CONFINED SPACE ENTRY

WRITTEN PLAN

The State University College at Oneonta is committed to provide a safe and healthful work environment for our entire staff. In pursuit of this endeavor, the following written program is in place to first 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 Administrations (OSHA) Permit-Required Confined Spaces Standard, Title 29, Code of Federal Regulations 1910.146.

RESPONSIBILITIES

OVERALL PROGRAM RESPONSIBILITY

The Environmental Health and Safety Officer 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.

PERMIT-REQUIRED CONFINED SPACE EVALUATION

The Environmental Health and Safety Officer is responsible for evaluating the workplace to determine if any permit spaces are present.

The Environmental Health and Safety Officer will be responsible for determining if a PRCS program is required, or if the permit space can be reclassified as a non-permit space, or if alternative procedures can be used.

TRAINING

The Environmental Health and Safety Officer is responsible for ensuring that all affected personnel are properly trained and that refresher training is given. Personnel who may be included are any authorized entrants, attendants, entry supervisor, on-site rescue team members, and employees who may potentially enter the space.

INITIAL CONTRACTING FOR RESCUE SERVICES

The Environmental Health and Safety Officer will ensure that rescue and emergency services have been informed of any permit-required confined spaces at SUCO and have been given access to the spaces for drills, training, etc.

EQUIPMENT

The Director of Physical Plant will ensure that all equipment needed for safe entry into any permit spaces and non-permit spaces is available and in proper working order.

PERMIT SPACE IDENTIFICATION

The Environmental Health & Safety Officer has evaluated the workplace and determined that Permit-Required Confined Spaces have been determined to exist.

The locations and hazards posed by these permit spaces are listed below:

PREVENTION OF UNAUTHORIZED ENTRY

If permit spaces are identified at our worksite, the Environmental Health & Safety Officer will inform exposed or potentially exposed employees of their existence and hazards.

PERMIT-REQUIRED CONFINED SPACE (PRCS)

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 Permit Space Entry Procedure Worksheet has been completed for each permit space by the Environmental Health & Safety Officer.

Each permit request shall address the following elements:

• 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 provide 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 employee entries.
• Review entire entry program at least annually, unless previously reviewed at conclusion of a specific entry.

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 as discussed in Section I do not required the implementation of a full PRCS program. the following is a list of permit spaces at our workplace which currently qualify for alternative procedures:

Telecommunications Manholes
Electrical Manholes (for inspections & other occupancies when electrical equipment is not being worked on or otherwise disrupted.)

RECLASSIFYING PERMIT SPACE TO NON-PERMIT SPACE

The OSHA regulations also allows 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. Information on reclassifying permit spaces to non-permit spaces is discussed in Section I. 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.

NONE

PERSONNEL, DUTIES AND TRAINING FOR FULL PERMIT-REQUIRED CONFINED SPACE ENTRY OPERATIONS

Entry into any PRCS where a full PRCS program is mandated will require a specially trained and equipped team. Each team will consist of an:

• authorized entrant
• attendant
• entry supervisor

The training program will include the duties of each team member as listed below:

AUTHORIZED ENTRANTS

• 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.

ATTENDANTS

• 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 entry 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.

ENTRY SUPERVISORS

• 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.

RESCUE PERSONNEL

SUCO will utilize the City of Oneonta Fire Department.

Training is needed on the following topics:

• 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:

1. oxygen, combustibles, toxins
2. pre-entry
3. check all levels of the space

• Methods for the control or elimination of any atmospheric hazards:

1. Inerting
2. Draining and rinsing
3. Purging and cleaning
4. 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, etc.
• Personal protective equipment:
• full body harness

1. respiratory protection
2. chemical protective clothing
3. eye and face protection
1. Personnel and their responsibilities:

1. authorized entrant
2. attendant
3. entry supervisor
4. rescue team

N. On-site or Off-site rescue:

1. Rescue Plan
2. practice rescues
3. basic first-aid and cardiopulmonary resuscitation certification
4. 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.

AUTHORIZED ENTRANTS TRAINER DATE OF TRAINING

The following is a list of employees who have been equipped and trained to service as attendants:

ATTENDANTS TRAINER DATE OF TRAINING

The following is a list of employees who have been trained to serve as entry supervisors:

ENTRY SUPERVISOR TRAINER DATE OF TRAINING

HOST EMPLOYER'S RESPONSIBILITIES WITH CONTRACTORS

Contractors are responsible for the safety of their own employees.When contractors are involved in permit space entry work at our workplace, the Environmental Health & Safety Officer will inform them of the following information and assist in any entry operations:

The location of the permit spaces at our facility and that entry into these spaces is only allowed through a permit space program or alternative procedures or space reclassification.
Precautions that we have implemented to protect employees working in or near the space.

When any contractor is hired to perform work in a PRCS, the contractor will obtain the following information from the host employer and ensure the following tasks are performed:

• Obtain any information on the hazards of the permit space and information from previous entry operations from the host employer.
• Determine if the host employers workers will be working in or near the space.
• If the host employer will have employees working in or near the space during our entry operation, the contractor will coordinate entry operations with the host employer's representative.
• Will inform the host employer of the permit space program that will be utilized.
• Hold a debriefing conference at the completion of the entry operation or during the entry operation (if needed) to inform the host employer of any hazards confronted or created.

The precautions and procedures outlined in our written PRCS program are designed to ensure that our employees are safe while working in permit spaces. Under no circumstances do we expect our employees to enter a permit space where hazards have not been eliminated or effectively controlled.

SUCO has contracted with the Oneonta City Fire Department for off-site rescue and emergency services.

NAME OF RESCUE SERVICE: Oneonta Fire Department
TELEPHONE NUMBER: 607-432-2222
LOCATION: Main Street, Oneonta
APPROXIMATE RESPONSE TIME: 5 minutes
NAME OF EMERGENCY MEDICAL SERVICE - Oneonta Fire Department

TRAINING

Training must be given to each employee who has access or potential access to a permit space. The amount and type of training needed will depend on the individual's duty assignment. For example, some employees may only be required to know the existence, location, and danger posed by a permit space. Others would need considerably more training if they are members of a PRCS team. Still others would need training as it pertains to the type of entry procedures used (i. e., alternative procedures or reclassifying to non-permit space procedures.) The overall intent of this training is to give employees the understanding, knowledge, and skills necessary for the safe performance of their assigned duties in relation to the permit spaces of concern.

Four basic categories have been set up to train employees based on duties and potential exposure.

AWARENESS TRAINING - Awareness training for employees potentially exposed to permit spaces can be satisfied by providing them with the specific information contained in this document.

TRAINING REQUIRED FOR USING ALTERNATIVE PROCEDURES - If the space qualifies for alternative procedures, training on the following topics is warranted:

• A major point concerning the use of alternative procedures is that these procedures can only be used when a hazardous atmosphere is the only hazard of concern.
• The harm associated with the atmospheric hazards of concern including their acceptable entry levels and symptoms of overexposure.
• Awareness training to recognize other potential hazards in or around the space.
• Any conditions which may make it unsafe to remove the entrance cover.
• The need for prompt guarding of the entrance opening.
• Atmospheric testing protocol for oxygen, combustibles, toxins.
• Pre-entry, frequent or continuous testing of the permit space.
• Check all levels of the space for atmospheric hazards.

1. inerting
2. draining and rinsing
3. purging
4. continuous forced air ventilation including type, proper use and placement, and its limitations

Procedures the employee must follow if a hazardous atmosphere is detected.

The evaluation process to be used for reentry if a hazardous atmosphere is detected or the individual vacates the space and returns some time later.

Train employees on the use of entry equipment used including ladders and intrinsically safe lighting.

Personal protective equipment (e.g., gloves, hard hats, boots, etc.), its use, limitation, and required maintenance.

A review of the completed written certification form with the employee prior to entering the pace.

Any process which may introduce a hazard (e.g., welding, cleaning with chemical solvents, etc.) which would Prohibit use of alternative procedures.

Requirements of this document must be reviewed with the employee.

Any other information needed to ensure the safety of the employee.

The documentation of the training.

• Documentation of the elimination of the hazards. If the elimination of the hazards or verification of elimination requires employees to enter the space, then a full PRCS program is needed.
• Train employee on the hazards associated with the space (i.e., mechanical, chemical, atmospheric) and the methods needed to eliminate the hazards such as:

1. Isolation techniques
2. Lockout/Tagout
3. Disconnection and misalignment of pipes
4. Double block and bleed
5. Blanking and blinding
6. Removal of engulfment hazards
7. Elimination of hazardous atmosphere by draining, inerting, purging, cleaning, venting
8. Train employees on the use of entry equipment used including ladders, ground fault circuit interrupters for electrical equipment, etc.
9. Personal protective equipment (e.g., gloves, hard hat, boots, etc.) including its use, limitations, and required maintenance. A review of the completed written certification form with the employee entering the space.

• Inform employees that any procedures such as welding, cleaning with a chemical, etc. would negate the reclassification and convert the space back to a permit space.
• Any conditions which may make it unsafe to remove entrance cover.
• The need for prompt guarding of the entrance opening.
• Atmospheric testing equipment including its use, method of calibration, and maintenance.
• Atmospheric testing protocol
  
  1. oxygen, combustibles, toxins
  2. Pre-entry, frequent or continuous testing
  3. Check all levels of the space

• Procedures the employee will follow if a hazard is detected.
• The evaluation process to be used for re-entry if a hazard is detected or the individual vacates the space and returns some time later.
• Awareness training to recognize other potential hazards in or around the space.
• The documentation of the training