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Confined Space Standard

 

Permit Required Confined Space Entry Program

GENERAL COMPANY POLICY

PURPOSE

The purpose of this program is to inform interested persons, including employees, that HOPE COLLEGE is complying with the OSHA Confined Space Standard, Title 29 Code of Federal Regulations 1910.146. We have determined that this workplace needs written procedures for the evaluation of confined spaces, and where permit-required spaces are identified, we have developed and implemented a permit-required confined space entry program. This program applies to all work operations at HOPE COLLEGE where employees must enter a permit-required confined space as part of their job duties.

The DIRECTOR OF OCCUPATIONAL HEALTH AND FIRE SAFETY has overall responsibility for coordinating safety and health programs at Hope College. The Maintenance Supervisor is the person having overall responsibility for the Permit-Required Confined Space Program. The Occupational Health and Fire Safety Director, will review and update the program, as necessary.


SCOPE:

Under this program, we identify permit-required spaces in HOPE COLLEGE, and provide training for our employees according to their responsibilities in the permit space. These employees receive instructions for safe entry into our specific type of confined spaces, including testing and monitoring, appropriate personal protective equipment, rescue procedures, and attendant responsibilities. This program is designed to ensure that safe work practices are utilized during all activities regarding the permit space to prevent personal injuries and illnesses that could occur.

If, after reading this program, you find that improvements can be made, please contact the DIRECTOR OF OCCUPATIONAL HEALTH AND FIRE SAFETY or Maintenance Supervisor. We encourage all suggestions because we are committed to creating a safe workplace for all our employees and a safe and effective permit-required confined space entry program is an important component of our overall safety plan. We strive for clear understanding, safe work practices, and involvement in the program from every level of the company.


HAZARD EVALUATION FOR CONFINED SPACES

To determine if there are permit-required confined spaces in HOPE COLLEGE, the Director of Occupational Health and Fire Safety. has conducted a hazard evaluation of our workplace. This evaluation has provided us with the information necessary to identify the existence and location of permit-required confined spaces in our workplace that must be covered by the Permit-Required Confined Space Entry Program. This written hazard evaluation is kept in the Department of Occupational Health and Fire Safety, Public Safety Building. A copy of this evaluation is also attached to this Policy.


PREVENTING UNAUTHORIZED ENTRY

To provide a safe work environment and to prevent exposed employees from accidentally entering a permit space, we have implemented the following procedures to inform all employees of the existence, location, and danger posed by permit spaces in HOPE COLLEGE. To inform employees of the existence of a permit space, signs have been placed at permit required confined space entrances. Employees can also become familiar with which spaces are considered Permit Required Spaces by familiarizing themselves with the Survey Results from Dell Engineering and attached map of the campus. Areas designated on this map as Permit Required Spaces must follow the instructions in this policy. Copies of this survey can be obtained in the Maintenance Office or by contacting the Occupational Health and Fire Safety Department at Public Safety . To ensure that unauthorized employees do not enter and work in permit spaces, Danger signs shall be posted near the entrance to all Permit Required confined spaces designating them as off limits to unauthorized employees.


SAFE PERMIT SPACE ENTRY PROCEDURES

The Maintenance Supervisor, is the Entry Supervisor responsible for authorizing entry and issuing entry permits for work in our permit spaces. The file of permits and related documents are kept in Maintenance Department, Maintenance Supervisors Office or Main Office. The procedures we follow for preparing, issuing, and canceling entry permits includes the following elements:

  1. Work to be done in confined spaces must be forwarded to the Maintenance Supervisor. The maintenance supervisor will fill out the entry permit and give a copy to the employees who will be entering the space. Once work has been completed or the space has been secured again the permit shall be handed into the Maintenance Supervisor so it can be closed.

  2. Any further work in the confined space will require another permit to be issued.

  3. These are the employees who have current authorization to work in or near our permit spaces. This list also includes the work activities they are expected to perform Dave Dubois, Carl Meyer, Ken Aalderink, Randy Vereeky, Rick Middlecamp, Dave Vincent, Jim Bailey, Henry Bosch.
    Each person Shall be trained on the following:

    1. Know the Hazards that may be faced during entry, including information on the mode, signs or symptoms, and consequence of the exposure.

    2. Continuously maintains an accurate count of authorized entrants.

    3. Remains outside the permit space until properly relieved.

    4. Communicates with the entrants by two way radio or as necessary to monitor activities inside and outside the space.

    5. Summon rescue and other emergency services by two way radio as soon as the attendant determines that the authorized entrant may need assistance to escape the confined space. Specific requests for assistance should include request for fire department rescue or ambulance.


PRE-ENTRY EVALUATION

To ensure the safety and health of our employees, before allowing authorized workers to enter a permit space, we evaluate conditions in that space to determine if the conditions are safe for entry. These are the procedures we follow to evaluate each permit space before entry:

    Continuous forced air ventilation shall be used as follows.

  1. An employee may not enter the space until the forced air ventilation has eliminated any hazardous atmosphere.

  2. The air supply for the forced air ventilation shall be from a clean source and may not increase the hazards in the space.

  3. The atmosphere within the space shall be periodically tested every two hours to ensure that the continuous forced air ventilation is preventing the accumulation of hazardous atmosphere.

  4. Employees shall leave the space immediately if any hazardous atmosphere is detected. Re-entry is not permitted until evaluation and correction of the hazard has been made.


EQUIPMENT

To ensure the safety and health of our employees, HOPE COLLEGE provides appropriate equipment to all employees who work in or near our permit spaces. The equipment we provide to these employees includes:

    Personal Oxygen Monitor with pump attachment $ 567.80
    Allegro Model 9504 Electric Blower $ 630.00
    25' 8" diameter ducting $ 175.00
    Duct storage rack $ 49.00
    Mini-gas monitor for O2/LEL/CO2 $1800.00.

We maintain all equipment in excellent working condition, train the entrants in the correct usage of this equipment, and ensure that all equipment, including that used for personal protection, is used properly. We follow these procedures to ensure that the appropriate equipment is being used by entrants Confined Space entry Permit must be filled out and signed by confined space personnel and their supervisor.


DUTIES: AUTHORIZED ENTRANTS

Those persons who have completed the training and are authorized to enter our permit spaces (authorized entrants) are assigned specific duties and responsibilities which they must perform when they work in the permit space.

  1. Authorized entrants must be familiar with and do the following:

    1. Review survey data before entering the confined space .

    2. Eliminate any hazardous conditions that may make it unsafe to remove a cover to a confined space.

    3. Properly guard all entrance openings so that others will not enter or fall in.

    4. Properly ventilate confined space before entering.

    5. Take an initial reading with O2 monitor to make sure atmosphere is safe.

    6. Be familiar with possible hazards and conditions that may be in the area.

    7. No one shall enter a confined space without an assistant who shall remain outside the confined space and monitor the entrants progress.

  2. The elements covered in the training program for authorized entrants includes: All entrants shall be trained on the following:

    1. Use of air monitoring equipment and how to obtain accurate readings.

    2. Rescue techniques including CPR and first aid.

    3. How to summon assistance on the radio.

    4. Proper use of ventilation equipment - setup/use/clean-up.

    5. Physical signs and symptoms of over exposure to environmental conditions that may be encountered in the confined space.

    6. How to request and fill out a confined space permit.

    7. Procedures for properly entering a confined space.

    8. Procedures for properly guarding a confined space.


DUTIES: ATTENDANTS

Those persons who have completed the training and have been designated as permit space attendants are assigned specific duties and responsibilities which they must perform in permit space job duties.

  1. Their duties and responsibilities include:

    1. Know the hazards that may be faced during entry, including information on the mode, signs or symptoms, and consequences of the exposure.

    2. Continuously maintain an accurate count of authorized entrants.

    3. Remain outside the permit space until properly relieved and continually monitor the entrants well-being.

    4. Communicate with entrants, verbally or by radio, to assist in monitoring the entrants activities and well-being.

    5. Be familiar with signs and symptoms of overexposure to atmospheric and environmental conditions within the confined space.

    6. Summon rescue and other emergency services by two way radio as soon as the attendant determines that the authorized entrant may need assistance to escape the confined space.

    7. Be familiar with CPR and basic first aid treatment.

  2. The elements covered in the training program for permit space attendants includes:

    1. First Aid and CPR training

    2. Confined space rescue procedures such as how to properly use a two way radio and summon emergency services, rescuing a person from a confined space.

    3. How to properly monitor a confined space using O2 monitors

    4. How to properly monitor the ventilation equipment.


DUTIES: ENTRY SUPERVISORS

Those persons who have completed the training and have been designated as permit space entry supervisors are assigned specific duties and responsibilities which they must perform in permit space job duties.

  1. Their duties and responsibilities include:

    1. Making sure that confined space permits are filled out prior to anyone entering a confined space. The supervisor should be familiar with the work being done and the time and location of the entry.

    2. Make sure that employees are using proper procedures for entry into confined spaces and that proper monitoring is done prior and during entry.

    3. Keep records of entry and make sure that paperwork on entries is followed up and filed.

  2. The elements covered in the training program for permit space entry supervisors include:

    1. Supervisors should be familiar with this policy and the procedures that are listed.

    2. Supervisors should also be familiar and receive training on the equipment that is needed to enter a confined space (ie O2 monitors, entry permits, ventilation equipment, and rescue procedures.


TRAINING PROGRAM

Every employee at HOPE COLLEGE who faces the risk of confined space entry is provided with training so that each designated employee acquires the understanding, knowledge and skills necessary for the safe performance of the duties assigned to them. The Director of Occupational Health and Fire Safety conducts the initial permit-required confined space training. All subsequent training must be done by the employee's supervisor. Training related materials, documents, and signed certificates are kept in a file at the Maintenance Office. A copy of this policy is available from the Department of Occupational Health and Fire Safety in the Public Safety Office. Additional information or training materials can be obtained from the Occupational Health and Fire Safety office by calling extension 7999.

  1. We use this criteria to determine which employees must receive permit-required confined space training:

    Employees who, as a result of their service training and job description, may be called upon to enter confined spaces on campus to do repairs or maintenance work will be trained on confined space entry.

  2. When we conduct the training, we use The training program will consist of the following:

    1. (2) videos, one on confined space and one on Mini-gas monitor use.

    2. Going over this policy to make sure that employees are familiar with it and where they can get information on this subject.

    3. Hands on training at a confined space:
      • Filling out a sample entry permit
      • Taking an air sample using the Mini-gas sampler
      • Using the blower to ventilate the confined space
      • Going over the duties of the entrant and attendant.
      • Going over how to summon assistance on the radio.

  3. New employees are always trained before their initial assignment of duties. In addition to the above listed training of these procedures new employees:

    1. Must become familiar with the confined spaces and their hazards by performing their duties with an experienced mechanic until they are competent in performing their duties unassisted.


CHANGES IN CONFINED SPACE AREAS

When changes occur in permit-required confined space areas of our company, we do the following:

  1. Any confined space which presently exists but is altered in any way by either function or equipment must be re-evaluated by the Department of Occupational Health and Fire Safety. Entry into such a space is forbidden until the evaluation is completed and the Maintenance Supervisor is informed of the results and any new steps that may need to be added to the entry procedures for this space.

  2. A training session will have to be scheduled before entry is allowed into these spaces by the Department of Occupational Health and Fire Safety. Employees will review entry procedures and the survey data map will be updated and this policy revised, by the Department of Occupational Health and Fire Safety.


DEVIATION POLICY

If we have reason to believe that an employee has deviated from a previously trained upon procedure or that their knowledge seems inadequate, Supervisors should:

  1. Go over procedures with employee to assure that employee is aware of the proper way in which to proceed.

  2. Employees who deliberately disobey and fail to comply with the provisions of this standard could face disciplinary procedures or even termination.


RESCUE AND EMERGENCY PROCEDURES

In an emergency call the Department of Public Safety at extension 911 or if on radio, Base, H4, or H2. The Department of Public Safety will dispatch an officer to the scene and if needed, additional assistance can be summoned from the Fire Department or other agency.


MULTIPLE EMPLOYER ENTRY PROCEDURES

When outside employers/contractors enter our facility to perform work in permit spaces, we coordinate entry and work operations following these procedures: confined space permits must be filled out before anyone enters a confined space on campus.

  1. Contractors working alone are required to abide by confined space polices of their respective companies.

  2. Contractors working with Hope Employees will be required to abide by the procedures outlined in this policy.


POST-OPERATIONS PROCEDURES

Upon completion of work in a permit space, we follow these procedures to close off the space and cancel the permit:

  1. The confined space must be secured to prevent entry by unauthorized personnel (i.e. putting manhole covers back in place, securing entry)

  2. All confined space equipment must be returned to its storage location

  3. Confined space Permits must be completed, signed and turned into the maintenance supervisor. A copy of the Permit shall be fowarded to the Occupational Health and Fire Safety Office.


ENFORCEMENT

Constant awareness of and respect for permit-required confined space entry hazards, and compliance with all safety rules are considered conditions of employment. Supervisors and individuals in the Safety and Personnel Department reserve the right to issue disciplinary warnings to employees,up to and including termination, for failure to follow the guidelines of this permit entry program.

APPENDIX

We have attached to this plan any lists, samples, or procedures we thought would ensure better understanding of our written program.