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. Each confined space entry program will include a written plan containing various policies, processes, procedures and safe work practices.
An effective confined space program will contain many important elements. Each of the elements should be described 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!
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:
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, permit space has one or more of the characteristics listed below.
Take a look at the Confined Space Decision Tree to help determine if you have permit or non-permit confined spaces.
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 measure.
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.
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 order listed below:
Never assume a confined space is hazard-free. Non-atmospheric hazards include conditions such as:
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.
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.
You must train entry procedures and practices for the specific space being entered. The training must specify the 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.
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:
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