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This material is for training purposes only to inform the reader of occupational safety and health best practices and general compliance requirements and is not a substitute for provisions of the OSH Act of 1970 or any governmental regulatory agency.
MODULE 2: CONFINED SPACE PROGRAM ELEMENTS

Introduction

Now that we've covered some of the basic concepts we'll discuss the various components of a confined space entry program. If you allow employees entry into a permit space, you must develop and implement a written plan as part of your confined space entry program.

Elements of the confined space program

An effective confined space program will contain many important elements. Each of the elements should be describe in a written plan that includes a permit system. The items on the permit address the components of your written plan to ensure safety and health of all involved!

What is the written plan?

The written plan is an important element of the Confined Space Program because it helps to clarify what everyone is supposed to do and how to do it (a recurring theme). If everyone understands their duties and responsibilities, and is able to perform in a professional manner, the likelihood of serious accidents will decrease significantly. The written confined space safety plan should address the following:
  • Identification of confined spaces
  • Evaluation of permit spaces and hazards
  • Development & implementation of safe entry operations
  • Providing and maintaining all necessary equipment (PPE, monitors, etc.)
  • Evaluating permit space conditions before & during entry operations
  • Confined space entry team duties (authorized entrants, attendants, entry supervisors)
  • Procedures for multiple spaces
  • Confined space entry and rescue training
  • Rescue & emergency procedures
  • Entry permit procedures (issue, use, cancel)
  • Measures implemented to prevent unauthorized entry
  • Multi-employer entry procedures
  • Procedures for concluding the entry (closing off the space)
  • Review & evaluation of entry operations during the year (as needed)
  • Annual permit space program review using the historic permits
Workplace evaluation procedures

The first step in confined space program development is to identify confined spaces. Next, evaluate each confined space to determine if it is a permit space. Keep in mind that a permit space has one or more of the following characteristics:

  1. Contains — or could contain — an atmospheric hazard.
  2. Contains material that could trap or bury an entrant.
  3. Is shaped such that an entrant could become trapped or asphyxiated.
  4. Contains any other safety or health hazard that could harm an entrant.

Take a look at the Confined Space Decision Tree to help determine if you have permit or non-permit confined spaces.

Warning signs

Confined Space Warning Sign If a workplace contains permit spaces, the employer must inform exposed employees of their existence, location and the hazards they pose. When your employees will not enter confined spaces, you must place warning signs that prohibit entry and take other effective measures that prevent them from entering confined spaces. This can be done by posting danger signs such as "DANGER -- PERMIT-REQUIRED CONFINED SPACE -- AUTHORIZED ENTRANTS ONLY" or using an equally effective means.

Usually "effective measures" means making sure employees can't get into the confined space without unlocking or unbolting a hatch. It should not be easy to get in to a confined space. Hatches and covers must be relatively difficult to open.

Hazard identification procedures

Identify and evaluate permit space hazards before allowing employee entry. This should be done initially and prior to each entry if the space is designated a confined space. You must identify all existing or potential hazards in each permit space at your workplace. Those who enter permit spaces face two kinds of hazards: atmospheric and non-atmospheric. Atmospheric hazards affect the air in the space and can be flammable, toxic, corrosive, or asphyxiating.

Test atmospheric conditions in the permit space before entry operations and monitor the space during entry. Always test the atmosphere as most confined space injuries and fatalities are caused by hazardous atmospheres. Be especially careful when evaluating a space that could contain an atmospheric hazard! The only way to identify an atmospheric hazard is to test for it from outside the space.

Perform appropriate testing for the following atmospheric hazards in this sequence: oxygen, combustible gases or vapors, and toxic gases or vapors. Remember "O-F-T" and you can't go wrong.

Always test for atmospheric hazards in the following order:
  1. O - oxygen deficiency, enrichment or displacement
  2. F - flammable or explosive atmospheres
  3. T - toxic or corrosive atmospheres

Never assume a confined space is hazard-free. Non-atmospheric hazards include conditions such as:
  • mechanized equipment
  • loose materials
  • excessive noise
  • extreme temperatures
  • low light
  • difficult access
  • psychological stress

Procedures and practices

Once you analyze and determine the hazards and nature of the external and internal environment, you must develop procedures and practices to make sure the work is safe. Establish and implement the means, procedures and practices to eliminate or control hazards necessary for safe permit space entry operations. Have ways to eliminate the hazards if they're detected. Identify employee job duties. Entry supervisors, attendants and authorized entrants must know their jobs. We'll cover all of these topics in future modules.

Review established entry operations annually and revise the permit space entry program as necessary. An annual review and refresher training is important. Practice rescue if you have a team at least annually.

Entry permit system

Establish, in writing, and implement a system for the preparation, issue, use and cancellation of entry permits. If it meets the requirements for a permit, you must complete the permit before entry. An entry permit must be developed and used for each entry into a permit-required confined space.

Employee training for authorized entrants, attendants, and entry supervisors

You must train entry procedures and practices for the specific space being entered. The training must specify confined space entry team (supervisor, attendant, and entrant) duties and responsibilities. Ensure that at least one attendant is stationed outside the permit space for the duration of entry operations. Coordinate entry operations when employees of more than one employer are working in the permit space. Typically the Entry Supervisor does this. You'll read more about confined space entry team duties and responsibilities in Module 7.

Controlling confined space hazards

Your written confined space plan should establish the means, procedures and practices to eliminate or control hazards necessary for safe permit space entry operations. These may include:

  • Specifying acceptable entry conditions;
  • Isolating the permit space;
  • Providing barriers;
  • Verifying acceptable entry conditions; and
  • Purging, making inert, flushing or ventilating the permit space.
Equipment and Resources for safe entry

The employer must provide and maintain, at no cost to the employee, confined space entry tools, equipment, materials and whatever it takes to make sure they are safe while working in a confined space. The employer must also insist that employees use the confined space entry equipment they have been provided. Don't do confined space entry "on the cheap" as it could kill a worker. A quality personal protective equipment program will pay for itself in the long term.

Once again, providing work equipment and PPE at no cost to employees is an absolute must do. In addition to personal protective equipment, other equipment that employees may require for safe entry into a permit space includes:
  • Testing, monitoring, ventilating, communications and lighting equipment;
  • Barriers and shields;
  • Ladders; and
  • Retrieval devices.
A measurement system

You must develop and deploy a system to ensure that pre-entry testing is performed, pre-entry preparation is completed, and acceptable conditions are attained. Typically a periodic audit of the confined space entry plan, procedures, and observation of practices will help to continually improve the confined space program.

Confined Space Rescue Plan

Implement appropriate procedures for summoning rescue and emergency services, and preventing unauthorized personnel from attempting rescue. You're either going to have your own rescue team, or rely on a 911 emergency rescue service. If your company doesn't rely on emergency responders (911 system), you must develop and deploy your own rescue team. The rescue team must be trained, and practice drills should be conducted at least annually.

Implement the procedures that any attendant who is required to monitor multiple spaces will follow during an emergency in one or more of those spaces. The attendant must be able to perform "non-entry" rescue. The attendant is not supposed to enter the confined space to rescue a worker. Most confined space fatalities are rescuers!

Annual Program Evaluation

It's important to review and evaluate the components of the confined space entry program. Make sure you review established entry operations annually and revise the permit space entry program as necessary. Evaluate the written plan and the procedures to see how well they work. To do that, make sure you observe confined space entry procedures, interview confined space team members, and review permits and training records.



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