammability, and toxic chemicals) and performing a visual inspection to determine if there are physical hazards. There are numerous methods for conducting risk assessments; one such method is outlined in ANSI/AIHA Z10-2012, Occupational Health and Safety Management Systems. (4) Prioritize the risks. The entry supervisor should prioritize and note which of the hazards pose the highest risk and focus on controlling or eliminating those first. (5) Determine control measures. Entry supervisors should know it is always best to eliminate hazards wherever possible regardless of the probability or severity of the hazard. If that is not feasible, the next best strategy is to use engineering controls to reduce exposures. Engineering controls include, but are not limited to,local exhaust ventilation to remove contaminants, general dilution ventilation to supply fresh air to the space, and substitution of materials so that chemicals are not introduced or produced during work in the space. Other types of control measures include administrative controls and PPE. Administrative controls include such measures as posting warning signs on confined spaces; ensuring that personnel are trained how to identify, evaluate, and control hazards; and developing and implementing appropriate confined space, isolation, hot work, and other safety programs.PPE should be used when engineering and administrative controls are not sufficient to reduce or eliminate the hazards as PPE does not reduce or remove the hazard. (See also, Chapter 8.) (6) Verify control measures. Entry supervisors should ensure that the control measures chosen do not introduce additional hazards that have a higher level of risk or change the risk. For example, if ventilation ducts block the exit for entrants, it may be determined that the risk of not having the ventilation outweighs the risk posed by the blocked exit. (7) Determine if the level of risk is acceptable. Entry supervisors should determine if the risk has been reduced to an acceptable level,as determined by the organization or the supervisor, with the control measures chosen. For example, the risk assessment might conclude that a complicated, redundant ventilation system is required for entry. A facility in-house confined space entry team might conclude they are uncomfortable and unfamiliar with implementing such a system and determine that they will not complete the entry; instead, they conclude the risk is too great and decide to not conduct entry operations choosing instead to hire a professional contractor. (8) Implement and train. After the controls are implemented, entry supervisors should ensure that personnel involved in the entry operations are informed of the hazards, risk assessment determinations, specific control measures,and if the those control measures may pose a hazard. (9) Institute ongoing assessment. Entry supervisors should ensure that the identification and evaluation of hazards is an on-going process as conditions often change in a confined space due to inherent, introduced, and adjacent hazards. Entry supervisors should conduct regular visual and atmospheric monitoring of the space to ensure conditions do not change. Personnel should be aware that changing conditions may indicate the need to evacuate the space and re-evaluate it. 12/12/2014 2:22 PM National Fire Protection Association Report 99 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Statement of Problem and Substantiation for Public Comment Within this section (hazard evaluation) it states that the entry supervisor should conduct an assessment to determine the actual and potential risks to the entrants and other confined space workers and further states that the entry supervisor should assess and evaluate the risks etc. Risk assessments normally should not be conducted solely by one individual and almost always should include those involved with the work activities. Recommend that this is changed to reflect that the entry supervisor should lead the assessment and include entrants, confined space works and those involved with the work. Related Item First Revision No. 5-NFPA 350-2014 [Chapter 6] Submitter Information Verification Submitter Full Name: EMERY THOMAS Organization: CONOCOPHILLIPS Street Address: City: State: Zip: Submittal Date: Fri Nov 14 16:01:09 EST 2014 12/12/2014 2:22 PM National Fire Protection Association Report 100 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 360-NFPA 350-2014 [ Section No. 6.4.2 ] 12/12/2014 2:22 PM National Fire Protection Association Report 101 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... 6.4.2 The general steps needed to provide acceptable entry conditions include, but are not limited to, the following: (1) Investigate thoroughly. Using information in this guide, entry supervisors should conduct a thorough investigation of existing or potential hazards that could pose a danger to entrants and confined space workers. Entry supervisors should then ensure entry requirements are documented on permits and that entrants and workers know what the hazards are, where and when they may be located or expected, and what control measures are appropriate for each hazard. (2) Conduct a hazard evaluation to determine the risks. Entry supervisors should develop hazard scenarios that describe the environment, possible exposures, actions, or events that could precipitate a hazard, and the outcome should the hazard occur. Hazard scenarios should determine what can go wrong, how the event may occur, what the consequences may be, and how likely the event is to happen. Consideration should also be given to the entry supervisors and entrants themselves, because their level of training, experience, and use of PPE can contribute to or create hazards in and around confined spaces. For example, wearing chemical protective clothing to prevent skin contact for an extended period of time in a hot environment may create heat stress hazards. (3) * Assess and evaluate risks. Entry supervisors should conduct a risk assessment to evaluate the hazards. This assessment can be quantitative, semiquantitative, or qualitative based on the needs of the situation and the identified hazards. Examples include performing air monitoring in the space (e.g., for oxygen levels, flammability, and toxic chemicals) and performing a visual inspection to determine if there are physical hazards. There are numerous methods for conducting risk assessments; one such method is outlined in ANSI/AIHA Z10-2012, Occupational Health and Safety Management Systems. (4) Prioritize the risks. The entry supervisor should prioritize and note which of the hazards pose the highest risk and focus on controlling or eliminating those first. (5) Determine control measures. Entry supervisors should know it is always best to eliminate hazards wherever possible regardless of the probability or severity of the hazard. If that is not feasible, the next best strategy is to use engineering controls to reduce exposures. Engineering controls include, but are not limited to,local exhaust ventilation to remove contaminants, general dilution ventilation to supply fresh air to the space, and substitution of materials so that chemicals are not introduced or produced during work in the space. Other types of control measures include administrative controls and PPE. Administrative controls include such measures as posting warning signs on confined spaces; ensuring that personnel are trained how to identify, evaluate, and control hazards; and developing and implementing appropriate confined space, isolation, hot work, and other safety programs.PPE should be used when engineering and administrative controls are not sufficient to reduce or eliminate the hazards as PPE does not reduce or remove the hazard. (See also, Chapter 8.) (6) Verify control measures. Entry supervisors should ensure that the control measures chosen do not introduce additional hazards that have a higher level of risk or change the risk. For example, if ventilation ducts block the exit for entrants, it may be determined that the risk of not having the ventilation outweighs the risk posed by the blocked exit. (7) Determine if the level of risk is acceptable. Entry supervisors should determine if the risk has been reduced to an acceptable level,as determined by the organization or the supervisor, with the control measures chosen. For example, the risk assessment might conclude that a complicated, redundant ventilation system is required for entry. A facility in-house confined space entry team might conclude they are uncomfortable and unfamiliar with implementing such a system and determine that they will not complete the entry; instead, they conclude the risk is too great and decide to not conduct entry operations choosing instead to hire a professional contractor. (8) Implement and train. After the controls are implemented, entry supervisors should ensure that personnel involved in the entry operations are informed of the hazards, risk assessment determinations, specific control measures,and if the those control measures may pose a hazard. (9) Institute ongoing assessment. Entry supervisors should ensure that the identification and evaluation of hazards is an on-going process as conditions often change in a confined space due to inherent, introduced, and adjacent hazards. Entry supervisors should conduct regular visual and atmospheric monitoring of the space to ensure conditions do not change. Personnel should be aware that changing conditions may indicate the need to evacuate the space and re-evaluate it. 12/12/2014 2:22 PM National Fire Protection Association Report 102 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Statement of Problem and Substantiation for Public Comment “… assessment can be quantitative, semi quantitative, or qualitative…” For confined space entry risk assessment to date have never seen a quantitative method used. Recommend to remove quantitative and state that qualitative and semi quantitative being the most widely used methods. Related Item First Revision No. 5-NFPA 350-2014 [Chapter 6] Submitter Information Verification Submitter Full Name: EMERY THOMAS Organization: CONOCOPHILLIPS Street Address: City: State: Zip: Submittal Date: Fri Nov 14 16:09:15 EST 2014 12/12/2014 2:22 PM National Fire Protection Association Report 103 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 353-NFPA 350-2014 [ Section No. 6.5 [Excluding any Sub-Sections] ] A vital, reiterative part of reducing hazards is communication. It starts after the identification of hazards and the employer communicates them to all persons involved with the entry or working around a confined space. Statement of Problem and Substantiation for Public Comment Clarity Related Item First Revision No. 5-NFPA 350-2014 [Chapter 6] Submitter Information Verification Submitter Full Name: TERRY W KRUG Organization: EXOSHA INC Affilliation: ASSE Street Address: City: State: Zip: Submittal Date: Fri Nov 14 12:37:05 EST 2014 12/12/2014 2:22 PM National Fire Protection Association Report 104 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 100-NFPA 350-2014 [ Section No. 6.5.2 ] 6.5.2 The authorization for entry procedure and permit should outline how communication during the entry, work, and exit stages will be conducted, ensuring that authorized entrants and attendants can maintain contact during entry and throughout the work shift. Because voice communications may Where the potential extists for voice communications to be hampered by noise, PPE, distance, and so forth space configuration or other blockage , two forms of communication should be used. Statement of Problem and Substantiation for Public Comment two forms are only needed where required due to blockages Related Item Public Input No. 794-NFPA 350-2013 [Section No. 6.5.2] Submitter Information Verification Submitter Full Name: Richard Kraus Organization: API/Petroleum Safety Consultan Street Address: City: State: Zip: Submittal Date: Tue Sep 23 09:09:46 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 105 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 101-NFPA 350-2014 [ Section No. 6.5.3 ] 6.5.3 The risks and potential exposures of the entry as well as the signs and symptoms of exposure need to be communicated to the entrant and the attendant. The supervisor should ensure that they are familiar with assigned equipment, such as PPE, atmospheric testing equipment, alarm systems, and and the rescue equipment available as well as alarms and means of communtication . Statement of Problem and Substantiation for Public Comment for clarity. alarm SYSTEMS are not necessarily equipment, need to add communications Related Item Public Input No. 795-NFPA 350-2013 [Section No. 6.5.3] Submitter Information Verification Submitter Full Name: Richard Kraus Organization: API/Petroleum Safety Consultan Street Address: City: State: Zip: Submittal Date: Tue Sep 23 09:13:53 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 106 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 354-NFPA 350-2014 [ Section No. 6.5.6 ] 6.5.6 The entry supervisor needs to ensure that the attendant(s) has the means to notify the designated rescue team, the notification method is operable, and the rescue team is aware of the entry . Statement of Problem and Substantiation for Public Comment Clarification. Related Item First Revision No. 5-NFPA 350-2014 [Chapter 6] Submitter Information Verification Submitter Full Name: TERRY W KRUG Organization: EXOSHA INC Affilliation: ASSE Street Address: City: State: Zip: Submittal Date: Fri Nov 14 12:39:05 EST 2014 12/12/2014 2:22 PM National Fire Protection Association Report 107 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 102-NFPA 350-2014 [ Section No. 6.6.1 [Excluding any Sub-Sections] ] Safety datasheets data sheets (SDS) should be available and reviewed for recent materials that previously have been stored or used in a confined space being entered, have been used to purge a confined space being entered, or are being brought into the space being entered. Statement of Problem and Substantiation for Public Comment editorial and consistency with other sections Related Item Public Input No. 801-NFPA 350-2013 [Section No. 6.6.1 [Excluding any Sub-Sections]] Submitter Information Verification Submitter Full Name: Richard Kraus Organization: API/Petroleum Safety Consultan Street Address: City: State: Zip: Submittal Date: Tue Sep 23 09:17:43 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 108 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 361-NFPA 350-2014 [ Section No. 7.1 ] 7.1 General. The purpose of this chapter is to outline the steps necessary for testing and evaluating confined space atmospheres for gaseous hazards and to help determine the equipment necessary for this task. This chapter does not cover evaluating or testing for nongaseous hazards such as dusts, particulates, or other potential atmospheric hazards. Statement of Problem and Substantiation for Public Comment As stated this chapter does not include evaluating or testing for nongaseous hazards such as dust, particulates, or other potential atmospheric hazards. While this is understandable it does however feel like it is somewhat incomplete. Is it possible to at least refer to various standards or guidelines covering the nongaseous air monitoring? Or – …… consultation with Safety and Health or Industrial Hygiene professionals ….. be added here. Related Item First Revision No. 6-NFPA 350-2014 [Chapter 7] Submitter Information Verification Submitter Full Name: EMERY THOMAS Organization: CONOCOPHILLIPS Street Address: City: State: Zip: Submittal Date: Fri Nov 14 16:14:55 EST 2014 12/12/2014 2:22 PM National Fire Protection Association Report 109 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 103-NFPA 350-2014 [ Section No. 7.2 [Excluding any Sub-Sections] ] Atmospheric monitoring should be performed using the procedures described in this chapter prior to any confined space entry to determine if the atmosphere within the space is safe for entry. Atmospheric monitoring may not be necessary if the documented initial hazard evaluation, as described in Chapter 6, has determined that there is no potential for atmospheric hazards to exist in the space. Atmospheric monitoring is performed for two distinct purposes: (1) Pre-entry testing to evaluate the initial hazard(s) (2) Pre-entry testing to determine if any changes occurred fron the time of the initial evaluation (3) Continuous or periodic monitoring of the atmosphere within the space (see Section 7.14 ) as required by the applicable confined space program or as determined by the entry supervisor. Statement of Problem and Substantiation for Public Comment there are 2 phases to pre entry monitoring as noted There are many instances where continuous monitoring is NOT required. For example, the space may become or has been free of contaminants and monitoring may be only needed to evaluate initial entry and start of work to assure no disturbances occur. It is i9ndustry practice to provide for periodic monitoring where acceptable. Related Item Public Input No. 70-NFPA 350-2013 [Section No. 7.1 [Excluding any Sub-Sections]] Submitter Information Verification Submitter Full Name: Richard Kraus Organization: API/Petroleum Safety Consultan Street Address: City: State: Zip: Submittal Date: Tue Sep 23 10:18:13 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 110 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 104-NFPA 350-2014 [ Section No. 7.3 [Excluding any Sub-Sections] ] The atmosphere of a confined space should be tested for all potential hazardous atmospheric contaminants as identified in the initial hazard evaluation (see Chapter 6) before each entryby a gas tester.The appropriate testing equipment should be used to determine that the atmospheric concentrations at the time of entry are within the range of acceptable entry conditions as described in 8.4.2 . The results of the testing (e.g., actual gas concentrations) should be recorded along with the stipulated acceptable entry conditions according to the permit recommendations in Chapter 13. All gas monitors should be equipped with the proper sensors to detect the potential atmospheric hazards being tested and certified for use in the environment where it is being used. Refer to the gas monitor manufacturer’s specifications and hazardous location certifications . Statement of Problem and Substantiation for Public Comment what is this??? Needs a definition Related Item Public Input No. 857-NFPA 350-2013 [Section No. 7.1.2] Submitter Information Verification Submitter Full Name: Richard Kraus Organization: API/Petroleum Safety Consultan Street Address: City: State: Zip: Submittal Date: Tue Sep 23 10:31:04 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 111 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 89-NFPA 350-2014 [ Section No. 7.3.6 [Excluding any Sub-Sections] ] If the confined space has not been opened or the atmosphere is not immediately accessible for testing, the entry supervisor should open the confined space just enough to allow insertion of a probe for testing. Any potential hazard, including, but not limited to, pressure and electric shock should be eliminated, controlled, or mitigated prior to opening the space. Some manhole covers may have a small opening to allow the insertion of a sampling hose gas detector sampling tube or lowered via rope . Statement of Problem and Substantiation for Public Comment Gas detection equipment can also be lowered into spaces via a rope. Singling out sampling tubes may be too limiting especially considering the depth of the confined space being entered. Related Item First Revision No. 6-NFPA 350-2014 [Chapter 7] Submitter Information Verification Submitter Full Name: JAMES TYLER Organization: VESTAS Affilliation: American Wind Energy Association (AWEA) Street Address: City: State: Zip: Submittal Date: Fri Sep 12 12:53:43 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 112 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 11-NFPA 350-2014 [ Section No. 7.3.7 ] 7.3.7 As much of the confined space’s horizontal and/or vertical areaas possible should be tested by use of a pump and remote probe or sample hose from the outside before the space is entered for further testing. Statement of Problem and Substantiation for Public Comment typo corrected Related Item Public Input No. 350-NFPA 350-2013 [Section No. 11.4.4.1] Submitter Information Verification Submitter Full Name: Donald Raffo Organization: General Dynamics, Electric Boa Street Address: City: State: Zip: Submittal Date: Wed Sep 10 12:41:35 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 113 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 108-NFPA 350-2014 [ Section No. 7.3.10 ] 7.3.10 Where testing for entries involving a vertical descent, the atmosphere should be tested according to the procedures outlined in 7.13.2 . this chapter. Statement of Problem and Substantiation for Public Comment 7.13.2 is incorrect Related Item Public Input No. 868-NFPA 350-2013 [Section No. 7.1.12] Submitter Information Verification Submitter Full Name: Richard Kraus Organization: API/Petroleum Safety Consultan Street Address: City: State: Zip: Submittal Date: Tue Sep 23 10:46:24 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 114 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 109-NFPA 350-2014 [ Section No. 7.3.11 ] 7.3.11 If the confined space requires a horizontal entry, atmospheric monitoring should be performed according to 7.13.3 . procedures in this chapter. Statement of Problem and Substantiation for Public Comment 7.13.3 is incorrect Related Item Public Input No. 869-NFPA 350-2013 [Section No. 7.1.13] Submitter Information Verification Submitter Full Name: Richard Kraus Organization: API/Petroleum Safety Consultan Street Address: City: State: Zip: Submittal Date: Tue Sep 23 10:48:46 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 115 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 105-NFPA 350-2014 [ Section No. 7.3.13 ] 7.3.13 Whereas the pre-entry test determines the initial air quality before the confined space is entered, it is important there may be a need to continually or periodically monitor for changes in the atmosphere during work operations inside the space, depending on the actual or potential hazards, to ensure that a safe atmosphere is maintained. (See Section 7.14 .) . Statement of Problem and Substantiation for Public Comment There are many instances where continuous monitoring is NOT required. For example, the space may become or has been free of contaminants and monitoring may be only needed to evaluate initial entry and start of work to assure no disturbances occur. Remember, this committee has chosen to regard ALL confined spaces as permit required even if they actually may be categorized otherwise such as a non-permit required confined space. . Also it is industry practice to provide for periodic monitoring where acceptable. Related Item Public Input No. 871-NFPA 350-2013 [Section No. 7.1.15] Submitter Information Verification Submitter Full Name: Richard Kraus Organization: API/Petroleum Safety Consultan Street Address: City: State: Zip: Submittal Date: Tue Sep 23 10:34:31 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 116 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 106-NFPA 350-2014 [ Section No. 7.3.14 [Excluding any Sub-Sections] ] If hazardous atmospheric conditions as described in Section 7.14 are detected during pre-entry testing, entry should be prohibited until corrective actions are taken and retesting verifies acceptable atmospheric conditions in accordance with the applicable confined space program and entry permit . Entry into the space using appropriate respiratory protection may be considered acceptable corrective action provided the atmosphere does not contain flammable or combustible vapors in excess of the acceptable entry conditions. Statement of Problem and Substantiation for Public Comment need to tell where to find acceptable atmospheric conditions Related Item Public Input No. 872-NFPA 350-2013 [Section No. 7.1.16] Submitter Information Verification Submitter Full Name: Richard Kraus Organization: API/Petroleum Safety Consultan Street Address: City: State: Zip: Submittal Date: Tue Sep 23 10:40:24 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 117 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 107-NFPA 350-2014 [ Section No. 7.3.15.1 ] 7.3.15.1 If any results from atmospheric monitoringexceed monitoring exceed the acceptable limits for entry described in Section 7.17, all work within the confined space should cease and the space should be evacuated immediately. Statement of Problem and Substantiation for Public Comment editorial Related Item Public Input No. 72-NFPA 350-2013 [Section No. 7.1.17.1] Submitter Information Verification Submitter Full Name: Richard Kraus Organization: API/Petroleum Safety Consultan Street Address: City: State: Zip: Submittal Date: Tue Sep 23 10:43:11 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 118 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 12-NFPA 350-2014 [ Section No. 7.4.2 ] 7.4.2 Selection of Monitor. Confined space monitors should be calibrated, direct-reading, continuous-monitoring gas monitors. The monitor should detect for oxygen (O ) content, flammable gasses and vapors (LFL LEL ), and potential 2 toxic gases, all of whichare which are minimum requirements. The hazard evaluation will determine if it is necessary to monitor for specific gases, including, but not limited to, carbon monoxide (CO), hydrogen sulfide (H S), ammonia (NH ), or volatile organic compounds (VOCs), such as benzene. Each of these 2 3 hazardous gases can require unique sensor technology to be detected properly. In addition, real-time and integrated monitoring of other potential atmospheric hazards, such as welding fumes and particulates, might be necessary per the hazard identification and hazard evaluation. Statement of Problem and Substantiation for Public Comment Suggest the use of LEL throughout the document. It is defined and used more than LFL, also corrected a typo. Related Item Public Input No. 350-NFPA 350-2013 [Section No. 11.4.4.1] Submitter Information Verification Submitter Full Name: Donald Raffo Organization: General Dynamics, Electric Boa Street Address: City: State: Zip: Submittal Date: Wed Sep 10 12:42:46 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 119 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 110-NFPA 350-2014 [ Section No. 7.4.3 ] 7.4.3 Portable vs. Fixed Monitors. Portable gas monitors should be used for confined space entry atmospheric monitoring. In confined spaces where fixed gas detectors are installed, portable gas monitors should be used for pre-entry testing and either carried into or worn by the entrant in the space. Statement of Problem and Substantiation for Public Comment portable monitors may not necessarily be worn but may be carried INTO THE SPACE. Related Item Public Input No. 54-NFPA 350-2013 [Section No. 7.2.3] Submitter Information Verification Submitter Full Name: Richard Kraus Organization: API/Petroleum Safety Consultan Street Address: City: State: Zip: Submittal Date: Tue Sep 23 10:55:17 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 120 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 257-NFPA 350-2014 [ Section No. 7.4.4.1 ] 7.4.4.1 Direct-reading gas monitors used to evaluate or verify confined space atmospheres should provide a reading accuracy of ± 20 percent or better of the actual gas concentration in all use conditions that are covered within the monitors’ operating specifications. The following comments are the opinion of the AIHA’s Real‐Time Detec on Systems Commi ee but are not AIHA comments. 7.4.4 Monitor Accuracy 7.4.4.1 Direct‐reading gas monitors used to evaluate or verify confined space atmospheres should provide a reading accuracy of ± 20% or be er of the actual gas concentra on in all use condi ons that are covered within the monitors opera ng specifica ons Manufacturers of direct‐reading gas monitors used to evaluate or verify confined space atmospheres should provide documenta on that the equipment performs within the accuracy requirements specified in applicable na onal or interna onal standards (which may be different for flammable gas, oxygen concentra on or toxic gases) over the range of condi ons recommended for use. In the field, users should verify that the equipment provides a reading within appropriate specifica ons using standard gas mixtures traceable to na onal or interna onal standards. Statement of Problem and Substantiation for Public Comment The way it is currently written does not adequately protect the worker. Related Item First Revision No. 6-NFPA 350-2014 [Chapter 7] Submitter Information Verification Submitter Full Name: JACK HILL Organization: na Street Address: City: State: Zip: Submittal Date: Mon Nov 10 17:31:05 EST 2014 12/12/2014 2:22 PM National Fire Protection Association Report 121 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 258-NFPA 350-2014 [ Section No. 7.4.4.2 ] 7.4.4.2 The gas tester should verify that gas monitors using correlation or response factors to determine the level of a gas or vapor concentration that is different from that for which the sensor or gas monitors is calibrated have an accuracy of ± 30 percent or better with the correlation factor applied. For example, a monitor equipped with a PID calibrated to isobutylene can be used to detect the level of trichloroethylene in a confined space. The monitor reading should be multiplied by a correlation or response factor, specified by the manufacturer, to determine the relative concentration of trichloroethylene in the space. The accuracy of the value after the reading has been multiplied by the correlation factor should be better than ± 30 percent. The gas monitor manufacturer should be consulted for information related to response factors and gas monitor performance. Statement of Problem and Substantiation for Public Comment The way it is currently written does not adequately protect the worker. Related Item First Revision No. 6-NFPA 350-2014 [Chapter 7] Submitter Information Verification Submitter Full Name: JACK HILL Organization: na Street Address: City: State: Zip: Submittal Date: Mon Nov 10 17:36:50 EST 2014 12/12/2014 2:22 PM National Fire Protection Association Report 122 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 13-NFPA 350-2014 [ Section No. 7.4.5 ] 7.4.5 Limits of Detection. The minimum detection limit (MDL),which is the smallest level of a gas that can be detected within the specified accuracy or repeatability of the monitor, should be less than 2 percent for oxygen, 2 percent LFL LEL for combustible gases, and at least one order of magnitude lower than the published permissible exposure limit (PEL) or threshold limit value (TLV), whichever is lower, for toxic gases. The levels can be determined from manufacturers’ specifications. For example, the current OSHA PEL for chlorine (Cl ) is a 2 ceiling limit of 1.0 ppm. The MDL for a chlorine monitor should be less than or equal to 10 percent of 1.0 ppm, or 0.1 ppm. Lower MDLs provide for greater reading stability and confidence around gas concentration action points and reduce or eliminate false or nuisance alarms due to detector or sensor instability. Statement of Problem and Substantiation for Public Comment Suggest use of LEL throughout the document Related Item Public Input No. 350-NFPA 350-2013 [Section No. 11.4.4.1] Submitter Information Verification Submitter Full Name: Donald Raffo Organization: General Dynamics, Electric Boa Street Address: City: State: Zip: Submittal Date: Wed Sep 10 12:43:56 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 123 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 259-NFPA 350-2014 [ Section No. 7.4.5 ] 7.4.5 Limits of Detection. The minimum detection limit (MDL),which is the smallest level of a gas that can be detected within the specified accuracy or repeatability of the monitor, should be less than 2 percent for oxygen, 2 percent LFL for combustible gases, and at least one order of magnitude lower than the published permissible exposure limit (PEL) or threshold limit value (TLV), whichever is lower, for toxic gases. The levels can be determined from manufacturers’ specifications. For example, the current OSHA PEL for chlorine (Cl ) is a ceiling limit 2 of 1.0 ppm. The MDL for a chlorine monitor should be less than or equal to 10 percent of 1.0 ppm, or 0.1 ppm. Lower MDLs provide for greater reading stability and confidence around gas concentration action points and reduce or eliminate false or nuisance alarms due to detector or sensor instability. Statement of Problem and Substantiation for Public Comment The way it is currently written does not adequately protect the worker. Related Item First Revision No. 6-NFPA 350-2014 [Chapter 7] Submitter Information Verification Submitter Full Name: JACK HILL Organization: na Street Address: City: State: Zip: Submittal Date: Mon Nov 10 17:38:17 EST 2014 12/12/2014 2:22 PM National Fire Protection Association Report 124 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 14-NFPA 350-2014 [ Section No. 7.4.7.6.1 ] 7.4.7.6.1 Gas monitors used toevaluate to evaluate or verify confined space atmospheres should be certified by the manufacturer to test and perform in accordance with relevant guidelines for RFI/EMI. Statement of Problem and Substantiation for Public Comment Corrected typo and suggest that RFI and EMI be spelled out. Not everyone knows what they mean. If not they should be defined. Related Item Public Input No. 350-NFPA 350-2013 [Section No. 11.4.4.1] Submitter Information Verification Submitter Full Name: Donald Raffo Organization: General Dynamics, Electric Boa Street Address: City: State: Zip: Submittal Date: Wed Sep 10 12:44:43 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 125 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 230-NFPA 350-2014 [ Section No. 7.7.2 [Excluding any Sub-Sections] ] Gas Where required by owner/operator or contractor/subcontractor confined space programs or by applicable regulations, gas monitors used by confined space personnel for personal monitoring may be used in either diffusion or aspirated mode. Statement of Problem and Substantiation for Public Comment It is not industry practice to have every individual use a perso0nal monitor either inside or outside a confined space. Personal monitors should be used as required by applicable programs. Related Item Public Input No. 910-NFPA 350-2013 [Section No. 7.5.2 [Excluding any Sub-Sections]] Submitter Information Verification Submitter Full Name: Richard Kraus Organization: API/Petroleum Safety Consultan Street Address: City: State: Zip: Submittal Date: Sat Oct 25 13:50:20 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 126 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 231-NFPA 350-2014 [ Section No. 7.7.2.1 ] 7.7.2.1 Confined space Where required by the applicable confined space program and entry permit or by applicable regulations, confined space entrants should wear a gas monitor at all times during entry. It When used, it is critical that the monitor or sample input does not get covered by clothing or PPE or it will no longer be measuring the in order that it properly measures the atmosphere. Statement of Problem and Substantiation for Public Comment it is not industry practice THAT ALL entrants use individual monitors at all times. Use should be as required by program or regulations. Related Item Public Input No. 911-NFPA 350-2013 [Section No. 7.5.2.1] Submitter Information Verification Submitter Full Name: Richard Kraus Organization: API/Petroleum Safety Consultan Street Address: City: State: Zip: Submittal Date: Sat Oct 25 13:54:43 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 127 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 232-NFPA 350-2014 [ Section No. 7.7.2.2 ] 7.7.2.2 Confined space Where required by the confined space program, entry permit or regulations, confined space attendants should wear a direct-reading gas monitor , or one should a portable monitor should be placed in the a nearby area outside the of the confined space. This would allow Where there is a potential for outside atmospheric contamination, this provides a means for the attendant to monitor the environment outside the confined space to make sure it is not changing. If ventilation is exhausting toxic materials outside the space, it could affect the area immediately outside the space, includingthe including the attendant, even if the confined space itself is not showing elevated readings. Likewise, if a toxic or combustible atmosphere develops outside the confined space, it could affect the environment in the confined space. The sooner the attendant can be made aware of changes, the sooner a decision can be made whether or not to stop operations and vacate the space. Statement of Problem and Substantiation for Public Comment it is not industry practice to continually monitor outside atmosphere. Also, suppose entry is into a plenum in an office where people are working. Where is the need to monitor outside air???? There are specific cases where this is needed and should be recognized and required ON THE PERMIT...not across the board for all entries Related Item Public Input No. 912-NFPA 350-2013 [Section No. 7.5.2.2] Submitter Information Verification Submitter Full Name: Richard Kraus Organization: API/Petroleum Safety Consultan Street Address: City: State: Zip: Submittal Date: Sat Oct 25 13:59:44 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 128 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 15-NFPA 350-2014 [ Section No. 7.8.1.1 ] 7.8.1.1 The gas monitor should be programmed to sense to detect a set concentration of specific gases aligned to the configuration of the gas monitor for calibration purposes. For example, the gas monitor might be programmed to read 20.9 percent oxygen (O ), 32 percent methane (LEL), 25 ppm hydrogen sulfide (H S), 2 2 and 50 ppm carbon monoxide (CO) during the calibration process. The gas monitoris then exposed to a blend of the same calibration gases with identical defined concentrations . The gas monitor then “calibrates” what it is programmed to see against what it is being exposed to. This is a span calibration. Through this process, the gas monitor will either pass or fail the span calibration. If the calibration or the gas monitor fails, the unit should be removed from service and tagged for maintenance. If the gas monitor passes, it is ready for confined space monitoring. Statement of Problem and Substantiation for Public Comment Suggest replacing sense with detect. Detect is commonly used vs sense which is not. Related Item Public Input No. 350-NFPA 350-2013 [Section No. 11.4.4.1] Submitter Information Verification Submitter Full Name: Donald Raffo Organization: General Dynamics, Electric Boa Street Address: City: State: Zip: Submittal Date: Wed Sep 10 12:48:09 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 129 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 90-NFPA 350-2014 [ Section No. 7.10.3 ] 7.10.3 The gas tester qualified person should perform the test by applying a known concentration of each of the target gases to the gas monitor/sensors individually or in combination and verifying that each sensor responds in a positive manner and that all gas monitor alarms are activated accordingly. The gas tester qualifed person should refer to the manufacturer’s instructions and recommendations for performing a bump test. Statement of Problem and Substantiation for Public Comment Gas tester and gas detector terminology can be very confusing. Both can be confused with the hand-held, portable gas detector. Reading through this section intermingles the physical person with the physical device. Related Item First Revision No. 6-NFPA 350-2014 [Chapter 7] Submitter Information Verification Submitter Full Name: JAMES TYLER Organization: VESTAS Affilliation: American Wind Energy Association (AWEA) Street Address: City: State: Zip: Submittal Date: Fri Sep 12 13:23:23 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 130 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 111-NFPA 350-2014 [ Section No. 7.13.1 ] 7.13.1 The atmosphere in and around a confined space should remain safe during entry operations. Atmospheric conditions can change quickly or gradually over time; and without continuous air monitoring, air contaminants may increase or the oxygen percentage maydecrease or increase, creating dangerous confined space atmospheric conditions. Entrants, attendants, and other personnel may be unaware of changing conditions if the air quality was only initially monitored and determined to be acceptable. The atmosphere within and outside the confined space should be monitored continuously or periodically as required by the applicable confined space program, regulations and/or entry permit and as determined by the entry supervisor to ensure continued safe working conditions. Statement of Problem and Substantiation for Public Comment There are many instances where continuous monitoring is NOT required. For example, the space may become or has been free of contaminants and monitoring may be only needed to evaluate initial entry and start of work to assure no disturbances occur. It is industry practice to provide for periodic monitoring where acceptable and for continuous monitoring in situations where atmospheric conditions may change for the worse. Related Item Public Input No. 73-NFPA 350-2013 [Section No. 7.11.1] Submitter Information Verification Submitter Full Name: Richard Kraus Organization: API/Petroleum Safety Consultan Street Address: City: State: Zip: Submittal Date: Tue Sep 23 11:13:09 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 131 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 233-NFPA 350-2014 [ Section No. 7.13.2 ] 7.13.2 Entry supervisors, gas testers, attendants, and entrants should be aware that there are many reasons why air quality may deteriorate in and around confined spaces, including,but not limited to, air contaminants generated by activities inside or outside the space, increased temperatures causing additional chemical vaporization, and existing or new hazards that have not been adequately controlled or mitigated. Where the potential exists for such changes, monitoring should be conducted continuously or periodically in accordance with the requirements of the applicable confined space program, entry permit and regulations. Statement of Problem and Substantiation for Public Comment there is no need for this type of monitoring where that is no potential for contamination. Where the potential exists, then monitoring should be periodic or continuous as required. Related Item Public Input No. 923-NFPA 350-2013 [Section No. 7.11.2] Submitter Information Verification Submitter Full Name: Richard Kraus Organization: API/Petroleum Safety Consultan Street Address: City: State: Zip: Submittal Date: Sat Oct 25 14:14:17 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 132 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 112-NFPA 350-2014 [ Section No. 7.13.3 ] 7.13.3 Continuous air monitoring is the best method to ensure or periodic air monitoring, in accordance with the applicable confined space program, regulations or entry permit, may be required by the entry supervisor to determine that air quality remains acceptable throughout confined space entry operations, including those spaces that have been initially tested and declared to be vapor and gas free . . Statement of Problem and Substantiation for Public Comment There are many instances where continuous monitoring is NOT required. For example, the space may become or has been free of contaminants and monitoring may be only needed to evaluate initial entry and start of work to assure no disturbances occur. At other times, the confined space may no longer be a "permit required" space and there is no need for monitoring. It also is industry practice to provide for periodic monitoring where applicable and acceptable. Related Item Public Input No. 74-NFPA 350-2013 [Section No. 7.11.3] Submitter Information Verification Submitter Full Name: Richard Kraus Organization: API/Petroleum Safety Consultan Street Address: City: State: Zip: Submittal Date: Tue Sep 23 11:15:53 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 133 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 180-NFPA 350-2014 [ Section No. 7.14 ] 7.14 Acceptable Atmospheric Limits for Entry. Where levels are outside the following parameters, entry is allowed only after control measures as indicated in Chapter 8 are applied: (1) Oxygen content is between 19.5 percent and 22.0 percent; (2) Flammable gases and vapors are below 10 percent of the LFL or LEL of the material involved (3) * Potential toxic air contaminants are at or below one half the OEL — typically the action level — as determined by the written confined space program. Statement of Problem and Substantiation for Public Comment The way it is currently written does not adequately protect the worker. Related Item First Revision No. 6-NFPA 350-2014 [Chapter 7] Submitter Information Verification Submitter Full Name: JACK HILL Organization: na Street Address: City: State: Zip: Submittal Date: Thu Sep 25 11:30:04 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 134 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 234-NFPA 350-2014 [ Section No. 7.14 ] 7.14 Acceptable Atmospheric Limits for Entry. Where atmospheric levels are outside the following parameters, entry is allowed only after control measures as indicated in Chapter 8 are applied: supervisors may permit entry as provided for in regulations or the applicable confined space program, by requiring appropriate control measures such as those indicated in Chapter 8. (1) Oxygen content is between 19.5 percent and 22.0 percent; (2) Flammable gases and vapors are below 10 percent of the LFL or LEL of the material involved (3) * Potential toxic air contaminants are at or below one half the OEL — typically the action level — as determined by the written confined space program. Note: There may be situations where regulations or the applicable confined space program provides for entry under conditions other than those indicated above. An example of this is entry under inert conditions. Statement of Problem and Substantiation for Public Comment as written this is very restrictive and is not feasible in many instances. As proposed, this allows for safe variances. Related Item Public Input No. 925-NFPA 350-2013 [Section No. 7.12] Submitter Information Verification Submitter Full Name: Richard Kraus Organization: API/Petroleum Safety Consultan Street Address: City: State: Zip: Submittal Date: Sat Oct 25 14:27:43 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 135 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 362-NFPA 350-2014 [ Section No. 7.14 ] 7.14 Acceptable Atmospheric Limits for Entry. Where levels are outside the following parameters, entry is allowed only after control measures as indicated in Chapter 8 are applied: (1) Oxygen content is between 19.5 percent and 22 23 .0 5 percent; (2) Flammable gases and vapors are below 10 percent of the LFL or LEL of the material involved (3) * Potential toxic air contaminants are at or below one half the OEL — typically the action level — as determined by the written confined space program. Statement of Problem and Substantiation for Public Comment Note: an acceptable oxygen content up to 23.5% is in use by several organizations, can NFPA provide reference guidance in Appendix A which supports the oxygen ranges indicated as acceptable. Also referenced in sections 8.5.6 & 12.7.1 Related Item First Revision No. 6-NFPA 350-2014 [Chapter 7] Submitter Information Verification Submitter Full Name: EMERY THOMAS Organization: CONOCOPHILLIPS Street Address: City: State: Zip: Submittal Date: Fri Nov 14 16:56:30 EST 2014 12/12/2014 2:22 PM National Fire Protection Association Report 136 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 91-NFPA 350-2014 [ New Section after 7.15.1 ] Gas Monitor Cleaning Periodic cleaning of the gas monitor will enhance the longevity of the unit. However, some silicone based general purpose cleaners can poison or destroy the internal gas sensor. For example, LEL sensors more susceptable to poisioning to general purpose cleaners like Simple Green.) A multi-purpose neutral cleaner should be used to remove dirt, film, grease, nicotine and other inorganic contaminants. Statement of Problem and Substantiation for Public Comment Cleaning the gas detector can severely degrade the performance of the unit if an incompatible cleaner is used. If the gas detector is left turned on in a space that is not a confined space and Simple Green is in use, the LEL sensor will be poisoned. There may be others GP cleaners that affect other sensor types. Related Item First Revision No. 6-NFPA 350-2014 [Chapter 7] Submitter Information Verification Submitter Full Name: JAMES TYLER Organization: VESTAS Affilliation: American Wind Energy Association (AWEA) Street Address: City: State: Zip: Submittal Date: Fri Sep 12 13:29:38 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 137 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 260-NFPA 350-2014 [ Section No. 7.16.1 ] 7.16.1 The owner/operator or entry supervisor should ensure that the gas tester has been trained to complete the duties and responsibilities of the role in accordance with Chapter 11. Statement of Problem and Substantiation for Public Comment The way it is currently written does not adequately protect the worker. Related Item First Revision No. 6-NFPA 350-2014 [Chapter 7] Submitter Information Verification Submitter Full Name: JACK HILL Organization: na Street Address: City: State: Zip: Submittal Date: Mon Nov 10 17:39:18 EST 2014 12/12/2014 2:22 PM National Fire Protection Association Report 138 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 268-NFPA 350-2014 [ Section No. 7.17 ] 7.17 Record Retention. Owners/operators should maintain records pertaining to gas monitor calibration, bump testing, and maintenance along with records of personal exposures and results of confined space atmospheric monitoring for a minimum of 1 year or according to all applicable industry standards and regulations . Additional Proposed Changes File Name Description NFPA_350_7-17_Changes.docx Approved 7.17 Record Retention …along with records of personal exposures and results of atmospheric monitoring for a minimum of 1 year. or according to all industry standards and regulations. Rationale: The term “atmospheric monitoring” includes confined space clearance tests and aligns with the terminology used in section 8 and that should be the consistent term of choice for the purposes of this standard. The term “personal exposures” is a broad term and not specific to confined space operations while the term “atmospheric monitoring” is a more germane term for confined space operations. Some interpret personal exposure records to include confined space entry test and carry a 30-year record retention. This interpretation is a deviation from a classical definition of personal exposure record and is not relevant for the purposes of the NFPA standard. This is an important distinction. The O&G and other industries have differing interpretations and including this term in this NFPA standard complicates the issue. Therefore, we should exclusively establish the record retention at 1 year for NFPA 350. Keeping records beyond that for the sake of confined space entry serves no useful purpose. Statement of Problem and Substantiation for Public Comment 7.17 Record Retention The term “atmospheric monitoring” includes confined space clearance tests and aligns with the terminology used in section 8 and that should be the consistent term of choice for the purposes of this standard. The term “personal exposures” is a broad term and not specific to confined space operations while the term “atmospheric monitoring” is a more germane term for confined space operations. Some interpret personal exposure records to include confined space entry test and carry a 30-year record retention. This interpretation is a deviation from a classical definition of personal exposure record and is not relevant for the purposes of the NFPA standard. This is an important distinction. The O&G and other industries have differing interpretations and including this term in this NFPA standard complicates the issue. Therefore, we should exclusively establish the record retention at 1 year for NFPA 350. Keeping records beyond that for the sake of confined space entry serves no useful purpose. Related Item Public Input No. 268-NFPA 350-2013 [Section No. 10.6.2 [Excluding any Sub-Sections]] Submitter Information Verification Submitter Full Name: Todd Wilhite Organization: Chevron Street Address: 12/12/2014 2:22 PM National Fire Protection Association Report 139 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... City: State: Zip: Submittal Date: Thu Nov 13 13:39:39 EST 2014 12/12/2014 2:22 PM 7.17 Record Retention. Owners/operators should maintain records pertaining to gas monitor calibration, bump testing, maintenance and results of confined space atmospheric monitoring for a minimum of 1 year National Fire Protection Association Report 140 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 113-NFPA 350-2014 [ Section No. 8.1 ] 8.1 Purpose The purpose of this chapter is to provide best practices for eliminating, mitigating, or controlling hazards that either already exist in in or around confined spaces, or are created during entry to into and/or working in or around confined spaces. Statement of Problem and Substantiation for Public Comment this chapter ALSO covers hazards outside of the space Related Item Public Input No. 1231-NFPA 350-2014 [Chapter 8] Submitter Information Verification Submitter Full Name: Richard Kraus Organization: API/Petroleum Safety Consultan Street Address: City: State: Zip: Submittal Date: Tue Sep 23 11:27:35 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 141 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 114-NFPA 350-2014 [ Section No. 8.3 [Excluding any Sub-Sections] ] The hazard identification and risk assessment process as specified in Chapter 6 requires that hazards be eliminated or , mitigated or controlled to a safe level. This chapter addresses common confined space hazards. Confined spaces, however, may have unique hazards that are not addressed in this best practice guide. Nonetheless, the hazards need to be either eliminated or , mitigated or controlled using effective control methods appropriate and effective methods . Statement of Problem and Substantiation for Public Comment provides for mitigation (se 8.1) Related Item Public Input No. 1231-NFPA 350-2014 [Chapter 8] Submitter Information Verification Submitter Full Name: Richard Kraus Organization: API/Petroleum Safety Consultan Street Address: City: State: Zip: Submittal Date: Tue Sep 23 11:38:29 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 142 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 266-NFPA 350-2014 [ Section No. 8.3 [Excluding any Sub-Sections] ] The hazard identification and risk assessment process as specified in Chapter 6 requires that hazards be eliminated or controlled to a safe level. This chapter addresses common confined space hazards. Confined spaces, however, may have unique hazards that are not addressed in this best practice guide. Nonetheless, the hazards need to be either eliminated or controlled using effective control methods.One method for continuous improvement is nearmiss/good catch reporting, resolution and documentation. Statement of Problem and Substantiation for Public Comment Brian Mckay's paper "Measures of Effects of Near Miss Reporting has been requested and sent to NFPA Standards Admiinistrator The concept of near miss applies to NFPA 350 sections 6.5.1., 3.3.5 definitions , and to preplan and permit as well as MOC sections. It is an important part of training and communications and essential to the fabric of NFPA 350 Related Item Public Input No. 266-NFPA 350-2013 [Section No. 10.6.1 [Excluding any Sub-Sections]] Submitter Information Verification Submitter Full Name: cait casey Organization: Aspen Risk Management Group Street Address: City: State: Zip: Submittal Date: Wed Nov 12 15:29:22 EST 2014 12/12/2014 2:22 PM National Fire Protection Association Report 143 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 115-NFPA 350-2014 [ Section No. 8.4 [Excluding any Sub-Sections] ] Entry supervisors should ensure that atmospheric hazards identified during atmospheric monitoring have been eliminated, mitigated, or controlled prior to entry. Methods to remove hazardous atmospheres from confined spaces include, but are not limited to, cleaning; displacement or dilution via ventilation, inerting , ( which could create additional hazards, such as low oxygen; ), purging; or removal by other approved methods (see 8.4.2to 8.4.3). Prior to entry, a gas tester should perform atmospheric monitoring in accordance with Chapter 7 to confirm the space is safe to enter. Statement of Problem and Substantiation for Public Comment parens used for clarification that it only applies to inerting Related Item Public Input No. 931-NFPA 350-2013 [Section No. 8.2 [Excluding any Sub-Sections]] Submitter Information Verification Submitter Full Name: Richard Kraus Organization: API/Petroleum Safety Consultan Street Address: City: State: Zip: Submittal Date: Tue Sep 23 11:42:25 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 144 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 269-NFPA 350-2014 [ Section No. 8.4.1 ] 8.4.1 Acceptable Entry Conditions. Where levels are outside the following parameters, entry should be allowed only after the following control measures are taken: (1) Oxygen content between 19.5 percent and 22.0 percent (2) Flammable gases and vapors below 10 percent of the lower flammable limit (LFL or LEL) of the material involved (3) Potential toxic air contaminants at or below one half the occupational exposure limit (OEL) as determined by the written confined space program Additional Proposed Changes File Name Description NFPA_350_8-41_3_Changes.docx Approved 8.4.1 Acceptable Entry Conditions (3) potential toxic air contaminants at or below one half of the Occupational Exposure Limit (OEL). Rationale: The practice within Chevron and elsewhere to manage exposures to the OEL. There are other activities such as medical surveillance that are triggered by one half the OEL (sometimes referred to as an Action Level) that is included in some regulatory standard. Applying that “Action Level” concept to confined space entry is a misapplication. Exposures are sufficiently managed at or below the OEL. Statement of Problem and Substantiation for Public Comment 8.4.1 Acceptable Entry Conditions (3) potential toxic air contaminants at or below one half of the Occupational Exposure Limit (OEL). Rationale: The practice within Chevron and elsewhere to manage exposures to the OEL. There are other activities such as medical surveillance that are triggered by one half the OEL (sometimes referred to as an Action Level) that is included in some regulatory standard. Applying that “Action Level” concept to confined space entry is a misapplication. Exposures are sufficiently managed at or below the OEL. Related Item Public Input No. 269-NFPA 350-2013 [Section No. 4.1] Submitter Information Verification Submitter Full Name: Todd Wilhite Organization: Chevron Street Address: City: State: Zip: Submittal Date: Thu Nov 13 13:55:00 EST 2014 12/12/2014 2:22 PM 8.4.1 Acceptable Entry Conditions (3) potential toxic air contaminants at or below one half of the Occupational Exposure Limit (OEL). Rationale: The practice within Chevron and elsewhere to manage exposures to the OEL. There are other activities such as medical surveillance that are triggered by one half the OEL (sometimes referred to as an Action Level) that is included in some regulatory standard. Applying that “Action Level” concept to confined space entry is a misapplication. Exposures are sufficiently managed at or below the OEL. National Fire Protection Association Report 145 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 116-NFPA 350-2014 [ Section No. 8.4.4 [Excluding any Sub-Sections] ] Entry into inert atmospheres should not be allowed except in limited circumstances. Entry supervisors should be aware that ventilation will not always eliminate all of the atmospheric hazards within a confined space. If hot work is to be conducted within a confined space that contains flammable or combustible vapors or liquids, one method to control the ignition hazard is todisplace to displace any oxygen in the atmosphere within the space with an inert gas. Inert gas can also be used to displace oxygen where flammable materials or atmosphere cannot be removed prior to entry. Entry supervisors should Owners/operators and contractors/subcontractors should not permit entry into confined spaces with inert atmospheres except in limited circumstances in accordance with the owner/operator or contractor's confined space program. Persons engaged in inert entry operations, including entry supervisors, entrants, attendants, rescuers and others should be trained, experienced and qualified in this specific of activity. Entry supervisors should require entrants to use approved air-supplied respirators for entry into inert atmospheres. In addition, where vertical entry into inert spaces is required, the entrant should be equipped with a full body harness connected to an approved A Frame device securred to the top of the space. Enrty supervisors should preplan entry and work operations, particularly where inert entry is into a multi-level space or a space with interior obstructions (such as a catalytic reactor or similar vessel). Rescuers should preplan rescue scenarios covering different potential situations, preferably with rescue to be conducted from outside the space. Entry into inerted confined spaces in the petroleum and petrochemical industries should be in accordance with the requirements of API Publication 2217A Guidelines for Work in Inert Confined Spaces in the Petroleum Industry. Entry into other inert spaces should be in accordance with NFPA 326 and other applicable standards and regulations. Statement of Problem and Substantiation for Public Comment provides for guidance for entry into petroleum tanks Related Item Public Input No. 90-NFPA 350-2013 [Section No. 8.2.4 [Excluding any Sub-Sections]] Submitter Information Verification Submitter Full Name: Richard Kraus Organization: API/Petroleum Safety Consultan Street Address: City: State: Zip: Submittal Date: Tue Sep 23 11:51:14 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 146 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 117-NFPA 350-2014 [ Section No. 8.4.4.2 ] 8.4.4.2 Entry supervisors should be aware that tanks, vessels, containers, and equipment adjacent to a confined space entry and/or a confined space work areaare area are potential sources of flammable, combustible, or toxic vapors, gases, or hazardous materials. If the entry supervisor deems such conditions as potentially harmful to the confined space, the hazard should be eliminated, controlled, or mitigated prior to permitting entry and/or any work or hot work in the space or adjacent area. Statement of Problem and Substantiation for Public Comment editorial Related Item Public Input No. 91-NFPA 350-2013 [Section No. 8.2.4.1] Submitter Information Verification Submitter Full Name: Richard Kraus Organization: API/Petroleum Safety Consultan Street Address: City: State: Zip: Submittal Date: Tue Sep 23 12:05:08 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 147 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 229-NFPA 350-2014 [ Section No. 8.4.4.6 ] 8.4.4.6 Entry into inert atmospheres should not occur except in well-controlled situations where no other option for entry is available. If entry into an inert atmosphere is inert (or othwer oxygen deficient) atmosphere is needed, a combination full face-piece pressure demand supplied air respirator (SAR) with auxiliary self-contained breathing apparatus (SCBA) escape mechanism or a full face-piece pressure demand SCBA with a minimum 30 min.cylinder should be provided to and used by entrants. Entry supervisors, attendants and entrants should be aware that leakage or exhaust of breathing air into an inert (or flammable) atmosphere may create a hazard by reducing the effectiveness of the inert concentration and by possibly increasing the oxygen level ( thus affecting the explosive limits of a flammable atmosphere). 8.4.4.6.1 Where any entry requires supplied breathing air, the owner/operator and contractor/subcontractor should assure that the respiratory breathing air supplier adheres to practices that eliminate the potential for insufficient oxygen content in an air supply cylinder and the possibility of cross contamination of the cylinder air with other gases. They should assure that only certified compressor sourced breathing air meeting CGA 7.1 Grade D quality(or equivalent) is used for SAR required entries. Air supply clyinders should dedicated to breathing air service and be secured with sealed valves (and racks) and controlled to to prevent cross contaminatiion. 8.4.4.6.2.After cylinders and racks are in place at the job site and prior to each day's (or shift's) use, a qualifed person should test each breathing air cylinder (to be used) to assure the proper oxygen content. 8.4.4.6.3 The entry supervisor should assure that respiratory protective equipment (racks, cylinders, hoses, retrieval gear, helmets and masks) is designed, supplied and used to minimize risk and human error during entry work and in emergency situations by checking critical respiratory protection components prior to permiting entry. 8.4.4.6.4 Owners/operators and contractors/subcontractors should develop and implement respiratory protection programs that include medical evaluation, and training and fit testing should be developed and implemented before providing entrants with respirators respiratory equipment . Statement of Problem and Substantiation for Public Comment for example, released breathing air into an inert space containing pyrophorics or other flammables can create a fire hazard there is a whole missing piece in this guide about control of respiratory air and use of respiratory equipment which this proposed change addresses. A number of fatalities have occurred due to poor respiratory practices. Related Item Public Input No. 93-NFPA 350-2013 [Section No. 8.2.4.5] Submitter Information Verification Submitter Full Name: Richard Kraus Organization: API/Petroleum Safety Consultan Street Address: City: State: Zip: Submittal Date: Mon Oct 20 16:09:20 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 148 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 118-NFPA 350-2014 [ Section No. 8.4.4.7.1 ] 8.4.4.7.1 * Entry supervisors in the maritime industry should conduct inertingin inerting in accordance with NFPA 306 , which includes a section on inerting procedures for marine vessels and in accordance with ISGOTT . Statement of Problem and Substantiation for Public Comment EDITORIAL and adds ISGOTT which contains criteria for inerting marine vessels. Related Item Public Input No. 94-NFPA 350-2013 [Section No. 8.2.4.6.1] Submitter Information Verification Submitter Full Name: Richard Kraus Organization: API/Petroleum Safety Consultan Street Address: City: State: Zip: Submittal Date: Tue Sep 23 15:05:20 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 149 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 16-NFPA 350-2014 [ Section No. 8.4.4.7.1 ] 8.4.4.7.1 * Entry supervisors in the maritime industry should conduct inertingin inerting in accordance with NFPA 306, which includes a section on inerting procedures for marine vessels. A certified Marine Chemist may be required to oversee the inerting operation if hot work will be conducted. Statement of Problem and Substantiation for Public Comment The maritime industry operates under a different section of OSHA and generally when inerting a space for hot work a NFPA certified Marine Chemist is required under OSHA regulations. Related Item Public Input No. 350-NFPA 350-2013 [Section No. 11.4.4.1] Submitter Information Verification Submitter Full Name: Donald Raffo Organization: General Dynamics, Electric Boa Street Address: City: State: Zip: Submittal Date: Wed Sep 10 13:07:07 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 150 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 366-NFPA 350-2014 [ Section No. 8.5.5 ] 8.5.5 Where performing hot work above a tank, container equipment, vessel, sewer, pit, pipeline, drainage ditch, or similar areas containing, or having the potential to contain, flammable or combustible materials, entry supervisors should make sure that precautions are taken to shield the area below from falling sparks and hot materials, such as slag. In addition, precautions should be taken to ensure that vapors from these spaces cannot reach the hot work area. Entry supervisors should also give consideration to adjacent spaces above and below the hot work being conducted. Where welding takes place on an elevated surface, all surfaces below the elevated platform in the vicinity of the welding are potentially at risk. A wet fire blanket or a welding blanket can be used to protect sewer openings, open confined space manways, ditches, piping, and so on, containing flammable or combustible liquids or vapors from sparks and slag. Statement of Problem and Substantiation for Public Comment Recommend some comment be made to avoid hot work above a tank, container etc. while entry work is going on and only if it cannot be avoided to take the appropriate measures etc. Related Item First Revision No. 7-NFPA 350-2014 [Chapter 8] Submitter Information Verification Submitter Full Name: EMERY THOMAS Organization: CONOCOPHILLIPS Street Address: City: State: Zip: Submittal Date: Fri Nov 14 17:09:14 EST 2014 12/12/2014 2:22 PM National Fire Protection Association Report 151 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 17-NFPA 350-2014 [ Section No. 8.5.6 ] 8.5.6 Prior to issuing a hot work permit, entry supervisors should ensure that gas testers conduct atmospheric monitoring in adjacent open confined spaces within 50 ft (15 m) horizontally of the hot work area to confirm that there are no adjacent hazards that could impact or be impacted by the hot work. Entry supervisors should ensure that hot work is not authorized or performed unless atmospheric testing indicates that oxygen levels are less than 22 percent by volume, and the LFL LEL (if applicable) is less than 10 percent,or where oxygen and flammable levels are permitted to meet other requirements established by the applicable confined space and hot work programs. In such cases, the entry supervisor should indicate the specific requirements on the hot work permit and check that appropriate permit precautions are taken. Statement of Problem and Substantiation for Public Comment Suggest use of LEL throughout document Related Item Public Input No. 350-NFPA 350-2013 [Section No. 11.4.4.1] Submitter Information Verification Submitter Full Name: Donald Raffo Organization: General Dynamics, Electric Boa Street Address: City: State: Zip: Submittal Date: Wed Sep 10 13:08:32 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 152 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 18-NFPA 350-2014 [ Section No. 8.5.6 ] 8.5.6 Prior to issuing a hot work permit, entry supervisors should ensure that gas testers conduct atmospheric monitoring in adjacent open confined spaces within 50 ft (15 m) horizontally of the hot work area to confirm that there are no adjacent hazards that could impact or be impacted by the hot work. Entry supervisors should ensure that hot work is not authorized or performed unless atmospheric testing indicates that oxygen levels are less than 22 percent by volume, and the LFL LEL (if applicable) is less than 10 percent,or where oxygen and flammable levels are permitted to meet other requirements established by the applicable confined space and hot work programs. In such cases, the entry supervisor should indicate the specific requirements on the hot work permit and check that appropriate permit precautions are taken. Statement of Problem and Substantiation for Public Comment Suggest LEL throughout document Related Item Public Input No. 350-NFPA 350-2013 [Section No. 11.4.4.1] Submitter Information Verification Submitter Full Name: Donald Raffo Organization: General Dynamics, Electric Boa Street Address: City: State: Zip: Submittal Date: Thu Sep 11 04:37:14 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 153 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 19-NFPA 350-2014 [ Section No. 8.5.13.1.4 ] 8.5.13.1.4 NFPA 326contains 326 contains minimum procedures that permit repair, hot work, or other operations that could potentiallycreate potentially create a fire, an explosion, or other hazard wherever hot work is performed on tanks or containers containing flammable, combustible, or other hazardous vapors, liquids, or solid residues. The American Welding Society also has information regarding hot work operations. Statement of Problem and Substantiation for Public Comment Corrected typos. Related Item Public Input No. 350-NFPA 350-2013 [Section No. 11.4.4.1] Submitter Information Verification Submitter Full Name: Donald Raffo Organization: General Dynamics, Electric Boa Street Address: City: State: Zip: Submittal Date: Thu Sep 11 04:38:15 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 154 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 20-NFPA 350-2014 [ Section No. 8.5.13.3 ] 8.5.13.3 Shipyard/Maritime. In shipyard/maritime settings,29 CFR 1915.11 to 1915.16 and 1915.51 to 1915.57, and NFPA 306contain 306 contain information on hot work performed in the maritime industry. In addition, the latest edition of the International Safety Guide for Oil Tankers and Terminals (ISGOTT) provides considerable guidance for confined space and hot work activity in oil tankers and terminals. Statement of Problem and Substantiation for Public Comment Corrected Typo Related Item Public Input No. 350-NFPA 350-2013 [Section No. 11.4.4.1] Submitter Information Verification Submitter Full Name: Donald Raffo Organization: General Dynamics, Electric Boa Street Address: City: State: Zip: Submittal Date: Thu Sep 11 04:42:12 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 155 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 21-NFPA 350-2014 [ Section No. 8.5.13.4.2 ] 8.5.13.4.2 API Recommended Practice 2009, Safe Welding and Cutting and Hot Work Practices in the Petroleum and Petrochemical Industries. This document provides guidelines for safely conducting welding, cutting, or other hot work activities in refineries, gas plants, petrochemical plants, and other facilities in the petroleum and petrochemical industries. It provides specific guidance on evaluating procedures for certain types of work on equipment in service. It does not coverregulation cover regulation or code compliance; hot tapping; welding techniques; normal, “safe work” practices; or entry into or work in inert environments. Statement of Problem and Substantiation for Public Comment Corrected typo Related Item Public Input No. 350-NFPA 350-2013 [Section No. 11.4.4.1] Submitter Information Verification Submitter Full Name: Donald Raffo Organization: General Dynamics, Electric Boa Street Address: City: State: Zip: Submittal Date: Thu Sep 11 04:42:57 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 156 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 22-NFPA 350-2014 [ Section No. 8.5.13.4.4 ] 8.5.13.4.4 API Recommended Practice 2016, Guidelines and Procedures for Entering and Cleaning Petroleum Storage Tanks. This recommendedpractice recommended practice supplements the requirements of ANSI/API 2015, Requirements for Safe Entry and Cleaning of Petroleum Storage Tanks.API 2016 provides guidance and information on the specific aspects of tank cleaning to assist inconducting safe tank cleaning operations in accordance with the requirements of ANSI/API 2015. Statement of Problem and Substantiation for Public Comment Corrected typo Related Item Public Input No. 350-NFPA 350-2013 [Section No. 11.4.4.1] Submitter Information Verification Submitter Full Name: Donald Raffo Organization: General Dynamics, Electric Boa Street Address: City: State: Zip: Submittal Date: Thu Sep 11 04:43:28 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 157 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 119-NFPA 350-2014 [ Section No. 8.6 [Excluding any Sub-Sections] ] All sources of energy — mechanical, electrical, hydraulic, chemical, or stored energy — in confined spaces that could impact worker safety should be eliminated be eliminated or controlled using the appropriate isolation or lockout/tagout procedures in accordance with the owner/operator or contractor/subcontractor isolation program prior to issuance of an entry permit. 29 CFR 1910.147 covers the prevention of accidental startup of equipment and machinery or release of stored energy. 29 CFR 1910.333 contains specific requirements for de-energizing and locking out electrical equipment. OSHA electrical safe work practices requirements were derived from NFPA 70E, whichprovides comprehensive electrical safety information to prevent shock, arc, and other electrical safety hazards. Statement of Problem and Substantiation for Public Comment lockout etc, does not eliminate the source it only controls it. Related Item Public Input No. 113-NFPA 350-2013 [Section No. 8.4 [Excluding any Sub-Sections]] Submitter Information Verification Submitter Full Name: Richard Kraus Organization: API/Petroleum Safety Consultan Street Address: City: State: Zip: Submittal Date: Tue Sep 23 15:16:40 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 158 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 120-NFPA 350-2014 [ Section No. 8.6.3 ] 8.6.3 Pipes and lines containing materials that could enter into the confined space should be disconnected and / drained, or blanked, bled double blocked and bled , flushed, purged, or otherwise isolated prior to entry by the isolation specialist. Statement of Problem and Substantiation for Public Comment need to drain portions of disconnected lines leading into space. Lines should be double blocked and the portion between the blocks should be bled (or drained) Related Item Public Input No. 943-NFPA 350-2013 [Section No. 8.4.3] Submitter Information Verification Submitter Full Name: Richard Kraus Organization: API/Petroleum Safety Consultan Street Address: City: State: Zip: Submittal Date: Tue Sep 23 15:21:02 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 159 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 121-NFPA 350-2014 [ Section No. 8.6.4 ] 8.6.4 Pipes and lines that run through a confined space that will be worked on from inside the space need to be disconnected and drained, and /or double blocked and blanked, bled, flushed, purged, or isolated as needed by an isolation specialist beforework begins. Statement of Problem and Substantiation for Public Comment see 8.4.3 Need to double block and bleed in between blocks. also drain line within the space. Related Item Public Input No. 944-NFPA 350-2013 [Section No. 8.4.4] Submitter Information Verification Submitter Full Name: Richard Kraus Organization: API/Petroleum Safety Consultan Street Address: City: State: Zip: Submittal Date: Tue Sep 23 15:23:54 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 160 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 23-NFPA 350-2014 [ Section No. 8.6.4 ] 8.6.4 Pipes and lines that run through a confined space that will be worked on from inside the space need to be disconnected and/or blanked, bled, flushed, purged, or isolated as needed by an isolation specialist beforework before work begins. Statement of Problem and Substantiation for Public Comment Corrected typo Related Item Public Input No. 350-NFPA 350-2013 [Section No. 11.4.4.1] Submitter Information Verification Submitter Full Name: Donald Raffo Organization: General Dynamics, Electric Boa Street Address: City: State: Zip: Submittal Date: Thu Sep 11 04:44:09 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 161 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 122-NFPA 350-2014 [ Section No. 8.6.5 ] 8.6.5 Pipes and lines that run through but do not terminate within a confined space do not need to be disconnected or isolated as indicated in 8.6.3provided that the entry supervisordetermines supervisor determines that the materials in these lines are not impacted by the work being done in the space anddo and do not create a hazard to workers in the space. Statement of Problem and Substantiation for Public Comment editorial Related Item Public Input No. 1095-NFPA 350-2013 [Section No. 8.4.5] Submitter Information Verification Submitter Full Name: Richard Kraus Organization: API/Petroleum Safety Consultan Street Address: City: State: Zip: Submittal Date: Tue Sep 23 15:26:35 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 162 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 123-NFPA 350-2014 [ Section No. 8.6.6 ] 8.6.6 * Where it is necessary for equipment equipment to continue to operate (not be isolated) in order to perform work within the space, the entry supervisor should ensure that the work is performed using approved alternative methods or that control measures provide effective protection for workers in the space. Statement of Problem and Substantiation for Public Comment for clarification Related Item Public Input No. 118-NFPA 350-2013 [Section No. 8.4.6] Submitter Information Verification Submitter Full Name: Richard Kraus Organization: API/Petroleum Safety Consultan Street Address: City: State: Zip: Submittal Date: Tue Sep 23 15:29:02 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 163 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 24-NFPA 350-2014 [ Section No. 8.8.1 [Excluding any Sub-Sections] ] Bonding is the joining of objects to form an electrically conductive path that ensures electrical continuity and the capacity to safely conduct any current likely to be generated. Entry supervisors, attendants, entrants, and all workers in and adjacent to confined spaces should be aware that equipment, accessories, and appurtenances used in confined space entry, ventilation,cleaning, and other operations,may be capable of generating an electrostatic charge. Entry supervisors should ensure that such objects are electrically bonded to the confined space to avoid generating static electric sparks. Statement of Problem and Substantiation for Public Comment Bonding should be defined in the definition section. It should not be introduced here, this makes the document to wordy. Related Item Public Input No. 350-NFPA 350-2013 [Section No. 11.4.4.1] Submitter Information Verification Submitter Full Name: Donald Raffo Organization: General Dynamics, Electric Boa Street Address: City: State: Zip: Submittal Date: Thu Sep 11 05:38:06 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 164 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 124-NFPA 350-2014 [ Section No. 8.9 [Excluding any Sub-Sections] ] Entry supervisors should be aware that flammable or combustible liquids, vapors, and gases or combustible dusts and fibers may be released both in and around a confined space during working, ventilation, inerting, or gas freeing, or whereworking removing when removing , agitating, or cleaning residue inside the space. All confined space personnel should be aware that in addition to hot work (see Section 8.4), ignition sources that should be eliminated or , mitigated or controlled include, but are not limited to, the following: (1) Internal combustion engines located within an unsafe area, such as less than 50 ft downwind from, near, or adjacent to the space (2) Non-explosion-proof electrical equipment and electrical equipment not rated for the location or proposed operation (3) Non-bonded/non-grounded electrostatic generating equipment, such as welding machines, fans and eductors, vacuum trucks, portable generators, pumps, etc. (4) Nonapproved lighting equipment (5) Smoking or open flames (6) Blast cleaning equipment and blasting operations (7) Grinding and cutting equipment and operations (8) Unprotected pyrophoric iron sulfide deposits within the space (9) Nonapproved heating equipment, such as space heaters, hot plates, etc. (10) Vacuum trucks and vacuum operations (11) Nonapproved communication devices, including cell phones, two-way radios, and pagers Statement of Problem and Substantiation for Public Comment for clarity, added "mitigated" for consistency Related Item Public Input No. 131-NFPA 350-2013 [Section No. 8.7 [Excluding any Sub-Sections]] Submitter Information Verification Submitter Full Name: Richard Kraus Organization: API/Petroleum Safety Consultan Street Address: City: State: Zip: Submittal Date: Tue Sep 23 15:38:16 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 165 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 125-NFPA 350-2014 [ Section No. 8.10 [Excluding any Sub-Sections] ] Fall protection should be maintained for all those working in and around confined spaces where falls greater than 4 ft (1.2 m) could occur. Confined space fall hazards should be managed using the following fall protection hierarchy: (1) Elimination. Removal of the hazard by covering all vertical entry points until entry is required (2) Protection. Use of OSHA- approved guardrail systems to provide a controlled access zone around all vertical entry points (3) Restriction. Use of positioning or restraint devices to eliminate the possibility of a fall for all personnel outside of the immediate vertical entry point (4) Fall arrest. Use of OSHA- approved fall arrest/belay devices to limit the maximum arresting forces to below 1800 lb for a fall greater than 4 ft above the lower level of the vertical entry point for all personnel exposed to a fall hazard during confined space operations Statement of Problem and Substantiation for Public Comment no need to mention OSHA. OSHA not applicable to those not covered by OSHA Related Item Public Input No. 135-NFPA 350-2013 [Section No. 8.8 [Excluding any Sub-Sections]] Submitter Information Verification Submitter Full Name: Richard Kraus Organization: API/Petroleum Safety Consultan Street Address: City: State: Zip: Submittal Date: Tue Sep 23 15:46:00 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 166 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 126-NFPA 350-2014 [ Section No. 8.10.1 [Excluding any Sub-Sections] ] Falls into confined spaces can occur whereenteringor working where entering, working inside of or working outside a confined space. Floor and wall openings that leadinto lead into or mey be within confined spaces should be protected to prevent falls from occurring. There are a number of ways to do this as listed in 8.10.1.1 through 8.10.1.3 . Statement of Problem and Substantiation for Public Comment falls may also occur inside spaces Related Item Public Input No. 136-NFPA 350-2013 [Section No. 8.8.1 [Excluding any Sub-Sections]] Submitter Information Verification Submitter Full Name: Richard Kraus Organization: API/Petroleum Safety Consultan Street Address: City: State: Zip: Submittal Date: Tue Sep 23 15:48:46 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 167 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 25-NFPA 350-2014 [ Section No. 8.10.1 [Excluding any Sub-Sections] ] Falls into confined spaces can occur whereenteringor when entering or working outside a confined space. Floor and wall openings that leadinto lead into confined spaces should be protected to prevent falls from occurring. There are a number of ways to do this as listed in 8.10.1.1 through 8.10.1.3. Statement of Problem and Substantiation for Public Comment Typo correction. Related Item Public Input No. 350-NFPA 350-2013 [Section No. 11.4.4.1] Submitter Information Verification Submitter Full Name: Donald Raffo Organization: General Dynamics, Electric Boa Street Address: City: State: Zip: Submittal Date: Thu Sep 11 05:40:00 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 168 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 127-NFPA 350-2014 [ Section No. 8.10.2.1 ] 8.10.2.1 Where utilizing fixed ladders, entrants should maintain three points of contact should be maintained at contact at all times. Where the ladder extends Ladders extending beyond 20 ft it should ft should be equipped with a ladder climbing system or a secondary form of protection, such as a self retracting device or a belay line attached to a suitable anchor point able to withstand 5000 lb (2268 kg) of force or engineered with a 2:1 safety factor. Statement of Problem and Substantiation for Public Comment specifies who uses the ladders Related Item Public Input No. 142-NFPA 350-2013 [Section No. 8.8.2.2] Submitter Information Verification Submitter Full Name: Richard Kraus Organization: API/Petroleum Safety Consultan Street Address: City: State: Zip: Submittal Date: Tue Sep 23 15:52:11 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 169 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 128-NFPA 350-2014 [ Section No. 8.10.2.3 ] 8.10.2.3 Whereworkersneed Where entrants need to be lowered vertically into the confined space, a secondary form of protection should be used, such as a self-retracting device or a belay line attached to a suitable anchor point able to withstand 5000 lb (2268 kg) of force or engineered with a 2:1 safety factor. Statement of Problem and Substantiation for Public Comment only entrants enter spaces. also editorial change Related Item Public Input No. 143-NFPA 350-2013 [Section No. 8.8.2.3] Submitter Information Verification Submitter Full Name: Richard Kraus Organization: API/Petroleum Safety Consultan Street Address: City: State: Zip: Submittal Date: Tue Sep 23 15:57:03 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 170 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 26-NFPA 350-2014 [ Section No. 8.10.2.3 ] 8.10.2.3 Whereworkersneed Where workers need to be lowered vertically into the a confined space, a secondary form of protection should be used, such as a self-retracting device or a belay line attached to a suitable anchor point able to withstand 5000 lb (2268 kg) of force or engineered with a 2:1 safety factor. Statement of Problem and Substantiation for Public Comment Typo correction Related Item Public Input No. 350-NFPA 350-2013 [Section No. 11.4.4.1] Submitter Information Verification Submitter Full Name: Donald Raffo Organization: General Dynamics, Electric Boa Street Address: City: State: Zip: Submittal Date: Thu Sep 11 05:41:54 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 171 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 129-NFPA 350-2014 [ Section No. 8.11.4 [Excluding any Sub-Sections] ] Entry supervisors should ensure that approved in-space lighting used in accordance with Section 8.5 provides enough illumination so that all surfaces and obstructions are clearly visible to those working in the space. Portable lighting should be approved for the location in which it is used in accordance with entrants the applicable confined space program and permit requirements . Statement of Problem and Substantiation for Public Comment as proposed, sentence makes no sense. Lighting should be in accord with applicable programs, permits, etc not in accord with entrant Related Item Public Input No. 146-NFPA 350-2013 [Section No. 8.9.4] Submitter Information Verification Submitter Full Name: Richard Kraus Organization: API/Petroleum Safety Consultan Street Address: City: State: Zip: Submittal Date: Tue Sep 23 15:59:59 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 172 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 130-NFPA 350-2014 [ Section No. 8.11.5 ] 8.11.5 Wherever surfaces remain slippery or wet, entry supervisors can useportable should consider the use of non-combustible portable floor mats or duck boards to raise the entry base above the level of the liquid surface inside the confined space. Statement of Problem and Substantiation for Public Comment the use of combustible materials inside the space should be limited Related Item Public Input No. 950-NFPA 350-2013 [Section No. 8.9.5] Submitter Information Verification Submitter Full Name: Richard Kraus Organization: API/Petroleum Safety Consultan Street Address: City: State: Zip: Submittal Date: Tue Sep 23 16:06:47 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 173 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 131-NFPA 350-2014 [ Section No. 8.12 ] 8.12 Lighting. Entry supervisors can use approved, safe lighting in accordance with the applicable confined space program. The lighting selection should consider any hazards presented by the presence of flammable or combustible liquids, vapors, or gases in accordance with 8.7. Additional lighting options include, but are not limited to, approved helmet lights, approved low-voltage portable lighting, and so on approved flashlights, and other approved lighting sources . Entry supervisors and workers should also be aware that cyalume lights (i.e., glow sticks) can be used as backup lighting should the primary lighting fail and can also be used to mark a means of ingress and egress in poorly lit or extended confined spaces. Statement of Problem and Substantiation for Public Comment added "approved" took away "and so on" which is meaningless Related Item Public Input No. 147-NFPA 350-2013 [Section No. 8.10] Submitter Information Verification Submitter Full Name: Richard Kraus Organization: API/Petroleum Safety Consultan Street Address: City: State: Zip: Submittal Date: Tue Sep 23 16:11:41 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 174 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 27-NFPA 350-2014 [ Section No. 8.13 ] 8.13 Animals and Insects. Entry supervisors and all other confined space personnel should recognize that confined spaces are ideal hideouts for animals and insects. The confined space should be visually inspected by the entry supervisor prior to entry, and any potentially dangerous animals or insects should be safely removed or otherwise eliminated. The owner/operator or contractor/subcontractor can arrange for traps to be lowered into the space for insects or animals such as skunks or raccoons; however, if available, a pest control company or local animal control agency should be the first consideration. If be removed or eliminated. If an extermination chemical is used, it might be necessary to have the environment in and around the space reassessed prior to permitting entry. The gas tester should include the pesticide hazard when retesting. The entry supervisor should determine if the space needs to be ventilated and if respiratory protection and/or protective clothing and gloves should be worn by the gas testers and workers to prevent skin exposure to the chemicals. Statement of Problem and Substantiation for Public Comment To much detail, suggest shortened version. Related Item Public Input No. 350-NFPA 350-2013 [Section No. 11.4.4.1] Submitter Information Verification Submitter Full Name: Donald Raffo Organization: General Dynamics, Electric Boa Street Address: City: State: Zip: Submittal Date: Thu Sep 11 05:42:54 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 175 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 132-NFPA 350-2014 [ Section No. 8.14.1 ] 8.14.1 Entry supervisors should make sure that all confined space workers wear approved PPE including, but not limited to, eye protection, head protection, foot protection, hand protection, protective clothing, respiratory protection and hearing protection as required by the entry or hot work permit. Workers should be aware that injuries can be prevented or mitigated by the use of PPE (see Section 6.7). Additional PPE the entry supervisor might consider includes, but is not limited to, knee and elbow pads, forcrawlspaces for crawlspaces and cooling vests for hot environments. Statement of Problem and Substantiation for Public Comment sometimes PPE does not fully protect. also editorial change Related Item Public Input No. 951-NFPA 350-2013 [Section No. 8.12.1] Submitter Information Verification Submitter Full Name: Richard Kraus Organization: API/Petroleum Safety Consultan Street Address: City: State: Zip: Submittal Date: Tue Sep 23 16:16:09 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 176 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 133-NFPA 350-2014 [ Section No. 8.14.3.1 ] 8.14.3.1 Owners/operators and contractors/subcontractors should consider the general PPE requirements including, but not limited to, hazard assessments, maintenance, and training provided in 29 CFR 1910.132 applicable regulations and standards when developing PPE programs. Although the OSHA standards cover The OSHA standard 29 CFR 1910.132, which covers general industry in the U.S. only , they provide information provides information which may be used by contractors and non-covered organizations for developing theie own PPE programs elsewhere . Statement of Problem and Substantiation for Public Comment removes specific reference to OSHA as not all users are covered by OSHA. Adds additional information to help those not covered. Related Item Public Input No. 954-NFPA 350-2013 [Section No. 8.12.3.1] Submitter Information Verification Submitter Full Name: Richard Kraus Organization: API/Petroleum Safety Consultan Street Address: City: State: Zip: Submittal Date: Tue Sep 23 16:19:57 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 177 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 134-NFPA 350-2014 [ Section No. 9.1.1 ] 9.1.1 Ventilation Confined space ventilation is used for two reasons: to remove or control atmospheric contaminants and to control temperature for comfort. However, in most confined space applications, controlling atmospheric contaminants is the primary purposeof purpose of ventilation. Ventilation is commonly used to establish initial safe conditions (prior to initial entry initial and subsequent entries ) and might be necessary is also used to maintain safe conditions during entry where there are is a potential for changing atmospheric conditions within a space (e.g., presence of residues or during hot work). . Causes of changes in internal atmospheres include, but are not limited to, presence or disturbance of residues, vapors or fumes during hot work activity, outside influences, and use of chemicals inside the space for cleaning. Statement of Problem and Substantiation for Public Comment corrects editorial error. provides information for other causes of atmosphere changes, Adds use of ventilation for working inside space Related Item Public Input No. 151-NFPA 350-2013 [Section No. 9.1.1] Submitter Information Verification Submitter Full Name: Richard Kraus Organization: API/Petroleum Safety Consultan Street Address: City: State: Zip: Submittal Date: Wed Sep 24 10:11:19 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 178 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 135-NFPA 350-2014 [ Section No. 9.1.3 ] 9.1.3 * Where considering ventilation, the entry supervisor and ventilation specialist shouldunderstand should understand the differences between ventilation and purging. These terms are often used interchangeably, but actually apply to different atmospheric hazard control situations. Ventilation generally introduces provides for fresh, uncontaminated air to enter into a space and controls contaminants in that space through mixing through mixing and dilution. Purging uses is the use of air, steam, or an inert gas to displace air the atmosphere within the space. (See 9.3.) Statement of Problem and Substantiation for Public Comment changed for clarification. correct error Related Item Public Input No. 152-NFPA 350-2013 [Section No. 9.1.3] Submitter Information Verification Submitter Full Name: Richard Kraus Organization: API/Petroleum Safety Consultan Street Address: City: State: Zip: Submittal Date: Wed Sep 24 10:22:20 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 179 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 136-NFPA 350-2014 [ Section No. 9.2.2 [Excluding any Sub-Sections] ] Mechanical ventilation uses one is the use of one or more air-moving devices (e.g., fan, blower, eductor) are used to either push fresh air into into the confined space or pull air from out of the confined space and circulate it to introduce fresh air and space , (thus creating a slight vacuum allowing fresh air to enter into the space from other portals) and remove contaminants or mix and dilute air within a space. There are two types of mechanical ventilation: general (or dilution) and local exhaust. . Local exhaust may also be used within the space to mix and circulate the introduced air. Statement of Problem and Substantiation for Public Comment this is changed to more specifically explain the process Related Item Public Input No. 156-NFPA 350-2013 [Section No. 9.2.2 [Excluding any Sub-Sections]] Submitter Information Verification Submitter Full Name: Richard Kraus Organization: API/Petroleum Safety Consultan Street Address: City: State: Zip: Submittal Date: Wed Sep 24 10:28:57 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 180 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 28-NFPA 350-2014 [ Section No. 9.2.2 [Excluding any Sub-Sections] ] Mechanical ventilation uses one or more powered air-moving devices (e.g., fan, blower, eductor) are used to either push air into or pull air from the confined space and circulate it to introduce fresh air and remove contaminants or mix and dilute air within a space. There are two types of mechanical ventilation: general (or dilution) and local exhaust. Statement of Problem and Substantiation for Public Comment Suggest adding the word powered, this will make it clear that natural ventilation cannot be considered as mechanical ventilation. Related Item Public Input No. 350-NFPA 350-2013 [Section No. 11.4.4.1] Submitter Information Verification Submitter Full Name: Donald Raffo Organization: General Dynamics, Electric Boa Street Address: City: State: Zip: Submittal Date: Thu Sep 11 05:45:52 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 181 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 29-NFPA 350-2014 [ Section No. 9.2.2.1 [Excluding any Sub-Sections] ] General ventilation can be achieved via the introduction of an uncontaminated supply air or by exhausting contaminated air from within the confined space using a powered ventilator , or a combination of both techniques. Statement of Problem and Substantiation for Public Comment Using the word powered eliminates using natural ventilation as a method. Related Item Public Input No. 350-NFPA 350-2013 [Section No. 11.4.4.1] Submitter Information Verification Submitter Full Name: Donald Raffo Organization: General Dynamics, Electric Boa Street Address: City: State: Zip: Submittal Date: Thu Sep 11 05:46:35 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 182 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 30-NFPA 350-2014 [ Section No. 9.2.2.1.1 [Excluding any Sub-Sections] ] Supply ventilation uses one or more air powered air -moving devices oriented so that outside uncontaminated air is pushed into the confined space. Depending upon the size and configuration of the space and capacity of the air-moving devices, ducting might be necessary to direct the supply air a greater distance into the space to reach areas where entrants will work. Statement of Problem and Substantiation for Public Comment This makes it clear that the ventilator is powered and not natural ventilation Related Item Public Input No. 350-NFPA 350-2013 [Section No. 11.4.4.1] Submitter Information Verification Submitter Full Name: Donald Raffo Organization: General Dynamics, Electric Boa Street Address: City: State: Zip: Submittal Date: Thu Sep 11 05:52:27 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 183 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 137-NFPA 350-2014 [ Section No. 9.2.3 ] 9.2.3 Comfort Ventilation. The entry supervisor should perform a hazard evaluation and risk assessment to determineif determine if heat or cold stress conditions exist and provide heated for heated or cooled ventilation as necessaryto avoid the effects of prolonged exposure to extreme temperature conditions. Statement of Problem and Substantiation for Public Comment editorial Related Item Public Input No. 923-NFPA 350-2013 [Section No. 7.11.2] Submitter Information Verification Submitter Full Name: Richard Kraus Organization: API/Petroleum Safety Consultan Street Address: City: State: Zip: Submittal Date: Wed Sep 24 10:40:29 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 184 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 138-NFPA 350-2014 [ Section No. 9.3.1.1 ] 9.3.1.1 The entry supervisor should consider the following as part of the evaluation for identifying and selecting an appropriate ventilation method for controlling a hazardous atmosphere within a confined space: (1) Whether to use purging, inerting, or ventilation (2) The size and configuration of the confined space, including the number and location of openings that can be used for ventilation and entrant ingress and egress. (3) The capacity requirements forselected for selected ventilation equipment (4) If the confined space was used to store or containone contain one or more hazardous materials (5) The current use of the confined space , which might contribute to the existence of hazards within the space (6) Whether work processes in or adjacent to the space could introduce atmospheric hazards into the confined space (7) The type of ventilation equipment available Statement of Problem and Substantiation for Public Comment editorial Related Item Public Input No. 166-NFPA 350-2013 [Section No. 9.3.1.1] Submitter Information Verification Submitter Full Name: Richard Kraus Organization: API/Petroleum Safety Consultan Street Address: City: State: Zip: Submittal Date: Wed Sep 24 10:42:58 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 185 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 139-NFPA 350-2014 [ Section No. 9.3.1.2 ] 9.3.1.2 * Based upon the volume of the confined space, the capacity of the air-moving device(s), and the nature of the hazardous atmosphere within the space (see 9.3.2), the ventilation specialist should determine the time needed for a single air change and the required number the number of air changes required to ensure a stable atmosphere within the confined space. The number of required air changes should be based upon the ventilation equipment manufacturer’s specifications and in accordance with the confined space program and any applicable regulatory requirements or consensus standards. Statement of Problem and Substantiation for Public Comment adds confined space program which may have company specific requirements. Related Item Public Input No. 1103-NFPA 350-2014 [Section No. 9.3.1.2] Submitter Information Verification Submitter Full Name: Richard Kraus Organization: API/Petroleum Safety Consultan Street Address: City: State: Zip: Submittal Date: Wed Sep 24 10:45:47 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 186 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 31-NFPA 350-2014 [ Section No. 9.3.1.2 ] 9.3.1.2 * Based upon the volume of the confined space,the capacity of the air-moving device(s), and the nature of the hazardous atmosphere within the space (see 9.3.2), the ventilation specialist should determine the time for a single air change and the required number of air changes to ensure a stable atmosphere within the confined space. The number of required air changes should be based upon the ventilation equipment manufacturer’s specifications and in accordance with any applicable regulatory requirements or consensus standards. Statement of Problem and Substantiation for Public Comment This section does not provide valuable direction. Also, many land storage tanks may be to big and have limited openings for ventilation and a minimum number of air changes cannot be obtained. Many places throughout this document you make suggestions for specifications and limits, if you keep this section a minimum number of air changes should be suggested. Related Item Public Input No. 350-NFPA 350-2013 [Section No. 11.4.4.1] Submitter Information Verification Submitter Full Name: Donald Raffo Organization: General Dynamics, Electric Boa Street Address: City: State: Zip: Submittal Date: Thu Sep 11 05:55:18 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 187 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 375-NFPA 350-2014 [ Section No. 9.3.1.2 ] 9.3.1.2 * Based upon the volume of the confined space,the capacity of the air-moving device(s), and the nature of the hazardous atmosphere within the space (see 9.3.2), the ventilation specialist should determine the time for a single air change and the required number of air changes to ensure a stable atmosphere within the confined space. The number of required air changes The volume of air required should be based upon the ventilation equipment manufacturer’s specifications and in accordance with any applicable regulatory requirements or consensus standards. Statement of Problem and Substantiation for Public Comment Amend the text as shown Related Item First Revision No. 8-NFPA 350-2014 [Chapter 9] Submitter Information Verification Submitter Full Name: EMERY THOMAS Organization: CONOCOPHILLIPS Street Address: City: State: Zip: Submittal Date: Fri Nov 14 17:52:52 EST 2014 12/12/2014 2:22 PM National Fire Protection Association Report 188 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 140-NFPA 350-2014 [ Section No. 9.3.2 ] 9.3.2 Contaminant Characterization. Where selecting and designing a ventilation system, the ventilation specialist should consider the physical and chemical properties of gases, vapors, dusts, and all other contaminantsthat contaminants that might be present in a confined space. Considerations should include, but not necessarily be limited to, the following: (1) Characteristics of air, vapor, gas, and dust movement within the space (2) Vapor density forgases Density for gases and vapors (3) Specific gravity of liquids or residues (4) Vapor pressure and emission rate (5) Effect(s) of space temperature on air contaminants (6) Flammability characteristics, such asflammable as flammable range for gases and vapors or MEC for dusts (7) Flash points (8) Boiling points (9) Recommended exposure limits, such asPEL as PEL , TLV, or equivalent (10) Stability characteristics of contaminants Statement of Problem and Substantiation for Public Comment "vapor" density does not apply to gases. Also numerous editorial Related Item Public Input No. 976-NFPA 350-2013 [Section No. 9.3.2] Submitter Information Verification Submitter Full Name: Richard Kraus Organization: API/Petroleum Safety Consultan Street Address: City: State: Zip: Submittal Date: Wed Sep 24 10:50:02 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 189 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 32-NFPA 350-2014 [ Section No. 9.3.3.1.2 ] 9.3.3.1.2 The ventilation specialist should ensure that supply ventilation is only used when a clean source of makeup or return air is available. If compressed air is used in the ventilation system as a power source (e.g., in a pneumatic system) or as a source of supply air, it must meet the requirements for Grade D air. Statement of Problem and Substantiation for Public Comment The specification or standard body for Grade D air should be provided, is it from a CGA standard or other standard? The user should be able to locate it to determine the parameters of Grade D air Related Item Public Input No. 350-NFPA 350-2013 [Section No. 11.4.4.1] Submitter Information Verification Submitter Full Name: Donald Raffo Organization: General Dynamics, Electric Boa Street Address: City: State: Zip: Submittal Date: Thu Sep 11 05:59:22 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 190 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 376-NFPA 350-2014 [ Section No. 9.3.3.2.3 ] 9.3.3.2.3 The ventilation specialist should ensure that exhaust ventilation is evaluated so that the air-moving device(s) are located to capture contaminants or safely vent as described in 8 .4.2.2 Statement of Problem and Substantiation for Public Comment Add text as noted Related Item First Revision No. 8-NFPA 350-2014 [Chapter 9] Submitter Information Verification Submitter Full Name: EMERY THOMAS Organization: CONOCOPHILLIPS Street Address: City: State: Zip: Submittal Date: Fri Nov 14 17:56:49 EST 2014 12/12/2014 2:22 PM National Fire Protection Association Report 191 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 36-NFPA 350-2014 [ Section No. 9.3.4 ] 9.3.4 * Purging Applications and Design. The purging medium should be determined by the ventilation specialist based on contaminant characteristics, configuration of the confined space, and the entry or work objective. 9.3.4.1 * Where purging is required to safely enter a storage tank or other confined space that previously contained a flammable liquid,it is important to reduce the potential for fire or explosion.The ventilation specialist should purge the confined space with an inert gas to reduce the oxygen level within the confined space. CAUTION Inert gas purging can create an immediately dangerous to life and health (IDLH) condition within the confined space and appropriate respiratory protection for entrants might be required for safe entry. 9.3.4.1.1 Where an inert gas purge is used to displace flammable vapors that exceed or are within the flammable range, the inert gas should be introduced by the ventilation specialist into the space and maintained until the flammable vapor concentration has been reduced to approximately 1 percent by volume,which is the LFL LEL for typical petroleum products. 9.3.4.1.2 Once the flammable vapor concentration has been lowered to 1 percent by volume, the ventilation specialist can then resume purging with fresh air to displace the remaining flammable vapors and to increase the oxygen content to ambient fresh-air levels. 9.3.4.1.3 * While monitoring atmospheric conditions during the inerting process, the gas tester should be aware that the flammable vapor concentrations in the inerted atmosphere cannot be detectedby catalytic bead–type sensors and the testing equipment manufacturer should be consulted to determine any necessary steps to collect accurate measurements. 9.3.4.2 The ventilation specialist should purge the confined space with fresh air to displace toxic contaminants or oxygen deficient air and return the confined space atmosphere to acceptable air levels as specified on the entry permit. 9.3.4.3 The ventilation specialist should purge the confined space with an inert gas wherever hot work will be performed on or adjacent to a confined space that has not been thoroughly cleaned and freed of flammable gases, vapors, and residues in accordance with the safe work practices specified in NFPA 51B. 9.3.4.4 The entry supervisor should alert all workers performing work near confined spaces that have been inerted thatthe that the inert gas might displace the oxygen in localized areas near the space and create unsafe levels of oxygen. Statement of Problem and Substantiation for Public Comment Changed LFL to LEL to be consistent. Also, corrected typo. Related Item Public Input No. 350-NFPA 350-2013 [Section No. 11.4.4.1] Submitter Information Verification Submitter Full Name: Donald Raffo Organization: General Dynamics, Electric Boa Street Address: City: 12/12/2014 2:22 PM National Fire Protection Association Report 192 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... State: Zip: Submittal Date: Thu Sep 11 06:38:02 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 193 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 37-NFPA 350-2014 [ Section No. 9.3.4 ] 9.3.4 * Purging Applications and Design. The purging medium should be determined by the ventilation specialist based on contaminant characteristics, configuration of the confined space, and the entry or work objective. 9.3.4.1 * Where purging is required to safely enter a storage tank or other confined space that previously contained a flammable liquid,it is important to reduce the potential for fire or explosion.The ventilation specialist should purge the confined space with an inert gas to reduce the oxygen level within the confined space. CAUTION Inert gas purging can create an immediately dangerous to life and health (IDLH) condition within the confined space and appropriate respiratory protection for entrants might be required for safe entry. 9.3.4.1.1 Where an inert gas purge is used to displace flammable vapors that exceed or are within the flammable range, the inert gas should be introduced by the ventilation specialist into the space and maintained until the flammable vapor concentration has been reduced to approximately 1 percent by volume,which is the LFL for typical petroleum products. 9.3.4.1.2 Once the flammable vapor concentration has been lowered to 1 percent by volume, the ventilation specialist can then resume purging with fresh air to displace the remaining flammable vapors and to increase the oxygen content to ambient fresh-air levels. 9.3.4.1.3 * While monitoring atmospheric conditions during the inerting process, the gas tester should be aware that the flammable vapor concentrations in the inerted atmosphere cannot be detectedby catalytic bead–type sensors and the testing equipment manufacturer should be consulted to determine any necessary steps to collect accurate measurements. 9.3.4.2 The ventilation specialist should purge the confined space with fresh air to displace toxic contaminants or oxygen deficient air and return the confined space atmosphere to acceptable air levels as specified on the entry permit. 9.3.4.3 The ventilation specialist should purge the confined space with an inert gas wherever hot work will be performed on or adjacent to a confined space that has not been thoroughly cleaned and freed of flammable gases, vapors, and residues in accordance with the safe work practices specified in NFPA 51B. 9.3.4.4 The entry supervisor should alert all workers performing work near confined spaces that have been inerted thatthe inert gas might displace the oxygen in localized areas near the space and create unsafe levels of oxygen. Statement of Problem and Substantiation for Public Comment I believe that this should not be in Chapter 9 and purging should be its own chapter due to the many issues involved in purging a space Related Item Public Input No. 350-NFPA 350-2013 [Section No. 11.4.4.1] Submitter Information Verification Submitter Full Name: Donald Raffo Organization: General Dynamics, Electric Boa Street Address: 12/12/2014 2:22 PM National Fire Protection Association Report 194 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... City: State: Zip: Submittal Date: Thu Sep 11 06:38:20 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 195 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 226-NFPA 350-2014 [ Section No. 9.3.4.1 [Excluding any Sub-Sections] ] Where purging is required to safely enter a storage tank or other confined space that previously contained a flammable liquid,it is important to reduce the potential for fire or explosion.The ventilation specialist should purge the confined space with an inert gas to reduce the oxygen level within the confined space. The entry supervisor should assure that a means of securing the inert gas valve is provided in order to prevent tampering with the gas flow. CAUTION Inert gas purging can create an immediately dangerous to life and health (IDLH) condition within the confined space and appropriate respiratory protection for entrants might be required for safe entry. Statement of Problem and Substantiation for Public Comment the rste of flow could be changed accidentally or purposely thereby creating a hazardous atmosphere in the inerted space. Related Item Public Input No. 984-NFPA 350-2013 [Section No. 9.3.4.1 [Excluding any Sub-Sections]] Submitter Information Verification Submitter Full Name: Richard Kraus Organization: API/Petroleum Safety Consultan Street Address: City: State: Zip: Submittal Date: Mon Oct 20 14:57:51 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 196 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 377-NFPA 350-2014 [ Section No. 9.3.4.1.1 ] 9.3.4.1.1 Where an inert gas purge is used to displace flammable vapors that exceed or are within the flammable range, the inert gas should be introduced by the ventilation specialist into the space and maintained until the flammable vapor concentration has been reduced to approximately 1 percent by volume,which is 20% of the LFL for typical petroleum products value, for the specific contents . Statement of Problem and Substantiation for Public Comment Modify text as shown Related Item First Revision No. 8-NFPA 350-2014 [Chapter 9] Submitter Information Verification Submitter Full Name: EMERY THOMAS Organization: CONOCOPHILLIPS Street Address: City: State: Zip: Submittal Date: Fri Nov 14 18:01:39 EST 2014 12/12/2014 2:22 PM National Fire Protection Association Report 197 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 141-NFPA 350-2014 [ Section No. 9.3.4.1.2 ] 9.3.4.1.2 Once the flammable vapor concentration has been lowered to 1 percent by volume, the ventilation specialist can then resume purging with fresh air to displace then introduce fresh air in order to displace the remaining flammable vapors and to increase the oxygen content within the space to ambient fresh-air levels. Statement of Problem and Substantiation for Public Comment for clarity Fresh air is NOT used for purging (as this would indicate) - see definitions Related Item Public Input No. 173-NFPA 350-2013 [Section No. 9.3.4.1.2] Submitter Information Verification Submitter Full Name: Richard Kraus Organization: API/Petroleum Safety Consultan Street Address: City: State: Zip: Submittal Date: Wed Sep 24 10:57:07 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 198 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 378-NFPA 350-2014 [ Section No. 9.3.4.1.2 ] 9.3.4.1.2 Once the flammable vapor concentration has been lowered to 1 percent by volume, the ventilation specialist can then resume purging with fresh air to displace the remaining flammable vapors and to increase the oxygen content to ambient fresh-air levels. Statement of Problem and Substantiation for Public Comment Modify text as shown. Related Item First Revision No. 8-NFPA 350-2014 [Chapter 9] Submitter Information Verification Submitter Full Name: EMERY THOMAS Organization: CONOCOPHILLIPS Street Address: City: State: Zip: Submittal Date: Fri Nov 14 18:12:01 EST 2014 12/12/2014 2:22 PM National Fire Protection Association Report 199 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 142-NFPA 350-2014 [ Section No. 9.3.4.1.3 ] 9.3.4.1.3 * While monitoring atmospheric conditions during the inerting process, the gas tester should be aware that the flammable vapor concentrations in the inerted atmosphere cannot be detectedby detected by catalytic bead–type sensors and the testing equipment manufacturer should be consulted to determine any necessary steps to collect accurate measurements. Statement of Problem and Substantiation for Public Comment editorial Related Item Public Input No. 1106-NFPA 350-2014 [Section No. 9.3.4.1.3] Submitter Information Verification Submitter Full Name: Richard Kraus Organization: API/Petroleum Safety Consultan Street Address: City: State: Zip: Submittal Date: Wed Sep 24 11:05:11 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 200 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 38-NFPA 350-2014 [ Section No. 9.3.4.1.3 ] 9.3.4.1.3 * While monitoring atmospheric conditions during the inerting process, the gas tester should be aware that the flammable vapor concentrations in the inerted atmosphere cannot be detectedby catalytic bead–type sensors and the testing equipment manufacturer should be consulted to determine any necessary steps to collect accurate measurements. Statement of Problem and Substantiation for Public Comment Suggest moving to either a purging section under its own chapter or to the meter section. It would be a better fit there. Related Item Public Input No. 350-NFPA 350-2013 [Section No. 11.4.4.1] Submitter Information Verification Submitter Full Name: Donald Raffo Organization: General Dynamics, Electric Boa Street Address: City: State: Zip: Submittal Date: Thu Sep 11 06:40:30 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 201 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 143-NFPA 350-2014 [ Section No. 9.3.4.2 ] 9.3.4.2 The ventilation specialist should purge the confined space with should provide for fresh air to be introduced into the confined space to displace toxic contaminants or oxygen deficient air and return the confined space atmosphere to acceptable air atmospheric levels as specified on the entry permit. Statement of Problem and Substantiation for Public Comment ventilation is NOT purging -- see previous comments and definitions in this chapter Related Item Public Input No. 1107-NFPA 350-2014 [Section No. 9.3.4.2] Submitter Information Verification Submitter Full Name: Richard Kraus Organization: API/Petroleum Safety Consultan Street Address: City: State: Zip: Submittal Date: Wed Sep 24 11:06:34 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 202 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 144-NFPA 350-2014 [ Section No. 9.3.4.3 ] 9.3.4.3 The ventilation specialist should purge the confined space with an inert gas wherever hot work will be performed on or adjacent to a confined space that has not been thoroughly cleaned and freed of flammable gases, gase, tanks or vessels in flammable or combustible services, vapors, and residues in accordance with the safe work practices specified in NFPA 51B. Where hot work is to be performed on or adjacent to lines, appurtenances, tanks or vessels in flammable or combustible liquid service, the pocedures for hot tapping and welding provided in applicable API Recommended Practices should be followed. Statement of Problem and Substantiation for Public Comment API guides provide for safe hot work to be performed without the need to purge and inert equipment. Related Item Public Input No. 1108-NFPA 350-2014 [Section No. 9.3.4.3] Submitter Information Verification Submitter Full Name: Richard Kraus Organization: API/Petroleum Safety Consultan Street Address: City: State: Zip: Submittal Date: Wed Sep 24 11:13:27 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 203 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 246-NFPA 350-2014 [ Section No. 9.3.4.4 ] 9.3.4.4 The entry supervisor should alert all workers performing work near confined spaces that have been inerted thatthe that exhausted inert gas might displace might displace the oxygen in localized areas near the space and create unsafe levels of oxygen in areas where workers may be present . 9.3.4.4.1 Because inert gas typically is lighter than hydrocarbon gases, the hydrocarbon gas and vapors will exit from the lower portion of the space when inert gas is introducted at an upper level. The ventilation specialist should be aware that an amount of inert gas equal to several volumes of the space to be inerted is required to replace the atmosphere in the space. The incoming inert gas should have sufficient energy velocity to disperse and penetrate to all areas within the space. It is important to take gas and oxygen measurements at various times, levels and areas within the space the check the efficiency and continuance of inerting operations. 9.3.4.4.2 Entry supervisors, ventilation specialists and attendants should be aware that a mixture of inert gas and hydrocarbon gas or vapors can become flammable when vented and mixed with air and assure that appropriate measures are in place to eliminate or cottrol any sources of ignition in the discharge area. 9.3.4.4.3 In the event that the inert gas system fails to deliver the required amount of inert gas or fails to maintain positive inert pressure in the space, the entry supervisor, ventilation specialist and attendant should take immediate action to vacate the space and repair the inert gas system before reentry is permitted. entry supervisors should be aware that regulations may require the failure of an inert system to be repored the the authority having jurisdiction. 9.3.4.4.4 Where the confined space contains pyrophoric iron sulphide deposits, such as may be found in crude oil tanks and process vessels in the petroleum, petrochemical and marine industries, m owners/operators and contractors should immediately repair and restart the inert gas system in order to prevent an ignition within the space. In the event that it is impossible or impractical to resume ineerting operations, alternate means of protection should be considered and provided for in the preplanning stage of operations. . Statement of Problem and Substantiation for Public Comment there is a need to include a minimum of information regarding safe inerting practices. Related Item Public Input No. 178-NFPA 350-2013 [Section No. 9.3.4.4] Submitter Information Verification Submitter Full Name: Richard Kraus Organization: API/Petroleum Safety Consultan Street Address: City: State: Zip: Submittal Date: Mon Oct 27 08:20:19 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 204 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 34-NFPA 350-2014 [ Section No. 9.3.4.4 ] 9.3.4.4 The entry supervisor should alert all workers performing work near confined spaces that have been inerted thatthe inert gas might displace the oxygen in localized areas near the space and create unsafe levels of oxygen isolate an area where the inert gas may collect and prevent workers from entering the area until the purging operation is complete . Statement of Problem and Substantiation for Public Comment Notifying workers that they may enter a low oxygen environment is not a good practice. The area should be roped off/isolated until the operation is over and it is deemed safe to re-enter. Related Item Public Input No. 350-NFPA 350-2013 [Section No. 11.4.4.1] Submitter Information Verification Submitter Full Name: Donald Raffo Organization: General Dynamics, Electric Boa Street Address: City: State: Zip: Submittal Date: Thu Sep 11 06:34:15 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 205 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 145-NFPA 350-2014 [ Section No. 9.4.1 [Excluding any Sub-Sections] ] This includes fan (blower) systems and venturi-type devices that exhaust only (e.g., eductors) and fan or blower systems . Statement of Problem and Substantiation for Public Comment rearranged for clarity ( and fans used most so should come first) Related Item Public Input No. 179-NFPA 350-2013 [Section No. 9.4.1 [Excluding any Sub-Sections]] Submitter Information Verification Submitter Full Name: Richard Kraus Organization: API/Petroleum Safety Consultan Street Address: City: State: Zip: Submittal Date: Wed Sep 24 11:20:19 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 206 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 146-NFPA 350-2014 [ Section No. 9.4.2.2 ] 9.4.2.2 It is recommended that the ventilation specialist use flexible ducting that includes a means tobond or ground to bond the duct materialand material and the air-moving device device to the space to control the generation of static electricity and dissipate ground the system to dissipate any accumulated static electric charge. Statement of Problem and Substantiation for Public Comment duct work is connected to the fan creating a bond. the fan should be bonded to the space to prevent sparks. The system should be grounded to dissipate any built up change Related Item Public Input No. 182-NFPA 350-2013 [Section No. 9.4.2.2] Submitter Information Verification Submitter Full Name: Richard Kraus Organization: API/Petroleum Safety Consultan Street Address: City: State: Zip: Submittal Date: Wed Sep 24 11:24:50 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 207 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 147-NFPA 350-2014 [ Section No. 9.4.3 ] 9.4.3 * Thermal Oxidizers. Where ventilating tanks and , vessels and other confined spaces with flammable atmospheres, local environmental regulations often restrict emissions. The entry supervisor or ventilation specialist should determine if a gas-freeing or vapor-freeing tank is necessary to safely use exhaust ventilation with the discharge the exhaust ventilation discharge needs to be connected to a thermal oxidizer unit or vapor recovery system, and if so, provide for the necessary equipment . Statement of Problem and Substantiation for Public Comment rewritten to make more sense (clarity) Related Item Public Input No. 184-NFPA 350-2013 [Section No. 9.4.3] Submitter Information Verification Submitter Full Name: Richard Kraus Organization: API/Petroleum Safety Consultan Street Address: City: State: Zip: Submittal Date: Wed Sep 24 11:30:33 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 208 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 148-NFPA 350-2014 [ Section No. 9.4.4 ] 9.4.4 * Bonding/Grounding. Static electricity is created wherever surfaces are separated, through movement, such as air moving through wherever air moves through a fan, blower, or ducting. Where When ventilation is used on to dilute or remove flammable gas or vapor concentrations, the ventilation specialist should control all ignition sources. Regulations and best practices require that all air-moving devices be properly bonded or grounded to the space and grounded to ensure the dissipation of any accumulated static charge within the ventilation system. This includes ducting and attachments appurtenances attached to the air-moving device. Statement of Problem and Substantiation for Public Comment changes fopr correctness. One must first BOND separate objects (fan to tank) to provide for same equal charge and then must GROUND to dissipate the charge. Related Item Public Input No. 185-NFPA 350-2013 [Section No. 9.4.4] Submitter Information Verification Submitter Full Name: Richard Kraus Organization: API/Petroleum Safety Consultan Street Address: City: State: Zip: Submittal Date: Wed Sep 24 11:35:17 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 209 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 149-NFPA 350-2014 [ Section No. 9.5.3 ] 9.5.3 * The entry supervisor and ventilation specialist should evaluate the confined space for stratified atmospheres (see Chapter 7 ) and ensure that ventilation ductwork is positioned to remove or displacecontaminants displace contaminants . Statement of Problem and Substantiation for Public Comment editorial Related Item Public Input No. 993-NFPA 350-2013 [Section No. 9.5.3] Submitter Information Verification Submitter Full Name: Richard Kraus Organization: API/Petroleum Safety Consultan Street Address: City: State: Zip: Submittal Date: Wed Sep 24 11:42:48 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 210 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 40-NFPA 350-2014 [ Section No. 9.5.4 ] 9.5.4 The entry supervisor and ventilation specialist should identify and implement any necessary precautions to control or remove all ignition sources from the area where there is a potential for the presence of flammable gases and vapors within the flammable range inside the confined space,at the point of ventilation discharge or in areas adjacent to the space. Statement of Problem and Substantiation for Public Comment This section should be combined with 9.5.6 Related Item Public Input No. 350-NFPA 350-2013 [Section No. 11.4.4.1] Submitter Information Verification Submitter Full Name: Donald Raffo Organization: General Dynamics, Electric Boa Street Address: City: State: Zip: Submittal Date: Thu Sep 11 06:45:34 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 211 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 39-NFPA 350-2014 [ Section No. 9.5.5 ] 9.5.5 The ventilation specialist should ensure that all air-moving devices and related equipment are bonded and grounded. Statement of Problem and Substantiation for Public Comment This is covered in 9.4.4 and suggest eliminating it here. Related Item Public Input No. 350-NFPA 350-2013 [Section No. 11.4.4.1] Submitter Information Verification Submitter Full Name: Donald Raffo Organization: General Dynamics, Electric Boa Street Address: City: State: Zip: Submittal Date: Thu Sep 11 06:44:20 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 212 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 235-NFPA 350-2014 [ Section No. 9.5.6 ] 9.5.6 Where flammable gases or vapors are exhausted from within a confined space, the ventilation specialist should ensure that the discharge point from all exhaust ventilation processes (i.e., those not connected to scrubbing systems or other contaminant control systems) are located a minimum of 3.7 m (12 ft) above grade. The selection of the exhaust discharge point should ensure that exhausted contaminants are directed away from areas that might contain sources of ignition and areas where personnel might be working and directed to a location that will reduce the likelihood of re-entrainment. Alternately, if discharge cannot be controlled, then the entry supervisor should assure that all souces of ignition and personnel are situated a safe distance from the area of potential contamination. Statement of Problem and Substantiation for Public Comment provides a alternative if discharge cannot be controlled Related Item Public Input No. 193-NFPA 350-2013 [Section No. 9.5.6] Submitter Information Verification Submitter Full Name: Richard Kraus Organization: API/Petroleum Safety Consultan Street Address: City: State: Zip: Submittal Date: Sat Oct 25 14:38:40 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 213 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 379-NFPA 350-2014 [ Section No. 9.5.6 ] 9.5.6 Where flammable gases or vapors are exhausted from within a confined space, the ventilation specialist should ensure that the discharge point from all exhaust ventilation processes (i.e., those not connected to scrubbing systems or other contaminant control systems)are located a minimum of 3.7 m (12 ft) above grade. The selection of the exhaust discharge point should ensure that exhausted contaminants are directed away from areas that might contain sources of ignition and areas where personnel might be working and directed to a location that will reduce the likelihood of re-entrainment. Statement of Problem and Substantiation for Public Comment What is the source or citation of the 3.7 meter above grade specification? It may be helpful to explain why and how this minimum distance was chosen. (such as in Appendix A) Related Item First Revision No. 8-NFPA 350-2014 [Chapter 9] Submitter Information Verification Submitter Full Name: EMERY THOMAS Organization: CONOCOPHILLIPS Street Address: City: State: Zip: Submittal Date: Fri Nov 14 18:15:00 EST 2014 12/12/2014 2:22 PM National Fire Protection Association Report 214 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 380-NFPA 350-2014 [ Section No. 9.5.7.1 ] 9.5.7.1 Where the ventilation specialist uses the method described in 9.5.7(2 1 ) , the following conditions apply: (1) The connection between the eductor and the confined space should be airtight. (2) Air should be drawn through the confined space to allow cross ventilation and removal of vapors. (3) All equipment should be bonded and grounded. Statement of Problem and Substantiation for Public Comment The reference to (.5.7.1(2) is incorrect based upon the details provided in this sub section. Related Item First Revision No. 8-NFPA 350-2014 [Chapter 9] Submitter Information Verification Submitter Full Name: EMERY THOMAS Organization: CONOCOPHILLIPS Street Address: City: State: Zip: Submittal Date: Fri Nov 14 18:20:10 EST 2014 12/12/2014 2:22 PM National Fire Protection Association Report 215 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 41-NFPA 350-2014 [ Section No. 9.5.7.2 ] 9.5.7.2 Where the ventilation specialist uses the method described in 9.5.7(2) , the following conditions apply: (1) If a fill opening that extends into the confined space is used as an air supply point, the portion of the fill pipe that extends into the space should be removed. If entry is required to remove the fill pipe from a space with a flammable atmosphere, then the space might require inerting prior to entry. (2) The air should be supplied from an approved compressor or blower that has been checked for delivery of Grade D air that is free of contaminants. (3) The air-diffusing pipe, if used, should be bonded to the confined space to control the accumulation and discharge of static electricity. Statement of Problem and Substantiation for Public Comment This should be combined with 9.5.7.1 as they apply to the same section. Related Item Public Input No. 350-NFPA 350-2013 [Section No. 11.4.4.1] Submitter Information Verification Submitter Full Name: Donald Raffo Organization: General Dynamics, Electric Boa Street Address: City: State: Zip: Submittal Date: Thu Sep 11 06:48:47 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 216 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 384-NFPA 350-2014 [ Section No. 9.5.8.2 ] 9.5.8.2* Based upon the results of a hazard evaluation and risk assessment, the ventilation specialist should determine an appropriate method to condition or warm the air within the confined space as appropriate for the environment and work. Statement of Problem and Substantiation for Public Comment Consider a statement or wording to evaluate the exhaust of any heating device that may produce an atmospheric hazard such as CO from a salamander type heater. Related Item First Revision No. 8-NFPA 350-2014 [Chapter 9] Submitter Information Verification Submitter Full Name: EMERY THOMAS Organization: CONOCOPHILLIPS Street Address: City: State: Zip: Submittal Date: Fri Nov 14 18:25:33 EST 2014 12/12/2014 2:22 PM National Fire Protection Association Report 217 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 43-NFPA 350-2014 [ Section No. 9.5.9 ] 9.5.9 * Purging. The ventilation specialist should determine if purging can be safely implemented based upon the results of a hazard evaluation and risk assessment. Statement of Problem and Substantiation for Public Comment This should be in a purging section. Related Item Public Input No. 350-NFPA 350-2013 [Section No. 11.4.4.1] Submitter Information Verification Submitter Full Name: Donald Raffo Organization: General Dynamics, Electric Boa Street Address: City: State: Zip: Submittal Date: Thu Sep 11 06:53:46 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 218 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 42-NFPA 350-2014 [ Section No. 9.5.10 ] 9.5.10 Atmospheric Monitoring. 9.5.10.1 The gas tester should conduct atmospheric testing in accordance with Chapter 7 and as directed by the entry supervisor. 9.5.10.2 If the hazard evaluation and risk assessment indicates that atmospheric conditions within the confined space can change adversely or without warning, the entry supervisor and ventilation specialist should ensure continuous forced mechanical ventilation and continuous air monitoring is maintained during all entry and work. 9.5.10.3 * If the hazard evaluation and risk assessment indicate that atmospheric conditions will not be maintained within acceptable levels at all times during entry and work, the ventilation specialist should use flow monitoring, alarms, secondary power systems, and similar backup systems to ensure the safety of entrants and the integrity of the ventilation system and fresh air supply. 9.5.10.4 Where ventilation cannot or does not completely eliminate a recognized atmospheric hazard, other protective measures or methods for controlling air contaminants and protecting entrants should be determined by the entry supervisor prior to entry authorization. Statement of Problem and Substantiation for Public Comment This should be in Chapter 7 and not covered in this section. Related Item Public Input No. 350-NFPA 350-2013 [Section No. 11.4.4.1] Submitter Information Verification Submitter Full Name: Donald Raffo Organization: General Dynamics, Electric Boa Street Address: City: State: Zip: Submittal Date: Thu Sep 11 06:52:49 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 219 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 150-NFPA 350-2014 [ Section No. 10.1.1 ] 10.1.1 General. Recognition and prevention of existing and potential hazards associated with confined space entry and operations may be the best method to avoid the need for rescue. Conducting a proper hazard evaluation and eliminating, mitigating, or controlling all hazards should reduce or eliminate the chance of harm to entrants, thereby also reducing the need for potential rescue. Owners/operators and contractors should train or educate entrants to understand and protect themselves from potential hazards, including the proper selection and proficient use of personal protective equipment (PPE). Entrants should be trained that when they recognize a threat they should immediately exit the space on their own power, which is better than waiting until they are incapacitated and require rescue. There are two types of rescue options: non-entry rescue, in which ill or injured entrants are removed without the rescuers entering the space, and entry rescue, in which rescuers enter the space to properly remove ill or injured entrants. The information provided in this guide should be applied by all owners/operators and contractirs who are responsible for the selection or provision of a response capability for rescue emergencies within confined spaces and who are associated with confined space operations. The elements associated with rescue program requirements should be identified in the hazard evaluation and risk assessment conducted by the owner/operator and contractor . Statement of Problem and Substantiation for Public Comment contractors are often responsible to provide for rescue resources Related Item Public Input No. 218-NFPA 350-2013 [Section No. 10.1.1] Submitter Information Verification Submitter Full Name: Richard Kraus Organization: API/Petroleum Safety Consultan Street Address: City: State: Zip: Submittal Date: Wed Sep 24 13:42:26 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 220 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 46-NFPA 350-2014 [ Section No. 10.1.2.2.3.1 [Excluding any Sub-Sections] ] In entries where portable anchor devices and manufactured systems are employed with only one entrant, retrieval system configurations can be very simple. Where the need for multiple entrants occurs or specific structural restrictions in and around the space exist, configuring the systems canbe can be complicated. Statement of Problem and Substantiation for Public Comment Corrected a typo. Also, I am not sure that this section adds anything to the document, consider eliminating it. It does not really tell you anything except that it may be difficult. Related Item Public Input No. 350-NFPA 350-2013 [Section No. 11.4.4.1] Submitter Information Verification Submitter Full Name: Donald Raffo Organization: General Dynamics, Electric Boa Street Address: City: State: Zip: Submittal Date: Thu Sep 11 08:15:06 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 221 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 151-NFPA 350-2014 [ Section No. 10.1.2.4 ] 10.1.2.4 Owner/operators and contractors should implement procedures for the following attendant operations: (1) Recognizing the need for confined space search and rescue (2) Initiating contact and establishing communications with victims where possible (3) * Recognizing and identifying the hazards associated with non-entry confined space emergencies (4) Advising the responding rescuers of the situation and potential hazards (5) Recognizing confined spaces (6) * Identifying the need for and performing a non-entry retrieval, based on the conditions present (7) * Implementing the emergency response system for confined space emergencies Statement of Problem and Substantiation for Public Comment contractor's attendants are often employes Related Item Public Input No. 236-NFPA 350-2013 [Section No. 10.1.2.4] Submitter Information Verification Submitter Full Name: Richard Kraus Organization: API/Petroleum Safety Consultan Street Address: City: State: Zip: Submittal Date: Wed Sep 24 13:50:36 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 222 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 2-NFPA 350-2014 [ Section No. 10.1.3.4 ] 10.1.3.4 Rescue Response Modes. The degree and rapidity of response should be driven principally by the anticipated hazards. Those spaces that contain known hazards should receive greater scrutiny and perhaps more rapid or complex response based on the hazards. Consideration should also include those spaces where technical rescue may be required to move an ill or injured entrant to a stable environment once extracted from the space. Rescue capabilities should be evaluated to ensure they are appropriate to the response. Many emergency response agencies do not have the training or equipment to respond to confined space emergencies. Simply summoning them to react to these specialized emergencies without ascertaining that they are capable is unacceptable. It is important that the qualifications of the rescue service be assessed and verified in advance of an emergency in accordance with the recommendations provided in Section 10.2. Consideration should be given to three basic modes of rescue response: (1) Tier 1 — Those that have no recognized hazards but could require technical rescue for extraction should a worker become incapacitated (2) Tier 2 — Those with non-life-threatening hazards requiring rapid intervention (3) Tier 3 — Those with life-threatening hazards requiring immediate intervention 10.1.3.4.1* Tier 1 Response Mode. A Tier 1 response mode may be indicated if a hazard evaluation has been performed (in accordance with Chapter 6), and although the space contains no potential for hazards, its configuration would prohibit entrants from being easily removed if they were to become incapacitated, either due to medical illness or injury. At the minimum, this should be applicable to any vertically oriented space greater than 4 ft (1.2 m) in height, whether or not retrieval equipment is in place. A Tier 1 capability suggests that a fully trained rescue team meeting NFPA 1670, Chapter 7, technician level, is available to respond within 5 minutes to the site and is capable of setup and rescue entry within 12–15 minutes of arrival on site. in a timely manner commensurate with the level of risk. 10.1.3.4.2* Tier 2 Response Mode. A Tier 2 response mode is indicated if a space contains no IDLH or other potentially immediate life-threatening hazards but does contain other actual or potential hazard that could incapacitate entrants or prevent them from exiting the space without assistance (self-rescue evacuation ). A Tier 2 capability suggests that a fully trained rescue team meeting NFPA 1670, Chapter 7, technician level, is on site with appropriate capability to make safe entry for rescue. The team should be equipped and mobile, capable of setup and rescue entry within 12-15 minutes of incident occurrence in a timely manner commensurate with the level of risk . 10.1.3.4.3* Tier 3 Response Mode. A Tier 3 response mode is indicated if work is occurring inside a space that contains an IDLH or other immediately life-threatening hazard, either actual or potential. A Tier 3 capability suggests that a fully trained rescueteam meeting requirements stated in NFPA 1670, Chapter 7, technician level, is standing by in the immediate area with appropriate capability to make safe entry for rescue. This team should be completely set up rigged, ready, tested and capable of rescue entry within 2 minutes of incident occurrence. The rescueteam should be dedicated to this singular entry with no other responsibilities. Statement of Problem and Substantiation for Public Comment Paragraph 10.1.3.4 is much too limiting for some industries. Wind industry, for example, has machines most often located in very remote areas. Machines in the northeast are accessible in winter time by snow cats. We often work in teams of two unless the scope of work has risks that require a 3rd or 4th person on the team. The added members serve as an on-location rescue team. (All personnel are trained in excess of OSHA 1910.146) . Adding a suggested 12 - 15 minute response time would cost wind industry many millions of dollars per year to arrange for rescue services (adding them organically, hiring dedicated 3rd party rescue services or a combination both or other options.) Related Item First Revision No. 9-NFPA 350-2014 [Section No. 10.1] 12/12/2014 2:22 PM National Fire Protection Association Report 223 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Submitter Information Verification Submitter Full Name: JAMES TYLER Organization: VESTAS Affilliation: American Wind Energy Association (AWEA) Street Address: City: State: Zip: Submittal Date: Mon Sep 08 17:14:58 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 224 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 227-NFPA 350-2014 [ Section No. 10.1.3.4.3 ] 10.1.3.4.3 * Tier 3 Response Mode. A Tier 3 response mode is indicated if work is occurring inside a space that contains an IDLH or other immediately life-threatening hazard, either actual or potential. A Tier 3 capability suggests that a fully trained rescueteam meeting requirements stated in NFPA 1670, Chapter 7, technician level, is standing by in the immediate area with appropriate capability to make safe entry for rescue rescue the entrant, preferably without requiring rescuer entry. It is preferable in IDLH/inert atmospheres to conduct rescue operatons from outside the space without the need for rescuer entry . This team should be completely set up and capable of rescue entry within conducting a rescue within 2 minutes of incident occurrence. The rescueteam rescue team should be dedicated to this singular entry with no other responsibilities. Statement of Problem and Substantiation for Public Comment Numerous fatalities and injuries have occurred to rescuers entering IDLH/inert atmospheres, even when prescribed PPE. The safest way to conduct such rescues is from outside the space. Related Item Public Input No. 1018-NFPA 350-2013 [Chapter 10] Submitter Information Verification Submitter Full Name: Richard Kraus Organization: API/Petroleum Safety Consultan Street Address: City: State: Zip: Submittal Date: Mon Oct 20 15:16:46 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 225 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 152-NFPA 350-2014 [ Section No. 10.2.2 [Excluding any Sub-Sections] ] Confined The rescue requirements of confined space rescue programs should be audited annually by the a designated person (or team) responsible for rescue services selection as defined in 10.2.2.2. Audits should be conducted annually or whent a management of change occurs affecting the space or operations and in accordance with the owner/operator’s or contractor's confined space program requirements or applicable government regulations. The owner/operator should also review the rescue program and contractor should review the rescue requirement following each rescue operation and make adjustments to the program if needed. Statement of Problem and Substantiation for Public Comment Clarifies that audits are not needed annually. In many cases a specific type of entry my be carried out once every 5 to 10 years (as in an industry turn around) and there is no need for annual review. provides for a review when MOC occurs. Related Item Public Input No. 250-NFPA 350-2013 [Section No. 10.2.2 [Excluding any Sub-Sections]] Submitter Information Verification Submitter Full Name: Richard Kraus Organization: API/Petroleum Safety Consultan Street Address: City: State: Zip: Submittal Date: Wed Sep 24 13:57:44 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 226 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 153-NFPA 350-2014 [ Section No. 10.2.3 [Excluding any Sub-Sections] ] Performance evaluations are a principal means of deciding who is qualified among a group of prospective rescue service providers. Performance evaluations should be conducted by the owner/operator or contractor prior to considering a rescue service and then periodically to ensure thatthe provider’s performance is still satisfactory. Performance should be evaluated by means of simulated rescue operations in which the rescue service removes dummies, mannequins, or persons from actual confined spaces or from representative confined spaces resembling all the spaces to which the rescue service could be required to respond in an emergency within their jurisdiction. Representative confined spaces should, with respect to opening size, configuration, and accessibility, simulate the types of confined spaces from which rescue could be performed. Statement of Problem and Substantiation for Public Comment there is a need to show who performs the evaluation of rescue service Related Item Public Input No. 1132-NFPA 350-2014 [Section No. 10.2.3 [Excluding any Sub-Sections]] Submitter Information Verification Submitter Full Name: Richard Kraus Organization: API/Petroleum Safety Consultan Street Address: City: State: Zip: Submittal Date: Wed Sep 24 14:00:53 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 227 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 47-NFPA 350-2014 [ Section No. 10.2.3 [Excluding any Sub-Sections] ] Performance evaluations are a principal means of deciding who is qualified among a group of prospective rescue service providers. Performance evaluations should be conducted prior to considering a rescue service and then periodically to ensure thatthe that the provider’s performance is still satisfactory. Performance should be evaluated by means of simulated rescue operations in which the rescue service removes dummies, mannequins, or persons from actual confined spaces or from representative confined spaces resembling all the spaces to which the rescue service could be required to respond in an emergency within their jurisdiction. Representative confined spaces should, with respect to opening size, configuration, and accessibility, simulate the types of confined spaces from which rescue could be performed. Statement of Problem and Substantiation for Public Comment Corrected typo Related Item Public Input No. 350-NFPA 350-2013 [Section No. 11.4.4.1] Submitter Information Verification Submitter Full Name: Donald Raffo Organization: General Dynamics, Electric Boa Street Address: City: State: Zip: Submittal Date: Thu Sep 11 08:20:06 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 228 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 154-NFPA 350-2014 [ Section No. 10.3 [Excluding any Sub-Sections] ] The owner/operator and contractor should conduct a hazard evaluation and risk assessment of the response area and should determine the feasibility and type of incidents that might require confined space rescue operations. Statement of Problem and Substantiation for Public Comment the contractor may be responsible to provide rescue and should therefore do the evaluation Related Item Public Input No. 255-NFPA 350-2013 [Section No. 10.3 [Excluding any Sub-Sections]] Submitter Information Verification Submitter Full Name: Richard Kraus Organization: API/Petroleum Safety Consultan Street Address: City: State: Zip: Submittal Date: Wed Sep 24 14:03:30 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 229 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 155-NFPA 350-2014 [ Section No. 10.3.1 ] 10.3.1 Components. These assessments should include, but not be limited to, the following: (1) Evaluation of the environmental, physical, social, and cultural factors influencing the scope, frequency, and magnitude of a potential incident (2) The impact these factors may have on the ability of the owner/operator operatorand/or contractor to respond to an incident and to continue operating while minimizing threats to rescuers at an incident site. (3) Identification and maintenance of a list of the type and availability of internal resources needed for technical search and rescue incidents. (4) Identification of the type and availability of external resources needed to augment existing capabilities in confined space rescue incidents (5) Determination of the potential to respond to rescue incidents that might involve nuclear or biological weapons, chemical agents, or weapons of mass destruction, including those with the potential for secondary devices. If the owner/operator determines that a hazard evaluation exists for rescue response into a nuclear, biological, explosive, and/or chemical environment, appropriate training and equipment for response personnel should be provided. Statement of Problem and Substantiation for Public Comment the contractor could be responsible for response and determining if operations should continue Related Item Public Input No. 256-NFPA 350-2013 [Section No. 10.3.1] Submitter Information Verification Submitter Full Name: Richard Kraus Organization: API/Petroleum Safety Consultan Street Address: City: State: Zip: Submittal Date: Wed Sep 24 14:06:07 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 230 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 156-NFPA 350-2014 [ Section No. 10.3.2 ] 10.3.2 Acquisition of Resources. Where an advanced level of search and rescue capability may be needed in a given confined space, owner/operators and contractors should have a system in place to utilize the most appropriate resource(s) available through the use of local experts, agreements with specialized resources, and mutual aid. The owner/operator's or contractor's confined space program should establish procedures for the acquisition of the external resources needed for specific emergencies in and associated with confined spaces. A list of the resources should be maintained and updated at least once a year. Additionally, the list should be reviewed and updated by the owner/operator and contractor prior to a planned entry requiring advanced capability. Statement of Problem and Substantiation for Public Comment contractors often are responsible for these items Related Item Public Input No. 257-NFPA 350-2013 [Section No. 10.3.2] Submitter Information Verification Submitter Full Name: Richard Kraus Organization: API/Petroleum Safety Consultan Street Address: City: State: Zip: Submittal Date: Wed Sep 24 14:08:37 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 231 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 157-NFPA 350-2014 [ Section No. 10.5 ] 10.5 Regulatory Compliance. The owner/operator and contractor should comply with all applicable local, state, and federal laws and regulations and should ensure that rescue personnel adhere to program requirements. Statement of Problem and Substantiation for Public Comment contractors are also required to do this Related Item Public Input No. 264-NFPA 350-2013 [Section No. 10.5] Submitter Information Verification Submitter Full Name: Richard Kraus Organization: API/Petroleum Safety Consultan Street Address: City: State: Zip: Submittal Date: Wed Sep 24 14:14:16 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 232 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 158-NFPA 350-2014 [ Section No. 10.6 [Excluding any Sub-Sections] ] The owner/operator or contractor should train responsible personnel in procedures for developing pre-incident emergency action plans to prepare the rescue service for safe practices associated with rescue from specific and generic confined spaces for which they provide rescue. This process should include determining, reviewing, accessing, and using relevant components of applicable national, state, industry, and local response plans. Statement of Problem and Substantiation for Public Comment contractors also responsible for these items for their personnel Related Item Public Input No. 265-NFPA 350-2013 [Section No. 10.6 [Excluding any Sub-Sections]] Submitter Information Verification Submitter Full Name: Richard Kraus Organization: API/Petroleum Safety Consultan Street Address: City: State: Zip: Submittal Date: Wed Sep 24 14:16:02 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 233 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 159-NFPA 350-2014 [ Section No. 11.1 ] 11.1 * General. All persons engaged in confined space activities and operations should be competent and qualified. There are numerous entities that may be involved, individually or working together, in confined space entry and related activities. These include, but are not limited to, owners/operators, contractors/subcontractors, facility personnel, rescue services and visitors, as well as other persons and operations both within and outside of the confined space. This chapter covers the duties, responsibilities, qualifications, and competencies of these individuals as related to confined space activities. This chapter lists requirements for all persons and tasks that might be required for entry. It is important to recognize that there are at least three key positions required for a basic confined space entry that requires permitting: the entry supervisor, the entry attendant, and the entrant. In addition to these three positions, rescue should be provide as outlined in Chapter 10. In many applications one or more of these persons (often the entry supervisor) can handle other tasks addressed in this chapter (e.g., permit issuer, ventilation specialist, standby worker , including, but not limited to gas testing, issuing permits, conducting ventilation and providing standby services ). Statement of Problem and Substantiation for Public Comment adds contractors and rescuers. also is more definitive as to additional duties. Related Item Public Input No. 1134-NFPA 350-2014 [Section No. 11.1] Submitter Information Verification Submitter Full Name: Richard Kraus Organization: API/Petroleum Safety Consultan Street Address: City: State: Zip: Submittal Date: Wed Sep 24 15:02:47 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 234 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 48-NFPA 350-2014 [ Section No. 11.2.1.2 ] 11.2.1.2 As defined in the applicable confined space program, entry should occur occurs when any part of the entrant’s body breaks the plane of a confined space opening that provides for entry access . Statement of Problem and Substantiation for Public Comment Changed wording to make when an entry occurs clear. Related Item Public Input No. 350-NFPA 350-2013 [Section No. 11.4.4.1] Submitter Information Verification Submitter Full Name: Donald Raffo Organization: General Dynamics, Electric Boa Street Address: City: State: Zip: Submittal Date: Thu Sep 11 08:25:16 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 235 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 160-NFPA 350-2014 [ Section No. 11.2.2.1.2 ] 11.2.2.1.2 Entrants should be aware of the hazards that might be encountered during entry, including the confined space hazards and controls noted on the permit and be able to verbally identify these to the entrysupervisor. Statement of Problem and Substantiation for Public Comment this was missing and the sentence makes no sense with out the qualifier Related Item Public Input No. 302-NFPA 350-2013 [Section No. 11.2.2.1.2] Submitter Information Verification Submitter Full Name: Richard Kraus Organization: API/Petroleum Safety Consultan Street Address: City: State: Zip: Submittal Date: Wed Sep 24 15:10:39 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 236 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 3-NFPA 350-2014 [ Section No. 11.2.2.6 ] 11.2.2.6 Entrants should react to emergencies as trained and directed, including, but not limited to, self -rescue or evacuation of the confined space. Statement of Problem and Substantiation for Public Comment Self-rescue can be mistaken as a rescue plan. Self-rescue throughout the document should be changed to self evacuation to prevent the implication of using self-rescue as a rescue plan. Related Item First Revision No. 10-NFPA 350-2014 [Chapter 11] Submitter Information Verification Submitter Full Name: JAMES TYLER Organization: VESTAS Affilliation: American Wind Energy Association (AWEA) Street Address: City: State: Zip: Submittal Date: Mon Sep 08 17:53:39 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 237 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 236-NFPA 350-2014 [ Section No. 11.2.3.1 ] 11.2.3.1 An entrant should be able to understand and verbally identify to the entry supervisor the governmental comply with applicable governmental regulations that pertain to the planned confined space entry and work as explained by the entry supervisor or included in the entry permit . Statement of Problem and Substantiation for Public Comment it is unrealistic to expect entrants to know all government regulations. There is a need to know and understand requirements applicable to the operations and it is the responsibility of the entry supervisor to cover these in the pre-job and daily safety meetings. Related Item Public Input No. 1140-NFPA 350-2014 [Section No. 11.2.3.1] Submitter Information Verification Submitter Full Name: Richard Kraus Organization: API/Petroleum Safety Consultan Street Address: City: State: Zip: Submittal Date: Sat Oct 25 15:26:26 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 238 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 49-NFPA 350-2014 [ Section No. 11.2.3.2 ] 11.2.3.2 An entrant should understand and be able to verbally identify to the entry supervisor the use, limitations, and hazards of materials, substances, and equipment approved for use within the specific confined space (e.g., tools, personal protective equipment, energy isolation devices, gas testers atmosphere testing instruments , and chemicals) before entry. Statement of Problem and Substantiation for Public Comment Suggest this use of monitoring equipment. Related Item Public Input No. 350-NFPA 350-2013 [Section No. 11.4.4.1] Submitter Information Verification Submitter Full Name: Donald Raffo Organization: General Dynamics, Electric Boa Street Address: City: State: Zip: Submittal Date: Thu Sep 11 08:28:27 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 239 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 50-NFPA 350-2014 [ Section No. 11.2.3.4 ] 11.2.3.4 An entrant should understand and be able to verbally explain to the entry supervisor before entry how to interpret and respond to air monitor atmosphere meter displays and alarms. Statement of Problem and Substantiation for Public Comment When describing atmosphere sampling instrumentation the wording should be the same throughout the document Related Item Public Input No. 350-NFPA 350-2013 [Section No. 11.4.4.1] Submitter Information Verification Submitter Full Name: Donald Raffo Organization: General Dynamics, Electric Boa Street Address: City: State: Zip: Submittal Date: Thu Sep 11 08:30:06 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 240 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 51-NFPA 350-2014 [ Sections 11.2.3.4, 11.2.3.5, 11.2.3.6, 11.2.3.7 ] Sections 11.2.3.4, 11.2.3.5, 11.2.3.6, 11.2.3.7 11.2.3.4 An entrant should understand and be able to verbally explain to the entry supervisor before entry how : How to interpret and respond to air monitor displays and alarms. 11.2.3.5 An entrant should understand and be able to verbally explain to the entry supervisor before entry all An understanding of all sections of the confined space entry permit that are applicable to the entrants’ duties. 11.2.3.6 An entrant should understand and be able to verbally explain to the entry supervisor before entry personal An understanding of personal warning signs and overexposure symptoms, including actions that must betaken in the event of exposure. 11.2.3.7 An entrant should understand and be able to verbally explain to the entry supervisor before entry applicable emergency Emergency procedures to be taken within or around the confined space. Statement of Problem and Substantiation for Public Comment Section should be consolidated to make it shorter and easier to understand Related Item Public Input No. 350-NFPA 350-2013 [Section No. 11.4.4.1] Submitter Information Verification Submitter Full Name: Donald Raffo Organization: General Dynamics, Electric Boa Street Address: City: State: Zip: Submittal Date: Thu Sep 11 08:33:35 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 241 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 54-NFPA 350-2014 [ Section No. 11.3.2.1 ] 11.3.2.1 Attendants should understand and be able to verbally identify to the entry supervisor the the following: The hazards inside and outside the specific confined space that might occur during entry, including information Information on the modes, signs or symptoms, and consequences of exposure to entrants. 11.3.2.1.1 Each attendant should verify that That his or her name is listed on the entry permit. This may require initialing or signature, as required by the entry supervisor. 11.3.2.1.2 Attendants should be constantly observing Observe , monitoring, and evaluating the conditions in and around the confined space to ensure that compliance with the requirements of the permit are maintained throughout the entry . 11.3.2.1.3 Attendants should monitor adjacent Adjacent areas outside the confined space for changing conditions that might affect safe entry work or activities. Statement of Problem and Substantiation for Public Comment This section should be short and consise Related Item Public Input No. 350-NFPA 350-2013 [Section No. 11.4.4.1] Submitter Information Verification Submitter Full Name: Donald Raffo Organization: General Dynamics, Electric Boa Street Address: City: State: Zip: Submittal Date: Thu Sep 11 10:14:16 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 242 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 55-NFPA 350-2014 [ Section No. 11.3.3.3 ] 11.3.3.3 Attendants should know and be able to verbally identify to the entry supervisor the use, limitations, and hazards of materials, substances, and equipment approved for use outside the specific confined space,including, but not limited to, tools, PPE, energy isolation devices, atmospheric measuring devices instruments and associated alarms, and chemicals. Statement of Problem and Substantiation for Public Comment Suggest change for consistency. Related Item Public Input No. 350-NFPA 350-2013 [Section No. 11.4.4.1] Submitter Information Verification Submitter Full Name: Donald Raffo Organization: General Dynamics, Electric Boa Street Address: City: State: Zip: Submittal Date: Thu Sep 11 10:21:11 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 243 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 56-NFPA 350-2014 [ Section No. 11.3.4.3 ] 11.3.4.3 Attendants should be able to communicate with entrantsin entrants in order to evacuate the confined space when conditions arise that might endanger the entrant. Statement of Problem and Substantiation for Public Comment Corrected typo Related Item Public Input No. 350-NFPA 350-2013 [Section No. 11.4.4.1] Submitter Information Verification Submitter Full Name: Donald Raffo Organization: General Dynamics, Electric Boa Street Address: City: State: Zip: Submittal Date: Thu Sep 11 10:22:00 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 244 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 57-NFPA 350-2014 [ Section No. 11.4.1.2 ] 11.4.1.2 * Entry supervisorscan supervisors can also be designated on the permit(s) as attendants, gas testers, ventilation specialists, isolation specialists, and entrants in accordance with the applicable confined space program.Entry supervisors should be trained and/or qualified in accordance with the respective requirements provided in this chapter for alternative activities. Statement of Problem and Substantiation for Public Comment Corrected typo. Related Item Public Input No. 350-NFPA 350-2013 [Section No. 11.4.4.1] Submitter Information Verification Submitter Full Name: Donald Raffo Organization: General Dynamics, Electric Boa Street Address: City: State: Zip: Submittal Date: Thu Sep 11 10:22:44 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 245 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 237-NFPA 350-2014 [ Section No. 11.4.2.1.3 ] 11.4.2.1.3 Assigned entrysupervisors Where required by the applicable confined space program or regulations, the assigned entrysupervisor should remain at the confined space work site to control operations unless relieved by another competent, qualified, and authorized entrysupervisor entry supervisor . The relieving entry supervisor should initial or sign the permit(s) to document the change of responsibility, if applicable. Statement of Problem and Substantiation for Public Comment it is industry practice to often have one supervisor at a site where there may be multiple crews conducting simultaneous entries. Also some operators require a full-time on site entry supervisor and others do not. Related Item Public Input No. 337-NFPA 350-2013 [Section No. 11.4.2.1.3] Submitter Information Verification Submitter Full Name: Richard Kraus Organization: API/Petroleum Safety Consultan Street Address: City: State: Zip: Submittal Date: Sat Oct 25 15:33:04 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 246 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 58-NFPA 350-2014 [ Section No. 11.4.2.1.3 ] 11.4.2.1.3 Assigned entrysupervisors should remain at the confined space work site to control operations unless relieved by another competent, qualified, and authorized entrysupervisor entry supervisor . The relieving entry supervisor should initial or sign the permit(s) to document responsibility if applicable. Statement of Problem and Substantiation for Public Comment Corrected typo Related Item Public Input No. 350-NFPA 350-2013 [Section No. 11.4.4.1] Submitter Information Verification Submitter Full Name: Donald Raffo Organization: General Dynamics, Electric Boa Street Address: City: State: Zip: Submittal Date: Thu Sep 11 10:23:20 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 247 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 59-NFPA 350-2014 [ Section No. 11.4.2.1.4 ] 11.4.2.1.4 Entry supervisors should ensure that personnel involved with the confined space operations are informed when another person assumes the entrysupervisor entry supervisor role. Statement of Problem and Substantiation for Public Comment Corrected typo Related Item Public Input No. 350-NFPA 350-2013 [Section No. 11.4.4.1] Submitter Information Verification Submitter Full Name: Donald Raffo Organization: General Dynamics, Electric Boa Street Address: City: State: Zip: Submittal Date: Thu Sep 11 10:23:47 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 248 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 4-NFPA 350-2014 [ Section No. 11.4.2.1.6 ] 11.4.2.1.6 Entry supervisors should be trained and qualified as gas testers detection equipment if duties require maintaining, testing, and operating gas monitors detection equipment , including interpreting and analyzing test results. Statement of Problem and Substantiation for Public Comment Inconsistent use of terminology. Suggest landing on one term and using the same term throughout document. Related Item First Revision No. 10-NFPA 350-2014 [Chapter 11] Submitter Information Verification Submitter Full Name: JAMES TYLER Organization: VESTAS Affilliation: American Wind Energy Association (AWEA) Street Address: City: State: Zip: Submittal Date: Mon Sep 08 17:58:13 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 249 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 60-NFPA 350-2014 [ Section No. 11.4.3.3 ] 11.4.3.3 Entry supervisors should know the proper use of atmospheric monitors and atmospheric monitoring instruments and be able to understand, analyze, and interpret monitor interpret instrument readings in order to provide for safe entry and work in confined spaces. Statement of Problem and Substantiation for Public Comment Used instrument for conformity. Related Item Public Input No. 350-NFPA 350-2013 [Section No. 11.4.4.1] Submitter Information Verification Submitter Full Name: Donald Raffo Organization: General Dynamics, Electric Boa Street Address: City: State: Zip: Submittal Date: Thu Sep 11 10:25:02 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 250 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 61-NFPA 350-2014 [ Section No. 11.5.2 ] 11.5.2 Rescuer Duties and Responsibilities. 11.5.2.1 Prior to the start of confined space operations (such as during pre-planning), rescuers should evaluate the internal and external physical, atmospheric, and other hazards specific to the confined space that might be encountered during a rescue situation. 11.5.2.2 Rescuers should respond in accordance with the established response plan — upon arrival, they should establish a command system and develop an action plan as appropriate to the situation. 11.5.2.3 Rescuers should ensure that all required rescue and PPE is inspected and in good working order prior to start of confined space operations. 11.5.2.4 Rescuers should determine if a non-entry rescue or an entry-required rescue is needed. 11.5.2.4.1 Rescuers may conduct the rescue from outside the confined space and without the need for rescuer entry. 11.5.2.4.2 Training for rescuers should be similar to that for entrants. Rescuersshould meet the same entry requirements applicable to entrants should the rescue require entry into the space. 11.5.2.5 Rescuers should develop a pre-emergency action plan with the ability to respond in an organized and appropriate manner that includes, but is not limited to, the following: (1) Determining the alarm or notification method specific to the facility or operation (2) Assessing the incident and identifying potential related hazards (3) Determining if rescue is to be external or internal (4) Determining the appropriate PPE and respiratory protection required for entry (5) Organizing equipment and personnel prior to start of rescue operations (6) Determining signals or communication to be used during rescue (7) Planning the specific step-by-step operations of the rescue (8) Responding to the incident and performing rescue (9) Conducting a post-incident evaluation and taking necessary action to correct pre-emergency rescue plans where needed 11.5.2.6 Rescuers should consider the rescue requirements with respect to entrants’ self-rescue capabilities,physical and mental condition, hazards, equipment, communications, confined space configuration, and other rescue-related conditions prior to starting rescue operations. Statement of Problem and Substantiation for Public Comment This was covered in Rescue Chapter, redundant and should be eliminated Related Item Public Input No. 350-NFPA 350-2013 [Section No. 11.4.4.1] Submitter Information Verification Submitter Full Name: Donald Raffo 12/12/2014 2:22 PM National Fire Protection Association Report 251 of 340 Organization: http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... General Dynamics, Electric Boa Street Address: City: State: Zip: Submittal Date: Thu Sep 11 10:27:02 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 252 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 62-NFPA 350-2014 [ Section No. 11.6.2.1 ] 11.6.2.1 Gas testers should determine proper selection of monitoring equipment instrumentation based on the atmospheric hazards that are present or that could be encountered during confined space operations. Statement of Problem and Substantiation for Public Comment Used instrumentation for consistency. Related Item Public Input No. 350-NFPA 350-2013 [Section No. 11.4.4.1] Submitter Information Verification Submitter Full Name: Donald Raffo Organization: General Dynamics, Electric Boa Street Address: City: State: Zip: Submittal Date: Thu Sep 11 10:28:11 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 253 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 63-NFPA 350-2014 [ Section No. 11.6.2.2 ] 11.6.2.2 Gas testers should inspect, calibrate, test, and adjust equipment adjust instruments prior to use. Statement of Problem and Substantiation for Public Comment Changed for consistancy Related Item Public Input No. 350-NFPA 350-2013 [Section No. 11.4.4.1] Submitter Information Verification Submitter Full Name: Donald Raffo Organization: General Dynamics, Electric Boa Street Address: City: State: Zip: Submittal Date: Thu Sep 11 10:29:02 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 254 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 64-NFPA 350-2014 [ Section No. 11.6.3.2 ] 11.6.3.2 Gas testers should be trained and qualified in the appropriate selection, inspection, calibration, adjustment, and use of monitoring equipment instruments . Statement of Problem and Substantiation for Public Comment Changed for consistency. Related Item Public Input No. 350-NFPA 350-2013 [Section No. 11.4.4.1] Submitter Information Verification Submitter Full Name: Donald Raffo Organization: General Dynamics, Electric Boa Street Address: City: State: Zip: Submittal Date: Thu Sep 11 10:30:02 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 255 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 261-NFPA 350-2014 [ Section No. 11.6.4.1 ] 11.6.4.1 Gas testers should be able to demonstrate the competencies required for a gas tester and an entrant and understand permit requirements for entering confined spaces, conducting monitoring, and recording monitoring results. Statement of Problem and Substantiation for Public Comment The way it is currently written does not adequately protect the worker. Related Item First Revision No. 10-NFPA 350-2014 [Chapter 11] Submitter Information Verification Submitter Full Name: JACK HILL Organization: na Street Address: City: State: Zip: Submittal Date: Mon Nov 10 17:40:37 EST 2014 12/12/2014 2:22 PM National Fire Protection Association Report 256 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 65-NFPA 350-2014 [ Section No. 11.6.4.2 ] 11.6.4.2 Gas testers should be able to select, inspect, adjust, calibrate, bump test, and properly use required equipment instrumentation . Statement of Problem and Substantiation for Public Comment Changed for consistancy Related Item Public Input No. 350-NFPA 350-2013 [Section No. 11.4.4.1] Submitter Information Verification Submitter Full Name: Donald Raffo Organization: General Dynamics, Electric Boa Street Address: City: State: Zip: Submittal Date: Thu Sep 11 10:30:53 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 257 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 66-NFPA 350-2014 [ Section No. 11.7.2.3 ] 11.7.2.3 / Owners/operators should identify and designate those individuals (facility personnel, contractors, and contract personnel under facility supervision) who are educated, trained, competent, and/or qualified to perform specific confined space–related duties, including, but not limited to, supervising operations, issuing permits, entering into confined spaces, conducting atmospheric monitoring, providing rescue, performing attendant duties, overseeing ventilation, and conducting hot or cold work operations within or associated with confined spaces. Owners/operators should designate and identify the individuals and their duties in the written confined space program in accordance with Chapter 12. Statement of Problem and Substantiation for Public Comment Corrected typo Related Item Public Input No. 350-NFPA 350-2013 [Section No. 11.4.4.1] Submitter Information Verification Submitter Full Name: Donald Raffo Organization: General Dynamics, Electric Boa Street Address: City: State: Zip: Submittal Date: Thu Sep 11 10:31:45 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 258 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 161-NFPA 350-2014 [ Section No. 11.7.2.5 ] 11.7.2.5 Prior to entry, owners/operators should conduct a confined space entry safety meeting in accordance with Chapter 5 to ensure that assignedentry assigned entry supervisors, gas testers, entrants, attendants, ventilation and isolation specialists, rescuers, and workers are apprised of and understand the hazards associated with the confined space activity. Statement of Problem and Substantiation for Public Comment editorial Related Item Public Input No. 416-NFPA 350-2013 [Section No. 11.8.2.5] Submitter Information Verification Submitter Full Name: Richard Kraus Organization: API/Petroleum Safety Consultan Street Address: City: State: Zip: Submittal Date: Wed Sep 24 15:27:35 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 259 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 386-NFPA 350-2014 [ Section No. 11.7.2.7.2 ] 11.7.2.7.2 Owners/operators should debrief contractors at the conclusion of entry operations regarding the permit the confined space program that was followed and regarding any hazards confronted or created in confined spaces during entry operations. Where the debriefing indicates a need to change program requirements, owners/operators and contractors should revise confined space programs accordingly. Statement of Problem and Substantiation for Public Comment appears to be an error in referencing a "Permit" program as that is another subject not always just confined space entry Related Item First Revision No. 10-NFPA 350-2014 [Chapter 11] Submitter Information Verification Submitter Full Name: EMERY THOMAS Organization: CONOCOPHILLIPS Street Address: City: State: Zip: Submittal Date: Fri Nov 14 18:35:34 EST 2014 12/12/2014 2:22 PM National Fire Protection Association Report 260 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 162-NFPA 350-2014 [ Section No. 11.8.2.3 ] 11.8.2.3 Contractorsand Contractors and owners/operators should review the applicable confined space program and determine what is needed to conduct entry and work operations in compliance with program requirements. The confined space program applicable to the operations may be that of the owner/operator,the contractor, or both. Statement of Problem and Substantiation for Public Comment editorial, need to specify what program Related Item Public Input No. 444-NFPA 350-2013 [Section No. 11.9.2.3] Submitter Information Verification Submitter Full Name: Richard Kraus Organization: API/Petroleum Safety Consultan Street Address: City: State: Zip: Submittal Date: Wed Sep 24 15:31:19 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 261 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 163-NFPA 350-2014 [ Section No. 11.8.2.4 ] 11.8.2.4 If contractorsdo contractors do not agree to use the owner/operator’s confined space program, they should develop and implement their own confined space program in accordance with regulatory requirements, industry standards, applicable safe work practices and procedures, and Chapter 12 of this guide. The contractor’s confined space program should not conflict with and may be used to supplement the owner/operator’s confined space program. Statement of Problem and Substantiation for Public Comment editorial Related Item Public Input No. 445-NFPA 350-2013 [Section No. 11.9.2.4] Submitter Information Verification Submitter Full Name: Richard Kraus Organization: API/Petroleum Safety Consultan Street Address: City: State: Zip: Submittal Date: Wed Sep 24 15:34:03 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 262 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 164-NFPA 350-2014 [ Section No. 11.8.2.14 ] 11.8.2.14 If rescue service is provided by the contractors/subcontractors, contractorsshould contractors should identify, evaluate, and qualify assignedrescuers assigned rescuers or rescue and emergency services and develop and implement procedures for summoning rescuers and emergency services. Statement of Problem and Substantiation for Public Comment editorial Related Item Public Input No. 455-NFPA 350-2013 [Section No. 11.9.2.14] Submitter Information Verification Submitter Full Name: Richard Kraus Organization: API/Petroleum Safety Consultan Street Address: City: State: Zip: Submittal Date: Wed Sep 24 15:38:58 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 263 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 165-NFPA 350-2014 [ Section No. 11.9.2.4 ] 11.9.2.4 Ventilation specialists should ensure that if the exhausted atmospheremight atmosphere might be combustible or flammable, ignition sources in and around confined spaces be spaceshave been eliminated or controlled prior to ventilation. Statement of Problem and Substantiation for Public Comment editorial Related Item Public Input No. 477-NFPA 350-2013 [Section No. 11.10.2.4] Submitter Information Verification Submitter Full Name: Richard Kraus Organization: API/Petroleum Safety Consultan Street Address: City: State: Zip: Submittal Date: Wed Sep 24 15:42:25 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 264 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 70-NFPA 350-2014 [ Section No. 11.9.2.6 ] 11.9.2.6 Ventilation specialists should never use pure oxygen or oxygen above normal atmospheric levels to ventilate a confined space for a number of reasons, including but not limited to the following: (1) Oxygen above normal levels will negatively affect the readings on gas detection instruments. (2) Oxygen above normal levels will increase the flammable range of combustible and flammable gases, dusts, and vapors, creating a fire or explosion hazard. (3) Oxygen above normal levels is not safe for entrants to breathe. Statement of Problem and Substantiation for Public Comment This does not seem like a qualification and it goes into to much detail, this falls under the gas tester. If it is left in this section it should be shortened to: The ventilation specialist must understand the effects of high oxygen levels and ventilate properly. Related Item Public Input No. 350-NFPA 350-2013 [Section No. 11.4.4.1] Submitter Information Verification Submitter Full Name: Donald Raffo Organization: General Dynamics, Electric Boa Street Address: City: State: Zip: Submittal Date: Fri Sep 12 05:37:34 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 265 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 387-NFPA 350-2014 [ Section No. 11.9.2.10 ] 11.9.2.10 Ventilation specialists should not direct ventilation flows toward occupied areas, as well as toward areas that might compromise air quality in occupied spaces. Statement of Problem and Substantiation for Public Comment Significant correction "not" is very critical here for good job planning Related Item First Revision No. 10-NFPA 350-2014 [Chapter 11] Submitter Information Verification Submitter Full Name: EMERY THOMAS Organization: CONOCOPHILLIPS Street Address: City: State: Zip: Submittal Date: Fri Nov 14 18:39:08 EST 2014 12/12/2014 2:22 PM National Fire Protection Association Report 266 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 166-NFPA 350-2014 [ Section No. 11.10.1 ] 11.10.1 * General. Isolation is the process of removing a confined space from service and completely protecting the space from the unwanted release of energy, liquids, gases, chemicals, and other materials into the space through fixed or temporary connections to the space, as well as disconnecting and de-energizing potentially hazardous machinery and equipment within or attached to the space. Isolation may be permanent or temporary. Isolation operations should be performed by isolation specialists, who should be trained, educated, or qualified and competent to perform required isolation duties. Isolation specialists should be assigned and authorized by the owner/operator or contractors, as appropriate, in accordance with the requirements of the applicable permits, isolation, or the lockout/tagout program and the confined space program. At the conclusion of confined space operations, isolation specialists may also be required by the owner/operator or contractor to de-isolate the space in preparation for return to service . . Statement of Problem and Substantiation for Public Comment need to tell why specialist is required at the end Related Item Public Input No. 495-NFPA 350-2013 [Section No. 11.11.1] Submitter Information Verification Submitter Full Name: Richard Kraus Organization: API/Petroleum Safety Consultan Street Address: City: State: Zip: Submittal Date: Wed Sep 24 15:47:10 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 267 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 71-NFPA 350-2014 [ Section No. 11.10.3.1 ] 11.10.3.1 Isolation specialists should understand and comply with the requirements of confined space, isolation (lockout/tagout) and permitprograms permit programs , industry procedures and practices, and governmental regulations that pertain to isolation. Statement of Problem and Substantiation for Public Comment Corrected typo Related Item Public Input No. 350-NFPA 350-2013 [Section No. 11.4.4.1] Submitter Information Verification Submitter Full Name: Donald Raffo Organization: General Dynamics, Electric Boa Street Address: City: State: Zip: Submittal Date: Fri Sep 12 05:42:56 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 268 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 388-NFPA 350-2014 [ Section No. 11.12.1.2.6 ] 11.12.1.2.6 All confined space personnel should be retrained, educated,or qualified when regulatory requirements change or the confined space program is revised . Statement of Problem and Substantiation for Public Comment Recommend adding when confined space entry program changes not just regulatory changes. Related Item First Revision No. 10-NFPA 350-2014 [Chapter 11] Submitter Information Verification Submitter Full Name: EMERY THOMAS Organization: CONOCOPHILLIPS Street Address: City: State: Zip: Submittal Date: Fri Nov 14 18:57:21 EST 2014 12/12/2014 2:22 PM National Fire Protection Association Report 269 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 390-NFPA 350-2014 [ Section No. 11.12.2 ] 11.12.2 Rescue Training. The AHJ should The rescue provider organization should provide for training in the responsibilities that are commensurate with the needs of the organization. Statement of Problem and Substantiation for Public Comment Insert revised text Related Item First Revision No. 10-NFPA 350-2014 [Chapter 11] Submitter Information Verification Submitter Full Name: EMERY THOMAS Organization: CONOCOPHILLIPS Street Address: City: State: Zip: Submittal Date: Fri Nov 14 19:03:13 EST 2014 12/12/2014 2:22 PM National Fire Protection Association Report 270 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 72-NFPA 350-2014 [ Section No. 11.12.2 ] 11.12.2 Rescue Training. The AHJ should provide for training in the responsibilities that are commensurate with the needs of the organization. Statement of Problem and Substantiation for Public Comment AJH should be spelled out. Related Item Public Input No. 350-NFPA 350-2013 [Section No. 11.4.4.1] Submitter Information Verification Submitter Full Name: Donald Raffo Organization: General Dynamics, Electric Boa Street Address: City: State: Zip: Submittal Date: Fri Sep 12 05:45:41 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 271 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 167-NFPA 350-2014 [ Section No. 11.12.5 ] 11.12.5 Documentation of Training. The rescue service supervisor (or the owner/operator if or contractor, if responsible for rescue) should be responsible for the documentation of all required rescuer training, education, and qualification. The documentation should be maintained and available for inspection by individual team members or their authorized representatives, governmental agencies, and the owner/operator who has arranged for the rescue service. Statement of Problem and Substantiation for Public Comment contractor may have this responsibiulity Related Item Public Input No. 530-NFPA 350-2013 [Section No. 11.13.5] Submitter Information Verification Submitter Full Name: Richard Kraus Organization: API/Petroleum Safety Consultan Street Address: City: State: Zip: Submittal Date: Wed Sep 24 15:53:38 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 272 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 168-NFPA 350-2014 [ Section No. 11.12.6 ] 11.12.6 Fitness. The rescue service supervisor (or the owner/operator if or contractor, if responsible for rescue) should ensure that rescuers are psychologically, physically, and medically capable and qualified to perform assigned duties and functions for the specific confined space operations, including search and rescue and,as required, training exercises in accordance with Chapter 10 of NFPA 1500. Statement of Problem and Substantiation for Public Comment contractor may have responsibility Related Item Public Input No. 531-NFPA 350-2013 [Section No. 11.13.6] Submitter Information Verification Submitter Full Name: Richard Kraus Organization: API/Petroleum Safety Consultan Street Address: City: State: Zip: Submittal Date: Wed Sep 24 15:55:15 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 273 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 169-NFPA 350-2014 [ Section No. 11.12.7.1 ] 11.12.7.1 Rescuers should be provided with and trained, educated, or qualified to properlyuse properly use PPE and rescue equipment necessary for rescues from inside and around confined spaces according to their designated level of competency. Statement of Problem and Substantiation for Public Comment editorial Related Item Public Input No. 533-NFPA 350-2013 [Section No. 11.13.7.1] Submitter Information Verification Submitter Full Name: Richard Kraus Organization: API/Petroleum Safety Consultan Street Address: City: State: Zip: Submittal Date: Wed Sep 24 15:56:44 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 274 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 238-NFPA 350-2014 [ Section No. 11.12.7.5 ] 11.12.7.5 Rescuers should be certified to the level of first responder or equivalent according to U.S. Department of Transportation (DOT) First Responder Guidelines. Statement of Problem and Substantiation for Public Comment delete and renumber. DOT has NOTHING to do with confined space entry. DOT does do not even regulate entry for TTs and TCs. Also would eliminate use of many municipal responders especially for small businesses. Related Item Public Input No. 1166-NFPA 350-2014 [Section No. 11.13.7.6] Submitter Information Verification Submitter Full Name: Richard Kraus Organization: API/Petroleum Safety Consultan Street Address: City: State: Zip: Submittal Date: Sat Oct 25 15:39:54 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 275 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 170-NFPA 350-2014 [ Section No. 12.1.1 ] 12.1.1 General. Before confined space operations begin and workers enter the confined space for any reason, the owner/operator or entrant employer should develop and implement a written confined space program. The written program should be made availableto available to all employees and/or their representatives, and should include, but not be limited to, the following: (1) Program responsibilities (2) Identification of confinedspaces confined spaces (3) Identification of personnel involved in the confined space entry (4) Standard operatingprocedures operating procedures , such as atmospheric monitoring and ventilation (5) Entry permits (6) Other facilitysafetypermits facility safety permits and procedures (7) Rescue Emergency, communications and rescue procedures (8) Training (9) Resources (10) Program auditing (11) Medical qualifications (12) Regulatory and bestpractices (13) A written confined space policy where only qualified contractors will enter the confined space that explains the following: (a) How the owner/operator or employer determines contractors are qualified (b) How confinedspacehazards confined space hazards are communicated to contractors (c) How relevant facility safety information is communicated to contractors (d) How contractors aredebriefed are debriefed after entry is completed Statement of Problem and Substantiation for Public Comment adds provisions for communications and emergency procedures editorial corections Related Item Public Input No. 545-NFPA 350-2013 [Section No. 12.1] Submitter Information Verification Submitter Full Name: Richard Kraus Organization: API/Petroleum Safety Consultan Street Address: City: State: Zip: Submittal Date: Thu Sep 25 09:51:42 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 276 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 171-NFPA 350-2014 [ Section No. 12.2 [Excluding any Sub-Sections] ] There should be one person assigned as the program administrator for the company’s or facility’s confined space entry program. This person can be the owner/operator, employer, or other individual assigned by the owner/operator or employer. This individual should be identified in the written confined space program. The program should also establish the roles and responsibilities of all individual positions involved in confined space entries. As a minimum, the name of the program administrator should be listed along with a list of authorized entrants, attendants, and entrysupervisors entry supervisors in a separate document, which should be reviewed and updated as needed. Roles such as gastester gas tester , ventilationspecialist ventilation specialist , isolationspecialist isolation specialist , standby person, hot/cold work, etc., should also be identified in the program and assigned to a program administrator . Other individuals, if needed, can be assigned to the attendant or entrysupervisor by the entry supervisor . Chapter 11 provides a list of roles and required training. Statement of Problem and Substantiation for Public Comment a lot of the last 2 sentences did not make any sense so they have been corrected. also editorial changes Related Item Public Input No. 547-NFPA 350-2013 [Section No. 12.2 [Excluding any Sub-Sections]] Submitter Information Verification Submitter Full Name: Richard Kraus Organization: API/Petroleum Safety Consultan Street Address: City: State: Zip: Submittal Date: Thu Sep 25 09:58:26 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 277 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 73-NFPA 350-2014 [ Section No. 12.2 [Excluding any Sub-Sections] ] There should be one person assigned as the program administrator for the company’s or facility’s confined space entry program. This person can be the owner/operator, employer, or other individual assigned by the owner/operator or employer. This individual should be identified in the written confined space program. The program should also establish the roles and responsibilities of all individual positions involved in confined space entries. As a minimum, the name of the program administrator should be listed along with a list of authorized entrants, attendants, and entrysupervisors entry supervisors in a separate document, which should be reviewed and updated as needed. Roles such as gastester gas tester , ventilationspecialist ventilation specialist , isolationspecialist isolation specialist , standby person, hot/cold work, etc., should be identified in the program and assigned to a program administrator. Other individuals, if needed,can be assigned to the attendant or entrysupervisor entry supervisor . Chapter 11 provides a list of roles and required training. Statement of Problem and Substantiation for Public Comment Corrected typos Related Item Public Input No. 350-NFPA 350-2013 [Section No. 11.4.4.1] Submitter Information Verification Submitter Full Name: Donald Raffo Organization: General Dynamics, Electric Boa Street Address: City: State: Zip: Submittal Date: Fri Sep 12 05:47:16 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 278 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 239-NFPA 350-2014 [ Section No. 12.2.2 ] 12.2.2 Employee Involvement. Employers shouldensure that Where required by regulations or by their employer, employees who supervise or perform confined space operations , and/ ( or their authorized representatives, are ) may be provided an opportunity to be involved in the development and implementation of the written their employer's written confined space program. Statement of Problem and Substantiation for Public Comment This is not necessarily required as for example, a contractors employees are not involved in developing an owner's program. Owner employees are not involved in contractor program development and implementation. At very most employees may be involved in their own employer's program development not someone else. Related Item Public Input No. 549-NFPA 350-2013 [Section No. 12.2.2] Submitter Information Verification Submitter Full Name: Richard Kraus Organization: API/Petroleum Safety Consultan Street Address: City: State: Zip: Submittal Date: Sat Oct 25 15:44:50 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 279 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 240-NFPA 350-2014 [ Section No. 12.4 [Excluding any Sub-Sections] ] The written Where required by regulations or by the applicable confined space program, written confined space programs should be reviewed at least annually by the owner/operator or entrant employer and the workers involved in the confined space operations to determine if the program is effective in providing safe operations for confined space entries. This review may not be necessary if no entries have occurred during the year, if there have been no changes in reqguations and if no Management of Changes have occurred in equipment, materials or operations affecting designated confined spaces. Statement of Problem and Substantiation for Public Comment there is no need to review or change programs if there ahs been no activity or MOC changes Related Item Public Input No. 533-NFPA 350-2013 [Section No. 11.13.7.1] Submitter Information Verification Submitter Full Name: Richard Kraus Organization: API/Petroleum Safety Consultan Street Address: City: State: Zip: Submittal Date: Sat Oct 25 15:53:24 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 280 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 241-NFPA 350-2014 [ Section No. 12.4.1 ] 12.4.1 If a confined space–related near miss, accident, injury or equipment failure occurs, the confined space program should be audited reviewed and modified as if necessary to , modified to address any deficiencies before any additional entries are made , prior to permitting subsequent entries . Statement of Problem and Substantiation for Public Comment changed to clarify modification needed only if needed Related Item Public Input No. 554-NFPA 350-2013 [Section No. 12.4.1] Submitter Information Verification Submitter Full Name: Richard Kraus Organization: API/Petroleum Safety Consultan Street Address: City: State: Zip: Submittal Date: Sat Oct 25 15:59:37 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 281 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 242-NFPA 350-2014 [ Section No. 12.4.2 ] 12.4.2 The written confined space program should be approved, signed, and dated by senior management by appropriate management as designated in the program . Statement of Problem and Substantiation for Public Comment "senior" management is too broad .. in a large corporation it could refer to the CEO or Board of Directors. The change is more accurate as it refers to management designated in the program itself, which could be facility or area manager, or a VP of operations, or owner of small entity, etc. Related Item Public Input No. 555-NFPA 350-2013 [Section No. 12.4.2] Submitter Information Verification Submitter Full Name: Richard Kraus Organization: API/Petroleum Safety Consultan Street Address: City: State: Zip: Submittal Date: Sat Oct 25 16:03:58 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 282 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 172-NFPA 350-2014 [ Section No. 12.5 ] 12.5 * Identification of Confined Spaces. Owners/operators or entrant employers should conduct a hazard safety analysis audit of all confined spaces in accordance with Chapter 4. The recognized inherent and adjacent actual and potential hazards should be documented, including the most probable hazards that can be introduced based on work likely to be performed in the space(s). Statement of Problem and Substantiation for Public Comment qualifies employer, adds actual and potent ial hazards, editorial changes, Related Item Public Input No. 556-NFPA 350-2013 [Section No. 12.5] Submitter Information Verification Submitter Full Name: Richard Kraus Organization: API/Petroleum Safety Consultan Street Address: City: State: Zip: Submittal Date: Thu Sep 25 10:05:47 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 283 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 173-NFPA 350-2014 [ Section No. 12.6 ] 12.6 Program Procedures. The written confined space program should describe the procedures used to evaluate confined space hazards. Entry supervisors should use the criteria listed in Chapters 6 and 7 to identify and evaluate hazards, and the procedures listed in Chapters 7 and 8 to control or , mitigate or eliminate the hazards. Statement of Problem and Substantiation for Public Comment add mitigate reflect previous criteria Related Item Public Input No. 557-NFPA 350-2013 [Section No. 12.6] Submitter Information Verification Submitter Full Name: Richard Kraus Organization: API/Petroleum Safety Consultan Street Address: City: State: Zip: Submittal Date: Thu Sep 25 10:09:16 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 284 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 174-NFPA 350-2014 [ Section No. 12.7.1 ] 12.7.1 * The written confined space program should also specify atmospheric conditions that prohibit entry under normal conditions. The program should indicate that if acceptable atmospheric quality criteria are not met, or if a hazardous atmosphere develops during occupancy, all entrants must exit immediately. For example, entry should be allowed if any of the following conditions exists only when the or when proper protective measures delineated in this document, such as the use of PPE, are taken: (1) Oxygen is lower than 19.5 percent or higher than 22.0 percent. (2) Hydrogen sulfide is greater than 10 ppm. (3) LEL is greater than 10 percent. (4) Carbon monoxide is greater than 35 ppm. Statement of Problem and Substantiation for Public Comment provides for entry if listed conditions are not all fully met Related Item Public Input No. 561-NFPA 350-2013 [Section No. 12.7.1] Submitter Information Verification Submitter Full Name: Richard Kraus Organization: API/Petroleum Safety Consultan Street Address: City: State: Zip: Submittal Date: Thu Sep 25 10:11:54 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 285 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 74-NFPA 350-2014 [ Section No. 12.7.1 ] 12.7.1 * The written confined space program should also specify atmospheric conditions that prohibit entry under normal conditions. The program should indicate that if acceptable atmospheric quality criteria are not met, or if a hazardous atmosphere develops during occupancy, all entrants must exit immediately. For example, entry should be allowed if any of the following conditions exists only when the proper protective measures in this document are taken: (1) Oxygen is lower than 19.5 percent or higher than 22.0 percent. (2) Hydrogen sulfide is greater than 10 ppm. the accepted exposure limits (3) LEL is greater than 10 percent. (4) Carbon monoxide is greater than 35 ppm. accepted exposure limits Statement of Problem and Substantiation for Public Comment Prior to this you provided information on TLV's, PEL and other exposure limits, now you are limiting it to OSHA PEL's. The document should be consistent. Related Item Public Input No. 350-NFPA 350-2013 [Section No. 11.4.4.1] Submitter Information Verification Submitter Full Name: Donald Raffo Organization: General Dynamics, Electric Boa Street Address: City: State: Zip: Submittal Date: Fri Sep 12 05:50:09 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 286 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 175-NFPA 350-2014 [ Section No. 12.7.2 ] 12.7.2 The written confined space program should specify when and how atmospheric monitoring is conducted. For example, the program should specify if workers must wear or use monitoring devices during the entire entry, or if the attendant will be performing atmospheric monitoring, or both. Statement of Problem and Substantiation for Public Comment no need to wear monitors ... portable may be used Related Item Public Input No. 562-NFPA 350-2013 [Section No. 12.7.2] Submitter Information Verification Submitter Full Name: Richard Kraus Organization: API/Petroleum Safety Consultan Street Address: City: State: Zip: Submittal Date: Thu Sep 25 10:16:10 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 287 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 243-NFPA 350-2014 [ Section No. 12.8 [Excluding any Sub-Sections] ] The written confined space program should contain information about the use and maintenance of mechanical ventilation equipmentto be used for equipment for confined space entry , including where they are located and who is to be responsible for maintaining these systems. determining ventilation requirements. The work plan for a specific confined space entry should delineate the tyoe and size of ventilation equipment to be used, its placement and exhaust criteria.. Statement of Problem and Substantiation for Public Comment clarifies requirement in accordance with industry practices. Each entry/job is unique. the program cannot comprehend all of the possibilities involved in a specific ventilation..this has to be done at the job plan level Related Item Public Input No. 565-NFPA 350-2013 [Section No. 12.8 [Excluding any Sub-Sections]] Submitter Information Verification Submitter Full Name: Richard Kraus Organization: API/Petroleum Safety Consultan Street Address: City: State: Zip: Submittal Date: Sat Oct 25 16:08:40 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 288 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 176-NFPA 350-2014 [ Section No. 12.9 [Excluding any Sub-Sections] ] The written confined space program should state that all rescue services provisions should be identified prior to entry and during work site analysis in accordance with Chapter 10. The program should also make clear that the rescue service is responsible for all rescue or assigned rescuer is responsible for rescue operations. It should state that wherever possible, all confined where applicable (in accordance with Chapter 10) confined space entries should be done with entrants wearing a full-body harness attached to either a mechanical retrieval device or to a fixed object outside the space. Personal fall arrest may be necessary depending on the configuration of the confined space relative to entry operations. While self-rescue and non-entry rescue arealways are always a consideration they might not always be possible. Therefore, a comprehensive emergency rescue response should be developed. developed for each typical confined space configuration.. Statement of Problem and Substantiation for Public Comment rescue my be by a qualified attendant therefore rescue "services" is a poor word to use. Chap 10 does not require ALL entries to use harness, etc. There are entries on non-permit type spaces where this is not needed. changes to show where confined space planning is needed. editorial change Related Item Public Input No. 568-NFPA 350-2013 [Section No. 12.9 [Excluding any Sub-Sections]] Submitter Information Verification Submitter Full Name: Richard Kraus Organization: API/Petroleum Safety Consultan Street Address: City: State: Zip: Submittal Date: Thu Sep 25 10:21:01 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 289 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 177-NFPA 350-2014 [ Section No. 12.9.2 ] 12.9.2 The owner/operator or entrant employer should indicate the type of personal fall arrest equipment that will be used for entries involving descent from heights . Statement of Problem and Substantiation for Public Comment no need for this for horizontal entry Related Item Public Input No. 570-NFPA 350-2013 [Section No. 12.9.2] Submitter Information Verification Submitter Full Name: Richard Kraus Organization: API/Petroleum Safety Consultan Street Address: City: State: Zip: Submittal Date: Thu Sep 25 10:27:54 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 290 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 178-NFPA 350-2014 [ Section No. 12.11 ] 12.11 Energy Control Isolation Program (Lockout/Tagout). If there is an energy source (s) that can create a hazard in or around the confined space during entry operations, then the written confined space program should identify an isolation specialist to address these situations the situation . (See Chapter 8.) Additional information can be obtained by cross-referencing the employer’s energy control isolation program. Statement of Problem and Substantiation for Public Comment correct tenses. this is called "ISOLATION PROGRAM' in chapter 8. stick to same terminology throughout document Related Item Public Input No. 572-NFPA 350-2013 [Section No. 12.11] Submitter Information Verification Submitter Full Name: Richard Kraus Organization: API/Petroleum Safety Consultan Street Address: City: State: Zip: Submittal Date: Thu Sep 25 10:31:41 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 291 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 179-NFPA 350-2014 [ Section No. 12.16 ] 12.16 Contractors. The written confined space program shouldprovide a means for contractors should provide the method(s) by which contractors and subcontractors, where operating with within a controlling facility, to be informed of all hazards and potential hazards within and aroundall around all confined spaces where they are working . If a joint operation or entry (i.e., entrant employers’ entrant employees and owner/operator employees) isto is to be conducted, the applicable permits should detail operationsmanagementand operations management control and the person (s ie: entry supervisor ) responsible for the entry . Employers should ensure that the program details how contractors/subcontractors are debriefed afterconfined after confined space operations and entries, and how how the debriefing should be documented and who is responsible for the debriefing . The program should also indicate that if applicable procedures are not followed, the contractor/subcontractorcan subcontractor can be subject to discipline, including work stoppage and/or removal from the facility. Statement of Problem and Substantiation for Public Comment changed for clarity and specifity Related Item Public Input No. 580-NFPA 350-2013 [Section No. 12.16] Submitter Information Verification Submitter Full Name: Richard Kraus Organization: API/Petroleum Safety Consultan Street Address: City: State: Zip: Submittal Date: Thu Sep 25 10:36:25 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 292 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 75-NFPA 350-2014 [ Section No. 12.16 ] 12.16 Contractors. The written confined space program shouldprovide should provide a means for contractors and subcontractors, where operating with a controlling facility, to be informed of all hazards and potential hazards within and aroundall confined spaces. If a joint operation or entry(i.e., entrant employers’ employees and owner/operator employees) isto be conducted, the applicable permits should detail operationsmanagementand operations managementand the person(s) responsible.Employers should ensure that the program details how contractors/subcontractors are debriefed afterconfined after confined space operations and entries, and how the debriefing should be documented. The program should also indicate that if procedures are not followed, the contractor/subcontractorcan be subject to discipline, including work stoppage and/or removal from the facility. Statement of Problem and Substantiation for Public Comment Corrected typo Related Item Public Input No. 350-NFPA 350-2013 [Section No. 11.4.4.1] Submitter Information Verification Submitter Full Name: Donald Raffo Organization: General Dynamics, Electric Boa Street Address: City: State: Zip: Submittal Date: Fri Sep 12 05:53:48 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 293 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 244-NFPA 350-2014 [ Section No. 12.18 ] 12.18 * General Fitness for Duty Evaluation. Owner Where required by applicable regulations, owner /operators or entrant employers should ensure that the written confined space program includes evaluation procedures for the physical and mental capabilities of personnel assigned to work in confined space operations. The program should consider allactual and potential hazards and operations,and can reference industry and regulatory medical evaluation procedures, including, but not limited to, respiratory protection capability, toxic exposure determinations, and physiological and psychological stresses that might be present during confined space entries, such as climbing, ladders, heat stress, and claustrophia. Statement of Problem and Substantiation for Public Comment this is NOT mandatory or required in many localities and in fact, is not allowed in certain countries, It should only be considered where required by law. Related Item Public Input No. 596-NFPA 350-2013 [Section No. 12.18] Submitter Information Verification Submitter Full Name: Richard Kraus Organization: API/Petroleum Safety Consultan Street Address: City: State: Zip: Submittal Date: Sat Oct 25 16:20:10 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 294 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 82-NFPA 350-2014 [ Section No. 12.18 ] 12.18 * General Fitness for Duty Evaluation. Owner/operators or entrant employers should ensure that the written confined space program includes evaluation procedures for the physical and mental capabilities of personnel assigned to work in confined space operations. The program should consider allactual all actual and potential hazards and operations,and can reference industry and regulatory medical evaluation procedures, including, but not limited to, respiratory protection capability, toxic exposure determinations, and physiological and psychological stresses that might be present during confined space entries, such as climbing, ladders, heat stress, and claustrophia. Statement of Problem and Substantiation for Public Comment Corrected typo. Also mental evaluations are tricky and normally cannot be done by deck level individuals, not sure this part should be included. Related Item Public Input No. 350-NFPA 350-2013 [Section No. 11.4.4.1] Submitter Information Verification Submitter Full Name: Donald Raffo Organization: General Dynamics, Electric Boa Street Address: City: State: Zip: Submittal Date: Fri Sep 12 06:38:40 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 295 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 181-NFPA 350-2014 [ Section No. 13.1 [Excluding any Sub-Sections] ] The entry supervisor should perform a pre-entry evaluation immediately prior to all entries into a confined space. If hazards or potential hazards are identified that cannot be eliminated prior , mitgated or controlled prior to entry, then the entry supervisor should not issue a permit. Statement of Problem and Substantiation for Public Comment this documents provides for mitigation and control in addition to elimination Related Item First Revision No. 12-NFPA 350-2014 [Chapter 13] Submitter Information Verification Submitter Full Name: Richard Kraus Organization: API/Petroleum Safety Consultan Street Address: City: State: Zip: Submittal Date: Thu Sep 25 14:05:43 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 296 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 83-NFPA 350-2014 [ Section No. 13.1 [Excluding any Sub-Sections] ] The entry supervisor should perform a pre-entry evaluation immediately prior to all entries into a confined space. If hazards or potential hazards are identified that cannot be eliminated be controlled prior to entry, then the entry supervisor should not issue a permit. Statement of Problem and Substantiation for Public Comment Not all hazards can be eliminated, but may be controlled to allow entry. Related Item Public Input No. 350-NFPA 350-2013 [Section No. 11.4.4.1] Submitter Information Verification Submitter Full Name: Donald Raffo Organization: General Dynamics, Electric Boa Street Address: City: State: Zip: Submittal Date: Fri Sep 12 06:40:03 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 297 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 182-NFPA 350-2014 [ Section No. 13.1.1 ] 13.1.1 The permit (or pre-entry evaluation or permit ) should be displayed at the confined space location. Permits should be marked as cancelled after work the time allowed on the permit has expired, the work is completed or a change in conditions requires a new permit. Statement of Problem and Substantiation for Public Comment permits are time sensitive Related Item Public Input No. 581-NFPA 350-2013 [Section No. 13.1.1] Submitter Information Verification Submitter Full Name: Richard Kraus Organization: API/Petroleum Safety Consultan Street Address: City: State: Zip: Submittal Date: Thu Sep 25 14:08:22 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 298 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 391-NFPA 350-2014 [ Section No. 13.1.3 ] 13.1.3 Permits should be limited to one shift. If work activity exceeds one shift the permit should be reissued or revalidated . In addition, permits should be considered cancelled if personnel change. Statement of Problem and Substantiation for Public Comment Recommend adding to …permit should be reissued… add or revalidated Related Item First Revision No. 12-NFPA 350-2014 [Chapter 13] Submitter Information Verification Submitter Full Name: EMERY THOMAS Organization: CONOCOPHILLIPS Street Address: City: State: Zip: Submittal Date: Fri Nov 14 19:10:19 EST 2014 12/12/2014 2:22 PM National Fire Protection Association Report 299 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 85-NFPA 350-2014 [ Section No. 13.2 ] 13.2 Pre-Entry Evaluation and Permit Elements. A pre-entry evaluation and permit should be developed or adopted to meet the needs of the work activities of the owner/operator or employer. The evaluation and permit The permit can be a single form or two separate forms. Subsections 13.2.1 through 13.2.11 detail elements of each form, how they should be used, and why they are important. Each element can be modified to meet job task requirements and/or the responsible party’s program management requirements. Each element of the permit has an in-depth section that the owner/operator, entrant employer, entrysupervisor, attendant, and entrant should be familiar with and addressed as required under the training program . At a minimum, the elements listed in 13.2.1 through 13.2.11 should be addressed on the owner’s/operator’s or employer’s pre-entry evaluation/permit. An example of a combination pre-entry evaluation/permit is provided in Figure B.X. 13.2.1 Confined Space Identification. The confined space should be clearly identified on the permit and include the following: . (1) Location. The location of the confined space should be as precise as possibleand possible and may include, if necessary, the address of the location, street or crossroads near the site, building location and/or number, room or space number, and global positioning system (GPS) coordinates. If there is a space similar to the one on the permit, additional information should be added to the permit to ensure the correct space is identified by all personnel. (2) Description.A detailed description of the space can assist personnel in correctly identifying the confined space. For example, a description might include the type of space (e.g., tank, silo, vault), its function (e.g., fuel oil waste, grain hopper), and/or its physical attributes (type of material, color, size, shape, etc.). 13.2.2 Work Activities. The work activities to be performed in the confined space should be clearly identified on the permit and include the following: (1) Time. The permit should indicate thedate the date (s) and time(s) the permit is valid . Permits are void once the permit date(s)/time(s) have expired along with an expiration date and time . (2) Work. The permit should outline the specific work to be conducted in the space. If there is a change in the scope of work or its location, a new permit might need to be issued. Work not identified on the permit should not be done without the approval of the entry supervisor and might require a new permit. 13.2.3 Pre-Entry Evaluation. All confinedspaces should have a pre-entry evaluation. The intent of this evaluation is to make sure the confined space is examined before any work activity begins toconfirm to confirm hazardous conditions do not inherently exist or will not be introduced to, or are not adjacent to, the confined space. Evaluation The entry supervisor or a qualified person trained in confined space work and the hazards should sign off on the evaluation. If no hazardous conditions exist, work can proceed. If any hazards do exist, the entrysupervisorshould entry supervisor should complete the permit appropriately to ensure safe entry. 13.2.4 Hazard Identification. The entry supervisor should identify all actual and potential hazards on the permit and indicate methods to eliminate, control, or mitigate the hazards to reduce risk to an acceptable level.The entry supervisor should ensure personnel areinformed aboutall hazards in and around the space, including inherent hazards, introduced hazards, and adjacent hazards. 12/12/2014 2:22 PM National Fire Protection Association Report 300 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... 13.2.4.1 Inherent Hazards. Inherent hazards include, but are not limited to, the design, structure, configuration, size, and physical condition of the space, as well as any equipment within the space. (See Chapter 6.) It might not be possible to eliminate or controlthese hazards, but measures can be taken to assess their risks and take precautions. For example, where a steep ladder is needed to enter a fuel tank. The ladder’s configuration is not changeable, but the way in which supplies are brought into the space can be altered. The worker does not have to carrysupplies down the ladder; instead, they can be lowered down. 13.2.4.2 Introduced Hazards. Introduced hazards are typically brought into the space by workers or because of the work process. The introduction of materials, personnel, and work processes should be evaluated carefully to ensure that they do not create a hazardous condition. These are hazards that can be controlled or eliminated, making them a key element in a risk assessment. An example of an introduced hazard is the materials brought into a space to clean, such as solvents used to clean a tank, which can create a hazardous levelatmosphere.The condition of the space can be altered by the work process,for example, where workers disturb settled materials, such as fish processing or other biological waste. The disruption of the materials can allow trapped levels of hydrogen sulfide gas to be released, which can create a hazardous atmosphere. 13.2.4.3 Adjacent Hazards. Adjacent hazards are not in the confined space but are in close proximityand can impact operations in the space by entering through openings or other means. Examples of adjacent hazards include, but are not limited to, toxic smoke from a nearby fire or hot work, flammable vapors from a spill or release outside the space, and introduction of a hazard through a common wall with an adjacent space where work is in progress. Entry supervisors should recognize that adjacent hazards exist, or can potentially exist, should recognize and inspect the surrounding area, and should provide safeguards to eliminate, control, or mitigate all adjacent hazards. 13.2.4.4 Hazard Control. The entry supervisor should identify all hazards and provide should provide requirements to eliminate, control, or mitigate them mitigate hazards on the permit. (See Chapter 8.) Where hazards are inherent, they should be recognized and measures should be developed to reduce worker risk. Controls should be clearly outlined on the permit, and include such measures as outlined in 13.2.4.4.1 through 13.2.4.4.5. 13.2.4.4.1 Atmospheric Monitoring. The entry supervisor should understand and include atmospheric monitoring requirements on the permits for applicable hazardous conditions,whichinclude, but are not limited to, oxygen deficient, oxygen enriched, flammable or explosive, toxic, irritant/corrosive, or asphyxiating atmospheres. Atmospheric monitoring might be required intermittently or continuously. The frequency of monitoring depends on the work being performed and other potential introduced or adjacent hazards that could alter the atmospheric conditions in and around the confined space Atmospheric monitoring requirements should be listed on the permit . The permit should detail what atmospheric monitoring should be done, by whom, and at what levels personnel should exit the space. 13.2.4.4.2 Atmospheric Ventilation. The entry supervisor should understand ventilation Ventilation methods and requirements . The entry supervisor should verify that ventilating a confined space with fresh air before and during confined space work can reduce or remove atmospheric contaminants. Ventilation, especially during warmer months, can also provide relief from thermal stress. The permit should outline what ventilation should be used prior to and during entry. If ventilation will block access into or out of the space, the permit should outline procedures to ensure worker safety during operations be listed on the permit . 13.2.4.4.3 Personal Protective Equipment (PPE). The permit should address entrant and attendant PPE requirements. Also, if workers need to carry escape devices or additional PPE for specific work, such as cleaning or painting, that equipment carry additional PPE it should also be addressed. 13.2.4.4.4 Other Permits. All additional permits needed for the confined space should be listed on the entry permit (e.g., hotwork, line break, electrical work, etc.). 13.2.4.4.5 Grounding and Bonding. If the confined space or the ventilation or equipment brought into the space need to be grounded or bonded, then that information should be indicated on the permit as a control Any items required to be grounded should be listed on the permit . 12/12/2014 2:22 PM National Fire Protection Association Report 301 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... 13.2.5 Communications. The entry supervisor should select and indicate on the permit the appropriate methods of communication, and should document how communication will be maintained, as follows: such as (1) Verbal. Acceptable if line of sight is maintained (2) Radio. Permit to indicate test intervals (3) Rescue request. Permits indicate how rescueteam rescue team will be notified 13.2.6 Rescue. Confined spacerescue methodsshould be understood before entry into a confined space. Regardless of whether a confined space has hazards or not, the owner/operator or employer should ensure rescue is available and appropriate. All confined spaces should have a rescue incident action plan, which describes how rescue will be attempted. The incident action plan should be available to entry supervisors, attendants, and entrants. The incident action plan should be The rescue plan should be attached to the entry permit along with contact information .The emergency response team should be notified of all confined entries, including their location, hazards, and duration. The following are the four types of rescue: Self-rescue. Rescue before needing assistance.The entrant or attendant identifies a prohibited or dangerous condition and exits under their own power. Self-rescue is not a primary rescue method that can be utilized under a permit. External retrieval. The attendant activates a rescue system outside the confined space to remove or assist the entrant out. Rescue available. There is a rescue service that has been identified, evaluated, and able to respond in a timely manner should there be a need. Rescue stand-by. A rescue service is standing by the confined space, ready and equipped to make immediate entry. 13.2.7 Entrants. The following information should be clearly identified on the permit: Name should be printed on the entry permit. Entrant should sign the entry permit, indicating (1) Entrants name, indicating that they have been trained in confined space entry and have reviewed all the hazards associated with the permit-specific entry,including which condition changes would require their immediate evacuation. For multiple entrants, a sign-in sheet can be attached to the permit. 13.2.8 Attendant. The following information should be clearly identified on the permit: Name should be printed on the entry permit The attendantshould sign the entry permit, (1) Attendants name indicating that they have been trained in confined space entry and have reviewed all the hazards associated with the permit-specific entry. The attendant must be aware of all potential hazards in the confined space,including possible behavioral effects related to hazard exposure. An attendant must remain in constant contact with the entrant, until relieved by another attendant,maintain communication with the entrant, monitor activities, and order evacuations, where needed. The attendant also performs non-entry rescue or summons a rescue team, if necessary, andcannot perform any other duty that might interfere with the primary duty of ensuring the safety of the entrant. If the work or hazards change from what is stated on the permit, the attendant should re-evaluate the space and obtain a new permit. (1) 13.2.9 Entry Supervisor. The entry supervisor is responsible for all aspects of the entry and issuance of the entry permit. The entry supervisor should sign the permit, indicating that they have been trained in confined space entry and have reviewed all the hazards associated with the permit-specific entry. They must be aware of all potential hazards in each space and the standard operating procedures and equipment required for each entry. 12/12/2014 2:22 PM National Fire Protection Association Report 302 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... 13.2.10 Cancel Permit. Each permit should have an area on the permit to mark the permit as canceled. A permit can be canceled at the end of the work activity by the attendant or entrant, or at anytime by the attendant, entrant, supervisor, or safety professional because of hazards. The reason the permit was cancelled should be documented on the permit, for example, work was completed or conditions changed. 13.2.11 Rescue and Emergency Contact. The entry permit should indicate emergency rescue and contact information. Statement of Problem and Substantiation for Public Comment Section is to wordy, most items are detailed in other chapters. Items required on the permit should be listed and if help is needed the reader can refer to other chapters. The basic elememts on a permit should be listed here and not responsibilities as they are outlined elsewhere Related Item Public Input No. 350-NFPA 350-2013 [Section No. 11.4.4.1] Submitter Information Verification Submitter Full Name: Donald Raffo Organization: General Dynamics, Electric Boa Street Address: City: State: Zip: Submittal Date: Fri Sep 12 06:48:50 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 303 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 183-NFPA 350-2014 [ Section No. 13.2 [Excluding any Sub-Sections] ] A pre-entry evaluation and permit should be developed or adopted to meet the needs of the work activities of the owner/operator or entrant employer. The evaluation and permit can be a single form or two separate forms. Subsections 13.2.1 through 13.2.11 detail elements of each form, how they should be used, and why they are important. Each element can be modified to meet job task requirements and/or the responsible party’s confined space and other applicable program management requirements. Each element of the permit has an in-depth section that the owner/operator, entrant employer, entrysupervisor, attendant, and entrant should be familiar with and addressed, as required under the training program. At a minimum, the elements listed in 13.2.1 through 13.2.11 should be addressed on the owner’s/operator’s or entrant employer’s pre-entry evaluation/permit. An example of a combination pre-entry evaluation/permit is provided in Figure B.X. Statement of Problem and Substantiation for Public Comment specifies entrant employer. specifies types of programs Related Item Public Input No. 582-NFPA 350-2013 [Section No. 13.2 [Excluding any Sub-Sections]] Submitter Information Verification Submitter Full Name: Richard Kraus Organization: API/Petroleum Safety Consultan Street Address: City: State: Zip: Submittal Date: Thu Sep 25 14:15:19 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 304 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 184-NFPA 350-2014 [ Section No. 13.2.1 ] 13.2.1 Confined Space Identification. The confined space should be clearly identified on the permit and include the following: . (1) Location. The location of the confined space should be as precise as possibleand include, if necessary, the address of the location, street or crossroads near the site, building location and/or number, room or space number, assigned facility equipment or confined space identificaton number, and global positioning system (GPS) coordinates. If there is a space similar to the one on the permit, additional information should be added to the permit to ensure the correct space is identified by all personnel. (2) Description.A detailed description of the space can assist personnel in correctly identifying the confined space. For example, a description might include the type of space (e.g., tank, silo, vault), its function (e.g., fuel oil waste, grain hopper), and/or its physical attributes (type of material, color, size, shape, etc.). Statement of Problem and Substantiation for Public Comment adds equipment in addition to building Related Item Public Input No. 583-NFPA 350-2013 [Section No. 13.2.1] Submitter Information Verification Submitter Full Name: Richard Kraus Organization: API/Petroleum Safety Consultan Street Address: City: State: Zip: Submittal Date: Thu Sep 25 14:20:17 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 305 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 185-NFPA 350-2014 [ Section No. 13.2.2 ] 13.2.2 Work Activities. The work activities to be performed in the confined space should be clearly identified on the permit and include the following: (1) Time. The permit should indicate thedate the date (s) and time(s) the permit is valid. Permits are void once the permit date(s) / or time(s) have expired. (2) Work. The permit should outline the specific work to be conducted in the space. If there is a change in the scope of work or its location , a new permit might need to be that has the potential to create or introduce hazards not anticipated in the initial permit, a new permit should be issued. Work not identified on the permit should not be done without the approval of the entry supervisor and might should require a new permit if the potential exists for exposyre to hazards not anticipated in the original permit . Statement of Problem and Substantiation for Public Comment provides for issuance of new permits if potential new hazards are anticipated Related Item Public Input No. 584-NFPA 350-2013 [Section No. 13.2.2] Submitter Information Verification Submitter Full Name: Richard Kraus Organization: API/Petroleum Safety Consultan Street Address: City: State: Zip: Submittal Date: Thu Sep 25 14:24:29 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 306 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 392-NFPA 350-2014 [ Section No. 13.2.2 ] 13.2.2 Work Activities. The work activities to be performed in the confined space should be clearly identified on the permit and include the following: (1) Time. The permit should indicate thedate(s) and time(s) the permit is valid. Permits are void once the permit date(s)/time(s) have expired. (2) Work. The permit should outline the specific work to be conducted in the space. If there is a change in the scope of work or its location, a work should stop until it is evaluated if a new permit might need needs to be issued. Work not identified on the permit should not be done without the approval of the entry supervisor and might require a new permit. Statement of Problem and Substantiation for Public Comment Recommended changes for clarity and to reflect good practice Related Item First Revision No. 12-NFPA 350-2014 [Chapter 13] Submitter Information Verification Submitter Full Name: EMERY THOMAS Organization: CONOCOPHILLIPS Street Address: City: State: Zip: Submittal Date: Fri Nov 14 19:15:02 EST 2014 12/12/2014 2:22 PM National Fire Protection Association Report 307 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 84-NFPA 350-2014 [ Section No. 13.2.2 ] 13.2.2 Work Activities. The work activities to be performed in the confined space should be clearly identified on the permit and include the following: (1) Time. The permit should indicate thedate the date (s) and time(s) the permit is valid . Permits are void once the permit date(s)/time(s) have expired including an expiration date . (2) Work. The permit should outline the specific work to be conducted in the space. If there is a change in the scope of work or its location, a new permit might need to be issued. Work not identified on the permit should not be done without the approval of the entry supervisor and might require a new permit. Statement of Problem and Substantiation for Public Comment Edited for clarification Related Item Public Input No. 350-NFPA 350-2013 [Section No. 11.4.4.1] Submitter Information Verification Submitter Full Name: Donald Raffo Organization: General Dynamics, Electric Boa Street Address: City: State: Zip: Submittal Date: Fri Sep 12 06:43:22 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 308 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 186-NFPA 350-2014 [ Section No. 13.2.3 ] 13.2.3 Pre-Entry Evaluation. All confinedspaces confined spaces should have a pre-entry evaluation. The intent of this evaluation is to make sure the confined space is examined before any work activity begins toconfirm to confirm the both existing and potential hazardous conditions do not inherently exist or will not be introduced to, or are not adjacent to, within or adjacent to the confined space . Evaluation and that the potential for hazardous conditions to arise during confined space operations is considered. The entry supervisor or a qualified person trained in confined space work and the hazards existing and potential hazards should sign off on the evaluation. If no hazardous conditions exist, work can proceed. If any hazards do exist, the entrysupervisorshould entry supervisor should complete the permit appropriately to indicating the appropriate elimination, mitigation and control measures to be implemented to ensure safe entry. Statement of Problem and Substantiation for Public Comment editorial changes. adds consideration of potential hazards. Provides clarification that permit provides for elimination, mitigation or control methods Related Item Public Input No. 585-NFPA 350-2013 [Section No. 13.2.3] Submitter Information Verification Submitter Full Name: Richard Kraus Organization: API/Petroleum Safety Consultan Street Address: City: State: Zip: Submittal Date: Thu Sep 25 14:32:58 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 309 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 187-NFPA 350-2014 [ Section No. 13.2.4.4.5 ] 13.2.4.4.5 Grounding and Bonding. If the confined space or the ventilation or equipment brought into the space need to be grounded If any equipment used for confined space operations, including, but not limited to ventilation equipment; welding, grinding or cutting equipment; cleaning equipment; pumps; or compressors needs to be grounded and/ or bonded, then that information should be indicated on the permit as a control. Statement of Problem and Substantiation for Public Comment provide specific information on what needs to be bonded. Related Item Public Input No. 609-NFPA 350-2013 [Section No. 13.2.7.5] Submitter Information Verification Submitter Full Name: Richard Kraus Organization: API/Petroleum Safety Consultan Street Address: City: State: Zip: Submittal Date: Thu Sep 25 14:49:03 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 310 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 188-NFPA 350-2014 [ Section No. 13.2.6 ] 13.2.6 Rescue. Confined spacerescue methodsshould space rescue methods should be understood before entry into a confined space. Regardless of whether a confined space has hazards or not, the owner/operator or employer entrant employer should ensure rescue is available and appropriate to the space and operations . All confined spaces should have a rescue incident action plan , which describes how rescue will be attempted. The incident action plan should be available to entry supervisors, attendants, and entrants. The incident action plan should be attached to the entry permit. The Where an emergency response team is required by the incident rescue plan, the team should be notified of all applicable confined entries, including their location, hazards, and duration. The following are the four types of rescue: (1) Self-rescue. Rescue before needing anyone's assistance.The entrant The entrants ( or attendant) identifies a prohibited or dangerous condition and exits exit under their own power. Self-rescue is not a primary rescue method that can be utilized under and should not be included in a permit. (2) External retrieval Attendant Rescue . The attendant activates assists the entrant to vacate the space. The attendant may activate and use a rescue system ( outside the confined space to remove or assist the entrant out ) . (3) Rescue available (4) Av ailable . There is a rescue service that has been identified, evaluated, and able to respond in a timely manner should there be a need. (5) Rescue stand-by. A rescue service is standing by the confined space, ready and equipped to make immediate entry. Statement of Problem and Substantiation for Public Comment editorial changes. information added for clarification Related Item Public Input No. 611-NFPA 350-2013 [Section No. 13.2.9] Submitter Information Verification Submitter Full Name: Richard Kraus Organization: API/Petroleum Safety Consultan Street Address: City: State: Zip: Submittal Date: Thu Sep 25 14:57:53 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 311 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 189-NFPA 350-2014 [ Section No. 13.2.7 ] 13.2.7 Entrants. The following information should be clearly identified on the permit: (1) (2) Name Entrants names should be printed on the entry permit. Entrant Entrants should sign the entry permit, indicating that they have been trained in confined space entry and have reviewed all the hazards associated with the permit-specific entry,including which condition changes would require their immediate evacuation. For multiple entrants, a sign-in sheet can be attached to the permit. Statement of Problem and Substantiation for Public Comment indicates whose name is needed. editoirial Related Item Public Input No. 612-NFPA 350-2013 [Section No. 13.2.10] Submitter Information Verification Submitter Full Name: Richard Kraus Organization: API/Petroleum Safety Consultan Street Address: City: State: Zip: Submittal Date: Thu Sep 25 15:12:33 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 312 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 190-NFPA 350-2014 [ Section No. 13.2.8 ] 13.2.8 Attendant. The following information should be clearly identified on the permit: (1) (2) Name Attendant's name should be printed on the entry permit The attendantshould attendants should sign the entry permit, indicating that they have been trained in confined space entry and have reviewed all the hazards associated with the permit-specific entry. The attendant must be aware of all potential hazards in the confined space, including possible behavioral effects related to hazard exposure. An attendant must remain in constant contact with the entrant, until relieved by another attendant, maintain communication with the entrant, monitor activities, and order evacuations, where needed. The attendant also performs non-entry rescue or summons a rescue team, if necessary, andcannot and cannot perform any other duty that might interfere with the primary duty of ensuring the safety of the entrant. If the work or hazards change from what is stated on the permit, the attendant should order entrants to vacate, re-evaluate the space and obtain , and advise the entry supervisor in order to issue a new permit. Statement of Problem and Substantiation for Public Comment editorial and for clarification of duties Related Item Public Input No. 613-NFPA 350-2013 [Section No. 13.2.11] Submitter Information Verification Submitter Full Name: Richard Kraus Organization: API/Petroleum Safety Consultan Street Address: City: State: Zip: Submittal Date: Thu Sep 25 15:14:49 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 313 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 245-NFPA 350-2014 [ Section No. 14.4 ] 14.4 Contractor. Owners Contractors /operators or employers subcontractors should ensure contractor permits documenting air monitoring results and qualifications of their entrants are retained for at leastone year. least one year or longer, if required by applicable regulations or confined space programs. . Statement of Problem and Substantiation for Public Comment owners and not responsible for maintaining records for contractor employees. If owner issues permits, then owners will have a copy of the permit on file with this information Related Item Public Input No. 628-NFPA 350-2013 [Section No. 14.4] Submitter Information Verification Submitter Full Name: Richard Kraus Organization: API/Petroleum Safety Consultan Street Address: City: State: Zip: Submittal Date: Sat Oct 25 16:24:58 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 314 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 191-NFPA 350-2014 [ Section No. 15.1 ] 15.1 Purpose. The purpose of this chapter is to provide This chapter provides information for establishing a management of change (MOC) system for confined spaces. An MOC system identifies and evaluates potential impacts to confined space entrants and the necessary safety measures for changes other than the replacementin-kind type or modifications to the confined space space operations. Its purpose is to establish and implement procedures needed to provide for continuous safe operating conditions and work practices whenever changes or modifications, other than changes in kind, occur in confined space classification, configuration, equipment, materials, contents, and/or work tasks content, scope of work, operating procedures, processes and personnel as well as changes to owner/operator and contractor confined space and other applicable programs, industry practices and regulatory requirements. Owners/operators should conduct MOC reviews whenever permanent or temporary changes impact upon confined spaces in their facilities . Statement of Problem and Substantiation for Public Comment this more explicitly details the purpose of and requirements for MOC and clarifies that changes in kind are exempted Related Item Public Input No. 629-NFPA 350-2013 [Section No. 15.1] Submitter Information Verification Submitter Full Name: Richard Kraus Organization: API/Petroleum Safety Consultan Street Address: City: State: Zip: Submittal Date: Fri Sep 26 12:52:46 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 315 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 393-NFPA 350-2014 [ Section No. 15.1 ] 15.1 Purpose. The purpose of this chapter is to provide information for establishing a management of change (MOC) system for confined spaces. An MOC system identifies and evaluates potential impacts to confined space entrants and the necessary safety measures for changes other than the replacement-in-kind type or modifications to the confined space configuration, equipment, materials, contents, key personnel and/or work tasks. Statement of Problem and Substantiation for Public Comment MOC also needs to include critical or key personnel Related Item First Revision No. 14-NFPA 350-2014 [Chapter 15] Submitter Information Verification Submitter Full Name: EMERY THOMAS Organization: CONOCOPHILLIPS Street Address: City: State: Zip: Submittal Date: Fri Nov 14 19:19:59 EST 2014 12/12/2014 2:22 PM National Fire Protection Association Report 316 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 192-NFPA 350-2014 [ Section No. 15.2 ] 15.2 Responsibilities and Communication for Implementing MOC. For an MOC system to function effectively, confined space owners/operators or employers, entrants, attendants, supervisors, and rescuers and contractors/subcontractors and their employees should be able to recognize deviations and changes that are significant enough to trigger an MOC review. Once a deviation or change triggers an MOC review, facility owners/operators or employers assign qualified and contractors/subcontractors should assign qualified personnel and resources to determine what changes, if any, are needed in the their confined space program and hazard control measures. Owners and other applicable programs. Owners /operators and contractors/subcontractors should then implement make appropriate the changes in their programs and procedures to ensure confined space operations are conducted safely. Measures should then be implemented to eliminate, mitigate or control any new or different hazards arising from the identified changes. Statement of Problem and Substantiation for Public Comment rearranged for clarity in appropriate order of action . Term contractor/subcontractor used throughout, Related Item Public Input No. 630-NFPA 350-2013 [Section No. 15.2] Submitter Information Verification Submitter Full Name: Richard Kraus Organization: API/Petroleum Safety Consultan Street Address: City: State: Zip: Submittal Date: Fri Sep 26 13:06:12 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 317 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 193-NFPA 350-2014 [ Section No. 15.3 [Excluding any Sub-Sections] ] The MOC process should be developed, implemented, communicated, and documented by the owner/operator and contractor/subcontractor to ensure the changes and deviations affecting confined spaces are reviewed and authorized. The MOCprocess MOC process should ensure that changes to equipment, processes, personnel, procedures, or materials affecting confined spaces are properly reviewed against the original confined space hazard assessment data. The MOC process, if well implemented, A timely and correctly implemented MOC process can help prevent confined space accidents associated with changes or modifications to confined associated with confined space work operations . Statement of Problem and Substantiation for Public Comment tells "who" should do this. Replaces "well" which is nebulous. adds "are" editorial Related Item Public Input No. 631-NFPA 350-2013 [Section No. 15.3 [Excluding any Sub-Sections]] Submitter Information Verification Submitter Full Name: Richard Kraus Organization: API/Petroleum Safety Consultan Street Address: City: State: Zip: Submittal Date: Fri Sep 26 13:16:00 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 318 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 195-NFPA 350-2014 [ Section No. 15.3.1 ] 15.3. 1 2 Upon completion of the MOC review, the person(s) conducting the review should originate and submit an MOC form to the owner/operator or contractor/subcontractor for authorization prior to implementing any change affecting a confined space. An example management of change form is shown in Figure D.1. Statement of Problem and Substantiation for Public Comment 15.3.1 and 15.3.2 should be flip flopped to be chronologically correct Related Item Public Input No. 632-NFPA 350-2013 [Section No. 15.3.1] Submitter Information Verification Submitter Full Name: Richard Kraus Organization: API/Petroleum Safety Consultan Street Address: City: State: Zip: Submittal Date: Fri Sep 26 13:34:27 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 319 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 194-NFPA 350-2014 [ Section No. 15.3.2 ] 15.3. 2 1 Owners/operators and contractors/subcontractors should assign qualified persons familiar with the applicable equipment, processes, materials, and operations to review the MOC form. These qualified persons should identify potential MOC issues, develop preventive and protective measures, and propose changes to the confined space program, as well as other applicable programs, for approval and implementation by the owners/operators or contractors/subcontractors. Statement of Problem and Substantiation for Public Comment 15.3.1 and 15.3.2 should be flip flopped to be chronologically correct Related Item Public Input No. 633-NFPA 350-2013 [Section No. 15.3.2] Submitter Information Verification Submitter Full Name: Richard Kraus Organization: API/Petroleum Safety Consultan Street Address: City: State: Zip: Submittal Date: Fri Sep 26 13:21:44 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 320 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 196-NFPA 350-2014 [ Section No. 15.3.3 ] 15.3.3 After changes to the confined space program have been implemented but prior to entry into confined spaces , the MOC form should be reviewed and authorized by reviewed by the entry supervisor prior to authorizing entry into confined spaces . The entry supervisor should ensure all confined space program requirements and documentation have been fully addressed or updated and , and that any changeswere implemented and changes were consistent with the original or updated confined space classification and hazard assessment documentation prior to providing authorization for confined space entry. Statement of Problem and Substantiation for Public Comment rearranged for continuity and clarity Related Item Public Input No. 634-NFPA 350-2013 [Section No. 15.3.3] Submitter Information Verification Submitter Full Name: Richard Kraus Organization: API/Petroleum Safety Consultan Street Address: City: State: Zip: Submittal Date: Fri Sep 26 13:36:14 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 321 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 197-NFPA 350-2014 [ Section No. 15.4.1 ] 15.4.1 Equipment Changes Affecting Confined Space. Owners/operators and contractors/subcontractors should initiate an MOC process wherever the addition, modification , or removal of equipment might require new or revised hazard evaluations, processes, procedures, documentation, or training for the confined space work. Examples of changes to confined space equipment include, but are not limited to, the following: (1) Physical configuration of the space (e.g., external or internal dimensions of space, construction materials, physical condition) (2) Entry or internal access portals and paths, including the number, size, and configurations that can affect ingress/egress routes) (3) Internal equipment, (e.g., agitators, dampers, piping, obstructions, safety critical equipment, system parts, etc.) (4) Instrumentation and monitoring (e.g., monitors, electrical controls, program/control logic or set/alarm points, calibration, testing, process controls, etc.) (5) Electrical, hydraulic, pneumatic, or mechanical equipment, or change of electrical classification of equipment (6) Reclassification of the space so it is no longer a confined space Statement of Problem and Substantiation for Public Comment equipment change can create a new hazard Related Item Public Input No. 635-NFPA 350-2013 [Section No. 15.4.1] Submitter Information Verification Submitter Full Name: Richard Kraus Organization: API/Petroleum Safety Consultan Street Address: City: State: Zip: Submittal Date: Fri Sep 26 13:44:59 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 322 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 198-NFPA 350-2014 [ Section No. 15.5 ] 15.5 MOC Completion and Verification. Owners/operators and contractors/subcontractors should develop and implement an MOC verification process to confirm that the potential safety impacts and consequences from the proposed changes or deviations have been properly addressed. The MOC form should verify that all required MOC action items are complete; the confined space classification/hazard assessments have been updated; and the confined space program, entry procedure, and rescue plan have been revised accordingly; and the confined space is safe to enter . The entry supervisor should determine the requirements for safe entry, issue the necessary permits, and ensure compliance to commence confined space operations. An MOC completion and verification process should confirm, but not be limited to, the following items: (1) Construction and equipment in accordance with design specifications (2) Confined space safety, operating, maintenance, and emergency procedures are in place and are appropriate for the planned activity (3) An updated confined space classification and hazard assessment has been performed and recommendations have been implemented before startup (4) Requirements and authorizations in the MOC have been met (5) Retraining, re-education, or requalification of each affected employee in regard to the the changes has been completed and documented (6) Assurance that all requirements and authorizations in the MOC have been fulfilled and documented Statement of Problem and Substantiation for Public Comment the MOC has nothing to do whit whether the confines space is safe to enter or not. This is the purpose of a permit ... which assures compliance with the changes in the applicable programs that were required by the MOC process. Related Item Public Input No. 638-NFPA 350-2013 [Section No. 15.5] Submitter Information Verification Submitter Full Name: Richard Kraus Organization: API/Petroleum Safety Consultan Street Address: City: State: Zip: Submittal Date: Fri Sep 26 13:48:43 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 323 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 86-NFPA 350-2014 [ Section No. 15.5 ] 15.5 MOC Completion and Verification. Owners/operators and contractors/subcontractors should develop and implement an MOC verification process to confirm that the potential safety impacts and consequences from the proposed changes or deviations have been properly addressed. The MOC form should verify that all required MOC action items are complete; the confined space classification/hazard assessments have been updated; the confined space program, entry procedure, and rescue plan have been revised accordingly; and the confined space is safe to enter. The entry supervisor should determine the requirements for safe entry, issue the necessary permits, and ensure compliance to commence confined space operations. An An MOC completion and verification process should confirm, but not be limited to, the following items: (1) Construction and equipment in accordance with design specifications (2) Confined space safety, operating, maintenance, and emergency procedures are in place and are appropriate for the planned activity (3) An updated confined space classification and hazard assessment has been performed and recommendations have been implemented before startup (4) Requirements and authorizations in the MOC have been met (5) Retraining, re-education, or requalification of each affected employee in regard to the the changes has been completed and documented (6) Assurance that all requirements and authorizations in the MOC have been fulfilled and documented Statement of Problem and Substantiation for Public Comment This is not part of the MOC Related Item Public Input No. 350-NFPA 350-2013 [Section No. 11.4.4.1] Submitter Information Verification Submitter Full Name: Donald Raffo Organization: General Dynamics, Electric Boa Street Address: City: State: Zip: Submittal Date: Fri Sep 12 07:27:43 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 324 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 199-NFPA 350-2014 [ Section No. A.3.3.39 ] A.3.3.39 Job Hazard Analysis (JHA). For a JHA, the job is first broken into a sequence of steps. Each step should analyze some major task, which will consist of a series of movements. The analyst then looks at each series of movements within that basic task. Next, all the hazards or potential hazards associated with each step are identified. It is important that the entire environment be considered to determine every conceivable hazard that might exist. Finally, based on the basic job steps and the potential hazards, it can be determined what actions are necessary to eliminate, control, or minimize mitigate hazards that could lead to accidents, injuries, damage to the environment, or possible occupational illness. Each safe job procedure or action must should correspond to the job steps and identified hazards. Statement of Problem and Substantiation for Public Comment replaces "must" (mandatory) with "should". Replaces "minimize" with "mitigate" as used throughout the guide Related Item Public Input No. 746-NFPA 350-2013 [Section No. 3.3.15] Submitter Information Verification Submitter Full Name: Richard Kraus Organization: API/Petroleum Safety Consultan Street Address: City: State: Zip: Submittal Date: Sat Sep 27 15:51:22 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 325 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 200-NFPA 350-2014 [ Section No. A.3.3.70 ] A.3.3. 70 Span Calibration. 73 Supplier Air Respirator (SAR) SAR units for rescue must should maintain a separate egress cylinder capable of providing enough air for safe exit should the air hose or air supply malfunction. Statement of Problem and Substantiation for Public Comment corrects referenced section. replaces mandatory "must" with "should" Related Item First Revision No. 16-NFPA 350-2014 [Chapter 3] Submitter Information Verification Submitter Full Name: Richard Kraus Organization: API/Petroleum Safety Consultan Street Address: City: State: Zip: Submittal Date: Sat Sep 27 15:57:06 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 326 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 394-NFPA 350-2014 [ Section No. A.3.3.70 ] A.3.3. 70 Span Calibration. 73 Supplied Air Respirator (SAR) SAR units for rescue must maintain a separate egress cylinder capable of providing enough air for safe exit should the air hose or air supply malfunction. Statement of Problem and Substantiation for Public Comment Title and reference correction Related Item First Revision No. 16-NFPA 350-2014 [Chapter 3] Submitter Information Verification Submitter Full Name: EMERY THOMAS Organization: CONOCOPHILLIPS Street Address: City: State: Zip: Submittal Date: Fri Nov 14 19:23:23 EST 2014 12/12/2014 2:22 PM National Fire Protection Association Report 327 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 201-NFPA 350-2014 [ Section No. A.8.4.2.5 ] A.8.4.2.5 An example of an unseen and odorless harmful chemical would be a tank that contains, or hascontained has contained , leaded gasoline and that has not been cleaned and declared lead-vapor free must . The interior of the tank should be cleaned to the bare metal and the atmosphere then tested for lead-in-air hazards to ensure safe entry without air-supplied respiratory protection. Statement of Problem and Substantiation for Public Comment editorial. corrects complete sentence. adds requirements for air supplied so dust masks are not used Related Item Public Input No. 88-NFPA 350-2013 [Section No. 8.2.2.5] Submitter Information Verification Submitter Full Name: Richard Kraus Organization: API/Petroleum Safety Consultan Street Address: City: State: Zip: Submittal Date: Sat Sep 27 16:03:23 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 328 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 202-NFPA 350-2014 [ Section No. A.9.1.3 ] A.9.1.3 The entry supervisor and qualified ventilation specialist should understand the differences between ventilation, purging, and inerting. They should be able to select the appropriate hazard control method necessary for removing or controlling a hazardous atmosphere within the confined space. While the terms are frequently used interchangeably, they are distinct hazard control methods. Ventilation generally introduces fresh, uncontaminated air into a space and controls atmospheric contaminants in that the space through mixing and dilution. Purging uses air, steam, or inert gas to displace the air create a safe atmosphere in the space by dispersion, mixing, or dilution. Inerting is the use of an inert gas or flue gas to displace or expunge the atmosphere within the space. Purging typically uses water, fuel oil, steam, or nonreactive chemicals to physically displace the atmosphere within the space. (See Section 9.3 for guidance on appropriate methods of ventilation.) Statement of Problem and Substantiation for Public Comment corrects definition of purging Related Item Public Input No. 152-NFPA 350-2013 [Section No. 9.1.3] Submitter Information Verification Submitter Full Name: Richard Kraus Organization: API/Petroleum Safety Consultan Street Address: City: State: Zip: Submittal Date: Sat Sep 27 16:09:38 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 329 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 203-NFPA 350-2014 [ Section No. A.9.2.1.2 ] A.9.2.1.2 Where relying on natural ventilation as the sole means for implementing ventilation of a confined space it is important that continuous , continuous or periodic atmospheric monitoring is used should be used to confirm the conditions within the space remain safe for the duration of the entry operation. Statement of Problem and Substantiation for Public Comment 9.2.1.2 provides for periodic also. removes mandatory "is" with "should be" Related Item Public Input No. 153-NFPA 350-2013 [Section No. 9.2.1.2] Submitter Information Verification Submitter Full Name: Richard Kraus Organization: API/Petroleum Safety Consultan Street Address: City: State: Zip: Submittal Date: Sat Sep 27 16:13:52 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 330 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 204-NFPA 350-2014 [ Section No. A.9.3.4.1 ] A.9.3.4.1 For additional guidance on use of inert gases to gas-free spaces previously containing flammable liquids, see NFPA 306 or , NFPA 326 or API 2217A Inert Entry Standard . Statement of Problem and Substantiation for Public Comment adds definitive guide for inert entry into flammable and combustible spaces Related Item Public Input No. 984-NFPA 350-2013 [Section No. 9.3.4.1 [Excluding any Sub-Sections]] Submitter Information Verification Submitter Full Name: Richard Kraus Organization: API/Petroleum Safety Consultan Street Address: City: State: Zip: Submittal Date: Sat Sep 27 16:20:48 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 331 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 205-NFPA 350-2014 [ Section No. A.10.1.2.4(6) ] A.10.1.2.4(6) It is important that attendants be trained to recognize whether they should entrant attempt retrieval entrant retrieval . Employers shouldensurethat should ensure that attendants understand the implications of attempting retrieval in various situations. For example, say a significant fall takes place due to a interior collapse of scaffolding not related to the atmospheric hazard. If the entrant is complaining of numbness of the lower extremities, it is not prudent to extract the entrant with the retrieval system and possibly causingspinal causing spinal injury. The attendant should know how to assess each emergency quickly as to whether the hazards or entrant's condition necessitates or even permits rapid removal. Items to be considered by the attendant in making an assessment include, but are not limited to, the following: (1) What is the mechanism or cause of injury (atmospheric, mechanical, etc.)? (2) What is the entrant’s chief complaint? What is the injury or illness? (3) What is the entrant’s level of consciousness (talking coherently, disoriented, or nonresponsive)? (4) What are the current hazards (immediately life-threatening, low-hazard, or no hazards related to the emergency)? These and other questions can be used to perform a rapid risk-versus-benefit matrix to decide whether to attempt to retrieve an entrant from a confined space emergency where retrieval equipment is an option. If the conditions are immediately life threatening and the only choice is to activate the retrieval system or the patient is likely to die, then retrieval is the correct response. If the entrant’s condition and the hazards are not immediately life threatening or if the entrant’s condition could be worsened by retrieval, then entry rescue might be the appropriate option and the rescue service should be notified. Statement of Problem and Substantiation for Public Comment editorial. corrects language Related Item Public Input No. 236-NFPA 350-2013 [Section No. 10.1.2.4] Submitter Information Verification Submitter Full Name: Richard Kraus Organization: API/Petroleum Safety Consultan Street Address: City: State: Zip: Submittal Date: Sat Sep 27 16:31:29 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 332 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 206-NFPA 350-2014 [ Section No. A.10.1.3.4.1 ] A.10.1.3.4.1 Tier 1 response usually involvesrescues involves rescues from spaces not addressed by regulatory standards. While responses in such spaces might not require rescue capability of any sort, it should be recognized that medical emergencies occurring within these spaces can create difficult rescues. It is important that owner/operators and contractors conduct an assessment of each planned work activity to determine requirements for a rescue capability. If there is a need for potential rescue, the owner/operator or contractor should assess resources for a qualified rescue capability appropriate to the anticipated emergency. All rescue resources should be available and capable of responding in a timely manner. This should be addressed prior to making entry into spaces requiring Tier 1 response. Statement of Problem and Substantiation for Public Comment editorial.. adds contractors Related Item Public Input No. 242-NFPA 350-2013 [Section No. 10.1.3.4.1] Submitter Information Verification Submitter Full Name: Richard Kraus Organization: API/Petroleum Safety Consultan Street Address: City: State: Zip: Submittal Date: Sat Sep 27 16:35:43 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 333 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 228-NFPA 350-2014 [ Section No. A.10.1.3.4.3 ] A.10.1.3.4.3 With immediate life-threatening hazards, the speed of rescuer access to the entrant should be commensurate with the need for life-saving measures associated with cardiac arrest. It is generally considered that, without intervention, cessation of heart function in normal conditions will result in at least some irreversible brain death within 4 to 6 minutes. This is the reasoning behind the recommendations associated with Tier 3 response, especially where non-entry rescue (retrieval) is not possible. Pre-incident emergency action planning should always establish required response logistics. While Tier 3 response generally suggests a single dedicated rescue team for a single space, conditions may exist that allow a singlerescue team to address multiple entries in the same immediate area. The following should be considered when making this determination: (1) The walking transition time between the most remote two entry/egress points is 1 minute or less. (2) The team is able to divide its forces so that at least one rescuer is located at each entry/egress point with communications capability to allow immediate notification of other team members in the event of an emergency or, where there are multiple entry sites in close proximity, the rescuer is able to monitor a number of sites. (3) All rescue equipment needed to perform entry rescue is set up within a suitable distance at each entry/egress point or multiple points and every team member possesses the appropriate PPE to make immediate entry. For example , to provide for rescue of an entrant without rescuer vertical entry into a space, the entrant should be equipped with a full body harness connected to a suitable A-Frame lifting device. Rescuers descending into the space should be similarly equipped and connected. (4) In the event of an emergency at one entry/egress point, operations at the remaining entry/egress points should be terminated immediately so that the entrants exit the space and the rescue team member attending that entry/egress point can respond to the emergency at another point within 1 minute to begin or assist in rescue operations. This may not be possible with multiple simultaneous entries monitored by only one team since Tier 3 entries are associated with immediate life-threatening emergencies that require extremely rapid intervention. Statement of Problem and Substantiation for Public Comment In IDLH/inert atmospheres it is preferable that rescuers do not enter unless absolutely necessary. Rescue should be from outside the space. Related Item Public Input No. 707-NFPA 350-2013 [Section No. A.10.1.3.4.3] Submitter Information Verification Submitter Full Name: Richard Kraus Organization: API/Petroleum Safety Consultan Street Address: City: State: Zip: Submittal Date: Mon Oct 20 15:29:22 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 334 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 207-NFPA 350-2014 [ Section No. A.10.9.1 ] 12/12/2014 2:22 PM National Fire Protection Association Report 335 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... A.10.9.1 12/12/2014 2:22 PM National Fire Protection Association Report 336 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Confined space rescue teams should have enough qualified members to accomplish every function required to achieve the rescue objective.The size and capability of a team will depend on many factors, including, but not limited to; the condition of the entrant, the size and shape of the space, the size of the access opening, and the hazards present. The positions described in 10.9.1(1) through 10.9.1(5)suggest the minimum the number of roles that should be filled be considered to perform an entry-type rescue. Many rescues will rescues may require additional functions such as ventilation, rope rescue support, or communication that will may require additional trained resources. Pre-incident planning of representative spaces is a key element to determining the size and capabilities of the team rescue team . Table A.10.9.1 provides guidance for determining team size depending on the conditions of the space and anticipated rescue methods. Table A.10.9.1 Confined Space Rescue Team Staffing Decision Table IF THEN The confined space has no obstructions or entanglement hazards and One rescuer is needed to perform the entrant is properly attached to a retrieval system, a non-entryrescue. The confined space has obstructions or entanglement hazards, the entrant is notattached to a retrieval system, no potential atmospheric hazards exist,and vertical extraction isnot required, Three rescuers are needed to perform an emergency entry to effect rescue: 1 rescue attendant 2 rescue entrants The confined space has obstructions or entanglement hazards, the entrant is not attached to a retrieval system, no potential atmospheric hazards exist,and vertical extraction is required, Five rescuers are needed to perform an emergency entry to effect rescue: 1 rescue attendant 2 rescue system operators (with assistance from plant personnel) 2 rescue entrants The confined space has obstructions or entanglement hazards, the entrant is notattached to a retrieval system, potential atmospheric hazards exist, SARcannot be used (requiring SCBA ) and vertical extraction is not required, Five rescuers are needed to perform an emergency entry to effect rescue: 1 rescue attendant 2 person entry team 2 rescue entrants The confined space has obstructions or entanglement hazards, the entrant is not attached to a retrieval system, potential atmospheric hazards exist (requiring SAR ),and vertical extraction is not required, Six rescuers are needed to perform an emergency entry to effect rescue: 1 rescue attendant 2 rescue entrants 2 backup rescue entrants 1 air supply operator The confined space has obstructions or entanglement hazards, the entrant is not attached to a retrieval system, potential atmospheric hazards exist, SAR cannot be used (requiring SCBA ) and vertical extraction is required, Seven rescuers are needed to perform an emergency entry to effect rescue: 1 rescue attendant2 rescue system operators (with assistance from plant personnel) 2 rescue entrants2 backup rescue entrants The confined space has obstructions or entanglement hazards, the entrant is not attached to a retrieval system, potential atmospheric hazards exist (requiring SAR),and vertical extraction is required, Eight rescuers are needed to perform an emergency entry to effect rescue: 1 rescue attendant 2 rescue system operators (with 12/12/2014 2:22 PM National Fire Protection Association Report 337 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... IF THEN assistance from plant personnel) 2 rescue entrants 2 backup rescue entrants 1 air supply operator Four rescuers are needed to perform a pickoff rescue: An employee activates a fall arrest system and is suspended in a harness requiring rope rescue, 1 rescue attendant 2 rescue system operators (with assistance from plant personnel) 1 rescuer Statement of Problem and Substantiation for Public Comment see A10.9.1(1) As A10,9,1 is written (before changes) this would require a mandatory minimum number of rescuers per situation. The minimum is determined by the confined space program and rescue program in effect for the space and intended entry/work...not by a table. The table is just a guide as stated at the very end Related Item Public Input No. 288-NFPA 350-2013 [Section No. 10.9.1] Submitter Information Verification Submitter Full Name: Richard Kraus Organization: API/Petroleum Safety Consultan Street Address: City: State: Zip: Submittal Date: Sat Sep 27 16:44:30 EDT 2014 12/12/2014 2:22 PM National Fire Protection Association Report 338 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 395-NFPA 350-2014 [ Section No. A.11.1 ] A.11.1 Possible Crossover of Responsibilities for Persons involved in Confined Space Entry All personnel engaged in confined space–related activities may have responsibilities in addition to their primary assignment provided that they are trained, educated, or qualified in accordance with the requirements of Chapter 11. Table A.11.1 lists some, but not all, possibilities: Table A.11.1 Possible Crossover of Responsibilities for Persons involved in Confined Space Entry Title Possible Additional Responsibilities/Competencies Notes Entrant Gas tester, rescuer Attendant Entry supervisor, rescuer, gas tester, It is best practice fort he attendant to have ventilation specialist, isolation no other duties, however If performing specialist other duties that interfere with the primary attendant duties, assigned attendant should be relieved by another qualified attendant. Entry Supervisor Entrant, rescuer, gas tester, ventilation specialist, isolation specialist Designated entry supervisor may perform multiple tasks if qualified to do so, including, but not limited to, entering the space for inspection or atmospheric testing, checking isolation and de-isolation, approving ventilation, issuing permits, and assisting rescue. The entry supervisor should be qualified in multiple areas in order to ensure that each requirement of the permit continues to be met during entry operations. Rescuer Entrant, gas tester, isolation specialist, standby worker All rescuers (except those restricted to rescue from outside the space) should be qualified as entrants. Rescuers may also need to conduct atmospheric testing or check that isolation has not failed prior to entry. Rescuers assigned to be on site may perform other duties, if qualified, when not engaged in rescue operations. Gas tester Entrant, isolation specialist, attendant, standby worker Gas testers entering spaces should be qualified as entrants. Gas testers may perform other duties, if qualified, when not conducting atmospheric testing. Owner/operator, Entry supervisor, isolation specialist, contractor/subcontractor ventilation specialist, entrant, attendant, gas tester, standby worker, rescuer Entrants should know how to perform self-rescue. Owners/operators and contractors/subcontractors may perform any confined space activities for which they are qualified. Statement of Problem and Substantiation for Public Comment Need to stress this point again, so the appendix and main text match Related Item First Revision No. 10-NFPA 350-2014 [Chapter 11] Submitter Information Verification 12/12/2014 2:22 PM National Fire Protection Association Report 339 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Submitter Full Name: EMERY THOMAS Organization: CONOCOPHILLIPS Street Address: City: State: Zip: Submittal Date: Fri Nov 14 19:28:51 EST 2014 12/12/2014 2:22 PM National Fire Protection Association Report 340 of 340 http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... Public Comment No. 87-NFPA 350-2014 [ Chapter E ] Annex E Informational References (Just a general comment on the whole document. This document provides a good basis for entry into landside spaces and goes above and beyond the OSHA requirements. However, I believe it is too wordy and has many repetitive sections. During the review I suggest that the editors try to shorten the document and make it concise while maintaining basic information. In my opinion it should be written as a standard with checklists. In some sections it appears to be more of a novel. The definition section should be more developed so when you are reading the standard you can refer back to it. Also, in the section where the responsibilities are defined they should not be defined again later in the document. However, as a technical committee member I know how difficult this effort is and this is an outstanding first cut.) Statement of Problem and Substantiation for Public Comment Just a general comment on the whole document. This document provides a good basis for entry into landside spaces and goes above and beyond the OSHA requirements. However, I believe it is too wordy and has many repetitive sections. During the review I suggest that the editors try to shorten the document and make it concise while maintaining basic information. In my opinion it should be written as a standard with checklists. In some sections it appears to be more of a novel. The definition section should be more developed so when you are reading the standard you can refer back to it. Also, in the section where the responsibilities are defined they should not be defined again later in the document. However, as a technical committee member I know how difficult this effort is and this is an outstanding first cut. Related Item Public Input No. 350-NFPA 350-2013 [Section No. 11.4.4.1] Submitter Information Verification Submitter Full Name: Donald Raffo Organization: General Dynamics, Electric Boa Street Address: City: State: Zip: Submittal Date: Fri Sep 12 07:33:29 EDT 2014 12/12/2014 2:22 PM
