Confined Space Entry Program

Evaluating the workplace and classifying confined spaces
Each workplace shall be evaluated by a competent person to determine if it contains confined spaces as defined in section II of this policy. Each confined space shall then be classified as either a Permit Required Confined Space as defined in section III, or a Non-Permit Required Confined Space as defined in section IV of this policy.

Superintendents and supervisors of each area, such as, Maintenance, Telecommunications, Water and Wastewater Treatment, General Utilities and other such groups will ensure property and equipment under their responsibility are evaluated and confined spaces are controlled in accordance with this policy.


Confined Space
Any space that meets all the following criteria:

• Is large enough and so configured that an employee can bodily enter and perform assigned work; and,
• Has limited or restricted means for entry or exit (generally, openings that require the employee to crouch, crawl, climb, or be lowered into, or an interior configuration that restricts egress or rescue, is considered limited or restricted); and,
• Is not designed for continuous human occupancy.

Some examples of confined spaces are fuel storage tanks, manholes, underground vaults, equipment tunnels for wires or pipes, and sewers.


Definitions
Acceptable entry conditions: conditions that must exist in a permit space to allow entry and to ensure that employees involved with a permit required confined space entry can safely enter into and work within the space.
Attendant: An individual stationed outside one or more permit required confined spaces who monitors the authorized entrants and who performs all attendant's duties assigned in the employer's permit space program.
Authorized entrants: An employee who is authorized by the employer to enter a permit space.
Emergency: Any occurrences (including any failure of a hazard control or monitoring equipment) or event internal or external to the permit space that could endanger entrants.
Energy isolating device: A mechanical device that physically prevents the transmission or release of energy, including but not limited to the following:

• A manually operated electrical circuit breaker.
• A disconnect switch.
• A line valve, block and any similar device used to block or isolate energy.

Engulfment: The surrounding and effective capture of a person by a liquid or finely divided flowable solid substance that can be aspirated to cause death by filling or plugging the respiratory system or that can exert enough force on the body to cause death by strangulation, constriction or crushing.
Entry: The action by which a person passes through an opening into a permit required confined space. Entry is considered to have occurred as soon as any part of the entrants body breaks the plane of an opening into the space.
Entry supervisor: The person (such as the employer, foreman, or crew chief) responsible for determining if acceptable entry conditions are present at the permit space where entry is planned, for authorizing entry and overseeing entry operations, and for terminating entry.
Hazardous atmosphere: An atmosphere that may expose employees to the risk of death, incapacitation, impairment of ability to self-rescue (that is, escape unaided from a permit space), injury, or acute illness from one or more of the following causes:

• Flammable gas, vapor, or mist in excess of 10% of its lower flammable limit (LFL).
• Airborne combustible dust at a concentration that meets or exceeds its LFL.
• Atmospheric oxygen concentrations below 19.5% or above 23.5%.
• Atmospheric concentrations of any substance for which a dose or a permissible exposure limit is published in Subpart G, Occupational Health and Environmental Control, or in Subpart Z, Toxic and Hazardous Substances, of OSHA Standard, 29 CFR 1910.
• Any other atmospheric condition that is immediately dangerous to life or health.

Hot work permit: The employer's written authorization to perform operations (for example, riveting, welding, cutting, burning, and heating) capable of providing a source of ignition.
Immediately dangerous to life or health (IDLH): Any condition that poses an immediate or delayed threat to life or that would cause irreversible adverse health effects or that would interfere with an individual's ability to escape unaided from a permit space.
Isolation: The process by which a permit space is removed from service and completely protected against the release of energy and material into the space by such means as: removing sections of lines, pipes or duct work; a double block and bleed system; lockout or tagout of all sources of energy; or by disconnecting all mechanical linkage.
Lockout: The placement of a lockout device on an energy isolation device, in accordance with an established procedure, ensuring that the energy isolation device and the equipment being controlled cannot be operated until the lockout device is removed.
Oxygen deficient atmosphere: An atmosphere containing less than 19.5% oxygen by volume.
Oxygen enriched atmosphere: An atmosphere containing more than 23.5% oxygen by volume.
Permit required confined space program: The employer's written procedure for preparing and issuing permits for entry and for returning into a permit required confined space.
Rescue service: The personnel designated to rescue employees from permit spaces.
Retrieval systems: The equipment (including a retrieval line, full body harness, and a lifting device for retrieval) used for non-entry rescue of persons from a permit required space.
Tagout: The placement of a tagout device on an energy isolating device in accordance with an established procedure to indicate that the energy isolating device and the equipment being controlled may not be operated until the tagout device is removed.
Testing: The process by which the hazard that may confront entrants of a permit space are identified and evaluated.

Evaluating hazards for initial classification of confined spaces
When initially classifying confined spaces as permit or non-permit, they must be evaluated for internal and external conditions that have the potential for creating a hazard.

If the space has a potential atmosphere being oxygen enriched or deficient, explosive, or contains carbon monoxide or hydrogen sulfide, a quantitative analysis is required. A Metrosonics 4-gas monitor or equivalent instrument which analyzes and indicates oxygen in percent by volume, lower explosive limit in percent LEL, carbon monoxide and hydrogen sulfide expressed in parts per million (ppm) will be used. After calibration, a probe must be attached to the instrument for internal sampling. A person trained in the use of this instrument shall conduct this initial test while positioned outside the space. Samples shall be taken in all areas employees will be working or may need to access.

Due to size or configuration, some spaces will not allow atmospheric testing of all areas with an instrument probe while stationed outside the space. These situations may require entry for appropriate testing. This shall be accomplished by testing atmospheres as far as possible with an instrument probe. If safe readings are found, entrants may then proceed to areas probe tested. Once entry is gained, testing samples shall be read continuously in all areas employees will be working or may need to access. Testing personnel must carry with them an emergency escape self contained breathing apparatus (SCBA) unit which will provide breathing air for 5 minutes or more. If at any time the testing instrument alarms, entrants must immediately don the escape air pack and exit the space.

Any quantitative readings other than those shown below cause the initial evaluation and classification to cease and not resume until contact is made with the University of Central Florida's Environmental Health & Safety Department. The following are considered normal readings:

• Oxygen levels between 19.5% and 21.5% by volume.
• Lower Explosive Limit readings less than 5% LEL.
• Carbon Monoxide readings less than 15 ppm.
• Hydrogen Sulfide readings less than 5 ppm.

In some cases the space may have the potential to contain unknown atmospheric hazards which cannot be quantified or detected by a multi-gas monitor. In these situations appropriate measures shall be taken to ensure no entry is permitted and Environmental Health and Safety shall be contacted to conduct the evaluation.

If the space does not contain any other hazards and the initial atmospheric analysis reveals levels within permissible limits, the space may be classified as non-permit required. However, if EH&S has reasonable cause to believe the space has the potential of developing an atmosphere capable of causing inability for self rescue, unconsciousness, incapacitation, injury, acute illness, serious physical harm or death, such space must be classified as permit required.

Non-Permit Required Confined Space
Any Space that meets all the criteria found in section II of this policy and which entry is permitted without written authorization because:

• The confined space poses no actual or potential hazard described in section VII of this policy; and/or,
• No such hazard will be produced by work performed inside the space.

Procedures for entering spaces classified as non-permit required
Confined spaces classified as non-permit required do not need written procedures to authorize an employee to enter. No further action is needed unless work to be performed inside would change the classification to a permit required confined space. When there are changes in the physical configuration or nature of the process used within a non-permit required confined space that might increase the hazard to entrants, the space shall be reevaluated and , if necessary, reclassify to a permit required confined space.

Permit Required Confined Space
Any space that meets all the criteria found in section II of this policy and which will require written procedures to authorize an employee to enter because the space or work to be performed inside has one or more of the following characteristics:

• Poses an actual or potential hazardous atmosphere (such as oxygen deficiency, explosive vapors or gasses, toxic chemicals or dusts, etc.); or
• Contains materials that have the potential for engulfing an employee (such as sand, rock, grain, coal or similar finely divided particulate matter); or
• Has an internal configuration such that an entrant could be trapped or asphyxiated by inwardly converging walls or by a floor which slopes downwardly and tapers to a smaller cross section (such as a hopper car or sand tower); or
• Contains other recognized serious safety or health hazards (such that may be produced by chemicals, moving parts, falls, electrocution, drowning, etc.).

Notifying employees of permit required confined spaces
Employees exposed to permit required confined space(s) shall be informed of location and danger posed by each space by a sign at each permit required confined space which reads:

Danger
Permit Required Confined Space
Enter By Permit Only

Written procedures for entering spaces classified as permit required
Each confined space classified as permit required that will be entered by UCF employees must have written procedures for authorizing and controlling entry by one of the methods provided in this policy. Each written procedure must contain specific procedures and precautions to be taken for entering and working within the space. The written procedures shall conform with OSHA standard 29 CFR 1910.146 and the University of Central Florida policies and procedures.

A copy of the written procedures must be maintained at the place of entry and made readily available to employees affected by such procedures. A copy must also be sent to Environmental Health & Safety.

Entry by written permit method
When entry in a permit required confined space cannot be accomplished by one of the previously described methods, a written permit granting authority to enter must be issued. General Entry Permit (permit A) or Hot Work Permit (permit B) contained in this policy shall be used as the written permit.

Written procedures governing entry by permit shall contain at least the following elements:

• Method to prevent unauthorized entry
• Means, procedures and practices necessary for safe entry. Identify individual hazards and explain procedures for eliminating or controlling each. Identify the individuals authorized to issue written entry permits.
• Step by step procedures for evaluating conditions when entry operations are conducted. Specify acceptable entry conditions which include, but are not limited to:
1. Acceptable atmospheric conditions.
2. Isolation procedures (lockout-tagout etc.).
3. Purging, inerting, flushing, or ventilating procedures.
4. methods for providing pedestrian, vehicle, or other barriers to protect entrants from external hazards.

• Means, Procedures and practices necessary for continuous safe working conditions within the space and, if necessary, procedures for continuous monitoring of atmospheric conditions.
• Provide for at least one attendant outside the permit space for the duration of entry operations.
• Procedures for summoning or providing emergency services for rescuing employees in case of accident, injury or illness.

Issuing and controlling entry permits
Issuance and control of written permits for entry shall meet the following minimum guidelines:

• Before entry is authorized all protective measures outlined in this written procedure shall be completed.
• Only UCF permit forms may be used. Before entry begins the entry supervisor shall complete each applicable item on the permit and sign it. It shall be made available to all authorized entrants, either by posting it at the entry portal or any other equally effective means, so that entrants can confirm that pre- entry preparations have been completed.
• The duration of the permit may not exceed the time required to complete the assigned task or job identified in the permit.
• The entry supervisor shall terminate entry and cancel the entry permit when operations have been completed or a condition arises during operations which are not acceptable under the entry permit.

Entry by declassifying permit required to non-permit required space under OSHA Standard 29 CFR 1910.146(c)(7)

A space classified as permit required may be temporary declassified as non-permit confined space under the following procedures:

• The permit space poses no actual or potential atmospheric hazards and all other hazards are eliminated without entry. A practical example would be a pit which contained only the hazard of moving parts. The power source for all machinery is shut off under an approved lockout - tagout procedure, thus eliminating the hazard.
• After initial entry under some other method (such as permit), the workers eliminate all hazards. The space is then temporarily declassified and subsequent entries may be made without a permit.

The basis for determining that all hazards have been eliminated shall be recorded on the Temporary Reclassification Certification Form found in this program. This form shall be made available to each employee entering the space.

Written procedures must contain precautions to be taken for declassifying, entering, working within and exiting the space. The written procedures must also include a method by which it is verified that all entrants are out of the confined space prior to removing safeguards or returning it to service.

Entry by controlling atmosphere with continuous forced air method OSHA 29 CFR 1910.146(c)(5)
A space classified as permit required in which the only hazard posed is an actual or potential hazardous atmosphere, and the hazard can be controlled by continuous forced air, such space may be entered by written alternate procedures and without permit.

A written record of monitoring and inspection data to support decisions to enter without permits must be maintained and made available upon request by any employee who enters a confined space under this alternate procedure.

Written procedures must contain precautions to be taken for entering and working within the space and, at a minimum, must follow OSHA standards 29 CFR 1910.146(c)(5) protocols.

Before each entry in which continuous forced air is to be used to control an atmospheric hazard, the following must be done:

• Any condition making it unsafe to remove an entrance cover shall be eliminated.
• The opening shall be guarded by temporary barrier that will prevent an accidental fall through the opening and will protect employees working inside from foreign objects entering the space.
• Establish forced air ventilation for the prescribed time stated in the written procedures to control the atmosphere to within prescribed limits for the space.
• The internal atmosphere shall then be tested with a calibrated direct - reading instrument for control of the hazards stated and to insure atmospheric conditions are within the limits stated in the written entry procedures.
• The employee designated to verify the space as safe for entry shall complete the Forced Air Entry Certification Form found in this policy. A copy will be made available to each employee entering the space.

Notifying contractors or other company's employees of confined spaces
When a contractor or another company is invited to perform services on UCF property which involves a permit required confined space, Environmental Health & Safety or the department in charge of the project shall notify the contractor of:

• The location and nature of UCF's permit required confined spaces and that entry is allowed only through compliance with a permit space program meeting the requirements of OSHA standard 29 CFR 1910.146.
• Known or potential hazards and experience with the space.
• Precautions or procedures UCF has implemented for the protection of employees in or near the space.

The UCF Environmental Health & Safety Department or the supervisor in charge shall also:

• Coordinate entry operations with the contractor when UCF employees will be working simultaneously as authorized entrants in the confined space.
• Debrief the contractor at the conclusion of the entry operations regarding any hazards confronted or created in the space during operation.

If UCF employees are to enter simultaneously, UCF's written procedures shall be followed by all forces. If only contractors or other company's forces are entering, the written procedures established by that company will be followed.

Training
Each employees whose duties are affected by written procedures involving permit required confined spaces shall be trained sufficiently to ensure they are proficient in knowledge, understanding and skills necessary to perform duties assigned to them. They must also be trained of hazards that may be faced during entry, including information on the sign, symptoms, and consequences of exposure.

Training must be conducted before employees perform any duties associated with a permit required confined space; before there is a change in assigned duties; whenever there is a change in procedures that present a hazard about which an employee has not been previously been trained; or, when the written procedures for entry or safe work practices have been changed.

To ensure proficiency, training may include practice exercises in a safe environment covering the use of tools, personal protective equipment, communication equipment, emergency notification and rescue procedures.

It must be certified and shown on a written document at the establishment that each employee is proficient. The document must contain the employee's name, signature of the supervisor or training instructor making the determination of proficiency as well as the dates of training.