Chapter 34
CONFINED SPACES

Contents

Approved by Mark Schmidt
Revised 09/16


34.1 Scope and Applicability

34.2 Policy

34.3 Roles and Responsibilities

34.4 Definitions

34.5 Required Work Processes

Work Process A. Confined Space Database
Work Process B. Classification of Spaces
Work Process C. Safe Work Procedures, Engineering Controls, Rescue Plans, PPE, and Precautions
Work Process D. Entry into Inventoried Spaces by LBNL Employees or Affiliates (Does Not Include Subcontractors)
Work Process E. Entry into Inventoried Spaces by Subcontractors
Work Process F. Training
Work Process G. Program Effectiveness Review and Assurance

34.6 Appendices

Appendix A. LBNL Implementation of Permit-required Confined Space Decision Flowchart
Appendix B. Confined Space Evaluation Worksheet
Appendix C. PRCS Reclassification Certification
Appendix D. PRCS Alternate Entry Procedure Certification
Appendix E. Permit-Required Confined Space Entry Debrief

Confined spaces are work locations that meet regulatory definitions and require rigorous additional analysis and Work Authorization in addition to the usual safe work practices and procedures required by Integrated Safety Management Systems.

NOTE:
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34.1 Policy

Confined spaces are work locations that meet regulatory definitions and require rigorous additional analysis and Work Authorization in addition to the usual safe work practices and procedures required by Integrated Safety Management Systems.

This PUB-3000 program applies to:

  1. All spaces at LBNL, including those classified or not classified as:
    1. A Non-Permit Confined Space (NPCS)
    2. A Permit-Required Confined Space (PRCS)
  2. All employees, visitors, affiliates, and subcontractors who perform work at LBNL
  3. Off-site DOE/LBNL/UC facilities are not fully covered by this program. LBNL does not evaluate or maintain an inventory of off-site confined spaces. These facilities are managed by the respective property management firms. Subcontractors are responsible for obtaining information regarding confined spaces and the associated hazards and precautions from the property management firms. Please contact the Confined Space Program Manager for guidance prior to entering off-site confined spaces.

34.2 Scope and Applicability

Management of LBNL's confined spaces, including Permit-Required Confined Spaces (PRCS), is in accordance with the requirements of the Occupational Safety and Health Administration (OSHA) standard — Code of Federal Regulations (CFR), Title 29, Part 1910.146 (29 CFR 1910.146) — and the additional requirements in this PUB-3000 chapter. The OSHA Permit-Required Confined Space Decision Flowchart (29 CFR 1910.146 Appendix A), reproduced in this PUB-3000 chapter as Appendix A, forms the basis of LBNL's Confined Space Program. Exceptions: Pits, excavations, trenches, and confined spaces entered by subcontractors for Maintenance, Repair, and Operations (MRO) purposes under the subcontractor's approved PRCS Program are managed by LBNL's Construction Safety Program under the requirements of 29 CFR 1910.146. Chapter 38 of the Construction Safety Manual describes confined space work. Construction-related confined space entry is covered under OSHA 29 CFR Part 1926.1200–1213, Subpart AA, Confined Spaces in the Construction Industry. Where a standard applies and a provision addresses a confined space hazard in another applicable OSHA standard, the employer must comply with both that requirement and the applicable provisions of this standard.

All employees, visitors, affiliates, and subcontractors who perform work at LBNL (excluding subcontractors operating under their own approved PRCS Program) may not enter any PRCS unless:

  1. Facilities In-House Staff Confined Space EntryFacilities PRCS entry is allowed only for the following situations:
    1. For MRO purposes
    2. For non-construction related purposes
    3. When the entry is required to keep a critical utility system running for lab operations ("operationally critical")
    4. When the MRO work is critical and cannot be properly or timely scheduled or conducted by a subcontractor
  2. Subcontractor PRCS Entry 
    1. Prior to any subcontractor entering a PRCS, the subcontractor's written PRCS Program and the Entry Team worker's confined space training must be reviewed and approved by LBNL's Confined Space Program Manager.
    2. Subcontractors will be required to be used for PRCS entry when the following situations or conditions are present:
      1. For specialized, high-risk, high-hazard entries where conditions described in 34.1 section 2 cannot be met.
      2. When specialized equipment and training are needed
      3. When specialized PPE, such as a SCBA or supplied air lines are required
      4. When a specialized task must be performed. Specialized tasks may be those, which require specific training or experience to perform.
      5. For all entries where an atmospheric hazard, other than that associated with a sanitary sewer, is present and cannot be eliminated or controlled
      6. When applying chemicals or coatings such as epoxy coating
      7. When there is a risk or potential risk of exceeding an OSHA PEL.
      8. For all storage tank entries
    3. Subcontractors who perform construction-related PRCS entry or have confined spaces on their controlled job site are required to submit and maintain:
      1. Their company's written PRCS Program, which describes OSHA 29 CFR 1926.1200-1213, Subpart AA, Confined Spaces in Construction. Cal/OSHA Title 8 CCR Sections 1950-1962, Confined Spaces in Construction, may be used as an equivalent.
      2. A full Entry Team, including an attendant. Each team member must have applicable confined space training for their role and responsibility.
      3. The Entry Supervisor (Permit Writer) must be a Qualified Person per the OSHA definition and have training specific to atmospheric monitoring for confined space entry.
      4. An emergency rescue plan and/or arrangements
      5. Their own equipment necessary to conduct the entry.

34.3 Roles and Responsibilities

The following table describes the roles and responsibilities of confined space personnel:

Role

Responsibilities

Division directors

Ensure that entries into PRCSs under their divisions' control are made only in accordance with this program

Environment/Health/Safety (EHS) Division

  • Administers the LBNL Confined Space Program
  • Provides training (Work Process F) to LBNL personnel involved in entry into confined spaces
  • Designates the Confined Space Program Manager, who shall either personally or via delegation:
    • Classify spaces as an NPCS or a PRCS.
    • Determine which spaces are not confined spaces.
    • Be provided access to the Confined Space Database inventory.
    • Designate Entry Supervisors (permit writers).
    • Provide confined space training and field support.
    • Develop, in consultation with space owners and entrants, Safe Work Procedures for work in spaces. This is often conducted on a case-by-case basis.
    • Review PRCS Reclassification Certifications, PRCS Alternate Entry Procedure Certifications, and Subcontractor PRCS Permits on an annual basis.
    • Review Subcontractor PRCS programs and provide the Activity Lead with his or her comments.
    • Conduct ongoing program effectiveness review and assurance (Work Process G).

 

Activity Leads

Activity Leads include scientists, Facilities Project Construction Managers, Facilities Project Managers, Superintendents, Shop Supervisors, and others who manage or direct activities, including subcontracted work, that include entry into inventoried spaces. Activity Leads may or may not be the "requester" as described in PUB-3000, Chapter 31, Section 31.4.1, and may or may not be a "Line Manager" as described in PUB-3000, Chapter 1, Section 1.5. Activity Leads are NOT Entry Supervisors unless they have been separately so designated by the Confined Space Program Manager.
Activity Leads:

  • Define the activity that requires entry into a confined space.
  • Are ultimately responsible for successful completion of the activity.
  • May direct the day-to-day tasks that make up the activity.
  • Review the work area and determine whether spaces that must be entered are included in the Confined Space Database.
  • If any space that must be entered is included in the Confined Space Database, review the inventory and determine whether a Safe Work Procedure exists for work in that space.
  • For activities involving LBNL employee or affiliate entry into inventoried spaces, assign a properly trained and qualified Entry Supervisor for any entry into a PRCS and assure that entry proceeds only in accordance with Work Process DEntry into Inventoried Spaces by LBNL Employees or Affiliates (Does Not Include Subcontractors). A list of Entry Supervisors is provided on the Confined Space web page.
  • For activities involving subcontractor entry into inventoried spaces:
    • After review and concurrence by the Confined Space Program Manager, approve Subcontractor PRCS programs and procedures.
    • Co-approve (with the Construction Safety Entry Supervisor) documentation prepared by subcontractors for entry into PRCSs. Documentation includes but is not limited to Reclassification or Alternate Entry Procedure Certification, an entry permit, coordination procedures, and authorizations.
    • Ensure that entry proceeds only in accordance with Work Process EEntry into Inventoried Spaces by Subcontractors.
    • Document specialized procedures and controls used for a specific confined space entry event on the permit.
  • Immediately report to the Confined Space Program Manager:
    • Any unauthorized entry into a PRCS;
    • Detection of any hazard in a PRCS that is not covered in the permit;
    • Detection of a condition prohibited by the permit;
    • Occurrence of an injury or near-miss during entry;
    • Change in use or configuration of the Permit Space; or
    • Employee complaints about the effectiveness of the program.
  • Activity Leads are NOT Entry Supervisors unless they have been separately so designated by the Confined Space Program Manager.

Entry Supervisors (Permit Writers)

General Industry:

An Entry Supervisor or "Permit Writer" is the person responsible for determining whether there are acceptable entry conditions at a Permit-Required Confined Space where entry is planned; for authorizing entry and overseeing entry operations; and for terminating entry as required by this document and applicable regulations. Entry Supervisors must be designated by the Confined Space Program Manager, and are required to complete Confined Space Entry Supervisor course (EHS 0277). In-house LBNL Entry Supervisors must also complete a refresher course (EHS 0387) every two years.

Construction Industry:

For construction-related work, the Entry Supervisor is the Qualified Person (such as the employer, foreman, or crew chief) responsible for determining if acceptable entry conditions are present at a permit space where entry is planned, for authorizing entry and overseeing entry operations, and for suspending or terminating entry if required. Construction-related Entry Supervisors are required to complete and submit training that covers the principles of atmospheric testing, gas detection equipment, calibration, ventilation, hazard identification, hazard control, and elimination.   

Entry supervisors or permits writers:

  • Operate only in PRCSs within their specific area of technical expertise. Consult an Activity Lead or researcher if there are technical questions regarding potential safety hazards, such as electrical, mechanical, radioactive, or chemical hazards.
  • Ensure that PRCSs at LBNL are entered only as provided in this document and applicable regulations. See Work Process DEntry into Inventoried Spaces by LBNL Employees or Affiliates (Does Not Include Subcontractors).
  • Reclassify PRCSs to NPCSs and authorize entry thereto, or authorize entry into PRCSs via an Alternate Entry Procedure, as permitted by this program.
  • If present during later stages of an entry, remove all entrants from the space whenever conditions change to create a hazard.
  • Forward completed PRCS Reclassification Certification and PRCS Alternate Entry Procedure Certification to the Confined Space Program Manager after expiration of the certification. A drop box is currently available at Building 78 for completed forms.
  • Immediately report to the Confined Space Program Manager:
    • Any unauthorized entry of a PRCS;
    • Detection of any hazard in a PRCS that is not covered in the permit;
    • Detection of a condition prohibited by the permit;
    • Occurrence of an injury or near-miss during entry;
    • Change in use or configuration of the Permit Space; or
    • Employee complaints about the effectiveness of the program.

Construction Safety Entry Supervisors

A Construction Safety Entry Supervisor is a member of LBNL's EHS Division Construction Safety staff who has also been designated as an Entry Supervisor and has completed the EHS 0277 course.

  • Review, concur on adequacy, and co-approve (with the Activity Lead) documentation prepared by the subcontractor for entry into PRCSs. Documentation includes but is not limited to Reclassification or Alternate Entry Procedure Certification, an entry permit, coordination procedures, and authorizations.
  • Fulfill roles and responsibilities of "Entry Supervisors" above.

Subcontractors

  • Conform to the requirements of applicable regulations and this PUB-3000 program.
  • If the subcontractor is going to work in a construction-related confined space, then the subcontractor must comply with the 29 CFR OSHA Part 1926.1200 Confined Spaces in Construction Industry standard as well as any applicable sections of OSHA 29 CFR Part 1910.146. Construction-related spaces may include excavations, pits, and trenches; equipment brought on site, such as water tanks, cement mixing trucks, and cooling units; and any confined space created during the construction of a building or other structure. Construction-related spaces may also include existing spaces that are part of a construction site temporarily controlled by the controlling contractor.
  • 29 CFR Part 1926.1200 does not apply to: (1) construction work regulated by 1926 Subpart P, Excavations; (2) construction work regulated by 1926 Subpart S, Underground Construction, Caissons, Cofferdams and Compressed Air; or (3) construction work regulated by 1926 Subpart Y, Diving.
  • Subcontractor workers must provide EHS with valid proof of confined space training in both OSHA 29 CFR Part 1910.146 and OSHA 29 CFR Part 1926.1200.
  • Subcontractors who provide self-rescue personnel must also have current CPR training and conduct annual rescue practice.

Controlling contractor (for construction-related Work)

The controlling contractor is the employer that has overall responsibility for construction at the work site. The following section is a summary of the requirements that the controlling contractor must comply with per OSHA 29 CFR Part 1926.1200 Subpart AA. These requirements do not apply to LBNL's in-house staff entering confined spaces:

  • The controlling contractor must ensure that a competent person identifies all confined spaces in which one or more of the controlling contractor's employees may work, and identifies each space that is a Permit Space, through consideration and evaluation of the elements of that space, including testing as necessary.
  • The controlling contractor must post danger signs or any other equally effective means of communication to inform exposed employees of the existence and location of, and dangers posed by, each Permit Space.
  • The controlling contractor must inform its employees' authorized representatives of the existence and location of, and the danger posed by, each Permit Space in a timely manner and in a manner other than posting a danger sign.
  • Each employer who identifies, or receives notice of, a Permit Space and has not authorized its employees to work in that space must take effective measures to prevent those employees from entering that Permit Space in addition to complying with all other applicable requirements of this standard.
  • If any employer decides that its employees will enter a PRCS, that employer must have a written PRCS Program that complies with §1926.1204 and is implemented at the construction site. The written PRCS Program must be made available for inspection prior to and during entry operations by employees and their authorized representatives.
  • The employer must provide and maintain training and ensure that employees who are authorized to perform confined space entry rescues possess the understanding, knowledge, and skills necessary for the safe performance of the duties assigned. This training must result in an understanding of the hazards in the Permit Space as well as an understanding of the methods used to isolate, control, or in other ways protect employees from these hazards. The employee (i.e., the controlling contractor) must also provide and maintain training to ensure employees who are not authorized to perform confined space entry rescues are aware of the dangers of attempting such rescues.
  • The controlling contractor must designate each person who is to have an active role (for example, authorized entrants, attendants, entry supervisors, or persons who test or monitor the atmosphere in a Permit Space) in entry operations, and identify the duties of each employee.
  • The controlling contractor must provide testing and monitoring equipment, ventilating equipment, communication equipment, personal protective equipment, lighting equipment, barriers, guards and shields, ladders, etc.
  • The controlling contractor must ensure a safe method of entering and exiting the space.
  • The controlling contractor must eliminate or isolate the hazards without entering the space.
  • The controlling contractor must perform pre-entry atmospheric testing.
  • The controlling contractor must continuously monitor entry conditions in the areas where authorized entrants are working.
  • The controlling contractor must continuously monitor atmospheric hazards unless the they can demonstrate 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.
  • The controlling contractor must 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.
  • The controlling contractor must provide at least one attendant outside the Permit Space(s) into which entry is authorized for the duration of entry operations.
  • The controlling contractor must document the basis for determining that all hazards in a Permit Space have been eliminated or isolated, through a certification that contains the date, the location of the space, and the signature of the person making the determination.
  • The controlling contractor must obtain the host employer's information about the Permit Space hazards and previous entry operations.
  • The controlling contractor must provide each entity entering a Permit Space and any other entity at the work site whose activities could foreseeably result in a hazard in the Permit Space with the following information:
    • The controlling contractor and entry employer (employers who decide an employee will enter a confined space) must coordinate entry operations when more than one entity performs Permit Space entry at the same time; or when Permit Space entry is performed at the same time and place as another activity that could result in a hazard.
    • The controlling contractor must apprise the host employer (LBNL) of the information exchanged with the entry entities
  • The controlling contractor must 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); procedures for rescuing entrants from Permit Spaces; procedures for providing necessary emergency services to rescued employees; and procedures for preventing unauthorized personnel from attempting a rescue.

Fall Protection SME

The Fall Protection SME is responsible for developing, implementing, maintaining, and evaluating the Fall Protection Program. The SME also provides guidance to all others involved with the program, establishes a procedure to identify fall hazards, develops fall protection and rescue procedures, ensures training is completed, and participates in incident investigations.

  • Many confined spaces at LBNL have external and internal fall hazards. The requirements of the Fall Protection Program apply to working on any walking or working surface having an unprotected side or edge that is 6 feet or more above a lower level. This includes leading edges, roofs, tanks, manholes, unguarded machinery, aerial lifts, ladders, slopes steeper than 2:1 (horizontal to vertical) hillsides, roofs, and surfaces with open holes or skylights. For more information, see the ES&H Manual Fall Protection Program, or contact the LBNL Fall Protection SME.
  • Work inside vertical spaces (greater than 5 feet in depth) requires the entrant(s) to wear a full-body harness whether or not the entrant is connected to a tripod or davit arm. This requirement is not a fall protection requirement but an OSHA emergency rescue requirement.

Fire Department

The LBNL Fire Department crew, located at Building 48, provides high angle emergency rescue. However, self-rescue can be conducted by the Entry Team based upon professional judgment with regards to response time, hazardous conditions in the space, and the nature of the emergency.


 

34.4 Definitions

See also definitions in 29 CFR 1910.146, which are incorporated by reference.

Term

Definition

Acceptable entry conditions

 

The conditions that must exist in a Permit Space to allow entry and to ensure that employees involved with a Permit-Required Confined Space entry can safely enter into and work within the space.

Attendant

 

An individual stationed outside one or more Permit Spaces who monitors the authorized entrants and who performs all of the attendant's duties assigned in the employer's Permit Space Program.

Authorized entrant

 

An employee who is authorized by the employer to enter a Permit Space.

Blanking or blinding

 

The absolute closure of a pipe, line, or duct by the fastening of a solid plate (such as a spectacle blind or a skillet blind) that completely covers the bore and that is capable of withstanding the maximum pressure of the pipe, line, or duct with no leakage beyond the plate.

Competent person

One who is capable of identifying existing and predictable hazards in the surroundings or working conditions which are unsanitary, hazardous, or dangerous to employees, and who has the authorization to take prompt corrective measures to eliminate them.

Confined space

A confined space is a space that:

  • Is large enough and so configured that an employee can bodily enter and perform assigned work; and
  • Has limited or restricted means for entry or exit (for example, tanks, vessels, silos, storage bins, hoppers, vaults, and pits are spaces that may have limited means of entry); and
  • Is not designed for continuous employee occupancy; and
  • Is an open top space, pit, utility vault, trench, vessel, etc., which is deeper than 4 feet and has solid side walls (OSHA 1926.21[b][6][ii]).

Controlling contractor  

The employer that has overall responsibility for construction at the worksite. Note: If the controlling contractor owns or manages the property, then it is both a controlling employer and a host employer.

Double block and bleed

The closure of a line, duct, or pipe by closing and locking or tagging two in-line valves and by opening and locking or tagging a drain or vent valve in the line between the two closed valves.

Early-warning system

The method used to alert authorized entrants and attendants that an engulfment hazard may be developing. Examples of early-warning systems include but are not limited to: alarms activated by remote sensors, and lookouts with equipment for immediately communicating with authorized entrants and attendants.

Eliminated

Removed by a means that does not require active intervention to maintain. For example, lockout/tagout of rotating machinery or physical blocking of a hydraulic ram would be considered elimination. On the other hand, traffic control or continuous forced air ventilation would not be considered elimination but a reduction of a hazard.

Emergency

Any occurrence (including any failure of hazard control or monitoring equipment) or event that is internal or external to the Permit Space that could endanger entrants.

Engulfment

The surrounding and effective capture of a person by a liquid or finely divided (flowable) solid substance that can be aspirated to cause death by filling or plugging the respiratory system or that can exert enough force on the body to cause death by strangulation, constriction, or crushing.

Entry

The action by which a person passes through an opening into a Permit-Required Confined Space. Entry includes ensuing work activities in that space and is considered to have occurred as soon as any part of the entrant's body breaks the plane of an opening into the space.

Entry employer

Any employer who decides that an employee it directs will enter a Permit Space. Note: An employer cannot avoid the duties of the standard merely by refusing to decide whether its employees will enter a Permit Space, and OSHA will consider the failure to so decide to be an implicit decision to allow employees to enter those spaces if they are working in the proximity of the space.

Entry permit (permit)

The written or printed document that is provided by the employer to allow and control entry into a Permit.

Entry supervisor

The person (such as the employer, foreman, or crew chief) responsible for determining if acceptable entry conditions are present at a Permit Space where entry is planned, for authorizing entry and overseeing entry operations, and for terminating entry as required by this section.
Note: An entry supervisor may also serve as an attendant or as an authorized entrant, as long as that person is trained and equipped as required by Chapter 38 of the Construction Safety Manual for each role he or she fills. Also, the duties of entry supervisor may be passed from one individual to another during the course of an entry operation.

Hazardous atmosphere

An atmosphere that may expose employees to the risk of death, incapacitation, impairment of ability to self-rescue (that is, escape unaided from a Permit Space), injury, or acute illness from one or more of the following causes:

  • Flammable gas, vapor, or mist in excess of 10 percent of its lower flammable limit (LFL).
  • Airborne combustible dust at a concentration that meets or exceeds its LFL. (Note: This concentration may be approximated as a condition in which the dust obscures vision at a distance of 5 feet (1.52 m) or less.)
  • Atmospheric oxygen concentration below 19.5 percent or above 23.5 percent.
  • Atmospheric concentration of any substance for which a dose or a permissible exposure limit is published in Subpart G, Occupational Health and Environmental Control, or in Subpart Z, Toxic and Hazardous Substances, of this Part and which could result in employee exposure in excess of its dose or permissible exposure limit. (Note: An atmospheric concentration of any substance that is not capable of causing death, incapacitation, impairment of ability to self-rescue, injury, or acute illness due to its health effects is not covered by this provision.)
  • Any other atmospheric condition that is immediately dangerous to life or health. (Note: For air contaminants for which OSHA has not determined a dose or permissible exposure limit, other sources of information, such as Safety Data Sheets that comply with the Hazard Communication Standard, 29 CFR 1910.1200 published information, and internal documents can provide guidance in establishing acceptable atmospheric conditions.)

Hot work

Operations capable of providing a source of ignition (for example, riveting, welding, cutting, burning, and heating).

Host employer

The employer that owns or manages the property where the construction work is taking place. Note: If the owner of the property on which the construction activity occurs has contracted with an entity for the general management of that property, and has transferred to that entity the information specified in 29 CFR §1926.1203(h)(1), OSHA will treat the contracted management entity as the host employer for as long as that entity manages the property. Otherwise, OSHA will treat the owner of the property as the host employer. In no case will there be more than one host employer. LBNL is the host employer for existing confined spaces at the LBNL property.

Hot work permit

The employer's written authorization to perform operations capable of providing a source of ignition (for example, riveting, welding, cutting, burning, and heating).

Immediately dangerous to life or health (IDLH)

Any condition that poses an immediate or delayed threat to life or that would cause irreversible adverse health effects or that would interfere with an individual's ability to escape unaided from a Permit Space. (Note: Some materials — hydrogen fluoride gas and cadmium vapor, for example — may produce immediate transient effects that, even if severe, may pass without medical attention, but are followed by sudden, possibly fatal collapse 12–72 hours after exposure. For example, the victim "feels normal" from recovery from transient effects until collapse. Such materials in hazardous quantities are considered to be "immediately" dangerous to life or health.)

Inerting

The displacement of the atmosphere in a Permit Space by a noncombustible gas (such as nitrogen) to such an extent that the resulting atmosphere is noncombustible.
Note: This procedure produces an IDLH oxygen-deficient atmosphere.

Isolation

The process by which a Permit Space is removed from service and completely protected against the release of energy and material into the space by such means as: blanking or blinding; misaligning or removing sections of lines, pipes, or ducts; a double block and bleed system; lockout or tagout of all sources of energy; or blocking or disconnecting all mechanical linkages.

Limited or restricted means for entry or exit

A condition that has a potential to impede an employee's movement into or out of a confined space. Such conditions include, but are not limited to, trip hazards, poor illumination, slippery floors, inclining surfaces and ladders.

Line breaking

The intentional opening of a pipe, line, or duct that is or has been carrying flammable, corrosive, or toxic material, an inert gas, or any fluid at a volume, pressure, or temperature capable of causing injury.

Non-Permit Confined Space

A confined space that does not contain or, with respect to atmospheric hazards, have the potential to contain any hazard capable of causing death or serious physical harm. No other hazards may be present or introduced to maintain the NPCS status.

Oxygen-deficient atmosphere

An atmosphere containing less than 19.5 percent oxygen by volume

Oxygen-enriched atmosphere

An atmosphere containing more than 23.5 percent oxygen by volume

Permit-Required Confined Space (Permit Space)

A confined space that has one or more of the following characteristics:

  • Contains or has a potential to contain a hazardous atmosphere;
  • Contains a material that has the potential for engulfing an entrant;
  • Has an internal configuration such that an entrant could be trapped or asphyxiated by inwardly converging walls or by a floor which slopes downward and tapers to a smaller cross-section; or
  • Contains any other recognized serious safety or health hazard.

Permit-Required Confined Space Program (Permit Space Program)

The employer's overall program for controlling and, where appropriate, protecting employees from Permit Space hazards; and for regulating employee entry into Permit Spaces.

Permit system

The employer's written procedure for preparing and issuing permits for entry and for returning the Permit Space to service following termination of entry.

Prohibited condition

Any condition in a Permit Space that is not allowed by the permit during the period when entry is authorized.
For example, a hazardous atmosphere is a prohibited condition 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.

Qualified person

One who, by possession of a recognized degree, certificate, or professional standing, or who by extensive knowledge, training, and experience, has successfully demonstrated his or her ability to solve or resolve problems relating to the subject matter, the work, or the project. 

Representative Permit Space  

A mock-up of a confined space that has entrance openings that are similar to, and is of similar size, configuration, and accessibility to, the Permit Space that authorized entrants enter.

Rescue

Retrieving and providing medical assistance to one or more employees who are in a Permit Space.

Rescue service

Personnel designated to rescue employees from Permit Spaces.

Retrieval system

The equipment (including a retrieval line, full-body harness, and a lifting device or anchor) used for non-entry rescue of persons from Permit Spaces. (Note: Chest harnesses are no longer rated by ANSI for OSHA approval and cannot be worn at LBNL).

Serious physical damage

An impairment or illness in which a body part is made functionally useless or is substantially reduced in efficiency. Such impairment or illness may be permanent or temporary and includes, but is not limited to, loss of consciousness, disorientation, or other immediate and substantial reduction in mental efficiency. Injuries involving such impairment would usually require treatment by a physician or other licensed health-care professional.

Tagout

Tagout is the (1) placement of a tagout device on a circuit or equipment that has been de-energized, in accordance with an established procedure, to indicate that the circuit or equipment being controlled may not be operated until the tagout device is removed; and (2) the employer ensures that (a) a tagout provides equivalent protection to a lockout, or (b) that a lockout is infeasible and the employer has relieved, disconnected, restrained, and otherwise rendered safe stored (residual) energy.

Testing

The process by which the hazards that may confront entrants of a Permit Space are identified and evaluated. Testing includes specifying the tests that are to be performed in the Permit Space. Note: Testing enables employers both to devise and implement adequate control measures for the protection of authorized entrants and to determine if acceptable entry conditions are present immediately prior to, and during, entry.

Ventilate or ventilation

Controlling a hazardous atmosphere using continuous forced-air mechanical systems that meet the requirements of §1926.57—Ventilation.

 

34.5  Required Work Processes

Work Process A. Confined Space Database
Work Process B. Classification of Spaces
Work Process C. Safe Work Procedures, Engineering Controls, Rescue Plans, PPE, and Precautions
Work Process D. Entry into Inventoried Spaces by LBNL Employees or Affiliates (Does Not Include Subcontractors)
Work Process E. Entry into Inventoried Spaces by Subcontractors
Work Process F. Training
Work Process G. Program Effectiveness Review and Assurance


Work Process A.Maximo Confined Space Information

confined space flowchart

  1. The Confined Space Database lists LBNL spaces that have been evaluated and classified as:
    1. A Non-Permit Confined Space (NPCS)
    2. A Permit-Required Confined Space (PRCS)

The Facilities division maintains the Maximo system to track assets and control work order requests.  Maximo includes a Confined Space Database component that includes information including hazards and precautions. EHS also maintains a summary inventory in spreadsheet format. This is inventory information is periodically extracted from Maximo to keep it updated. The EHS inventory spreadsheet is accessible to the Lab population on the Confined Space Webpage. For each space, information generally collected includes:

  1. Information from the Confined Space Database is exported to the Facilities Maximo® Work Control System based upon location (e.g., LBNL building and room number for inventoried spaces associated with buildings) or Facilities Asset No. (e.g., for inventoried spaces not associated with buildings). Whenever the Maximo® Work Control System generates a work request, it checks to see if an inventoried space is associated with the location or asset referenced in the work request. If so, it extracts the inventory information and appends it to the work request.
    1. During work planning, Activity Leads must review the work area to evaluate its potential for containing inventoried spaces.
    2. The work request, if present, may list the space and supporting information (e.g., the Safe Work Procedure) as contained in the Confined Space Database.
    3. The absence of a listing does not mean that an NPCS or a PRCS is not present. It means that an evaluation may not have been performed or has not been entered into the database yet.
    4. Spaces that are not confined spaces (i.e., spaces classified as Not a Confined Space) are no longer included in the inventory. For example, many of these spaces included HVAC ducts, which cannot be bodily entered. Upon completion of EHS 0275 training employees will be able to identify whether a space is a confined space. Contact the Confined Space Program Manager for questions on whether a particular space is Not a Confined Space.
    5. Not all confined spaces are labeled with signage due to outdoor weathering. Manhole covers usually have the ID number bead welded or tagged with a circular brass badge. Some spaces such as vaults may have a signage stencil. The verification of unlabeled spaces can be confirmed by referring to the database, locating the space on a site drawing as well as the location description.
    6. The absence of a listing or an unclassified space does not mean that a hazard is not present. Hazards may exist (e.g., an exposed edge posing a fall hazard) that are unrelated to the confined space classifications.
    7. The Confined Space Program Manager must be consulted for evaluation and classification of spaces (see Work Process B below).
    8. A separate confined space inventory spreadsheet is maintained by EHS on the Confined Space web page. This is a limited summary of the spaces and their locations.

Work Process B. Classification of Spaces

  1. An individual must contact the Confined Space Program Manager to classify or review the classification of the space if the individual suspects that:
    1. A space not listed in the Confined Space Database is a confined space; or
    2. A space is listed in the Confined Space Database, but the classification is not correct; or
    3. The space cannot be found in the Confined Space Database; or
    4. A new hazard is encountered that should be documented; or
    5. There is a change in the configuration or use of the space.
  2. The Confined Space Program Manager has sole (delegable) authority for classification of spaces. Facilities staff enters new spaces into the Maximo database, generates Maximo identification numbers, marks their location on the site drawings, and tags the confined space entry covers.
  3. The Confined Space Program Manager classifies a space by:
    1. Evaluating the space;
    2. Determining its classification as Not a Confined Space, a Non-Permit Confined Space (NPCS), or a Permit-Required Confined Space (PRCS) using the Confined Space Evaluation Worksheet;
    3. Determining if a Safe Work Procedure is necessary for entry into that space; and if so
    4. Developing the Safe Work Procedure in consultation with the entrants and the space owner.
  4. Some spaces across LBNL are categorically classified as an NPCS or a PRCS. "Categorical classification" means that the space has been classified based upon general characteristics of the space, and that categorical classification applies unless the individual space has been specifically classified otherwise and listed in the Confined Space Database as such. For example, all manholes are classified as Permit-Required Confined Spaces. Generally, the categorical classification information is contained in the Confined Space Database under "General Safe Work Procedure."

Categorical classification is via the criteria specified in OSHA 1910.146 and Section 34.4, Definitions, above. If a space does not meet the regulatory definition of a Confined Space or PRCS, this does NOT imply that the space is without hazards. Hazards unrelated to the regulatory classification may exist. Other work control processes and/or permit requirements, including but not limited to this program's Work Process C may govern work in the space.
If the space is categorically classified as a PRCS, then it may or may not be individually labeled. Communication of categorical classification is made via this ES&H Manual program and via ongoing training.

If at any time any person feels that a categorical classification of a space is incorrect, he or she must contact the Confined Space Program Manager to make a determination (see Work Process B.1 above).

Examples of categorically classified spaces are listed below:

    1. Sanitary sewer manholes, lift stations, and wet sumps arePRCSs with hazardous atmosphere as the defining characteristic.
    2. Components of the storm-water system are Not a Confined Space, an NPCS, or a PRCS.
      1. Storm-water pipes with a diameter too small to bodily enter are Not a Confined Space.
      2. Storm-water pipes with a diameter large enough to bodily enter are NPCSs with associated Safe Work Procedures.
      3. Catch basins less than 4 feet deep are Not a Confined Space.
      4. Catch basins greater than 4 feet deep are NPCSs with associated Safe Work Procedures.
    3. Storm-water manholes are categorically PRCSs with falls, engulfment and hazardous atmospheres (oxygen deficiency) being the defining characteristics. Electrical and telecommunication manholes are PRCSs with a potential hazardous atmosphere (oxygen deficiency) and configurations being the defining characteristics. (Note: Vaults are not categorically classified. They are individually classified, and the information is listed in the Confined Space Database.)
    4. Fuel storage tanks, whether aboveground or underground, are PRCSs with hazardous atmosphere (flammable vapor) being the defining characteristic (exception: those that cannot be entered are Not a Confined Space).
    5. Cryogen (e.g., liquid nitrogen) storage tanks (fixed locations at buildings) are PRCSs with hazardous atmosphere (oxygen deficiency) being the defining characteristic (Exception: Those that cannot be entered are Not a Confined Space).
    6. Elevator pits and shafts are PRCSs with the presence of a recognized safety and health hazard (e.g., crushing by the elevator car or falls) being the defining characteristic.
    7. Air-handling units with exposed (unshrouded) moving mechanical parts or mechanical parts that are running or which may automatically start are PRCSs.
    8. Raised computer room floors, which can be bodily entered, are categorically classified as Non-Permit Confined Spaces.
    9. Liquid nitrogen tanks with hatch openings that are too small for bodily entry are not considered confined spaces.
    10. Attics and storage closets with standard-size entry doors are generally not considered confined spaces. Attics with hatch doors or small doors that require individuals to stoop, contort the body, or crawl to enter or exit, and/or that have any other type of limited access or exit, are considered confined spaces.

Work Process C. Safe Work Procedures, Engineering Controls, Rescue Plans, PPE, and Precautions

  1. Requirements for Authorized Confined Space Entry
    1. A Permit-Required Confined Space Entry Team, including an attendant, is required for Permit-Required Confined Space entry. In-house staff must have current EHS0276 Fall Protection training to be authorized to work as a member of a Permit-Required Confined Space Entry Team. This is to ensure the proper inspection, use and adjustment of a harness as well as other rescue systems such as the tripod, winch, or davit arm. Attendants must be competent in the use of the winch for lowering and hoisting personnel.
    2. All entries and Entry Team members must be authorized to perform the entry by the Activity Lead or Project/Construction Manager.
  1. Safe Work Procedures (SWPs) are steps or precautions developed by LBNL that provide guidance for working in spaces listed in the Confined Space Database.
    1. SWPs are established by the Confined Space Program Manager in cooperation with the owner of the space. Once established, they may be filed in the Confined Space Database and associated with the space(s) to which they apply. Entrants who enter that space, regardless of whether the space is Not a Confined Space, a Non-Permit Confined Space (NPCS), or a PRCS, must adhere to the requirements of the SWP. If the circumstances of a particular phase of work do not allow adherence to the SWP requirements, the SWP must be revised or supplemented as necessary and reviewed by the Confined Space Program Manager.
    2. SWPs may be either general or specific.
      1. General SWPS are associated with a type or type/subtype of space, and provide requirements for work within any space classified as such. For example, general SWPs for work in attics and crawlspaces (listed in the Confined Space Database as the type "Architectural Spaces" and subtype "Attic") prescribe notification procedures, radio contact requirements, do not introduce hazards, wear appropriate PPE, and use the "buddy system." All work within all attic spaces is subject to this General SWP unless it is supplemented by the Specific SWP for the specific attic.
      2. Specific SWPs are associated with a specific inventoried space. They supplement or replace any General SWP for that type of space. If there is a contradiction between a General and a Specific SWP, the Specific SWP applies.
    3. SWPs require precautionary labels (shown below) affixed to many of the NPCSs.



  1. Engineering Controls and PPE
    1. Full-Body Harnesses
      1. Wearing a full-body harness in a confined space does not imply working from height since the purpose and intent is specifically for lowering or hoisting personnel from a confined space, whether it is a routine entry or for rescue.
        1. In general, confined space entry does not require a fall matrix permit form be prepared since there is no working from height. If an engineered, fall protection system is required; a fall protection matrix permit may become necessary.
      2. ull-body harnesses are required for lowering or hoisting personnel from vertical confined spaces using a tripod or davit arm. Harnesses are required for emergency rescue when working in vertical spaces greater than 5 feet in depth. Full-body harnesses are required to be worn by in-house staff regardless of the permit type used (i.e. Alternate Entry, Reclassification, Regular Permit).
      3. Facilities or other in-house staff are responsible for acquiring their own harnesses. The LBNL EHS Division does not provide subcontractors with equipment such as harnesses or tripods.
    2. Retrieval Lines. In general, entrants must maintain a retrieval line attached to their harness during vertical confined space entry (i.e., manholes and deep vertical spaces such as storm drains) to enable rescue and retrieval. The retrieval line should be accessible by the attendant(s), but it does not necessarily need to be tied off. If the retrieval line causes a demonstrated danger of entanglement or hazardous impediment such that a greater hazard is created, then this condition may be evaluated on a case-by-case basis and exempted by the designated Entry Supervisor.
    3. Self-rescue equipment, including a tripod with winch and lifeline, must be set up in place or available at the location of entry during vertical space entry operations for either Facilities MRO work or construction-related work where the Fire Department is not relied upon as a primary rescue provider.
    4. Guarding Requirements
      1. Guarding must be used for vertical confined spaces. Guarding requires the use of a collapsible steel guard gate to warn and prevent pedestrians from falling into an opened confined space.
      2. Guarding of open manholes from tools and equipment falling into an open manhole includes the use of a circular manhole guard ring. Certain manhole configurations may not suitable for using the manhole guard ring. These conditions may include improper sizing that is not within the diameter range of 28", 30", or 32." Another condition may include a guard ring increasing the distance to an upper fixed ladder rung where the initial step-down distance becomes too great to allow a worker safe entry. In these situations, the use of the guard ring may create a hazard and therefore may be exempted by the Entry Supervisor. An alternative is to use a fixed manhole ladder, which extends at least 2 feet above the manhole guard ring. This will generally allow safe entry and exit as well as prevent tools and equipment from falling into the opened space. Another condition where a manhole guard ring may not be a feasible option is when a line of some type (for example, a supplied airline, hydraulic line, etc.) must be routed down into the manhole, which prevents the proper fit of the guard ring or can crimp off a line.
    5. Lighting Requirements. Adequate illumination must be provided. Headlamps are preferred since they provide hands-free operation. Intrinsically safe LED lights are also recommended to provide ambient light.
    6. Safety Guidelines for Equipment. Intrinsically safe electric devices and equipment are required when working in potentially hazardous atmosphere spaces such as sanitary sewer manholes. (Note: "Intrinsic safety" is a protection technique for the safe operation of electrical equipment in hazardous areas by limiting the electrical and thermal energy available for ignition, and to reduce sparking.)
    7. Ladder Requirements. Fixed manhole ladders are to be used when a ladder is required or an existing fixed ladder is deemed unsafe. Extension ladders are prohibited unless there is a reason why manhole ladders are not safe to use. Many of the fixed manhole ladders and/or rungs at LBNL are being removed since they are not properly secured.
  2. Rescue Plans and Associated Equipment
    1. Rescue plans can be of two types: (1) A self-rescue system can be used whereby the Entry Team provides their own rescue to the entrant through the use of their own equipment on site. This will typically be the case for MRO or construction-related work. (2) The second type of plan is where a rescue service provider, such as the Fire Department, is named and relied upon for rescuing an entrant(s). Both types of rescue plans are acceptable under certain circumstances. Regardless of the plan used, wearing a full-body harness enables emergency rescue.
    2. Although the preferred rescue device is a full-body harness, wristlets may be worn instead. Only in-house staff conducting short-term, non-hands-on inspection work may wear wristlets. Wristlets are not to be used by contractors or for the routine lowering or hoisting of personnel into a vertical confined space. Wristlets are designed for emergency rescue purposes only. Since wristlets are not allowable for lowering or hoisting personnel, it is implied that a ladder will be used to enter and exit the space. Chest harnesses are no longer load-rated by ANSI for OSHA and therefore may not be used. This ES&H Manual program does not authorize a requirement, make recommendations, or direct subcontractors to downgrade the PPE or controls as required by OSHA or that employees choose to voluntarily wear and use.
    3. Short-duration inspection-type work, which does not involve MRO work or a subcontractor's construction-related work in the space, will typically rely on the LBNL Fire Department as the rescue service. Provided this exception, a tripod is not required to be available on the entry site, although many project managers require it on their projects. Short duration inspection-type operations, without a tripod on-site, must have a rescue plan coordinated with the Fire Department in order to ensure an availability to respond during the time of the entry. Coordination includes calling the Fire Department at (510) 486-6015 to determine their emergency response staff's availability to perform rescue during a specific entry event.

 

Work Process D. Entry into Inventoried Spaces by LBNL Employees or Affiliates (Does Not Include Subcontractors)

  1. Pre-Entry

Prior to entry into any inventoried space, the Activity Lead must:

    1. Review the work request (if available) for that activity;
    2. Consult the Confined Space Database to determine the classification and hazards of that space;
    3. Inspect the work space to verify that conditions within the space are as described in the Confined Space Database, or to note changed conditions; and
    4. Notify the Confined Space Program Manager of any changed conditions.
  1. Entry into Non-Permit Confined Spaces (NPCSs)

If an NPCS must be entered as part of the work, the Activity Lead must do the following:

  1. Determine whether an applicable Safe Work Procedure (SWP) exists for entry into that NPCS by consulting the Confined Space Database. If so, follow that procedure. If there are any questions on that procedure, contact the Confined Space Program Manager prior to executing the work.
  2. Determine whether the work may introduce a hazard into that space. Examples of hazards that may be introduced include but are not limited to:
      1. Hazardous atmospheres (e.g., solvents, paints, or welding)
      2. Fire (e.g., hot work or grinding)
      3. Electrical (e.g., exposed live electrical energy)
      4. Energy (e.g., removing guards

If the work may introduce a hazard, then the space may need to be reclassified as a Permit-Required Confined Space (PRCS), and LBNL workers will be prohibited from entering that space (see Section 34.1, Policy, above). If the hazards can be successfully controlled, then this reclassification to a PRCS may not be necessary. Contact the Confined Space Program Manager to discuss further.

  1. Entry into PRCSs
    1. If a PRCS must be entered as part of the work, the Activity Lead must do the following:
      1. Determine whether in fact the PRCSneeds to be entered. There may be an SWP for that space allowing work from outside the space. If the desired work can be performed from outside the PRCS, then these requirements for entry do not apply. Work proceeds per that SWP. If there are any questions on that procedure, contact the Confined Space Program Manager prior to executing the work.
      2. Assign an Entry Supervisor to the work
    2. The Entry Supervisor determines what the hazards or potential hazards are within that PRCS.
      1. Reclassification: If the hazards posed by the PRCS are not related to an actual or potential hazardous atmosphere, and the hazards can be eliminated from outside the space prior to entry, the Entry Supervisor may temporarily declassify the PRCS to an NPCS per OSHA 29 CFR 1910.146(c)(7) by completing the PRCS Reclassification Certification prior to the entry.
        1. All spaces for information must be completed or marked "n/a" as applicable.
        2. Each hazards-analysis box must be completed, and a determination confirmed (checked off) that entry conditions are acceptable.
        3. If all hazards have been analyzed, eliminated if necessary, and confirmed as acceptable, the Entry Supervisor completes the final signature block at the bottom of the page, which temporarily declassifies the space as an NPCS.
      2. Alternate Entry Procedure: If the only hazard posed by the PRCS is actual or potential hazardous atmosphere, and continuous forced air ventilation is sufficient to maintain the PRCS safe for entry, then the Entry Supervisor may authorize entry via the Alternate Entry Procedure permitted by OSHA 29 CFR 1910.146(c)(5). This authorization is documented by completing the PRCS Alternate Entry Procedure Certification prior to the entry.
        1. All spaces for information must be completed or marked "n/a" as applicable.
        2. Each hazards-analysis box on page 1 must be completed, and a determination confirmed (checked off) that no non-atmospheric hazards exist within that PRCS.
        3. After air monitoring has been conducted (and recorded on page 1 continuing onto page 2) to document that the continuous forced air ventilation is sufficient to maintain the PRCS as safe for entry, the Entry Supervisor completes the final signature block at the bottom of the page, which authorizes entry under the Alternate Entry Procedure.
    3. If the hazards have been removed and the PRCS has been reclassified (Step 3.b.i above), or if the entry may be made under Alternate Entry Procedure (Step 3.b.ii above), the Entry Supervisor may authorize work to proceed per general safe work practices, including any specified for that work (e.g., an SWP). When entry proceeds, the Entry Supervisor must:
      1. Continually evaluate conditions to assure that the terms of the entry remain valid (for entry under the Alternate Entry Procedure, this includes periodic air-quality testing to support the determination that continuous forced air ventilation protects workers in the space); and
      2. Remove all workers from the space if at any time hazards arise within the space, and re-evaluate the space to determine whether it must be reclassified for permit entry.
    4. If the PRCS cannot be temporarily reclassified as an NPCS or entered under an Alternate Entry Procedure, then the Entry Supervisor must prohibit workers from entering the space, and advise the Activity Lead of the need to obtain the services of a qualified subcontractor to perform the work.

Work Process E. Entry into Inventoried Spaces by Subcontractors

  1. Pre-Entry

Prior to a subcontractor entering any inventoried space, the Activity Lead must:

    1. Consult the Confined Space Program Manager for subcontractor approval status, performance requirements;
    2. Inspect the work space to verify that conditions within the space are as described in the Confined Space Database, or to note changed conditions;
    3. Notify the Confined Space Program Manager of any changed conditions;
    4. Transmit a copy of the updated inventory information to the subcontractor; and
    5. Retain a copy of the transmitted information for post-entry submittal to the Confined Space Program Manager. Forward the completed PRCS Reclassification Certification and PRCS Alternate Entry Procedure Certification and Subcontractor's Entry Permits to the Confined Space Program Manager after expiration of the certification. A drop box for these forms is currently located at Building 78, Room 101E. Alternatively, PDF copies can be sent to mtschmidt@lbl.gov

The Site Specific Safety Plans, Work Planning and Control, or Non-Construction Subcontractor Job Hazards Analysis can provide information on whether the proposed work will require entry into confined spaces.

  1. If a subcontractor must enter a Non-Permit Confined Space (NPCS), then the Activity Lead must do the following:
    1. Determine whether an applicable Safe Work Procedure exists for entry into that NPCS by consulting the Confined Space Database and LBNL Activity Leads. If there are any questions on a procedure, contact the Confined Space Program Manager prior to executing the work.
    2. Determine whether the work may introduce a hazard into that space. Examples of hazards that may be introduced include but are not limited to:
      1. Hazardous atmospheres (e.g., solvents, paints, welding, oxygen deficient, contamination, or chemicals)
      2. Hot work (e.g., torch cutting or abrasive saw)
      3. Electrical (e.g., exposed live electrical energy)
      4. Energy (e.g., unshrouded equipment or removing guards)
      5. Dusts, such as respirable silica dusts, generated by a method such as  sandblasting

If the work will introduce a hazard, then the space needs to be reclassified as a PRCS. Contact the Confined Space Program Manager to discuss further.

  1. Entry into Permit-Required Confined Spaces (PRCSs)

If a subcontractor must enter a PRCS, including entries into a PRCS after reclassification or under Alternate Entry Procedures, then the Activity Lead or Controlling Contractor must do the following:

    1. Transmit the following information to the subcontractor:
      1. Inform the subcontractor that the work area contains a PRCS, and that entry into the PRCS is allowed only through compliance with a PRCS program meeting the requirements of OSHA 29 CFR 1910.146 and 1926.1200, Confined Spaces in Construction.
      2. Provide the subcontractor with Confined Space Database information about the PRCS in or near the area where the subcontractor will be working, including the locations, hazards identified and precautions or procedures that LBNL has implemented for the protection of employees.
    2. Approve the subcontractor's PRCS program after obtaining the Confined Space Program Manager's input as follows:
      1. Obtain a copy of the subcontractor's written confined space program as a contract submittal. The program needs to address and state compliance with the OSHA 1926.1200 Confined Space in Construction Industry standard if construction-related work is to take place.
      2. Provide the subcontractor's written confined space program to the Confined Space Program Manager for review. Allow at least five workdays for review and resolution of comments.
      3. For those subcontractors who wish to use their own Entry Supervisor to prepare entry permits the following items are required to be submitted to the Confined Space Program Manager for review and approval. 1. A certificate showing Confined Space Qualified Person classroom training in atmospheric testing principles for confined spaces 2. Documentation for the type of four-gas meter to be used; only pump-type meters will be approved. 3. Documentation of monthly and daily calibration. 4. Information on low and high meter alarm settings. 5. Submit blank copies of the entry permits to be used for review.
      4. Direct the subcontractor during resolution of the comments. The Confined Space Program Manager does not direct the subcontractor.
      5. Prohibit the subcontractor from entering the PRCS until any issues with the subcontractor's written confined space program have been resolved to the satisfaction of the Confined Space Program Manager
      6. Obtain confined space training certificates for all workers who will be on site. The worker training must includes all elements of the OSHA 1926.1200 Confined Spaces in Construction standard if construction-related work will be conducted. Training must include a hands on practical portion. Training certificates must have the name of the course instructor and the date completed. Online or in-house training is not acceptable for initial training.
      7. Obtain and submit records of monthly calibration documentation for the four-gas meters to be used on site.
    3. If multiple subcontractors will simultaneously enter the PRCS, or if subcontractor and LBNL personnel will work in or near the PRCS, convene a meeting of affected parties to discuss the work that will be performed in and around the PRCS. Coordinate entry operations such that employees of one subcontractor do not endanger LBNL employees or the employees of any other subcontractor. No subcontractor shall enter a PRCS under any reclassification, Alternate Entry Procedure, or permit until coordination procedures and authorizations have been agreed upon.
    4. Assure that prior to subcontractor entry into a PRCS, an LBNL Construction Safety Entry Supervisor has reviewed the documentation prepared by the subcontractor (e.g., the coordination procedures and authorizations) and concurs on the documentation's adequacy.
    5. Debrief the subcontractor at the conclusion of the PRCS entry operations regarding the confined space program followed, and regarding any hazards confronted or created, or changes in Permit Spaces during entry operations.
    6. Annual reviews of the confined space entry permits are conducted by the Confined Space Program Manager. As part of this review, debriefing and notification of deficiencies are communicated.

Work Process F. Training

  1. With the exception of subcontractors covered by their own approved Permit-Required Confined Space (PRCS) Program, any LBNL staff, affiliate, visitor, or other individual who performs work at LBNL and who will enter a space classified as a PRCS, whether on a Safe Work Procedure, reclassification, Alternate Entry Procedure, or another work plan, must have current training in EHS0275 Confined Space Hazards and EHS0274 Confined Space Hazards Retraining (if applicable). This training requirement is triggered by employee's work activities in Work Planning & Control (WPC). EHS0275 is not required for those entering Non-Permit Confined Spaces as long as the following criteria are met and maintained: No hazards are introduced into the space (i.e., hot work, chemicals, etc.); the buddy system is used (i.e., workers do not work alone); Safe Work Procedures are used; and proper PPE is worn (i.e., hard hats or helmets are worn while working in spaces with head injury hazards).
  2. With the exception of subcontractors covered by their own approved PRCS Program, any LBNL staff member, affiliate, visitor, or other individual who performs work at LBNL and who functions as an Entry Supervisor shall be current in EHS0277 Confined Space Entry Supervisor. This training requirement is delivered via the individual designated as an Entry Supervisor by the Confined Space Program Manager.
  3. EHS0276 Fall Protection training must be completed by in-house staff who will be an authorized member of a Confined Space Entry Team.

Work Process G. Program Effectiveness Review and Assurance

  1. The Confined Space Program Manager, Activity Lead, and Entry Supervisor must prohibit further entry into a Permit-Required Confined Space (PRCS) Program and review entry operations whenever there is reason to believe that measures taken under this program may not protect employees. In particular, the Activity Lead and Entry Supervisor must notify the Confined Space Program Manager of:

Additionally, the Confined Space Program Manager must review entry operations after:

  1. The Confined Space Program Manager must conduct an ongoing effectiveness (Technical Assurance) review of the program by annually reviewing all PRCS entries.


34.6 Appendices

Appendix A. LBNL Implementation of Permit-required Confined Space Decision Flowchart
Appendix B. Confined Space Evaluation Worksheet
Appendix C. PRCS Reclassification Certification
Appendix D. PRCS Alternate Entry Procedure Certification
Appendix E. Permit-Required Confined Space Entry Debrief

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