Confined Space Entry Program Update
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LBNL’s confined space entry program was substantially improved this year.
Several new features have been included which improve overall safety for Confined Space Entrants and better align the confined space entry program with the OSHA requirements.
As an Activity Lead, Confined Space Entrant or Entry Supervisor, you should be aware of the following:
- We improved the procedures for safely working in confined spaces. Please review the new Chapter 34 in Publication 3000. Additionally, we have a new planning tool known as the confined space inventory which is a registry of LBNL’s confined spaces, their potential hazards and safe work procedures unique to a particular confined space.
- Per LBNL Policy, LBNL personnel may not “break the plane” of a Permit Required Confined Space (PRCS) until it is reclassified as a Non-Permit Confined Space.
If the hazards in a PRCS cannot be eliminated or controlled, then it cannot be reclassified.
Whenever a PRCS cannot be reclassified, then the work activity will be subcontracted to a qualified Firm who specializes in this type of work.
On the other hand, when all hazards are eliminated, an LBNL Entry Supervisor will issue a Reclassification Certificate that certifies that all hazards were eliminated and that safe work procedures have been defined to work in the confined space.
- There are two types of Confined Spaces at LBNL:
- Permit Required Confined Spaces (PRCS): These are confined spaces that has one or more of the following characteristics:
(1) Contains or has a potential to contain a hazardous atmosphere;
(2) Contains a material that has the potential for engulfing an entrant;
(3) 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
(4) Contains any other recognized serious safety or health hazard.
- Typical examples of PRCS at LBNL include: Above Ground Tanks, Underground Storage Tanks, sanitary sewers manholes, lift stations and wet sumps, portions of storm-water systems, elevator pits and shafts and electrical & telecommunication vaults.
- With the exception of round manholes, all PRCS will be labeled with a Warning Sign that reads: DANGER -- PERMIT-REQUIRED CONFINED SPACE, DO NOT ENTER
Round manholes by definition are considered PRCS and will not have a Warning Sign.
Remember, before a PRCS can be entered by an LBNL employee, the Entry Supervisor must complete and sign the Reclassification Certificate.
- Non-Permit Confined Spaces: means 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.
Non-Permit Confined Space, under usual conditions, will be safe to enter and perform work. However, the Activity Lead must:
- Determine whether an applicable Safe Work Procedure exists by checking the confined space inventory and following that procedure. If there are any questions on that procedure, contact the Confined Space Program Manager prior to executing the work.
- Determine whether the work may introduce a hazard into that space. Examples of hazards that may be introduced by the work include but are not limited to:
- Hazardous atmospheres (from use of solvennts and coatings, or work such as welding and grinding, for example)
- Stored energy
If the work may introduce a hazard, then the space needs to be evaluated by an Entry Supervisor and personnel are prohibited from entering that space. Contact an Entry Supervisor or the Confined Space Program Manager to discuss further.
- Technical Resources: Should you have any questions about the confined space program, please contact:
Barbara Tuse’ Heather Madison
Confined Space Program Manager Deputy Confined Space Program Manager
"Barbara Tuse'" firstname.lastname@example.org "Heather Madison" email@example.com
Contact EHS training if you are having technical issues: CAyala@lbl.gov (510-495-2228)