This
is a sample written Permit-Required Confined
Space proced-ure provided only as a guide
to assist in complying with 29 CFR 1910.146.
It is not intended to supersede the requirements
detailed in the standards but only as
an aid in developing your procedures so
they meet the requirements of this standard.
You need to review the standard for particular
requirements which are applicable to your
specific situation. This program must
be tailored to fit your facility.
This
material and safety and health consultation
services are provided at no cost to owners,
proprietors, and managers of small businesses
by the Illinois Onsite Safety & Health
Consultation Program, Industrial Services
Division, Department of Commerce and Community
Affairs under a program funded largely
by the Occupational Safety and Health
Administration (OSHA), an agency of the
U.S. Department of Labor.
ILLINOIS ONSITE SAFETY & HEALTH CONSULTATION
PROGRAM
DEPARTMENT OF COMMERCE AND COMMUNITY AFFAIRS
DIVISION OF INDUSTRIAL SERVICES
100 West Randolph, Suites 3-400
Chicago, Illinois 60601
Phone: 312-814-2337 Fax: 312-814-7238
TDD: 800-419-0667
TABLE
OF CONTENTS
1.0 Policy
2.0
Responsibilities
3.0 Employee Participation & Access to
Information
4.0 Permit Space Identification
4
5.0 Prevention of Unauthorized Entry
6.0
Permit-Required Confined Space (PRCS)
7.0 Alternative Procedures
8.0 Reclassifying Permit Space to Non-Permit
Space
9.0
Personnel, Duties & Training for PRCS
Entry Operations
10.0
Training for Reclassification & Alternate
Procedures
11.0
Host Employer_s Responsibilities with
Contractors
12.0
Rescue and Emergency Services
13.0
Permit-Required Confined Space Program
Review
1.0
POLICY
We are committed to providing a safe and
healthful work environment for our entire
staff. Therefore, the following written
program is in place to identify any Permit-Required
Confined Spaces (PRCS) and to eliminate
or control hazards associated with PRCS
operations. This program is in accordance
with the Occupational Safety and Health
Administration's (OSHA) Permit-Required
Confined Spaces Standard, Title 29, Code
of Federal Regulations 1910.146.
2.0
RESPONSIBILITIES
Our Confined Space Co-ordinator (CSC),
Enter Company Representative's
Name , is responsible for the overall
implementation and maintenance of any
written program or any certification concerning
the requirements of the Permit-Required
Confined Space Standard at our facility.
2.1
Permit-Required Confined Space Evaluation.
All spaces are evaluated to determine
if any permit spaces are present and
the type of program required. Each space
is evaluated to determine if full permit
program is required, if the permit space
can be reclassified as a non-permit
space, or if alternative procedures
can be used.
Note
to the Employer: If you determine
that no permit-required confined spaces
exist at the facility, no further action
is needed (refer to subsection 4.0 for
additional clarification).
2.2
Training.
All affected personnel are properly
trained and refresher training is
given as needed. Personnel who may
be included are any authorized entrants,
attendants, entry supervisors, on site
rescue team members and employees
who may potentially enter the space.
2.3
Initial Contacting For Rescue Services.
Rescue and emergency services have been
informed of any permit-required confined
spaces at our facility and have been
given access to the spaces for drills,
training, ect..
Note
to the Employer: The completion of
2.4 is not a required entry if the permit
space is reclassified as a non-permit
space or if alternate procedures are used.
However, if an entry is required to verify
the elimination of the hazard, then a
full PRCS program is needed and 2.4 must
be completed.
2.4
Equipment.
All equipment needed for safe entry
into any permit spaces and non-permit
spaces is available and in proper working
order.
3.0
EMPLOYEE PARTICIPATION & ACCESS TO INFORMATION
All employees have some responsibility
for their own safety. To that end, employees
and their designated representatives are
consulted on the development and implementation
of all aspects of our program. Employees
or their designated representatives are
encouraged to observe testing or monitoring
of spaces. All testing or monitoring data,
determinations & supporting data, permits,
certifications are readily available to
any employee who enters a permit space,
or to that employee's authorized representative.
Any permit space will be retested in the
presence of an authorized entrant, or
that employee's authorized representative,
if requested because they have reason
to believe the evaluation was not adequate.
4.0
PERMIT SPACE IDENTIFICATION
4.1
The workplace has been evaluated and determined
(check box)
No Permit-Required Confined Space(s)
Exist at the Worksite.
Permit-Required Confined Space(s) Have
Been Determined to Exist.
Permit-Required
Confined Space(s)
Note to the Employer: As a reminder, a
confined space is a space which:
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 (for example, tanks, vessels,
silos, storage bins, hoppers, vaults,
and pits are spaces that may have limited
means of entry.) and;
Is
not designed for continuous employee occupancy.
A permit space is a confined space which
has one or more of the following characteristics:
1.
Contains or has a potential to contain
a hazardous atmosphere
2. Contains a material that has the
potential for engulfing an entrant
3. Has an internal configuration such
that an entrant could be trapped or
asphyxiated by inwardly converging walls
or by a floor which slopes downward
and tapers to a smaller cross-section;
or
4. Contains any other recognized serious
safety or health hazard.
If
no permit spaces are identified, no
further action is required.
4.2
The location(s) and hazard(s) posed by
these permit spaces are listed below:
Hazards ______________________Location
__________________ ____________________________________
__________________
____________________________________ __________________
Note
to the Employer: Develop a list of
all permit-required confined spaces including
their locations and identified hazard(s)
which qualify it as a permit space. Though
not mandated by the standard, it would
be wise to develop a second list of all
non-permit confined spaces in the event
that these spaces are reclassified in
the future.
5.0
PREVENTION OF UNAUTHORIZED ENTRY
5.1
For permit spaces that are identified
at our worksite, all potentially exposed
employees will be informed of their
existence and hazards. The method(s)
that will be used will be:
(check box for specific policy)
Posting
of danger signs at each permit space
reading "Danger, Permit-Required Confined
Space, DO NOT ENTER".
Other (specify) ______________________________________________
Note
to the Employer: The standard allows
any other equally effective means of informing
employees of the presence of any permit
spaces. For whatever method is chosen,
OSHA will check to ensure that the method
is effective.
5.2
It has been determined that the permit
spaces identified at our worksite:
Will
not be entered by our employees. The
following measures have been taken to
prevent employees from entering the
space(s):__________________
Will
be entered by employees of our workplace.
6.0
PERMIT-REQUIRED CONFINED SPACE (PRCS)
Note
to the Employer: A written PRCS program
is not required for:
1. Situations where alternative procedures
are used for entry. The procedures outlined
in paragraph (c)(5)(ii) are mandated and
written verification is required by (c)(5)(iii)(H).
2. Situations where a permit space is
reclassified as a non-permit space and
entry is not required to verify elimination
of all the hazards. Paragraph (c)(7)(iii)
requires employers to document that the
hazards have been eliminated.
If procedure 1 or 2 cannot be used and
if the employer determines that their
employees will enter a permit space, then
a written PRCS program is needed for each
permit space and Section 9 must be completed.
Keep in mind that a written PRCS program
is a guidance document for employers and
employees so they can develop and utilize
the procedures required for safe entry
into a permit space. An entry permit is
basically a checklist to ensure all the
steps for the safe entry have been taken
prior to entry.
The
program elements to be considered for
a full PRCS are outlined in paragraph
(d) of the standard.This program must
specify the potential hazards of the space
and the procedures needed to correct them.
These step by step procedures must include
acceptable entry conditions, isolation
methods needed, methods for eliminating
or controlling hazardous atmospheres (i.e.,
purging, cleaning, ventilation), equipment
needed, testing protocol and duties of
permit space team members.
Safe
entry procedures have been developed for
each permit space at our facility. These
procedures specify the proper methods
and equipment necessary to conduct the
entry operation in a safe manner.
A
written PRCS Program addresses the following
elements for each permit space entered:
The
methods used to prevent unauthorized
entry.
Identify
and evaluate the specific hazards
before entry.
Establish
measures for the safe control of identified
hazards such as isolation, purging,
inerting, ventilation, barricades,
lockout/tagout, etc.
Providing
and maintaining equipment necessary
for safe entry, including testing
and monitoring, ventilation, communications,
personal protection, lighting, barriers,
entry and egress, and rescue equipment.
Procedure
to test the permit space and document
results.
Procedure
to maintain acceptable conditions
in the permit space.
Identify
duties of each employee required and
provided training.
Provide
at least one attendant outside the
permit space for the duration of the
entry operations.
Implement
proper procedures for rescue.
Establish
a written system for preparation,
issuance, use and cancellation of
permits.
Coordinate
entry operations during multiple employer
entries.
Review
entire entry program at least annually,
unless previously reviewed at conclusion
of a specific entry.
7.0
ALTERNATIVE PROCEDURES
The OSHA regulations allow permit spaces
which have, as their only hazard, an actual
or potential hazardous atmosphere to use
alternative procedures for entry. These
alternative procedures do not require
the implementation of a full PRCS program.
The following is a list of permit spaces
at our workplace which currently qualify
for alternative procedures: _______________________________________________
_______________________________________________
_______________________________________________
_______________________________________________
Note
to the Employer: Refer to Attachments
for a Worksheet that can be used to certify
that alternative procedures can be used
and that the space is safe for entry.
For those employers who can demonstrate
that continuous forced air ventilation
alone is sufficient to maintain the permit
space safe for entry, only the General
Requirements - paragraph (c)(5) and Training
- paragraph (g) are required. Remember,
continuous forced air ventilation controls
the hazard, it does not eliminate it.
8.0
RECLASSIFYING PERMIT SPACE TO NON-PERMIT
SPACE
The
OSHA regulations also allow permit spaces
to be reclassified as non-permit spaces
by the total elimination of all the hazards.
A permit space can be reclassified as
a non-permit space if there are no actual
or potential atmospheric hazards and if
all the other hazards within the space
are eliminated without entry into the
space. The following is a list of permit
spaces at our workplace that can be reclassified
as non-permit spaces by the elimination
of the hazards: _________________________________________________
_________________________________________________
_________________________________________________
Note
to the Employer: If an entry is needed
to eliminate or verify the elimination
of a hazard, then a full PRCS program
is required. Once it has been determined
that all the hazards have been eliminated,
then the space can be reclassified.
9.0
PERSONNEL, DUTIES AND TRAINING FOR FULL
PRCS ENTRY OPERATIONS
9.1
Entry into any space where a full PRCS
program is mandated requires a specially
trained and equipped team. Each team consists
of an authorized entrant; attendant; entry
supervisor and rescue personnel.
Note
to the Employer: This subsection does
not apply if a full PRCS is not used.
Note that subsection 12.0 contains the
training needed when reclassifying or
alternative procedures are used.
9.2
Each member of the team receives initial
and annual refresher training. The training
is specific for the duties of each team
member and includes the procedures and
practices necessary to protect them from
the dangers of the permit space.
Note
to the Employer: Provide a training
program for employees using the information
contained in this document and any other
applicable resources. Make your training
program specific to the particular permit
space(s) to be entered. This training
must give team members the understanding,
knowledge and skills necessary for them
to safely perform their assigned duties.
9.3
Training Required for using full Permit-Required
Confined Space Procedures includes:
Types of confined space hazards
Components
of the written PRCS program
Components
of the entry permit system
Components
of the hot work permit
The
need for prompt guarding of the entrance
opening
Atmospheric
testing equipment including its use,
calibration and maintenance
Atmospheric
testing protocol: oxygen, combustibles,
toxics; pre-entry, frequent or continuous
testing; check all levels of the space
Methods
for the control or elimination of
any atmospheric hazards: inerting;
draining and rinsing; purging and
cleaning; continuous forced air ventilation
Procedures
the employees must follow if they
detect a hazard
The
evaluation process to be used for
reentry if hazards are detected
Train
employees on the use of entry equipment
(e.g., ladders, communication devices,)
Personal
protective equipment required: full
body harness; respiratory protection;
chemical protective clothing; eye
and face protection
Personnel
and their responsibilities: authorized
entrant; attendant; entry supervisor;
rescue team
On site
or Off-site rescue:rescue plan; practice
rescues; basic first-aid and cardiopulmonary
resuscitation certification; full
body harness with retrieval line attached
to mechanical retrieval device
Procedures
for annual review of canceled permits
Any
other information necessary to ensure
employee safety during a permit space
entry operation
Documentation
of the training
Note
to the Employer: The training required
depends on the specific permit space to
be entered and the procedures which are
needed to protect entrants. The information
provided in this training subsection is
a generalization of the topics which must
be covered during employee training.
9.4
In addition, the training program for
authorized entrants includes:
Know the hazards associated with the
permit space and their effects.
Properly
use the equipment required for entry.
Maintain
a continuous means of communication
with the attendant.
Alert
the attendant in the event of an emergency.
Evacuate
the space if an emergency occurs.
9.5
In addition, the training program for
attendants includes:
Know the hazards associated with the
permit space and their effects.
Maintain
an accurate account of the authorized
entrants.
Remain
at their assigned station until relieved
by another attendant or until the
permit space is complete.
Monitor
conditions in and around the permit
space.
Summon
rescue and applicable medical services
in the event of an emergency.
Perform
non-entry rescue procedures.
Perform
appropriate measures to prevent unauthorized
personnel from entering the permit
space.
9.6
In addition, the training program for
entry supervisors includes:
Know the hazards associated with the permit
space and their effects.
Verify
that the safeguards required by the permit
have been implemented.
Verify
that rescue services are available and
that means for summoning them are operable.
Cancel
the written permit and terminate the permit
space entry when required.
Remove
personnel who are not authorized to enter
the permit space during entry operations.
Periodically,
determine that the entry operation is
being performed in a manner consistent
with the requirements of the permit space
entry procedures and that acceptable entry
conditions are maintained.
9.7
In addition, the training program for
rescue personnel includes:
Permit space recognition;
Permit
space hazards;
Control
of permit space hazards;
Atmospheric
monitoring equipment and testing protocol;
Use
and maintenance of personal protective
equipment;
Rescue
equipment;
Simulation
of permit space rescues and required rescue
techniques;
Basic
first aid and cardiopulmonary resuscitation
(CPR);
Requirements
stated in paragraph (k) and (g) of 1910.146.
Note
to Employer: Again, the training required
is dependent on the specific space to
be entered and the procedures needed to
protect entrants. The information provided
in this training subsection is a generalization
of the topics which must be covered during
employee training. See also section 10.
Additionally, document employees' training
and refresher training. This certification
simply requires the employees' names,
the signatures or initials of the trainers
and the dates of the training.
9.8
The following is a list of employees who
have been equipped and trained to serve
as authorized entrants, attendants, entry
supervisors or rescue personnel at our
facility: