Confined Space Permit Program

Purpose

The University is required to have a Permit Confined Space Program that meets the Occupational Safety and Health Administration (OSHA) requirements. This program consists of procedures to prevent injuries to workers who must work near, or enter, confined spaces that contain serious or life threatening hazards.

Scope

Spaces that are ‘physically confining’ or ‘enclosed’ must be identified and evaluated by departments to determine if the space is regulated under OSHA’s standard for permit confined spaces. For OSHA Permit Required Confined Spaces, requirements include supervisory and employee responsibilities, training procedures, management of change, periodic reviews, and coordination of information with other parties needing access to the space.

Policy and Regulation

University of Iowa Operations Manual, Part III Human Resources, Division II Standards and Ethics, Chapter 16.4d Policy on Ethics and Responsibilities for University of Iowa Staff.

OSHA Regulation, 29 CFR 1910.146, Permit-Required Confined Spaces for General Industry.

Roles and Responsibilities

EHS is responsible for:

  • Establishing University expectations to meet regulatory requirements.
  • Developing training related to confined spaces.
  • Conducting a yearly audit of each department’s program.
  • Providing technical assistance to departments when requested.

Departments are responsible for:

  • Designating a Confined Space Program Administrator.
  • Identifying and evaluating confined spaces.
  • Maintaining an inventory of confined spaces.
  • Maintaining Confined Space Entry Permits for at least 1 year.
  • Implementing and maintaining a permit confined space program. This document, when Appendix A is filled out, serves as the department’s written program.

Supervisors are responsible for:

  • Ensuring employees are aware of this program.
  • Ensuring employees receive required training before entering a confined space, serving as the attendant, or serving as the entry supervisor.
  • Ensuring employees have equipment needed to enter confined spaces and complete the needed work.

Employees are responsible for:

  • Complying with the requirements of this program, and any further safety requirements set by supervisors.

Program Requirements

Confined Space Evaluations

Each department with confined spaces shall have at least one employee trained as a confined space evaluator. The form in Appendix B must be used to evaluate spaces. The information Appendixes C, H, and I can help during the evaluation. The evaluation will determine if the space is a confined space and, if a confined space, what hazards are present in the space. Evaluations must be completed for every space even if University employees will be prohibited from entering the space. Once the evaluation has been completed it shall be maintained on file for the life of the space. The evaluations shall be maintained on the confined space SharePoint site, see Appendix D.

Spaces that are entered shall be re-evaluated at least every 5 years. This is to ensure the assessment is still accurate and takes into account any changes to OSHA or University requirements.  

All new spaces that are possibly confined spaces must be evaluated within 6 months of installation or before entry, whichever is first.

Confined Space Inventory

Once the evaluation has been completed the space needs to be added to the confined space inventory. All confined spaces, both permit and non-permit, are required to have a confined space ID when entered into the inventory.  If a space is evaluated and is classified as not a confined space it should be entered into the inventory but a space ID is not needed.

The confined space ID can be one of two numbering systems. This can be the current system of using a 2 letter code for the department or area and sequential numbers or using an asset number already assigned to the piece of equipment.  For both systems the number must be unique to the space.

The confined space inventory shall be maintained on the Campus Confined Space Inventory SharePoint site. Instructions on accessing and using the site are found in appendix D.

Ownership of Confined Spaces

The department that is responsible for maintaining the space is the department that has ownership of the space. Checking the space from outside, entering the space to perform work, or hiring contractors to work in the space are examples of maintaining a space.

If the space is located within one department but another is the owner of the space (i.e. a maintenance access area) the department where the space is located will be listed on the inventory in the other affected department’s column.

Signage

All confined spaces are required to be labeled with the appropriate warning sign and the confined space ID at each entry point into the space.

Permit required confined spaces must have a sign with “DANGER -- PERMIT-REQUIRED CONFINED SPACE, ENTER BY PERMIT ONLY” or similar language.

If the permit required confined space will not be entered by any University employees or contractors the space may have a sign with “DANGER -- PERMIT-REQUIRED CONFINED SPACE, ENTRY PROHIBITED” or similar language.

Non-permit required confined spaces must have a sign with “CAUTION – NON-PERMIT CONFINED SPACE – KEEP OUT UNLESS AUTHORIZED” or similar language.

The “danger” and “caution” signs must comply with the requirements in 1910.145. They must be posted on each entrance to the space and be large enough to be easily seen. And be durable enough to withstand the environment in which they are posted.

Printable signs can be downloaded off of the confined space SharePoint site or ordered from the UI Print Shop.

The confined space ID number shall be included on the bottom of the confined space sign. Customized signs with the inventory ID are available from the UI Print Shop.

If labeling of the space is not feasible due to the nature of the space, i.e. manhole covers, training must be provided to inform employees of the spaces and their classification.

Entry Permit

To lower the risk associated with confined spaces, the department must use a Confined Space Entry Permit (Appendix E) to document the hazards of the space and the means of ensuring employee safety. Appendix H provides guidance on the whether a hazard is being controlled or eliminated and therefore if a reclassifying entry (C-7) or alternate entry (C-5) is allowed.

The Confined Space Evaluation Form for the space must be reviewed when completing the entry permit. The evaluation form will provide information on the potential hazards, the control or elimination measures available, and entry requirements for the space.

The Confined Space Entry Permit is to be used on all entries into spaces classified as permit required. This includes reclassifying entry, alternate entry, and full permit entry. The entry permit is not required for non-permit required confined spaces.

Each Confined Space Entry Permit is good for one shift.  A new permit will need to be completed at the start of each shift. Each permit will need to be maintained for one year. A list is available on the SharePoint site for maintaining the entry permits for one year.

Appendix F has the general entry procedures for permit required confined spaces. These procedures are general and will need to be adapted by departments to meet their needs.

Rescue Services

For full permit entries performed on the main campus rescue services will be provided by the Iowa City Fire Department and at the Research Park (Oakdale) by the Coralville Fire department. Rescue services are not available at other areas at this time so full permit entry buy University employees is not allowed.

Duty to Other Employers

When contractor employees will enter a permit required confined space under the control of the department, management shall provide the contractor with all available information on that space. It is the contractor’s responsibility to meet OSHA requirements to manage the space and entry for their employees. The contractor is to inform the department of any changes noted about the space.

Training

All employees and supervisors that must enter permit required confined spaces shall receive training and instruction so they have the understanding, knowledge, and skills to allow them to safely enter these spaces. All employees and supervisors involved in confined space programs with permit required confined spaces and do not enter them shall receive training and instruction so they have an understanding and knowledge of confined spaces to prevent entry into confined spaces.

University employees will take the general training through ICON. Site specific training must also be completed. The required training course titles and numbers for each job duty can be found in Appendix F.

EHS will develop and maintain the general training located on ICON. The training will cover the OSHA requirements in 29 CFR 1910.146 and the University’s forms and procedures. Each department must provide site specific training that covers the specific hazards in the departments’ spaces, warning signs and symptoms for potential chemical exposures, location of appropriate safety equipment, how to use the safety equipment, and any other information that would be unique to the department.

Training records are maintained through the University’s Employee Self Service site.

Reviews and Audits

Departmental Reviews

Each department should review its confined space program on an annual basis. The review should look at the entry permits from the past year to see if any updates need to be made to procedures or the assessments. The inventory and assessments should be reviewed to assure all new spaces have been added.

EHS Audits

EHS will audit each department with a confined space program on a yearly basis. The audit will cover all aspects of the written program to ensure they are up to date and complete. The audit will also include a walkthrough of the area to check for appropriate labels, and that all spaces have been assessed and added to the inventory.

Glossary

Alternate Entry:  An acceptable method of entering a permit confined space that requires the elimination (not just control) of all serious hazards from outside the space prior to entering it except for air contaminants, which are controlled using forced air ventilation.  This is also known as C5 entry, in reference to the section of the OSHA standard that it is described in 1910.146(c)(5).

Attendant:  An employee trained in confined space entry, assigned to standby outside of a permit-required confined space entrance and monitor air quality, monitor entrants’ safety and health, and summon rescue services, if needed.  (An attendant cannot leave his/her post unless replaced by another attendant and under no circumstances may enter the confined space.)

Authorized Entrant:  An employee who is trained and authorized to enter and perform work within the permit-required confined space. 

Biological Hazards: Infectious agents presenting a risk or potential risk to the wellbeing of personnel or other animals, either directly through infection or indirectly through disruption of the environment.

Blinding/Blanking: Inserting a solid barrier across the open end of a pipe leading into or out of a confined space, and securing the barrier to prevent leakage of material into the confined space.

Confined Space: Means any enclosure or vessel, which by design has all of the following characteristics:

  • It is large enough and so configured that an employee can bodily enter and perform assigned work.
  • It has limited or restricted means for rescue, entry or exit.
  • It is not designed for continuous employee occupancy.

Confined Space Entry Permit: This is the document that must be completed and signed by an Entry Supervisor before a permit required confined space can be entered. This includes entry by reclassifying entry and alternate entry procedures. This is the equivalent of the “Permit Required Entry Permit” required by OSHA regulations.

Confined Space Evaluator: A person trained and authorized by the department to perform evaluations of potential confined spaces and designate the acceptable entry procedure and requirements.

Confined Space Program Administrator: The employee designated by the department to maintain the confined space program. This includes making sure the inventory and assessments are current and complete, and maintains the entry permits for one year.

Control: The source of the hazard still exists, but means are implemented to prevent it from causing harm to employees. This includes lockout/tagout of flowable materials such as steam, natural gas, and other substances that can cause hazardous atmospheres or engulfment hazards; and use of continuous forced air ventilation.

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 to prevent leakage of material into the confined space.

Elimination: The complete removal of the hazard from the space. Lockout/Tagout is considered to eliminate electro-mechanical hazards but not hazards created by flowable materials such as steam, natural gas, and other substances that can cause hazardous atmospheres or engulfment hazards. Elimination of these hazards is achieved through blanking, blinding, misaligning or removing sections of lines or pipes and a double block and bleed system. 

Engulfment: The surrounding and effective capture of a person by a liquid or finely divided (flowable) solid substance that can be breathed in 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 Supervisor:  The person trained and authorized by the department to determine 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. They are also responsible for determining if reclassification or alternate entry are acceptable. An entry supervisor also may serve as an attendant or as an authorized entrant.

Flammable / Combustible Atmosphere: An atmosphere that contains flammable or explosive gases, vapors, or dusts in a concentration that is 10% or higher of the lower explosive limit of the hazardous material.

Full Permit Procedure: This is the acceptable method for entering a confined space while a permit hazard or potential for a permit hazard still exists in the space. This is the equivalent of the “Permit Required Confined Space Entry” described in OSHA regulation 1910.146.

Hazard Evaluation: A process to assess the severity of known, real, or potential hazards, or all three, at or in the confined space.

Hazardous Atmosphere: An atmosphere that may expose employees to the risk of death, incapacitation, impairment of ability to self-rescue (that is, escape unaided from a permit space), injury, or acute illness from oxygen deficiency or enrichment, flammability, explosively, or toxicity.

Hot Work:  Work that produces arcs, sparks, flames, heat, or other sources of ignition.

Immediately Dangerous to Life and 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.

Inadvertent Energization: The accidental application of power that results in the movement of machinery, or the flow of hazardous material into a confined space.

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/tagout of all sources of energy; or blocking or disconnecting all mechanical linkages.

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, to prevent leakage of material into the confined space.

Lower Explosive Limit (LEL) or Lower Flammability Limit (LFL) and:  The minimum concentration of vapor in air below which propagation of a flame does not occur in the presence of an ignition source.

Lockout/Tagout (LOTO):  The placement of a lock/tag on the energy isolating device in accordance with an established procedure, indicating that the energy isolating device shall not be operated until removal of the lock/tag in accordance with an established procedure.

Non-Permit Confined Space:  A confined space that does not contain or, with respect to atmospheric hazards, have the potential to contain any serious hazard capable of causing death or serious physical harm.

Occupational Exposure Limit (OEL): The OSHA permissible exposure limit (PEL), American Conference of Governmental Industrial Hygienist (ACGIH) Threshold Limit Value (TLV), or the National Institute of Occupational Safety and Health (NIOSH) recommended exposure limit (REL). The lowest of any one of these values will be used. 

Oxygen Deficient Atmosphere:  An atmosphere containing less than 19.5% oxygen by volume.

Oxygen Enriched Atmosphere:  An atmosphere containing more than 23.5% oxygen by volume.

Permit Required Confined Space (same as Permit Confined Space):  Means a confined space that has any one or more of the following characteristics:

  • It contains or has the potential to contain a hazardous atmosphere.
  • It contains a material that has the potential for engulfing an entrant.
  • It has an internal configuration such that an entrant could be trapped or asphyxiated by inwardly converging walls or by a floor that slopes downward and tapers to a smaller cross-section.
  • It contains any other recognized safety or health hazard capable of causing serious physical harm or death.

Reclassifying Entry:  An acceptable method of entering a permit confined space that requires the elimination (not just control) of all serious hazards from outside the space before entering it.  This is also known as C7 entry in reference to the section of the OSHA standard that it is described in 1910.146(c)(7).

Retrieval System:  The equipment (including a retrieval line, chest or full body harness, wristlets, if appropriate, and lifting device) used for non-entry rescue of persons from a permit space.

Upper Explosive Limit (UEL) or Upper Flammability Limit (UEL): the maximum concentration of flammable vapor in air above which propagation of flame does not occur on contact with a source of ignition.

Appendices

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