Additionally,
the work to be performed within the space must
not introduce any new hazards. For example, work
with hazardous quantities of flammable or toxic
substances and hot work are not permitted. This
additional work would introduce hazards beyond
those accounted for by the initial determination
and the permit space may not be maintained safe
for entry. Paragraph (c)(5)(i)(B) clearly indicates
that an employer who relies on continuous forced
air ventilation to maintain the space safe for
entry must be able to establish that other measures
are not needed to protect entrants. When other
measures are needed such as when welding is performed,
a full PRCS program is required.
3)
Paragraph (c)(5)(i)(C) requires atmospheric
monitoring and inspection data be gathered to
support items (1) and (2). The data must show
that the forced air ventilation will keep the
air within the space at safe levels.
4)
Paragraph (c)(5)(i)(D) states that if entry
is necessary to conduct initial data gathering,
the entry must be performed under a full entry
permit program [paragraphs (d) through (k)].
5)
Paragraph (c)(5)(i)(E) mandates providing
written certification to verify that the space
is safe for entry and that all measures listed
here to qualify for these alternative procedures
have been performed. Supporting documentation
must also include: certification date, location
of the space and signature of the person providing
the determination.
Ensure
that this information is available to each employee,
authorized representative and OSHA representatives.
Again, Appendix A has been included to assist
employers with this task.
6)
Paragraph (c)(5)(i)(F) stipulates that the
entry must be performed in accordance with the
specific procedures required by paragraph (c)(5)(ii).
Paragraph
(c)(5)(ii) states that if qualified for
the alternative procedures as outlined above,
the entry can take place after the following
specific procedures are performed:
1)
Paragraph (c)(5)(ii)(A) requires that any
conditions that will make it unsafe to remove
an entrance cover be eliminated before the cover
is removed. Some conditions within a permit
space, such as high temperature and high pressure,
may make it hazardous to remove the cover from
the space. For example, if the atmospheric hazards
within the space cause high pressure to be present
within the space, the cover could be blown off
in the process of removing it. To protect employees
from such hazards, a determination must be made
as to whether or not it is safe to remove the
cover. Such determination would require the
employer to examine the conditions that are
likely to occur in the permit space. For example,
the cover should be checked to see if it is
hot; and, if it is fastened in place, it should
be loosened gradually to release any residual
pressure. An evaluation must also be made of
whether conditions at the site could cause a
hazardous atmosphere to accumulate in the space
which would make it unsafe for employees to
remove the cover. The cover must not be removed
until it is safe to do so.
2)
Paragraph (c)(5)(ii)(B) requires that openings
to permit spaces be guarded to protect employees
from falling into the space, to protect employees
in the permit space from being injured by objects
entering the space and from the hazards of vehicle
traffic. The guard could be in the form of a
railing, a temporary cover or any other temporary
barrier that provides the required protection.
If the opening to the space is situated so that
employees and objects cannot fall into the space,
no additional guarding is necessary.
3)
Paragraph (c)(5)(ii)(C) requires the internal
atmosphere of the permit space to be tested
with a calibrated, direct-reading instrument
before any employee enters the space. The atmosphere
must be tested, in sequence, for oxygen content,
for flammable gases and vapors, and for potential
toxic air contaminants.
4)
Paragraph (c)(5)(ii)(D) prohibits employees
from being in the space when a hazardous atmosphere
is present. Any entry into a permit space containing
a hazardous atmosphere must be conducted in
accordance with the full permit space program
requirements given in paragraphs (d) through
(k).
5)
Paragraph (c)(5)(ii)(E) sets out requirements
for the use of continuous forced air ventilation.
First, no employee may enter the space until
the forced air ventilation has eliminated any
hazardous atmosphere found within the space.
Second, the ventilation must be directed to
ventilate the immediate areas where an employee
is or will be present. Third, the air supply
for the ventilation must be from a clean source
and must not increase the hazards in the space.
6)
Paragraph (c)(5)(ii)(F) requires the permit
space to be tested frequently or continuously
to ensure the air is safe. The frequency for
testing during entry will depend on the space
and the results from the initial testing conducted.
If, for example, the initial testing found no
detectable levels of airborne contaminants and
if the permit space is not normally expected
to present atmospheric hazards, no further testing
may be necessary. However, if the initial testing
detected airborne contaminants, then frequent
or continuous testing would be appropriate.
7)
Paragraph (c)(5)(ii)(G) requires employees
to exit the permit space immediately if a hazardous
atmosphere is detected. Additionally, the employer
is required to reevaluate the permit space to
determine how the hazardous atmosphere developed
and to implement measures to protect employees
from the hazardous atmosphere before any subsequent
entry is undertaken.
8)
Paragraph (c)(5)(ii)(H) requires the employer
to verify that the permit space is safe for
entry and that the measures required by paragraph
(c)(5)(ii) have been taken. This verification
must be in the form of a certification that
contains the date, the location of the space
and the signature of the certifying individual.
The certification must be made available to
entrants. This certification, in combination
with the documentation required under paragraph
(c)(5)(i)(E), will maintain employer accountability
for compliance with paragraph (c)(5)(ii). AppendixA
has been included for this task.
Paragraph
(c)(6) requires that if there are any changes
in the use or configuration of a non-permit
space that may increase hazards to entrants,
the space must be reevaluated, and if necessary,
reclassified as a permit required space. This
does not mean that employers have to reevaluate
spaces because of trivial changes. Only those
changes that may increase the hazards to the
workers need to be addressed.
Paragraph
(c)(7) states that OSHA has determined that
permit spaces that have all hazards eliminated
can be temporarily reclassified as non-permit
spaces for as long as the hazards remain eliminated.
Note
to the Employer: OSHA believes that employees
are fully protected from the hazards of permit
spaces once all hazards within the space have
been eliminated. Clearly, if there are no hazards
within the permit space, an entrant is in very
little or no danger. By contrast, if the hazards
are simply controlled rather than removed, the
entrant could be injured upon failure of the
control system. Therefore, the Agency has determined
that it is appropriate to allow employers who
eliminate hazards within permit spaces to reclassify
those spaces as non-permit confined spaces.
Paragraph
(c)(7)(i) allows employers to reclassify
a permit space to a non-permit confined space
if there are no potential atmospheric hazards
and if all other hazards within the space are
eliminated without entry into the space. The
reclassification would be valid as long as the
non-atmospheric hazards remain eliminated.
The
reclassification of permit spaces allowed under
paragraph (c)(7)(i) recognizes that spaces such
as mixers and material bins can have their hazards
removed before entry, so that entrants are fully
protected without the need for permits, attendants,
or other features required by the full permit
space program requirements given in paragraphs
(d) through (k). Mixers can be locked out before
they are entered for servicing or maintenance,
thereby removing the mechanical hazards. A material
bin posing an engulfment hazard can be emptied
before entry, thus removing that hazard. These
are examples of the types of spaces that can
be made safe for entry following paragraph (c)(7)(i).
In these circumstances, after the hazards have
been eliminated, it is believed that entry into
the space is at least as safe as (if not safer)
than entry in accordance with the full permit
program.
Note
to the Employer: If the equipment or machinery
is not deenergized and locked out or tagged
out in accordance with 29 CFR 1910.147, then
it must be guarded as required in other general
industry standards, such as Subpart O, for machine
guarding, and 29 CFR 1910.303(g) and (h) for
the guarding of electric equipment. As long
as the equipment inside the permit space remains
guarded, employees within the space are not
considered to be exposed to any equipment-related
hazards. For spaces posing only engulfment hazards,
it may be possible to remove the hazard by removing
the engulfing material from the space before
entry.
In
many permit spaces possessing the above noted
conditions, employees can eliminate the hazard
without having to enter into the space. However,
if it is necessary to enter the space to verify
elimination of the hazards, then this entry
must be performed in accordance with a full
permit-space program as stated in paragraph
(d) through (k).
Paragraph
(c)(7)(ii) allows permit spaces that contain
or have the potential to contain hazardous atmospheres
to also be reclassified as non-permit spaces
by elimination of the hazards. These types of
spaces must first be isolated, purged and ventilated.
The elimination of a hazardous atmosphere must
be verified by testing the atmosphere and inspecting
the interior conditions of the space. The entry
to determine that the source of the hazard has
been eliminated must be conducted in accordance
with the full permit space program requirements
[paragraph 9d through (k) of the standard].
Types of permit spaces which may fall into this
category include chemical tanks and boilers.
Some
chemical tanks can frequently be made safe by
draining them of their contents, purging the
residual chemicals with water, and ventilating
the space after purging is complete. Boilers
can be made safe for entry by shutting them
down, opening the access ports to allow for
temperature reduction and natural ventilation,
and entering the space to remove any residual
hazards, such as loose buildup that could fall
onto entrants. In each case, an entry conducted
in accordance with the full permit space program
requirements must be completed to ensure that
the hazards have been eliminated.
If
the atmospheric hazard has been found to be
the eliminated, the permit can be reclassified
to a non-permit space.
Note
to the Employer: The control of atmospheric
hazards with forced air ventilation, as stated
in paragraph (c)(5) of the standard, is different
than elimination of the hazard as stated in
paragraph (c)(7)(ii) of the standard. Forced
air ventilation will control the hazard but
does not constitute elimination of it. If the
forced air ventilation is terminated, the hazardous
atmosphere may return.
Paragraph
(c)(7)(iii) requires employers who desire
to reclassify a permit confined space to provide
written certification which includes:
-
documentation to substantiate that all hazards
have been eliminated,
-
the date of the certification,
-
the location of the space and
-
signature of the individual certifying the
elimination of the hazards
Note
to the Employer: Appendix C has been included
for this task.
Paragraph
(c)(7)(iv) requires that if conditions in
the space were to change and a hazard were found
to arise, the entrants must evacuate the space
immediately. The employer is then required to
reevaluate the space to determine the cause
of the hazards and to determine if the space
should revert back to a permit-required confined
space.
Paragraph
(c)(8) contains requirements pertaining
to the responsibilities of host employers to
employees of other employers (contractors) who
are to perform permit-required confined space
entry. If the "host employer" has
employees of another employer (contractor) perform
work that involves permit space entry, the host
employer must perform the following duties:
1)
Paragraph (c)(8)(i) requires informing the
contractor that the work site contains permit
required confined spaces. It is also necessary
to inform the contractor that entry into these
permit spaces must be in accordance with a permit
space program [paragraphs (d) through (k)] that
is program-specific to the space.
2)
Paragraph (c)(8)(ii) requires informing
the contractor of any known hazards and the
host employer's experiences with the space.
This provision of the standard does not require
the host employer to make a detailed investigation
of any permit spaces, but just to provide whatever
information was used for identifying the space
as a permit space.
3)
Paragraph (c)(8)(iii) requires informing
the contractor of any precautions that have
been instituted by the host employer to protect
employees in or near the permit space.
4)
Paragraph (c)(8)(iv) requires that the host
employer develop and implement procedures to
coordinate entry operations when both the host
employer and the contractor have employees working
in the space.
5)
Paragraph (c)(8)(v) requires that at the
conclusion of the entry operation, a debriefing
session must be held with the contractor concerning
the permit space program used and any hazards
confronted or created while working in the space.
Any information concerning hazards or potential
hazards should be documented and steps taken
to control or eliminate the situation.
Note
to the Employer: The above information should
be provided to the contractor in written form.
By doing so, all required responsibilities are
performed and available information is communicated.
Appendix E has been included for this purpose.
Paragraph
(c)(9) contains requirements pertaining
to the responsibilities of contractors who are
retained to perform permit space entry operations,
including:
1)
Paragraph (c)(9)(i) requires contractors
to obtain any available information from the
host employer regarding any hazards and entry
operations in the permit space.
2)
Paragraph (c)(9)(ii) requires contractors
to coordinate entry operations with the host
employer if both parties will have personnel
working in the permit space.
3)
Paragraph (c)(9)(iii) requires the contractors
to inform the host employer of the contractors'
permit space program that will be followed during
the entry operation.
Coordination
requirements between the host employer and contractor
are included in paragraphs (c)(8)(iv), (c)(9)(ii),
and(d)(11) of the standard. Paragraph (d)(11)
requires employers to coordinate entry operations
when employees of more than one employer are
working simultaneously as authorized entrants
in a permit space, so that employees of one
employer do not endanger the employees of any
other employer. This provision applies generally
to all multi-employer permit space entry operations.
The potential hazards of multi-employer permit
space entry operations exist whether or not
one of the employers acts as a host employer.
For example, a manhole that is shared by two
utility companies (gas and water, for example)
is one case in which neither employer may be
considered the host employer. If employees of
both employers are present, but neither employer
acts as the host, paragraph (d)(11) would still
require coordination of permit space entry operations.
Therefore, OSHA has adopted paragraph (d)(11)
to cover coordination among all employers whose
employees are present during entry operations.
Paragraphs (c)(8)(iv) and (c)(9)(ii) direct
the host employer and contractor, respectively,
to the basic requirement for coordination including
a determination of what permit program is to
be used by the contractor. The standard does
not prohibit the host employer from requiring
a contractor to use the host's permit program,
nor does it require the contractor to use the
host's program. However, the host employer may
choose to condition its contract on the contractor's
compliance with the host's program, as is often
the case in the petrochemical industry.
Additionally,
contractors are required to inform host employers
of the permit program to be followed and of
any hazards confronted or created in the permit
space during entry operations. At the completion
of the operation, a debriefing session must
be held between the host employer and contractor
to exchange any information and hazards found
or created in the permit space.
Note
to the Contractor: The above information should
be provided to the host employer in written
form. By doing so, all required responsibilities
are performed and available information is communicated.
Appendix F is included for this purpose.
Permit
Required Confined Space Program - Paragraph
(d)
The
general requirements which an employer must
follow were discussed in the previous section.
The requirements needed for the actual design
and implementation of a written permit space
program are included in this section entitled
Permit-Required Confined Space Program. Though
employers may defer the specific hazard evaluation
of the permit space until the actual entry operation,
employers are expected to begin developing their
written program once they know employees will
eventually perform an entry operation. These
steps are needed prior to the entry operations
to ensure that the permit space program is effective.
Employers who wait until the last minute before
an entry operation to begin to develop a program
are likely to have problems which could significantly
increase the risks to employees.
Note
to the Employer: Remember, if alternative procedures
[(c)(5)] or reclassify to a non-permit space
procedures [(c)(7)] can be used, paragraphs
(d) through (f) and (h) through (k) are not
required.
Paragraph
(d)(1) requires the employer to implement
measures to prevent unauthorized entry into
a permit space. It is the employer's responsibility
to use whatever measures are necessary to prevent
unauthorized entry; such as:
-
locks
- fences
- guardrails
-
signs in combination with training
- any
other effective measure
Paragraph
(d)(2) requires that the identification
and evaluation of hazards in a confined space
must be conducted in detail prior to entry so
that the operation can be safely planned. Identifying
the existence of permit spaces must be accomplished
by the effective date of the final rule, April
15, 1993.
Note
to the Employer: OSHA anticipates that employers
will identify and evaluate permit space hazards
as necessary for development of written permit
space programs. For example, OSHA expects that
employers who conduct frequent entries into
permit spaces will be identifying and evaluating
permit space hazards at the same time they are
identifying permit spaces. On the other hand,
OSHA understands that employers may not need
to identify or evaluate the hazards of permit
spaces that are entered at 5- or 10-year intervals
until several years after the identification
of those spaces. In the interim, since there
are no authorized entries into those spaces,
the program would only require that unauthorized
entries be prevented. The hazards in the spaces
need only be evaluated in detail some time before
entry. The standard makes this clear - - the
basic identification of permit spaces required
by paragraph (c)(1) must be performed by the
effective date of the final rule; the evaluation
of the specific hazards posed by permit spaces
identified under paragraph (d)(2) is required
"before" entry.
Paragraph
(d)(3) requires the employer to develop
and implement the means, procedures, and practices
necessary for safe entry operations, including,
but not limited to the following elements:
1)
Paragraph (d)(3)(i) requires specifying
the acceptable entry conditions. This control
measure ensures that the employer has identified
the hazards that could reasonably be expected
to be found in the space and has limited entry
conditions to those that are safe for entry.
For example, if a space could contain a flammable
gas, the employer would set a limit of 10 percent
of the LFL of the gas as an entry condition.
This would ensure that a flammable mixture is
not present upon entry into the space.
2)
Paragraph (d)(3)(ii) requires specifying
the isolating procedures to be used. The permit
space must be isolated from serious hazards.
For example, if energized parts of electric
equipment are exposed, the circuit parts must
be deenergized and locked out in accordance
with 29 CFR 1910.333(b). Mechanical equipment
posing a hazard within the space must be locked
out or tagged in accordance with 29 CFR 1910.147
or guarded in accordance with subpart O of the
General Industry Standards. Chemical or gas
lines that are open within the permit space
must be isolated by such means as blanking or
binding, misaligning or removing section of
lines, pipes, or ducts, or double block and
bleed system.
3)
Paragraph (d)(3)(iii) requires specifying
if purging, inerting, flushing or ventilating
the space is needed to eliminate or control
any atmospheric hazards.
4)
Paragraph (d)(3)(iv) requires the use of
barriers. Barriers must be provided around the
permit space opening for two reasons: (1) to
prevent unauthorized entry into the space and
(2) to protect employees inside the space from
objects and persons outside the space. Paragraph
(d)(3) requires barriers whenever they are necessary
to protect employees within the permit space.
If entrants face a substantial risk of injury
due to unauthorized entry, objects falling into
the space, or vehicular hazards during entry
into and exit from the space, then barriers
would be required.
5)
Paragraph (d)(3)(v) requires testing and
monitoring of the space. The employer must ensure
that conditions in the permit space are acceptable
for entry throughout the duration of entry operations.
This is accomplished through the use of ventilation
to maintain a safe atmosphere and the use of
inspections to ensure that isolation procedures
are being maintained for the space.
Paragraph
(d)(4) requires the employer to provide
the equipment needed for safe entry operations.
This equipment must be available at no cost
to employees and must be property maintained.
The employer must ensure its proper use by employees.
The equipment required may vary on the specific
permit space to be entered. Equipment likely
to be needed includes:
1)
Paragraph (d)(4)(i) atmospheric testing
and monitoring equipment.
2)
Paragraph (d)(4)(ii) ventilation equipment.
3)
Paragraph(d)(4)(iii) communication equipment.
4)
Paragraph (d)(4)(iv) personal protective
equipment.
5)
Paragraph (d)(4)(v) lighting equipment
6)
Paragraph (d)(4)(vi) barriers.
7)
Paragraph (d)(4)(vii) access and egress
equipment such as ladders.
8)
Paragraph (d)(4)(viii) rescue and emergency
equipment.
9)
Paragraph (d)(4)(ix) any other equipment
deemed necessary for safe entry into and rescue
from the permit space.
Paragraph
(d)(5) requires evaluation of the permit
space for atmospheric hazards. The specific
requirements for atmospheric monitoring to ensure
that the hazard is controlled or eliminated
are listed below:
1)
Paragraph (d)(5)(i) requires the employer
to test conditions in the permit space to determine
if acceptable entry conditions exist before
entry is authorized to begin. This testing is
important to detect any hazardous atmospheres
or other hazards that may be present in the
permit space.
An
exception to the above would be applied in the
case where isolation of the space is infeasible
because the space is large or is part of a continuous
system (such as a sewer system). In that case,
the employer must perform pre-entry testing
to the extent feasible before authorizing entry.
If entry is authorized, then continuous monitoring
of entry conditions in the areas where authorized
entrants are working is required.
The
type of testing that needs to be performed is
dependent on the specific hazards that are present
within the space. For permit spaces posing atmospheric
hazards, atmospheric testing would be necessary.
If the permit space poses thermal hazards, then
the temperature within the space would need
to be tested.
Because
sewers and similar permit spaces are large continuous
systems, conditions encountered at the point
of entry may not be indicative of conditions
at distances further from the point of entry.
Also, since the space usually cannot be effectively
isolated, conditions at any particular point
in the space may deteriorate suddenly due to
the introduction of a material from another
point in the system that creates a hazardous
environment for the entrants. Under these conditions,
pre-entry testing often will not detect such
hazards, and the need for continuous atmospheric
monitoring becomes paramount. Atmospheric monitoring
is necessitated virtually from the time pre-entry
testing is done until the last entrant leaves
the permit space. Because of these conditions,
the procedure for authorizing entry into sewers
has evolved so that authorization is usually
granted immediately before entry.
2)
Paragraph (d)(5)(ii) of the final rule requires
permit spaces to be tested or monitored, as
necessary, to determine if acceptable entry
conditions are being maintained during the course
of entry operations. This provision requires
whatever period of monitoring (frequent or continuous)
that would be necessary to protect employees.
3)
Paragraph (d)(5)(iii) specifies the proper
sequence to be used when permit spaces are tested
for atmospheric hazards. This provision requires
employers to test first for oxygen, secondly
for combustible gases and vapors, and then for
toxic gases and vapors.
A
test for oxygen must be performed first because
most combustible gas meters are oxygen dependent
and will not provide reliable readings in an
oxygen-deficient atmosphere.
Paragraph
(d)(6) requires providing at least one attendant
outside the permit space for the entire duration
of the entry operation.
Attendants
may monitor no more permit space entry operations
than they can safely handle. For example, if
the attendant is communicating with authorized
entrants by voice contact only, that attendant
would not be able to monitor any other permit
spaces that were not within voice contact. Also,
if the number of spaces and the number of authorized
entrants are too much for one attendant to keep
track of, then additional attendants would be
required.
In
paragraph (d)(7) the standard also allows the
use of electronic surveillance and other devices
as aids or augmentations to the monitoring process.
The use of such devices would allow an employer
to increase the number of permit spaces a single
attendant could effectively and simultaneously
monitor (although OSHA is not permitting the
use of such devices to replace an attendant
entirely). Additionally, the attendant would
normally be stationed near the entry point of
the permit space, but the use of an electronic
monitoring device makes it possible for an attendant
to effectively perform his or her assigned duties
from a remote location. Television monitors,
public address systems, and barricades can be
used to assist the attendant in monitoring activities
outside the space and in warning unauthorized
personnel away from the space.
If
the attendant is monitoring activities in multiple
spaces, the specific procedures used to respond
to an emergency situation affecting one or more
spaces, must be documented in the written permit
program.
Paragraph
(d)(8) requires the employer to designate
in writing the specific employees who will perform
the various functions of the permit space entry,
such as:
- authorized
entrant,
- attendant,
- entry
supervisor and
- person
performing the atmospheric testing.
Additionally,
identify the specific duties of each individual
and ensure that they are properly trained for
their assigned role.
Paragraph
(d)(9) requires the employee to develop
and implement written rescue procedures for
summoning rescue and emergency medical services
to:
- rescue
entrants.
- provide
necessary emergency medical services and
- prevent
unauthorized personnel from attempting a rescue.
Paragraph
(d)(10) requires the development and implementation
of a system for the:
- preparation,
- issuance,
- use
and
-
cancellation of the entry permit as stated
in paragraphs (e), (f) and (j) of the standard.
Paragraph
(d)(11) requires employers to coordinate
entry operations when employees of more than
one employer are working simultaneously as authorized
entrants. Effective communication and coordination
between employers will reduce the risk of employees
of one employer endangering the welfare of employees
of another employer.
Paragraph
(d)(12) requires employers to establish
the necessary procedures for concluding the
entry once the entry operation has been completed.
This is required so that the employer may carefully
plan and control the entry operation from start
to finish. Cancellation of the permit by established
procedures alerts the employer to take the appropriate
measures which include;
- the
shut down of the space,
-
the closing of the entry portal and
-
the return of the space to normal operating
conditions.
By
implementing these control procedures, situations
such as these can be avoided:
-
accidentally locking an employee inside the
space,
- employees
accidentally entering the space,
- possible
fire or explosion when the space is returned
to its normal operating activity,
- leakage
from misaligned pipes that have not been reconnected.
Paragraph
(d)(13) requires that the employer must
institute a review of entry operations if the
employer has reason to believe that the control
measures taken under the program are not adequately
protecting employees. Correct any deficiencies
found before subsequent entries are authorized.
Circumstances that may prompt such review include:
-
any unauthorized entry into the permit space,
- detection
or discovery of a permit space hazard not
covered by the entry permit,
-
detection of a condition prohibited by the
entry permit,
- a
change in the use or configuration of the
confined space and
-
employee complaints about the effectiveness
of the program.
Paragraph
(d)(14) requires the employer to conduct
a review of the permit space program using canceled
permits within one year after each entry. The
program may be reviewed sooner if needed, to
ensure employees are protected from permit space
hazards. Employers can perform a single annual
review covering all entries performed during
a 12-month period if they desire. If no entry
is performed during a 12-month period, no review
is necessary.
Note
to the Employer: Appendix D PRCS Program Worksheet
and Appendix D-1 contains an example of a completed
written PRCS Program that is considered to comply
with the standard. The program should be modified
as necessary to meet the specific demands of
the permit space to be entered.
Permit
System - Paragraph (e)
It
is well documented that many injuries and fatalities
are the result of employers not taking the proper
precautions necessary to ensure the safety of
the employees working in permit spaces. Paragraph
(e) Permit System requires employers to systematically
implement measures to prevent these injuries
and fatalities by instituting the following:
Paragraph
(e)(1) requires the employer to document
the completion of the measures needed for safe
entry operations through the preparation of
an entry permit as required in paragraph (d)(3).
Careful
and thorough planning is required to ensure
all measures are taken to ensure the safety
of the authorized entrants. The specific elements
that must be included on the permit are dependent
on the particular space and the operation to
be conducted in the space.
Appendix
N provides an example of an entry permit that
is considered to comply with the section. The
elements in the entry permit can be modified
to meet the specific hazards to be encountered.
Paragraph
(e)(2) requires the entry supervisor to
sign the entry permit to authorize entry.
Paragraph
(e)(3) requires the employer to make the
completed permit available to all entrants at
the time of entry. It may consist of posting
the permit at the entry portal or any other
acceptable means so long as the authorized entrants
can check to see if pre-entry preparations have
been completed.
Paragraph
(e)(4) requires that the duration of the
permit not exceed the time required to complete
the task or job identified on the permit. The
entry permit is limited to the duration of whatever
period of time is necessary for completion of
the assigned task or job. The employer can state
the permit's duration in terms of a specific
task to be performed; for example, the cleaning
of interior surface of a tank, or the removal
and installation of a relief valve. The duration
of the permit is not of major concern to the
safety of employees as long as acceptable entry
conditions are maintained.
If
conditions within the space change so that entrants
are endangered, then the following steps are
needed to fully protect these employees:
1)
The entry supervisor, when they assume responsibility
for a space and when they performs periodic
checks, ensures the presence of acceptable
entry conditions [paragraph (j)(6)].
2)
If the hazard being introduced is atmospheric
in nature, the testing and monitoring of the
space will detect it [paragraph (d)(5)(ii)].
3)
If other hazards are being introduced, the
entry supervisor, the attendant, and authorized
entrants are trained to detect their presence
[paragraphs(g),(h)(1), and (j)(1)].
4)
Entrants would vacate the permit space [paragraphs
(h)(4) and (h)(5), (i)(6), and (j)(3)].
Paragraph
(e)(5) requires the entry supervisor to
terminate the entry and cancel the permit when:
- Entry
operation has been completed, or
-
A prohibited condition arises in or near the
permit space
Note
to the Employer: It is understood that there
are situations where more than one entry supervisor
may be needed over the course of an entry operation.
For example, when multi-shift entry operations
are conducted, more than one entry supervisor
would be used for a permit space. Additionally,
even for entry operations that do not extend
across more than one shift, the original entry
supervisor may be absent from the workplace
for other reasons. Therefore, OSHA has adopted
language to provide that the entry supervisor,
not the person who authorized entry, will cancel
the permit. As noted under the discussion of
the term "entry supervisor", OSHA
does not intend to restrict the position of
entry supervisor to a single individual. Any
individual who has been designated as the entry
supervisor has the authority to terminate entry
and cancel a permit.
Paragraph
(e)(6) requires that all canceled permits
be maintained for a minimum of one year to assist
in the annual review process, i.e., paragraph
(d)(14) of the standard. By making canceled
permits available, any problems that arise can
be evaluated and steps taken to avoid a reoccurrence.
Entry
Permit -Paragraph (f)
Paragraph
(f) requires that each permit space have
an entry permit prepared as part of the employer's
determination that conditions in the space are
safe for employee entry. A specific, properly
prepared entry permit will help assure that
employees will be protected against any permit
space hazards. The regulation requires all the
information listed in paragraphs (f)(1) through
(f)(15) of the standard be included and addressed
on an entry permit.
Paragraph
(f)(1) requires identification of the space
to be entered
Paragraph
(f)(2) requires the purpose on entry to
be listed on the permit
Paragraph
(f)(3) requires the date and the authorized
duration of the entry permit.
Note
to the Employer: The duration of the entry permit
need not be stated in terms of actual time,
but may be stated in terms of the completion
of the specific task [see (e)(4)] of the Permit
System paragraph for additional information.]
Paragraph
(f)(4) requires a listing of the authorized
entrants. The employer may place the names on
the entry permit, choose to use entry tags,
badges, sign-out sheets, or any other effective
means to track the authorized entrants. Whatever
method is used, it must allow for quick and
accurate accountability of the authorized entrants
by the attendant. The method to be used must
be stated on the entry permit.
Paragraph
(f)(5) requires that the names of current
attendants involved with the entry operation
be placed on the permit.
Paragraph
(f)(6) requires the names of the current
entry supervisors, including a space for their
signatures or initials for the entry supervisor
who originally authorized entry.
Note
to the Employer: New attendants or entry supervisors
must have their names recorded when they assume
the role at the permit space. This also provides
these individuals with an opportunity to review
the permit, as required by paragraph (j)(6)
of the standard.
Paragraph
(f)(7) requires the permit to contain a
list of the hazards of the permit space to be
entered.
Paragraph
(f)(8) requires the permit to contain a
list of the specific measures taken to isolate
the permit space to either control or eliminate
the hazards.
Note
to the Employer: The permit need only refer
to the procedures in sufficient detail to enable
employees to know what measures should be taken
and how to perform them (e.g., the use of blanking
to isolate the permit space). The standard does
not require the entry permit to contain an in-depth
discussion of the procedures used. The detailed
procedures are required under paragraph (d)(3)
of the written PRCS Program and authorized personnel
trained in their use under paragraph (g) of
the standard.
Paragraph
(f)(9) requires the permit to contain a
list of the acceptable entry conditions.
Note
to the Employer: These conditions must be included
on the permit so permit space personnel are aware
of the acceptable entry conditions. For example,
the acceptable conditions that may be listed on
the permit might include:
- oxygen,
flammable gas and vapor, and toxic substance
levels that must be met before entry,
- energy
isolation controls, etc.
Paragraph
(f)(10) requires the recording of pre-entry
and periodic atmospheric testing results on
the permit along with:
- the
name or initials of the individual performing
the tests,
- the
date and time of the testing and
-
an indication where the testing was performed.
Having
this information on the permit assists confined
space team members in accessing the conditions
during entry operations and also facilitates
the review of canceled permits.
Paragraph
(f)(11) requires the permit to list the
rescue and emergency services (i.e., in-house,
outside) that can be summoned and the means
for contacting those services (e.g., phone,
CB radio).
Paragraph
(f)(12) requires the permit to list the
communication procedures that will be used between
the attendants and authorized entrants.
Paragraph
(f)(13) requires that the permit contain
a list of equipment that is required for the
entry operation, such as:
- personal
protective equipment,
- testing
equipment,
-
communications equipment,
-
alarm systems,
- rescue
equipment,
- barriers
and fences and
- any
other equipment deemed necessary for the safety
of the workers.
Paragraph
(f)(14) requires that the permit contain
any other information that is needed for the
protection of the employees during the entry
operation.
Paragraph
(f)(15) requires that any other additional
permits (i.e., hot work permits) that have been
issued to authorize work be identified on the
permit or attached to it (see Appendix G for
a copy of a typical hot work permit).
Training
- Paragraph (g)
A
major factor in permit space accidents is the
lack of employee awareness of the dangers involved
in these spaces. For example, many times, the
lack of adequate training can result in death
or serious physical harm to workers. Employees
may enter a permit space unaware that the space
contains an Immediately Dangerous to Life and
Health (IDLH) atmosphere since in many situations
there are no obvious symptoms associated with
these life-threatening environments. Additionally,
untrained rescuers of incapacitated individuals
often become victims themselves because they
are unaware of the hazards and of safe rescue
procedures.
To
prevent these types of situations from occurring,
the regulation requires mandatory training of
all members of the permit space team. The elements
are listed in paragraph (h),(i),(j) and (k)
for the authorized entrants, attendants, entry
supervisors, and rescue personnel, respectively.
Paragraph (g) requires employers to provide
this training to these individuals so they obtain
the background necessary for safe permit space
entry. Training under paragraph (g) requires
the following:
Paragraph
(g)(1) requires employees to provide training
to those employees whose work involves or may
involve contact with permit spaces to acquire
the understanding, knowledge, and skills necessary
for the safe performance of their assigned duties.
Note
to the Employer: This requires the employer
to develop and implement the most effective
confined space training program needed to meet
the specific demands of the permit space at
the worksite.
Paragraph
(g)(2) sets out the general conditions under
which training would have to be provided.
1)
Paragraph (g)(2)(i) requires an employee
to be trained when he or she is first assigned
duties involving permit space entry.
Note
to the Employer: Employees who are currently
performing duties outlined in the standard and
who have previously been trained need further
instruction only insofar as they are unfamiliar
with the hazards involved and must change their
work practices so as to conform to 1910.146.
The employer must still certify the training
of these individuals. Additionally, OSHA will
accept on-the-job training as long as the employee
involved is under the direct supervision of
a trained individual and has received sufficient
instruction to enable the trainee to work safely
at his or her level of training.
2)
Paragraph (g)(2)(ii) requires training before
there is a change in assigned duties. Such changes
could be from introduction of new equipment,
techniques, or reassignments.
3)
Paragraph (g)(2)(iii) requires training
before there is a change in the permit space
operation that presents a hazard for which the
employee has not previously received training.
4)
Paragraph (g)(2)(iv) requires training whenever
the employer believes that there are deviations
by the employees from the prescribed permit
space entry procedures, or lack of employee
knowledge or use of these procedures.
Note
to the Employer: Refresher or follow-up training
is required in paragraphs (g)(2)(ii), (g)(2)(iii)
and (g)(2)(iv), or whenever there is a demonstrated
need for it (i.e., an accident with or without
injury, employees not following procedures).
Paragraph
(g)(3) requires that the training
must make the employees proficient in the tasks
assigned to them.
Paragraph
(g)(4) requires the employer to certify
that employees have received training as required
by (g)(1) through (g)(3) by maintaining a record
of the following:
- Employees
name
- Signature
or initial of the trainers
- Date
of training
Note
to the Employer: Appendix O has been included
for recording employee training. The employer
is not required to generate individual certificates;
a list or roster is sufficient. Also, make this
training record available for inspection to
the employees or authorized representatives.
Duties
of Authorized Entrant - Paragraph (h)
An authorized entrant is an employee who is authorized
by the employer to enter a permit space. Since
this individual is at the greatest risk, it is
imperative that this individual fully understand
and practice safe permit space entry procedures.
To accomplish this goal, the employer must provide
training, communicate safe work practices and
effectively implement the permit space program.
Paragraph
(h)(1) requires entrants:
- to
know the potential hazards associated within
a specific permit space,
-
to be able to recognize the signs or symptoms
of exposure and
-
to understand the consequences of exposure
to the hazards.
Paragraph
(h)(2) requires that the entrants properly
use all the equipment necessary for a safe entry
operation.
Paragraph
(h)(3) requires that the entrant communicate
with the attendant as necessary to enable the
attendant to monitor the entrant's status and
to enable the attendant to alert him/her of
the need to evacuate the space.
Note
to Employer: Depending on the types of atmospheric
contaminants that might be present within a
permit space, subtle behavioral changes detected
in the authorized entrant's speech or deviation
from set communication procedures could alert
the attendant that it is necessary for the authorized
entrant to evacuate the space or be rescued.
Additionally, the attendant needs to be able
to communicate with authorized entrants to order
them to evacuate the space in an emergency.
Paragraph
(h)(4) requires authorized entrants to alert
attendant when the entrant recognizes any warning
sign or symptom of exposure to a dangerous condition
or when the entrant detects a prohibited condition.
The entrant ensures that other entrants are
protected by informing the attendant of the
presence of these conditions, which may make
the space hazardous to other entrants as well.
Paragraph
(h)(5) through (h)(5)(iv) requires the entrant
to exit from the permit space as quickly as
possible whenever:
- the
attendant or entry supervisor orders evacuation,
- the
authorized entrant recognizes any warning
sign or symptom of exposure to a hazardous
substance,
- the
entrant detects a prohibited condition,
-
an evacuation alarm is activated.
Given
the speed with which permit space hazards can
incapacitate and kill entrants, it is essential
that the entrants evacuate permit spaces as
soon as any one of the four conditions set out
in paragraphs (h)(5)(i) through (h)(5)(iv) is
found to exist. OSHA believes that self-rescue
will often provide the entrant=s best chance
of escaping a permit space when a hazard is
present.
Note
to the Employer: Alerting other authorized entrants
can also improve their chances of escape as
well. However, there are several reasons why
OSHA is not mandating this. First, the permit
space may well be so large that the entrant
who detects a hazard cannot quickly or efficiently
communicate with other authorized entrants.
Under paragraph (i)(5), the attendant is required
to have the means of communicating with all
authorized entrants in the space. The quickest
and most effective means of ordering the evacuation
of the space is therefore normally through the
attendant. In fact, this is required under paragraph
(i)(6). Furthermore, OSHA does not believe that
it is appropriate to require one employee to
risk injury or death to warn another. While
in some cases it may be reasonable for entrants
to inform each other of the presence of uncontrolled
hazards and in other cases an employee may voluntarily
risk injury or death to warn his/her fellow
employees, OSHA has determined that the final
rule should only require authorized entrants
to inform attendants.
Duties
of Attendants - Paragraph (i)
Paragraph
(i) requires an attendant to be located
outside the permit space to monitor the status
of authorized entrants, watching for safety
hazards that may arise in and around the space,
keeping unauthorized employees away from the
space and summoning rescue services in the event
of an emergency. To accomplish this task, the
employer must ensure that the attendant is familiar
with the following information as outlined in
paragraph (i)(1) - (i)(10):
Paragraph
(i)(1) requires the attendant to know and
recognize the hazards and potential hazards
associated with the specific permit space.
Paragraph(i)(2)
requires the attendant to be aware of possible
behavioral effects of exposure to atmospheric
hazards (e.g., carbon monoxide, hydrogen sulfide,
etc.). Review material Safety Data Sheets (MSDS)
for the chemical substances contained in the
permit space.
Paragraph
(i)(3) requires the attendant to maintain
an accurate count of authorized entrants within
the permit space. The system used should quickly
enable the attendant to determine if authorized
entrants are inside the permit space.
Paragraph
(i)(4) requires the attendant to remain
outside the permit space until termination of
the entry operation or being relieved by another
authorized attendant. Additionally, the attendant
may only enter a permit space to attempt a rescue
if it is allowed under the specific permit program,
if they are properly equipped and trained and
if they are relieved by another attendant.
Paragraph
(i)(5) requires the attendant to maintain
communication with the authorized entrant to
monitor their authorized status and to alert
the entrant of any need to evacuate the space.
Subtle behavioral changes detected in the authorized
entrant's speech or deviation from a set communication
procedure could be the first signs of trouble.
Paragraph
(i)(6) requires the attendant to monitor
activities inside and outside the space to determine
if it is safe for entrants to remain in the
space or order evacuation if the attendant:
a)
detects a prohibited condition,
b)
detects behavioral effects manifested from
exposure to atmospheric hazards in the authorized
entrant,
c)
detects a condition outside the space (e.g.,
weather conditions, other work activity, etc.)
that could endanger the authorized entrants,
or
d)
cannot effectively and safely perform all
required duties of an attendant.
Paragraph
(i)(7) requires the attendant to summon
rescue and other emergency services as soon
as it is determined that an emergency exists.
Note
to the Employer: As long as the attendant is
certain that self-rescue can be performed, no
rescue summoning would be necessary. However,
if the attendant has any doubts as to whether
an authorized entrant can exit the space under
his or her own power, then the attendant is
required to summon rescue and emergency medical
services.
Paragraph
(i)(8) requires that the attendant take
the following actions when unauthorized persons
approach or enter a permit space while entry
is underway:
