Before workers enter a permit space, you must ensure that the hazards associated with the space have been eliminated or controlled.
A completed entry permit verifies that hazards have been eliminated or controlled and the permit space is safe. The entry supervisor must certify that the space is safe to enter, sign the entry permit, and post it on the space so that authorized entrants can see it.
Host Employer Communications: The host employer owns or manages the property where the construction work is taking place. Before permit space entry operations begin, the host employer must provide the following three items of information, if it has it, to the controlling contractor:
Controlling Contractor Communications: The controlling contractor has overall responsibility for construction at the worksite. If the controlling contractor owns or manages the property, then it is both a controlling employer and a host employer. Before entry operations begin, the controlling contractor must:
If there is no controlling contractor present at the worksite, the controlling contractor's role and responsibilities must be fulfilled by the host employer or other employer who arranges to have employees of another employer perform work that involves permit space entry.
Entry Employer Communications: The entry employer is usually a subcontractor who decides that an employee it directs will enter a permit space. Before entry operations begin, each entry employer must:
Coordination between the Controlling Contractor and Entry Employer: The controlling contractor and entry employer(s) must coordinate entry operations when:
Essential requirements to establish safe entry conditions into a permit space including:
Guarding the space: Use warning signs or barriers at entry locations to keep out unauthorized people and to protect entrants from falling objects.
Isolating the space: Disconnect, lock out, or tag out hazardous equipment in the space. If you lock out equipment, remember that “lock out” includes testing to ensure the lockout method works.
Testing the space for hazardous atmospheres: Test the atmosphere from outside the space for all potential atmospheric hazards, which may include oxygen; flammable gasses, dusts, or vapors; toxic gasses or vapors; and corrosive atmospheres. Provide entrants with test results. Re-test the space if an entrant believes that initial testing was inadequate.
Eliminating or controlling hazardous atmospheres: Eliminate or control the hazards in the space then document the method and the steps necessary to eliminate or control the hazards. Allow entrants to observe testing, monitoring, and any other activity necessary to eliminate or control hazards.
For permit spaces that are deep or have areas leading away from the entry point, the atmosphere may be layered or may be different in remote areas. For these spaces, testing must be done in the area surrounding the worker, which is considered four (4) feet in the direction of travel and to each side. If a sample probe is used to do the testing, then the worker must move slowly enough so that testing is completed, keeping the equipment "response time" in mind, before he/she moves into the new area.
Providing necessary equipment: Ensure the entrants have the equipment they need to do their jobs (including rescue equipment) and they know how to use the equipment.
Planning for emergencies: Attendants must know how to respond to emergencies, including who to contact and how to remove entrants.
You must have all necessary equipment to ensure safe entry into permit spaces. This equipment can include:
The equipment must be available to the employees at no cost, must be used in accordance with the instructions from the manufacturer, and the employees must be trained to use it properly.
Before the employer can use alternate permit space entry procedures, the employer must prove with supporting monitoring and inspection data that:
If the employer can meet the above conditions, entry into permit spaces is allowed using the following procedure:
Prior to entry, test for each of these conditions in the following order:
Allow all permit space entrants to observe the pre-entry testing and results prior to entry.
Be sure to comply with the following requirements for using continuous forced air ventilation:
It's critically important to monitor the atmosphere within a permit space to make sure it's safe for employees. Monitoring must ensure forced air ventilation is preventing the development of a hazardous atmosphere.
Be sure to always continuously monitor the atmosphere within the space unless one of the following two conditions are met:
Make sure the monitoring equipment has an alarm to notify all entrants if a specified atmospheric threshold is achieved, or that an employee will frequently check the monitor to make sure employees have time to escape. Periodic monitoring is always required if continuous monitoring is not used.
Ensure employees or their authorized representatives are able to observe monitoring and testing as desired.
It's important to quickly evacuate the space if any kind of hazard is detected. If a hazard is detected during entry or work be sure to do the following:
It's important to understand that control of atmospheric hazards through forced air ventilation does not constitute elimination or isolation of the hazards unless the employer can prove that forced air ventilation alone will control all hazards in the space.
Make sure a safe method of entering and exiting the space is used. If a hoisting system is used, it must be designed and manufactured for personnel hoisting; however, a job-made hoisting system is permissible if it is approved for personnel hoisting by a registered professional engineer, in writing, prior to use.
Prior to entry, certify in writing that the space is safe for entry and that required pre- entry measures have been taken.
Make sure a competent person reevaluates the non-permit space and, if necessary, reclassify it as a permit space when any of the following two conditions exist:
A permit space may only be reclassified as a non-permit confined space when a competent person determines that each of the following requirements are met:
If hazards arise within a permit space that has been reclassified as a non-permit space, each employee in the space must exit the space. The entry employer must then reevaluate the space and reclassify it as a permit space as appropriate.
The permit space may be reclassified as a non-permit confined space for as long as testing and inspection demonstrates that the hazards within the permit space have been eliminated or isolated.
Controlling Contractor Communications: The controlling contractor must debrief each entity that entered a permit space regarding the permit space program followed and any hazards confronted or created in the permit space(s) during entry operations.
The controlling contractor must also apprise the host employer of the information exchanged with the entrants.
Entry Employer Communications: The entry employer must inform the controlling contractor in a timely manner of the permit space program followed and of any hazards confronted or created in the permit space(s) during entry operations.
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