Quick Start Guide
Chapter 34: Confined Spaces

Program: Confined Spaces
Revised 12/17
URL: http://www.lbl.gov/ehs/pub3000/CH34.html
Revision Record: http://www.lbl.gov/ehs/pub3000/Pub3000Changes.html

Who needs to know about these requirements?

The requirements of the Confined Spaces program apply to:

• Berkeley Lab employees, researchers, interns, and affiliates 
• Consultants, utility companies, inspectors, visitors, and guests
• Facilities Maintenance and Repair Operations (MRO) personnel, including those from UC Berkeley who service utilities, such as electrical utilities
• Prime contractors and their subcontractors, and tradespeople

Whenever they are:

• Performing general industry work at an LBNL facility, including work performed in confined spaces by Facilities staff, custodians, researchers, and their assistants 
• Performing work in adjacent confined spaces, such as manholes, sewer flumes, storm drains, or other infrastructures related to the operation of the LBNL facility but are located immediately outside its boundaries  
• Performing work that involves entering either non-permit or permit-required confined spaces 
• Performing construction-related work that requires confined space entry 

Why?

Confined spaces are work locations that meet regulatory definitions and require rigorous and continuous evaluations and work authorization. In addition, safe work practices and procedures required by Integrated Safety Management systems and Work Planning & Control are required. Improper entry into confined spaces may result in:

• Injury or death
• Fire or explosions
• Violation of federal and state regulations

What you need to do before performing work:

1. Define the work.

1. Review the Maximo Confined Space Information or consult with the Program Manager to determine if the space in which the work will be performed has been evaluated for classification as a Permit-Required Confined Space. See Work Process A.
2. Identify any new spaces where work will be performed to determine if the space should be classified as a Permit-Required Confined Space. If it does, contact the Confined Space Program Manager to perform and document the classification. See Work Process B.
3. Determine if the work requires general industry-related entry into a Permit-Required Confined Space by LBNL employees or affiliates. If it does, a specially trained and designated Entry Supervisor must evaluate the hazards and controls, and write the entry permit, and then conduct initial atmospheric testing. See Work Process D.
4. If the work is construction-related or involves a subcontractor entering a Confined Space, notify the subcontractor of their requirements and submit the subcontractor's training and Permit-Required Confined Space Program to the LBNL Confined Space Program Manager for review and evaluation.  Subcontractors may be required to write their permits depending on whether they are the controlling contractor. See Work Process E.   

2. Analyze hazards.

1. Determine if the work will introduce hazards into the space that must be controlled or substituted in order to safely perform work.
2. Determine if hazards in Permit-Required Confined Spaces can be eliminated prior to entry or if continuous forced air ventilation is sufficient to control and maintain the atmosphere of the Permit-Required Confined Space safe for entry. Only a designated Confined Space Entry Supervisor may make this determination. See Work Process D and Work Process E, and use Appendix C or Appendix D (as appropriate) for documentation. If the hazards cannot be eliminated or controlled, or if LBNL does not have the needed equipment, experience, or protection, then the space may NOT be entered by an LBNL employee or guest. The Activity Lead for that project would need to engage a specialty subcontractor to conduct the work.

3. Develop Controls

1. Work in any space that has been evaluated and included in the Maximo Confined Space Information or backup inventories must be conducted at a minimum in conformance with the Safe Work Procedure(s) developed for work in that space. Most spaces will require the use of additional controls. See Work Process C.
2. If the space has been classified as a Permit-Required Confined Space, then hazards must be eliminated or controlled prior to entry into that space. See Work Process D and Work Process E, and use Appendix C or Appendix D (as appropriate) for documentation. If the hazards cannot be eliminated or controlled, then the space may NOT be entered by an LBNL employee or guest. The Activity Lead for that project would need to engage a specialty subcontractor to conduct the work.

Where to find out more:

• LBNL Health and Safety Manual (PUB-3000), Chapter 34 (Confined Spaces)

Whom to contact for help:

• Mark Schmidt, EHS Confined Space Program Manager, ext. 4915