Chapter 34
CONFINED SPACES

Contents

Approved by Mark Schmidt
Revised 12/17


34.1 Policy
34.2 Scope and Applicability
34.3 Roles and Responsibilities
34.4 Definitions
34.5 Required Work Processes

Work Process A. Maximo® Confined Space Information
Work Process B. Classification of Spaces
Work Process C. Safe Work Procedures, Engineering Controls, Rescue Plans, PPE, and Precautions
Work Process D. Planning an Entry into Inventoried Spaces by LBNL Employees or Affiliates (Does Not Include Subcontractors)
Work Process E. Subcontractor Entry into Confined Spaces
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

 

NOTE:
. . . . . Denotes a new chapter or section.
. . . . . . . . Denotes the beginning of changed text within a section.
. . . . . . . . Denotes the end of changed text within a section.

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34.1 Policy

Confined spaces are work locations that meet regulatory definitions and require rigorous evaluation, planning and Work Authorization in addition to the usual safe work practices and procedures required by Integrated Safety Management Systems.
This 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 the main LBNL campus.
  3. Subcontractors performing work directly for LBNL at off-site DOE leased or other off-site locations are covered by the health and safety components of this program. However, LBNL does not evaluate or maintain an inventory of off-site confined spaces. Each separate facility or respective property management firm manage their own confined space inventory. Subcontractors are responsible for obtaining information regarding confined spaces and the associated hazards and precautions from the property management firms.

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) Permit-Required Confined Spaces and the additional requirements in this 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 10, Section 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 Entry Facilities PRCS entry is allowed only for the following situations:
    1. For Maintenance and Repair Operation (MRO) purposes
    2. When the entry is required to keep a critical utility system running for lab operations ("operationally critical")
    3. 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.  For non-construction, general industry work the program and training will address OSHA 29 CFR 1910.146.
    2. Subcontractors are 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 34.2, work performance section, 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 an anticipated risk of exceeding an OSHA PEL and/or when there is no data to prove exposures will remain below the PEL/TLV for a specific operation
      8. For all entries into hazardous materials storage vessels, gas storage vessels, or any tank
    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 of such and have training specific to atmospheric monitoring concepts and evaluating hazards and controls for confined space entry.
      4. An emergency rescue plan and/or arrangements
      5. Supply 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 researchers, Facilities 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 31.5, and may or may not be a "Line Manager" as described in PUB-3000, Chapter 1, Section 1.8.  Activity Leads also may or may not be the Activity Lead as the term is described in Work Planning and Control.

Activity Leads will:

  • Define the activity that requires entry into a confined space.
  • Are ultimately responsible for successful planning, coordination and 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 in Maximo®.  Activity leads may also consult with the SME as to the type of confined space present.
  • 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 permit process.
  • 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 definition:

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 definition:

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 permit writers will:

  • Operate only on PRCSs within their specific area of technical expertise. Consult an Activity Lead, SME or researcher if there are technical questions regarding potential safety hazards, such as falls, electrical, mechanical, radioactive, or chemical hazards.
  • Ensure that PRCSs 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 with a permit to NPCSs and authorize entry thereto, or authorize entry into PRCSs via an Alternate Entry Procedure, as outlined by this program.
  • Forward completed entry permits to the Confined Space Program Manager after expiration of the certification. A drop box is currently available at Building 78 for completed permits.
  • Immediately report to the Confined Space Program Manager:
    • Any unauthorized entry of a PRCS;
    • Any unexpected or new hazards discovered;
    • 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 entry permit system.

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.

Construction Safety Entry Supervisors will:

  • 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 same roles and responsibilities of the regular Entry Supervisor as described above.
  • Uses the SBN safety reporting system to document entries

Subcontractors

Subcontractors will:
  • Conform to the requirements of applicable regulations,  this program and the LBNL Site Specific Safety Plan (SSSP) and attached Job Hazards Analysis (JHA) sheets.
  • If the subcontractor is going to work on a construction-related confined space entry, then the subcontractor will comply with the 29 CFR OSHA Part 1926.1200 Confined Spaces in Construction Industry regulation.
  • 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 built during the construction of or removed during demolition of a structure. Construction-related spaces include pre-existing confined spaces that fall within 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 OSHA 29 CFR Part 1926.1200.
  • If a subcontractor is engaging solely in non-construction work as related to facility maintenance and repair operations, then their confined space safety will be covered under the LBNL Subcontractor Job Hazard Analysis (sJHA) system.

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.

  • 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. Entry Team members are required to have training on how to use rescue equipment including: tripod, winch, life line, harnesses, and rescue pole. 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.
  • The contractor’s Entry Team may perform either entry or non-entry rescues.  However, if the space has IDLH conditions then the Entry Team must call the LBNL Fire Department for rescue provider services.

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.
  • Entries that require the Entrant be lowered into a vertical confined space and who are doing hands-free work requires a fall protection matrix permit. 
  • When the Entrant is wearing a harness, but is not connected directly to a life line, then a rescue pole must be immediately available at the work site in order to remotely connect a life line onto the Entrant’s harness.

Fire Department

The LBNL Fire Department crew, located at Building 48, provides high angle emergency rescue from confined spaces such as manholes. However, self-rescue (either by entry or non-entry) can be conducted by the Entry Team based upon professional judgment and with regard to response time, hazardous conditions in the space, and the nature of the emergency. IDLH and/or hazardous atmosphere emergencies require the specialized response action of the rescue service provider, the LBNL Fire Department.


 

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.

Alternate Entry An alternate entry procedure specified in paragraph 1910.146 (c)(5)(ii).  This is an entry permit that is sometimes simply referred to as “C-5”.  It is used if the employer can demonstrate that the only hazard posed by the permit space is an actual or potential hazardous atmosphere; The employer can demonstrate that continuous forced air ventilation alone is sufficient to maintain that permit space safe for entry.  Continuous atmospheric testing is also required for this type of permit.
Atmospheric testing The process of testing the atmosphere within a confined space to determine whether the atmosphere is both initially safe for entry as well as ensuring that will remain safe for the duration of work.  A four-gas meter is used to test for at minimum; oxygen, carbon monoxide, hydrogen sulfide and lower explosive limit (LEL).  The testing must occur at all levels of the confined space since different gases may settle or rise within the space.  Continuous atmospheric testing must be provided when operations are introduced into the space that are anticipated or known to create atmospheric hazards (i.e. hot work, exhausts, chemicals, fumes, welding)

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-required confined space. There are three types of permits; Alternate Entry, Reclassification, and Regular Permit-Required Confined Space.  Note that a reclassification is still considered a type of 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 10, Section 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 with toxic, oxygen deficient/enriched, or combustible gases 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 explosive limit (LEL), sometime referred to as LFL.
  • Atmospheric oxygen concentration below 19.5 percent (deficient) or above 23.5 percent (enriched)
  • Carbon monoxide greater than 25 ppm concentration
  • Hydrogen sulfide greater than 10 ppm concentration (or >1 ppm for the TLV)
  • 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.)
  • 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.)
  • 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 (e.g. grinding, brazing, 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 main facility 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. 

Reclassification Entry Permit A reclassification permit is commonly referred to as “C-7” and can be used 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 (e.g. LOTO used to shut of moving mechanical components or energized components). The Entry Supervisor may temporarily declassify (for the duration of the work shift) the PRCS to an NPCS per OSHA 29 CFR 1910.146(c)(7) by completing the PRCS Reclassification Certification prior to the entry. Note that even though the space is temporarily “reclassified”, it still requires this permit.

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. Rescues can be either entry or non-entry types.

Rescue service

Personnel designated to rescue employees from Permit Spaces. The Alameda County Fire Department at LBNL is the designated rescue service.

Retrieval system

The equipment (including a retrieval line [life 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. Maximo® Confined Space Information
Work Process B. Classification of Spaces
Work Process C. Safe Work Procedures, Engineering Controls, Rescue Plans, PPE, and Precautions
Work Process D. Planning an Entry into Inventoried Spaces by LBNL Employees or Affiliates (Does Not Include Subcontractors)
Work Process E. Subcontractor Entry into Confined Spaces
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 all assets and control work order requests. Maximo®includes a confined space asset 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.  To access a spreadsheet listing hazards and precautions in Maximo®, click here
    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 the space has not yet been entered into the database.  If there is not listing present, consult with the confined space SME with questions regarding classification.
    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.  To clarify, if a space cannot be bodily entered, is not a confined space. 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 danger or caution signage due to outdoor weathering of labels. Manhole covers usually have the ID number bead welded or tagged with a circular brass badge. Some spaces such as vaults or stormdrains may have painted stencil signage. The verification of unlabeled spaces can be confirmed by referring to the database location description or locating the space on a site map.  Site maps are available for storm water, sanitary sewage, electrical, and telecomm lines. 
    6. The absence of an inventory listing for a space 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 a formal evaluation and classification of new spaces (see Work Process B below) for entry into the Maximo® system by facilities.
    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 which provides respective locations and description notes.

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 (SME) has sole (delegable) authority for classification of spaces.
  3. Facilities staff then enters newly evaluated spaces into the Maximo® database, generates Maximo® identification numbers, marks their location on the site drawings, and tags the confined space entry covers.
  4. The Confined Space Program Manager classifies a space by:
    1. Evaluating the space using the Confined Space Evaluation Worksheet which is a checklist decision type form;
    2. Determining the space 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 any unique or sui generis Safe Work Procedures are necessary for entry into that space; and if so
    4. Developing the Safe Work Procedure in consultation with the entrants and the space owner
  1. Some spaces across LBNL are categorically classified as an NPCS or a PRCS. "Categorical classification" means that the category of the space has been classified based upon general homogenous 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 based on determining criteria specified in OSHA 1910.146 definitions and Section 34.4, Definitions, above.  If a space does not meet the regulatory definition of a Confined Space or PRCS, this does NOT necessarily 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 program and via ongoing classroom 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 are PRCSs with hazardous atmosphere being the primary, defining hazard characteristic.
    2. Components of the storm-water system may be Not a Confined Space, an NPCS, or a PRCS depending.  See component items i through iv below:
      1. Storm-water pipes or curb grate openings with a diameter or dimensions too small to bodily enter are considered Not a Confined Space.
      2. Underground storm-water pipes with a diameter large enough to bodily enter are PRCSs.
      3. Catch basins or sumps 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.  The presence of decaying leaf litter can create an oxygen deficient hazardous atmosphere making catch basins PRCS.
    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), standing water, and narrow 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. Electrical hazards may be present in confined spaces.  Electrical hazards are often caused by storm water flooding which submerges electrical outlets, submersible pumps, damaged components, and wiring. Standing water should always be tested to determine if it is energized before contacting.  Standing water also needs to be pumped out before work can occur at lower levels.  Some manholes have high voltage electrical cables (i.e. 12Kv) that will require a Qualified Electrical Worker III (QEW 3) to enter.  A QEW 2 may only enter high voltage confined spaces with direct supervision from a QEW 3.
    5. Fuel storage tanks, whether aboveground or underground, are PRCSs with hazardous atmosphere (flammable vapor) being the defining characteristic (exception: those that cannot be bodily entered are Not a Confined Space).
    6. 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).
    7. 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 and LOTO being the control.
    8. Air-handling units with exposed (unshrouded / unguarded) moving mechanical parts that are running or which may automatically start are PRCSs.  Air handling units that are under negative air pressure are also PRCS due to difficulty in entering and exiting the space if there is an emergency. 
    9. Raised computer room floors, which can be bodily entered, are categorically classified as Non-Permit Confined Spaces and require safe work practices or building-specific safety procedures such as those at Building 59 CRT. 
    10. Liquid nitrogen tanks with hatch openings that are too small for bodily entry are not considered confined spaces, Not a Confined Space.
    11. Attics and storage closets with standard-size entry doors are generally not considered confined spaces. However, attics with hatch doors or small doors that require entrants 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.
    12. Cooling towers are considered PRCS.  Typical hazards associated with cooling tower entries are moving mechanical parts, unshrouded mechanical, internal configurations, exterior caged ladder access, falls, and standing water. 

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, davit arm, life line and rescue pole. 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.
    3. Members of the Entry team are required to have CPR training and knowledge of how to set up and operate the tripod and winch system.  Use of such hoisting systems is taught in the EHS 0276 practical course. 
  1. Safe Work Procedures (SWPs) are steps and precautions developed by LBNL which apply to all PUB 3000 programs and hands on work.  The SWPs for confined space entry are described below.  SWPs for confined spaces are also now included in Work Planning and Control (WPC). 
    1. Specific SWPs are established by the Confined Space Program Manager in cooperation with the owner of the space, Activity Managers and Facilities MRO staff.   Entrants who enter that space, regardless of the category or type, 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 of entry procedures, radio contact requirements, do not introduce hazards, wear appropriate PPE, and use the "buddy system" (no work-alone policy).   Work within all attic and crawl spaces is subject to this general SWP.   See the general SWPs for Non-Permit Required confined spaces on the caution label below. 
      2. Specific SWPs are associated with a specific confined space. They supplement the general SWP for a particular space. If there is a contradiction between a General and a Specific SWP, the Specific SWP applies.
      3. SWPs are shown in the precautionary labels (shown below) and are affixed to many confined spaces at the point of entry.


    1.  

       


       

       

       



  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.  The two main purposes for harnesses are 1. for lowering or hoisting personnel from a confined space and 2, emergency 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. If the Entrant will be wearing a harness and will remain continuously tied off to a tripod or other such lowering device, and is required to perform ‘hands free’ work within the space, then a fall protection matrix form is required to be completed prior to work.
        3. If the Entrant is using a manhole ladder to enter the space and can maintain ‘three points of contact’ then no fall protection matrix is required.
      2. Full-body harnesses are required for lowering or hoisting personnel from vertical confined spaces when using a tripod or davit arm. A rescue-type harness is preferred. 
      3. A boatswain’s chair may be used in conjunction with the harness for lowering and raising Entrants.
      4. Harnesses are required to be worn by Entrants for work in vertical spaces greater than 5 feet in depth. 
      5. Full-body harnesses are required to be worn by any Entrant whether they are in-house staff, subcontractors or inspectors.
      6. Facilities or other in-house staff are responsible for acquiring their own harnesses.
      7. Entrants may choose to wear resuce-type harnesses.
    2. Retrieval Lines. In general, entrants must maintain a retrieval line connected to their harness during vertical confined space entry (i.e., manholes and deep vertical spaces such as storm drains) to enable a means for body support during retrieval. The retrieval line should be immediately accessible by the attendant(s), but it does not necessarily need to be tied off full time above the confined space. If the retrieval line causes a demonstrated danger of entanglement or hazardous impediment such that a greater hazard is created, then the conditions will be evaluated on a case-by-case basis and only then exempted by the designated Entry Supervisor.
    3. Self-rescue equipment, including a tripod with winch, life line, and rescue pole must be immediately 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.  For example, an Entry Team may choose to use a manhole ladder as the primary means for entry/exit; however; a tripod with winch, life line and rescue pole must still be available at the job site. Descriptions of self-rescue equipment appear below.

    Self-Rescue Equipment Descriptions

    Equipment

    Description and tasks used for

    Tripod with winch and cable

    A tripod can be used to lower and raise the entrant for access into a vertical confined space.  The Entrant is typically tied off continuously to the tripod cable which is attached to the winch.  However, a tripod can also be used for rescue purposes.  If a manhole ladder is used to access a vertical confined space, then then a tripod must be kept immediately available at the entry location for rescue purposes. 

    Davit Arm

    A davit arm is hoisting device that can also be used to raise and lower Entrants in vertical confined spaces.  The Entrant is typically kept continuously attached to the davit arm cable.  However, since davit arms are bulky, heavy, and require significant time to assemble the modular components, they not kept at the entry site as a rescue device.  A davit arm is typically when more access is needed to the entry point of vertical confined spaces. 

    Harness

    A full body harness is worn by the Entrant at all times when entering a vertical confined space.  However, the Entrant’s harness may not necessarily by connected full time to the tripod cable, or life line.  (For rescue a lifeline is connected to the dorsal D ring connector.) Rescue-type harness with seat or bridle that connects with double D rings is preferred. 

    SRL

    A self-retracting life line (SRL) is not required unless the confined space is excessively deep where a worker could fall to lower levels.  An SRL is commonly attached to one of the tripod arms in addition to the winch.   

    Lifeline

    Lifelines are attached to the worker’s harness for lower/raising or rescue purposes.  A lifeline must be immediately available at the entry site for rescue purposes. 

    Lanyard

    A flexible line of rope, wire rope, or strap which generally has a connector at each end for connecting the body belt or body harness to a deceleration device, lifeline, or anchorage.   Lanyards are typically 6 feet in length or less.  Lanyards may be used in some cases for rescues but a mostly used to retrain workers around unprotected edges of open vaults, pits and manholes. 

    Rescue pole

    A telescoping pole used to attach a lifeline to a fallen Entrant for rescue.  Rescue pole kits include a descender with carabiner, rope and safety hook, extension pole, mini-haul system anchorage strap.  The rescue pole is used to remotely hook up a lifeline to the Entrant’s harness for rescue purposes.  Rescue poles are often used for self-rescue when there are IDLH conditions present that would prevent an Attendant from an performing an entry rescue. 

    Wristlets

    Wristlets may be worn for rescue purposes only.   Wristlets offer a slight advantage for extracting an Entrant out vertically by the arms thus, offering more clearance in small diameter configuration manholes.  Workers are not to be lowered or raised by the use of wristlets. 

     

    1. Guarding Requirements

      When entrance covers are removed, the opening shall be promptly guarded by a railing, temporary cover, or other temporary barrier that will prevent an accidental fall through the opening and that will protect each employee working in the space from foreign objects entering the space.

      1. Guarding must always be used for vertical confined spaces. Guarding requires the use of a collapsible, steel guard gate to warn and prevent pedestrians and workers from falling into an opened confined space.
      2. Guarding of open manholes from tools and equipment falling into an open manhole may include 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" of the ring.  Another condition may include a guard ring increasing the distance to an upper ladder rung so that the initial step-down distance becomes too great to allow safe entry. In these situations, the use of the guard ring may create a hazard and therefore may be exempted by the Entry Supervisor.  The use of a fixed manhole ladder, which extends at least 3 feet above the manhole guard ring will generally allow safe entry and exit. 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, and which would prevent the proper fit of the guard ring or crimp a line.
    2. Lighting Requirements. Adequate illumination must be provided for work within confined spaces. Headlamps are a preferred supplement to ambient light since they provide hands-free operation. Intrinsically safe LED lights are recommended to provide ambient light.
    3. 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.)
    4. General Equipment. Facilities and contractors are expected to provide proper equipment for safe confined space entry.  LBNL does not loan out equipment to contractors.  The following equipment items are provided as a general guidance checklist for entering confined spaces.   Not all of these items will always apply since the types of confined spaces vary as well as the type of work operation. 
      • Manhole ladder (the ladder needs to be long enough to allow safe entry/exit).  Extension ladders are prohibited.   
      • Collapsible tripod with Self Retracting Device (SRD) (keep it at the site during entries in case rescue is needed).  A tripod can also be used for lowering and raising workers.
      • Rescue Poles are used to remotely attach a life line to an Entrant's harness if needed.
      • Harnesses (worn full time for vertical confined space entry.)
      • Hand free work were the Entrant is lowered into a vertical confined space via a tripod will need a fall protection matrix
      • Collapsible guard rail (yellow, steel tubular guardrail).
      • Barricades and barriers to regulate the work area, traffic control, and keeping unauthorized people out
      • Signage to prevent pedestrians from falling into open holes (if in walkways or building interiors)
      • Forced air ventilation blower unit with flex duct. 
      • Protect the opened vault from equipment or debris falling inside when an Entrant is inside.  A guard ring can be used. 
      • Illumination
      • Means of communication (radios)
      • Atmospheric testing meter (calibrated monthly)
      • Personal Protective Equipment (PPE)
    5. Ladder Requirements. If a ladder is used for entry, manhole ladders are to be used.  Manhole ladders are narrow, light, have handle hoops and are specifically designed for entering and exiting manholes confined spaces.  Extension ladders are not suitable and are prohibited unless there is a reason why manhole ladders are not safe to use.  Some internal ladders at LBNL are aging and the rungs or ladder assembly may be loose and/or unsafe.  Check the integrity of the rungs prior to relying on their ability to support weight.  Many of the internal sanitary sewer manhole ladders at LBNL have been removed, which will now require the use of a ladder or hoisting system for entry.
    6. Atmospheric Testing.  The Entry team is required to test the atmosphere within a confined space to determine whether the atmosphere is both initially safe for entry as well as ensuring it will remain safe for the duration of work.  A four-gas meter is required to test for at minimum; oxygen, carbon monoxide, hydrogen sulfide and lower explosive limit (LEL).  Four gas meters are available for check out by EHS 0277 trained staff at the Building 26 industrial hygiene lab, Room 032.  The Entry Supervisor will ensure that the meter to be used is within it’s monthly calibration period and will perform a ‘bump test’ or pre-work daily verification. 

      During the entry, if a meter alarms, the Attendant will direct the Entrant(s) to exit the space. An evaluation will then be made as to the source and cause of alarming.  Engineering controls and elimination methods will need to be re-evaluated to prevent further atmospheric hazards from occurring.  The current lower alarms (audible and visible) for these four gases are set as follows: 

      Oxygen = 19.5%
      Carbon Monoxide = 25 ppm
      Hydrogen sulfide = 10 ppm (1 ppm for the TLV)
      Lower Explosive Limit (LEL) = 10% of LEL

      Testing must occur at all levels of the confined space (top, middle and bottom and/or every five feet) since different gases may settle or rise within the space respectively.  Adequate time must be given for the pumped meter to pull up air from deep levels and analyze the gas.  Typically, the duration for gas to travel up the sample tubing is one second per foot of tubing.  Continuous atmospheric testing must be provided when operations are introduced into the space that are anticipated or known to create atmospheric hazards (i.e. hot work, exhausts, chemicals, fumes, welding).  All Alternate Entry permits require continuous atmospheric testing.  Entrants may also choose to wear a four-gas meter on their person, as a supplement to main testing meter.  The atmosphere in and around the confined space should remain safe during entry operations.  Attendants must be aware of common sources of hazardous atmospheres such as adjacent idling vehicles and portable generators which create carbon monoxide that can enter the space.

  2. Rescue Plans and Associated Equipment
    1. A rescue plan at LBNL involves two rescue scenario types as described below:

      A self-rescue system can be used whereby the Entry Team provides their own rescue to the entrant(s) via their own trained personnel and with the use of their own equipment kept on site.  Self rescue is generally the preferred method due to the faster response time as compared to summoning a rescue provider. IDLH conditions necessitate that the LBNL Fire Department is contacted to conduct the rescue. 
      1. The second type of system is where a rescue service provider, such as the LBNL Fire Department, is named by the Entry Team as the emergency responder and relied upon for rescuing an entrant(s).  Both types of rescue systems are acceptable depending upon the circumstances. Regardless of the plan used, wearing a full-body harness enables emergency rescue.  Keep in mind that 60% of all confined space fatalities are the would-be rescuers because they did not have the proper equipment or training to perform a safe rescue.  Therefore, a fallen entrant(s) trapped in a confined space with the presence of IDLH condition and/or hazardous atmospheres will require that the rescue be performed by the LBNL Fire Department. Note that self-contained breathing apparatus (SCBA) are usually required to be worn for emergency rescues and that LBNL staff and contractors do not own or use SCBA.
    2. Although the preferred rescue device is a full-body, rescue-type 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.
    3. Short duration inspection-type operations, without a tripod provided directly at the work site, must have a rescue plan coordinated with the Fire Department in order to ensure their availability to respond during the specific time of 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. Planning an Entry into Inventoried Spaces by LBNL Employees or Affiliates (Does Not Include Subcontractors)

  1. Entry into Permit-required Confined Spaces (PRCS)

Prior to entry into any Permit-Required Space (PRCS) , the Activity Lead must:

    1. Review the work request (if available) for that activity;
    2. Determine whether in fact the PRCS needs to be entered. There may be an SWP for that space allowing work from outside the space or if a substitution method can be implemented.  Keep in mind that if the plane of the entry to the confined space is broken (e.g. putting an arm into the space for example) then that is considered and “entry”.  
    3. Consult the Confined Space Database to determine the classification and determine what hazard(s) are present in the confined space.
    4. 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
    5. Notify the Confined Space Program Manager of any changed conditions.
    6. Select and coordinate an Entry Team.  Ensure the team members have current EHS 0275 training and the Entry Supervisor has EHS 0277 training. 
    7. Reference Work Plan and Control (WPC) for hazards and precautions.    
    8. Communicate hazards and determine the hazard controls to the Entry Team.
    9. Arrange a scheduled time for an Entry Supervisor to write a permit as needed.
  1. Entry into Non-Permit Confined Spaces (NPCSs) with Work that Introduces a Hazard

If the work introduces any hazard(s), then the space becomes a permit-required confined space (PRCS).  Prior to entry into a NPCS where the work will introduce a hazard, the Activity Lead must:

  1. Determine whether an applicable Safe Work Procedure (SWP) exists for entry into that NPCS by consulting the Maximo® Confined Space Database or other type of known hazard. If so, follow that procedure. If there are any questions on a confined space procedure, contact the Confined Space Program Manager prior to executing the work. 
  2. Determine whether in fact the PRCS needs to be entered. There may be an SWP for that space allowing work from outside the space or if a substitution method can be implemented.  Keep in mind that if the plane of the entry to the confined space is broken (e.g. putting an arm into the space for example) then that is considered and “entry”.  
  3. Reference Work Plan and Control (WPC) for hazards and precautions.   
  4. Determine what hazard(s) planned on being introduced into the NPCS space and determine an appropriate corresponding control. Examples of hazards that are commonly introduced include but are not limited to:
    • Hazardous atmospheres (e.g., solvents, paints, or welding)
    • Fire (e.g., hot work or grinding)
    • Electrical (e.g., exposed live electrical energy)
    • Energy (e.g., removing guards
    • Chemicals or contamination (which may expose entrant)

If the work introduces any hazard(s), then the space becomes a permit-required confined space (PRCS) and unauthorized workers will be prohibited from entering that space (see Section 34.1, Policy, above).   A permitting process will be required for entry when a hazard is introduced and an Entry Supervisor will be needed to prepare the entry permit.  In conjunction with the Activity Lead, 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 (e.g. LOTO used to shut of moving mechanical components or energized components), the Entry Supervisor may temporarily declassify (for the duration of the work shift) the PRCS to an NPCS per OSHA 29 CFR 1910.146(c)(7) by completing the PRCS Reclassification Certification prior to the entry.  The entry permits must be fully completed with detailed descriptions as follows:

  1. Describe in the detail the purpose of the work
  2. Describe the pre-existing and/or introduced hazards in detail
  3. Describe the hazard controls to be used in detail
  4. Record the initial and periodic atmospheric testing results
  5. Document the names of the entry team members
  6. All spaces for information must be completed
  7. Each hazards-analysis box must be completed, and a determination confirmed (checked off) that entry conditions are acceptable.
  8. When all hazards have been evaluated, eliminated if necessary, and confirmed as acceptable, the Entry Supervisor completes the final signature block at the bottom of the permit, which temporarily declassifies the space as an NPCS.
  1. Alternate Entry Procedure

If the only hazard posed by the PRCS is actual or potential hazardous atmosphere, and continuous forced air ventilation and continuous atmospheric testing 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. Describe in the detail the purpose of the work
  2. Describe the pre-existing and/or introduced hazards in detail
  3. Describe the hazard controls to be used in detail
  4. Record the initial and continuous atmospheric testing results
  5. Document the names of the entry team members
  6. All spaces for information must be completed
  7. 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.
  8. After air monitoring has been conducted (and recorded on page 1 continuing onto page 2) to document that the continuous forced air ventilation and continuous atmospheric testing 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.

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 may either stay at the work site or leave and pass over authority to the Attendant.  The Attendants must ensure the following:

    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)
    2. Provide continual, full-time, support to the entrant(s), recognize any unusual health symptoms of the entrant(s) and ensure their general safety. 
    3. 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.


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 confined space SME and Activity Lead. A qualified subcontractor may need to be retained to perform work where high hazard risks are involved and cannot be controlled or eliminated.

Work Process E. Subcontractor Entry into Confined Spaces

  1. Non-Construction Related Subcontractor Confined Space Entry into Either PRCS or Non-PRCS

For non-construction related work, such as MRO, a subcontractor may enter a pre-existing confined space at LBNL.  This type of work is covered under the general industry regulation 1910.146 and this Program.  Prior to a subcontractor entering an inventoried confined space, the Activity Lead must:

    1. Consult EHS and the Confined Space Program Manager (SME) for subcontractor approval and authorization status.  (Subcontractors must submit a program and training for review)
    2. Reference the subcontractor Job Hazard Analysis (sJHA) database for information on hazards, precautions, and equipment required for entry. 
    3. Inspect the space to verify that conditions within are as described in the Confined Space Database;
    4. Notify the subcontractor of the hazards and precautions
    5. Notify the Confined Space Program Manager (SME) of any changed conditions;
    6. Arrange for an Entry Supervisor to write an entry permit for PRCS. 
    7. Submit the completed entry permit to the confined space SME at Building 78.
  1. Construction-Related Subcontractor Entry in Confined Spaces

    If a subcontractor must enter a PRCS, including entries into a PRCS after reclassification or under Alternate Entry Procedures, then the Host Employer’s Activity Lead and Confined Space SME will 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 Persons 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. 6. A sampling methods plan.
      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 include and state that the elements of the OSHA 1926.1200-1213 Subpart AA Confined Spaces in Construction standard were part of the curriculum. Training must include a hands-on practical portion if the worker is to be a member of a PRCS entry team, and rescue training must also be included. Training certificates must have the name of the course instructor and the date completed. In-house training as provided directly to workers by the employer is not acceptable.
      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).
  2. EHS0275 or an equivalent one hour, 1:1 course is required for those entering Non-Permit Confined Spaces.  The following criteria must be met and maintained: No hazards are to  introduced into the space (i.e., hot work, chemicals, etc.); use the buddy system (i.e., workers do not work alone); Use Safe Work Procedures; and wear proper PPE (i.e., hard hats or helmets while working in spaces with head injury hazards).
  3. With the exception of subcontractors covered by their own approved PRCS Program, any LBNL staff member or affiliate who performs work at LBNL and who functions as an Entry Supervisor shall be pre-selected based on qualifications and remain current in EHS0277 Confined Space Entry Supervisor training. 
  4. EHS0276 Fall Protection training must be completed by in-house staff who will be an authorized member of a Confined Space Entry Team. The purpose of this training is to ensure proper use of harnesses, tripod and self-rescue.

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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