Permit Space Program (PSP)
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Confined space operations in construction are guided by a formal written Permit Space Program (PSP) that sets policies, processes, procedures, practices that:
- identify confined spaces and the hazards they may contain;
- allow employers to organize the work to avoid entry into a potentially hazardous space;remove hazards prior to entry to avoid employee exposure;
- restrict entry through a permit system where employers cannot remove the hazard;
- provide appropriate testing and equipment when entry is required; and
- arrange for rescue services to remove entrants from a confined space when necessary.
Employers must consult with affected employees and their authorized representatives on the development and implementation of all aspects of the PSP. They must also make available to each
affected employee and his/her authorized representatives all required PSP information by OSHA.
Under the PSP, the employer must develop and implement means, procedures, and safe practices necessary to assure safe permit space operations and prevent unauthorized entry to confined spaces.
They must also Identify and evaluate the hazards of permit spaces before employees enter them.
Means, Procedures, and Practices
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The employer must develop and implement the means, procedures, and practices in the PSP that, as a minimum, do the following:
- specifies acceptable entry conditions;
- provides each authorized entrant or that employee's authorized representative with the opportunity to observe any monitoring or testing of permit spaces;
- Isolates the permit space and physical hazard(s) within the space;
- uses purging, inerting, flushing, or ventilating the permit space as necessary to eliminate or control atmospheric hazards. When an employer is unable to reduce the atmosphere below 10
percent of the Lower Flammability Limit (LFL), the employer may only enter if the following three conditions are met:
- the employer inerts the space so as to render the entire atmosphere in the space non-combustible,
- employees use PPE to address any other atmospheric hazards (such as oxygen deficiency), and
- the employer eliminates or isolates all physical hazards in the space.
- determines that, in the event the ventilation system stops working, the monitoring procedures will detect an increase in atmospheric hazard levels in sufficient time for the entrants to
safely exit the permit space;
- provides pedestrian, vehicle, or other barriers as necessary to protect entrants from external hazards;
- verifies that conditions in the permit space are acceptable for entry throughout the duration of an authorized entry;
- ensures that employees are not allowed to enter into, or remain in, a permit space with a hazardous atmosphere unless the employer can demonstrate that personal protective equipment (PPE)
will provide effective protection for each employee in the permit space and provides the appropriate PPE to each employee; and
- Eliminates any conditions (for example, high pressure) that could make it unsafe to remove an entrance cover.
Confined Space Equipment
Barriers and shields as required in confined spaces.
The employer must provide PSP equipment at no cost to each employee, maintain that equipment properly, and ensure that each employee uses that equipment properly. Equipment for use under the PSP includes:
- Hazardous atmosphere testing and monitoring equipment;
- Ventilating equipment needed to obtain acceptable entry conditions;
- Communications equipment including any necessary electronic communication equipment for attendants assessing entrants' status in multiple spaces;
- Personal protective equipment insofar as feasible engineering and work-practice controls do not adequately protect employees;
- Lighting equipment that meets the minimum illumination requirements and is approved for the ignitable or combustible properties of the specific gas, vapor, dust, or fiber that will be present,
and that is sufficient to enable employees to see well enough to work safely and to exit the space quickly in an emergency;
- Barriers and shields as required;
- Equipment, such as ladders, needed for safe ingress and egress by authorized entrants;
- Rescue and emergency equipment;
- Any other equipment necessary for safe entry into, safe exit from, and rescue from, permit spaces.
Permit Space Evaluation Procedures
Confined Spaces: Test to Live
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The employer must use the following procedures to evaluate permit space conditions whenever entry operations are conducted.
Test conditions in the permit space to determine if acceptable entry conditions exist before changes to the space's natural ventilation are made, and before entry is authorized to begin.
If the employer proves that isolation of the space is infeasible because the space is large or is part of a continuous system (such as a sewer), the employer must:
- Perform pre-entry testing to the extent feasible before entry is authorized; and,
- If entry is authorized, continuously monitor entry conditions in the areas where authorized entrants are working.
- If the employer can prove that equipment for continuously monitoring that hazard is not commercially available, periodic monitoring of the permit space atmosphere may be used in accordance
- Provide an early-warning system that continuously monitors for non-isolated engulfment hazards. The system must alert authorized entrants and attendants in sufficient time for the authorized
entrants to safely exit the space.
- Continuously monitor atmospheric hazards unless it can be proved that the equipment for continuously monitoring a hazard is not commercially available or that periodic monitoring is of
sufficient frequency to ensure that the atmospheric hazard is being controlled at safe levels. If used, periodic monitoring frequency enough to ensure acceptable entry conditions are being
maintained during the course of entry operations.
Testing for Hazardous Atmospheres
It is imperative that each authorized entrant or employee's authorized representative monitor the confined space for atmospheric testing.
The employer should follow these procedures when testing for hazardous atmospheres within a permit space:
- Test for hazardous atmospheres in the following order:
- Oxygen level
- Flammable/combustible gases and vapors
- Toxic gases and vapors
To help you remember this order, just remember "OFT".
- Provide each authorized entrant or that employee's authorized representative an opportunity to observe the pre-entry and any subsequent testing or monitoring of permit spaces;
- Re-evaluate the permit space in the presence of any authorized entrant or that employee's authorized representative who requests that the employer conduct such reevaluation because
there is some indication that the evaluation of that space may not have been adequate; and,
- Immediately provide each authorized entrant or that employee's authorized representative with the results of any testing conducted.
Entry Team Designation
Designate each person who is to have an active role in entry operations.
The employer must do the following:
- designate each person who is to have an active role (as, for example, authorized entrants, attendants, entry supervisors, or persons who test or monitor the atmosphere in a permit space) in
- identify the duties of each such employee, and
- provide each team member adequate required training.
Permit Space Attendants
The employer should provide at least one attendant outside the permit space into which entry is authorized for the duration of entry operations. Some important points to remember include:
- Attendants may be assigned to more than one permit space provided the duties can be effectively performed for each permit space.
- Attendants may be stationed at any location outside the permit space as long as the duties can be effectively performed for each permit space to which the attendant is assigned.
- If multiple spaces are to be assigned to a single attendant, the employer must include in the permit program the means and procedures to enable the attendant to respond to an emergency affecting
one or more of those permit spaces without distraction from the attendant's responsibilities.
Note: Proving that an attendant can monitor multiple permit spaces without distraction will prove to be difficult. Don't attempt to do this unless you are certain that the procedures will work.
Rescue and Emergency Services
Develop and implement procedures for summoning rescue and emergency services.
Develop and implement procedures for summoning rescue and emergency services (including procedures for summoning emergency assistance in the event of a failed non-entry rescue), for rescuing
entrants from permit spaces, for providing necessary emergency services to rescued employees, and for preventing unauthorized personnel from attempting a rescue.
Administering Entry Permits
Develop and implement a system for the preparation, issuance, use, and cancellation of entry permits as required by this standard, including the safe termination of entry operations under
both planned and emergency conditions.
Coordinating Multi-Employer Entry Operations
The employees of one employer must not endanger the employees of another employer while working in a permit space. When employees of more than one employer are working simultaneously in a
permit space or elsewhere on the worksite the employer must:
- develop and implement procedures to coordinate multi-employer entry operations
- consult multi-employer permit space operations with the controlling contractor
Concluding Work in the Space
The employer must review entry operations when the measures taken under the permit space program may not protect employees.
The employer must develop and implement procedures (such as closing off a permit space and canceling the permit) necessary for concluding the entry after entry operations have been completed.
Confined Space Program Review
The employer must review entry operations when the measures taken under the permit space program may not protect employees. If deficiencies are found, the employer must revise the program to
correct deficiencies found to exist before subsequent entries are authorized.
Examples of circumstances requiring the review of the permit space program include, but are not limited to:
- any unauthorized entry of a permit space,
- the detection of a permit space hazard not covered by the permit,
- the detection of a condition prohibited by the permit,
- the occurrence of an injury or near-miss during entry,
- a change in the use or configuration of a permit space, and
- employee complaints about the effectiveness of the program.
Review of the permit space program, using the canceled permits should occur within 1 year after each entry. The permit space program should be revised as necessary to ensure employees participating
in entry operations are protected from permit space hazards.
Employers may perform a single annual review covering all entries performed during a 12-month period. If no entry is performed during a 12-month period, no review is necessary.
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