Administrative Policy 2-10 Confined Space Entry

DATE: January 24, 1994

SUBJECT: Confined Space Entry

PURPOSE: To protect employees against the hazards of entry into and work inside confined spaces.

BACKGROUND: This policy is in response to requirements for compliance with OSHA standards for Permit-RequiredConfined Spaces as it relates to public employeesin Oklahoma effective April 15, 1993.

DEFINITIONS: Confined Space: An area which 1) has adequatesize for entry, 2) has limited means of entry orexit, and 3) is not designed for continuous occupancy.

Engulfment: The surrounding and effective captureof a person by a liquid or finely divided (flowable) solid substance that can cause death bysuffocation or that can exert enough force on thebody to cause death by strangulation, constriction, or crushing.

Permit Space or Permit-Required Space: A confined space that 1) contains or has a potential tocontain a hazardous atmosphere, 2) contains amaterial that has the potential for engulfing anentrant, 3) has an internal configuration suchthat an entrant could be trapped or asphyxiated byinwardly converging walls or by a floor which slopes downward and tapers into a smaller cross-section, or 4) contains any other recognized serious safety or health hazard.

PROCEDURE: The head of each division within the City of Lawton shall perform an initial evaluation of all workplaces under their control for the purpose ofidentifying confined spaces which will require anentry permit. A report shall be submitted to the Safety and Risk Officer certifying that an evaluation has been performed and documenting the locations of any determined confined spaces and the hazards involved in entry of the confined space. Appendix A contains a checklist for determination of permit-required confined spaces.A copy of the report will be posted along withthis policy in a place readily available to employees who will be involved in confined space entry. Any subsequently determined spaces will bereported to the Safety and Risk Officer and posted.

Danger signs shall be posted where feasible, informing exposed employees of the existence and location of permit spaces and the danger of the spaces. Signs shall read "DANGER--PERMIT-REQUIRED CONFINED SPACE. DO NOT ENTER." Since it is not feasible to place such signs at all manholes, training and policies should emphasize that all manholes are considered permit-required confined spaces. If it is determined that employees will not enter permit spaces, supervisors will take the necessary means to ensure that employees do not enter permit spaces. If it is determined that employees will enter permit spaces, the following permit space entry procedures will be implemented.

1. Employees who are to have active roles in entry operations, including authorized entrants, attendants, entry supervisors, and persons who test or monitor the atmosphere in a permit space will be designated in writing by their division superintendent. The duties of each employee will be clearly identified and training provided as needed.

A. Duties of authorized entrants:

Supervisors will ensure that all authorized entrants 1) know the hazards that may be faced during entry, including information on the mode, signs or symptoms, and consequences of the exposure; 2) properly use equipment provided; 3) communicate with the attendant to monitor entrant status and alert entrants to evacuate when a situation warrants; 4) alert the attendant whenever any warning signs or symptoms of exposure to a dangerous situation are recognized or a prohibited condition is detected; 5) exit from the permit space as quickly as possible whenever an order to evacuate is given by the attendant or entry supervisor, any warning sign or symptom of exposure to a dangerous situation is recognized, a prohibited condition is detected, or an evacuation alarm is activated.

B. Duties of attendants;

Supervisors will ensure that each attendant 1) knows the hazards that may be faced during entry, including information on the mode, signs or symptoms, and consequences of the exposure; 2) is aware of possible behavioral effects of hazard exposure in authorized entrants; 3) continuously maintains an accurate count of authorized entrants in the permit space; 4) remains outside the permit space during entry operations until relieved by another attendant; 5) communicates with authorized entrants as necessary to monitor entrant status and to alert entrants of the need to evacuate; 6) monitors activities inside and outside the space to determine if it is safe for entrants to remain in the space and orders the authorized entrants to evacuate immediately under any of the following conditions:

a) If the attendant detects a prohibited condition;

b) If the attendant detects the behavioral effects of hazard exposure in an authorized entrant;

c) If the attendant detects a situation outside the space that could endanger the entrants;

d) If the attendant cannot effectively and safely perform all of the duties assigned;

7) summons rescue and other emergency services as soon as the attendant determines that entrants may need assistance to escape from permit space hazards; 8) warns unauthorized persons that they must stay away from permit space, advises unauthorized persons to exit immediately if they have entered permit space, and informs entrants and entry supervisor if unauthorized persons have entered permit space; 9) performs no duty that might interfere with the primary duty of monitoring and protecting entrants.

C. Duties of entry supervisors:

Each entry supervisor will 1) know the hazards that may be faced during entry, including information on the mode, signs or symptoms, and consequences of exposure; 2) verify, on a daily basis, by checking that the appropriate entries have been made on the permit, that all tests specified by the permit have been conducted and that all procedures and equipment specified by the permit are in place before endorsing the permit and allowing entry to begin; 3) terminate entry and cancel permit when the entry operations covered by the permit have been completed or a condition that is not allowed under the entry permit arises in or near the permit space; 4) verify, on a daily basis, that rescue services are available and that the means for summoning them are operable; 5) remove unauthorized persons who enter or who attempt to enter permit space during entry operations; and 6) determine that entry operations remain consistent with the terms of the entry permit and that acceptable entry conditions are maintained.

2. Each division will develop written programs or standard operating procedures specific to each type of confined space that their employees may be required to enter. These procedures must address the necessary measures to be taken to preventunauthorized entry of permit spaces, identify and evaluate the hazards that may be encountered in the confined space; specify acceptable entry conditions; details of how the permit space will be isolated; and entry conditions will be monitored where employees are working; how atmospheric hazards will be eliminated or controlled; what barriers will be provided to protect entrants from external hazards such as pedestrian or vehicular traffic; and how verification is to be made that conditions in the permit space are acceptable for entry. A copy of the written procedure for all identified permit spaces will be provided to the Safety and Risk Officer.

An entry permit will then be prepared by the division superintendent or responsible foreman,completely documenting the completion of measures required for entry into the confined space and signed by the entry supervisor before entry begins. The completed permit will be kept at the job site for the duration of the job. Entry permits will be kept on file for at least one year. Any problems encountered during an entry operation will be noted on the permit. Appendices A and B are examples of confined space pre-entry checklist; Appendix C is an example of an entry permit form. The forms used by individual divisions should be customized to meet their specific requirements.

3. Atmospheric testing for evaluation of hazards of permit space: Testing will be performed prior to each entry of confined space with appropriate direct reading atmospheric testing instruments, calibrated in compliance with manufacturers'instructions, only by an employee trained in such testing. The job foreman and entry supervisor will be responsible for insuring that this testing is completed. The atmosphere shall be tested quantitatively for the minimum acceptable levels as follows:

a) Oxygen level shall not be less than 19.5% by volume nor greater than 23.5% by volume;

b) Combustible gas concentration shall not exceed 10 to 20% of the LFL of any combustible material existing or introduced into the confined space;

c) Toxic substances in a concentration not to exceed toxic guidelines which constitute a threat of death, injury, acute illness, or disablement.

The test for oxygen concentration shall be made before tests for other contaminants are performed. Measurement should be made for at least the minimum response time of the test instrument specified by the manufacturer. If continuous ventilation or special breathing apparatus is not used, the space shall be tested as often asnecessary to insure acceptable air quality during the confined space work process. When 10% or more of the LFL of combustible gas is detected in any confined space, steps shall be taken to improve ventilation or reduce contaminants and increasefrequency of gas testing to insure improvement of the air quality. When 20% or more of the LFL of combustible gas is detected in any confined space work procedure all employees except those necessary to

eliminate the hazard shall exit to a safe location and all electrical apparatus except that certified as safe or explosion-proof shall be disabled or removed until the gas concentration has been reduced to less than 20% of the LFL. Hotwork shall not proceed in any confined space when atmospheric level of a combustible gas exceeds 10% of the LFL.

4. If it is determined that the only hazard of the permit space is an actual or potential hazardous atmosphere, continuous forced air ventilation may be used to alleviate the hazard and permit safe entry, no attendant is necessary. However,atmospheric testing must be performed before entry and periodically tested while work is being performed. Written certification will be made that the space is safe for entry by the foreman responsible for the work being performed.

5. The following equipment will be provided, as necessary, and be properly maintained and used only by employees properly trained in their use who are involved in confined space entry:

a) Testing and monitoring equipment;

b) Ventilating equipment needed to obtain acceptable entry conditions;

c) Communications equipment;

d) Personal protective equipment;

e) Lighting equipment needed to enable employees to see well enough to work safely and to exit the space quickly in an emergency;

f) Barriers and shields as necessary;

g) Ladders or other equipment needed for safe entry and exit;

h) Rescue and emergency equipment for rescuing entrants from permit spaces and providing necessary emergency services to rescued employees, except to the extent that the equipment is provided by rescue services;

i) Tripod, hoist and harness, escape self-contained breathing apparatus (ESCBA) with at least 10 minute air supply (or other NIOSH approved self-rescuer);

j) Other equipment deemed necessary for safe entry, work, exit, and rescue.

Certification of proper training in the use of equipment will be kept on file by the operating division.

6. Training: Every employee involved in confined space entry will receive training necessary for safe performance of assigned duties prior to the assignment of entry duties, before there is a change in assigned duties, whenever there is a change in operations that presents a hazard about which an employee has not previously been trained,and whenever an employee appears to lack adequate knowledge of proper procedures. Training will be certified with employee's name, date received, andsignature of instructor. The Public Works-Engineering Department will be responsible for designating and qualifying one or more employees to provide the required training to all employees who participate in confined space entry as described in this policy.

7. Rescue and emergency services: The general policy is that on-site rescue will be performed by employees who have been properly trained in rescue procedures, proper use of personal protective equipment, basic first-aid and CPR as well as thetraining required for authorized entrants, personal protective equipment and rescue equipment will be provided and available at all times of permit space entry. Each member of the rescue team will practice making rescues at least once every 12 months. If proper rescue equipment isnot available or the situation otherwise dictates, local fire rescue personnel will be called tostand by at the site during the permit space entry. In all cases, all personnel involved in the permit space entry, including the attendant, supervisor, and dispatcher, must be aware of the procedures for summoning emergency assistance,rescue or ambulance services, and be on alert to obtain such services, when needed, in the quickest manner possible while an entrant is in a permit space.

8. Sewer System Entry: Entrants should be equipped with, and trained in the use of atmospheric monitoring equipment which sounds an audible alarm, in addition to a visual readout for the following conditions:

a) Oxygen concentration less than 19.5%;

b) Flammable gas or vapor at 10% or more of the lower flammable limit;

c) Hydrogen sulfide or carbon monoxide at or above their PEL (10 ppm or 50 ppm, respectively);

d) If a broad range sensor device is used, at 100 ppm as characterized by its response to toluene.

All pumps and lines which may cause contaminants to flow into the space shall be disconnected,blinded and locked out, or effectively isolated to prevent development of dangerous air contamination or engulfment.

9. Contract work: When the City of Lawton contracts for work to be performed in existing, designated confined spaces, the contractor will be apprised of the hazards involved, the recommended precautions to be taken and the entry procedures developed by the City for the confined space. For contracts established and monitored by the Engineering Division, contractors will receive this information with the "Notice to Proceed".For other contracts, the responsible Department/Division will provide a copy of the entry procedure along with the work order or other notice authorizing the contractor to begin work. The contractor will be responsible for controlling entry into such permit spaces from the time his work begins on the site until the work has been accepted by the City Council. For areas that may qualify as confined spaces which are newly fabricated by the contractor as part of a construction contract, the contractor must develop any necessary entry procedures for his employees and provide, in writing, a copy of these procedures for City of Lawton employees who must enter these areas for inspection or other purposes.

10. Review: Entry operations will be reviewed on an annual basis, if at least one entry has been performed during the year. A review will also be performed if the supervisor has reason to believe that measures are not adequate to protect employees. Steps will be taken to revise procedures if it is determined by supervisory or safety personnel that employees are not adequately protected, prior to authorization of subsequent entries.

REFERENCES: OSHA Confined Space Entry Standard (1910.146)

EFFECTIVE DATE: This policy is in effect from and after February 1, 1994, and will remain in effect until rescinded.

_________________________

ROBERT M. HOPKINS

CITY MANAGER