Middlebury

 

Confined Space

Originator:  Edmund F. Sullivan
July, 1995                                                          
Last Update:        June, 2010

CONTENTS

 

1  INTRODUCTION................................................................

1.1  SCOPE....................................................................

1.2  POLICY...................................................................

1.3  RESPONSIBILITIES.........................................................

1.4  DEFINITIONS..............................................................

2  PROGRAM REQUIREMENTS........................................................

2.1  IDENTIFICATION OF CONFINED SPACES........................................

2.2  TRAINING.................................................................

2.3  SITE EMERGENCY RESPONSE..................................................

2.4  ENTRY ...................................................................

2.5  CONFINED SPACE PERMIT....................................................

2.6  CONFINED SPACE RESCUE...............................................................

2.7  REFERENCES ……………………………………………………….

Appendix A  CONFINED SPACE PERMIT.........................................
Appendix B   CONDITIONS/LOCATIONS REQUIRING A PERMIT
Appendix C   CONFINED SPACE INVENTORY
Appendix D   ERT Charter

 

CONFINED SPACE POLICY

1.   INTRODUCTION

The purpose of this Middlebury College  (MC) Policy is to define the basic elements and
responsibilities to insure the safe entry into a confined space on site.

1.1  Scope

This standard shall apply to operations conducted at Middlebury College.

 

1.2 POLICY

An effective written Confined Space Program shall be established,
implemented, and maintained.

1.3  RESPONSIBILITIES

o  Department Head

Ensure there is a written Confined Space Program developed, implemented
and maintained to ensure the safe entry into a confined space on site.

o  Manager/Supervisors                          

Understand and ensure full implementation and compliance with the
Confined Space Entry Program as it applies to employees and contractors.

Ensure employees enter confined spaces only when they are certified  
to do so.  All entries must be performed within the guidelines of     
this program.                                                         

Ensure that emergency off shift and  unscheduled entries (such as    
required) are conducted in full compliance  with this policy.

Ensure that confined spaces within your department are identified and that
procedures are developed for entry

Routine entries should be conducted during normal work hours, not off shift.

Any Permit Required Confined Space (PRCS) trained employee authorized by management may 
approve a permit for entry.

Ensure the proper maintenance of all confine space equipment.

Facilities will maintain all confined space monitoring equipment.

o  Environmental Health & Safety

Develop and review campus compliance with the Site Confined Space Entry
Program.

Ensure that applicable Middlebury College and contract employees are trained in the
Confined Space Entry Program, including emergency entry and exit procedures,
lockout procedures, safety equipment use, permit systems, and confined space work practice. 

Maintenance of the written program, procedures, and records, including
a list of employees certified to enter or standby during a confined space
entry.

Provide assistance in the evaluation of confined spaces to determine hazard potential. Ensure air monitoring is       conducted before personnel entry and during the work procedure in a confined space.

The Supervisor may delegate this responsibility to an employee trained in monitoring a confined space.

Review the need for all equipment, chemicals, or tools and ensure they are compatible for the environment            before they are brought into a confined space.

Certify that outside vendors/contractors are in compliance with the standard.

o  Employees

Conduct confined space entry only when certified to do so.

Inform your supervisor of any health condition that may                 
compromise your health or safety by entering a confined space.

Perform pre-entry inspections of confine space entry equipment before   
entering the confined space.

Maintain equipment, as required

Abide by all Middlebury College policies and procedures, including entry by permit,
atmospheric pre-testing, presence of a trained standby person while in the
confined space. Establish continued communications, at a minimum.

Secure a permit prior to entering a confined space.

Off shift emergency entry by trained Facilities personnel must be in full accordance with the    
details of this policy.

 

o  Contract/Vendor's Employees                                              

Shall provide their own confined space equipment in good condition.

Shall be trained in Confined Space Entry in accordance with VOSHA's      
1910.146, and certify training with the College in writing before the work is started.

Shall enter a designated confined space by permit only.

Shall be appraised of any potential hazards by the job supervisor or project manager..               

Shall be debriefed by EH&S after the job is completed if additional hazards were introduced  
into the space.

The contract/Vendor must also be able to demonstrate understanding of the
requirements of a safe confined space entry.

1.4  DEFINITIONS

Specific terms related to confined space entry that are used in this
standard are defined in this section.

Carbon monoxide (CO) - A colorless, odorless gas that, when in high
concentration, can cause unconsciousness with little or no warning.  As CO
concentrations rise, the harmful effects also rise.

Confined Space - A space that, by design, has limited openings for entry
and exit, has unfavorable natural ventilation that could contain or produce
dangerous air contaminant levels, and is not intended for continuous
employee occupancy.

Because air may not move in and out of confined spaces freely due to the
design, the atmosphere inside a confined space can be very  different from
the atmosphere outside.  Deadly gases may be trapped inside, particularly
if the space is used to store or process chemicals or organic substances
that may decompose.  There may not be enough oxygen inside the confined
space to support life, or the air could be so oxygen-rich that it is
likely to increase the chance of fire or explosion if an ignition source
is present.

Most confined spaces are not designed for workers to enter and work  in on
a routine basis.  They are designed to store a product, enclose materials
and processes, or transport products or substances.  Therefore, occasional
worker entry for inspection, maintenance, repairs, cleanup, or similar
tasks may pose potential hazards, such as chemical and physical hazards
for which precautions must be taken.

Confined spaces include, but are not limited to, manholes, storage tanks,
silos, boilers, incinerators, elevator pits, trenches, sewers, air handler,
ventilation and exhaust ducts, tunnels, vats, degreasers, underground
communication/utility vaults, and pipelines.

CPR -  Cardiopulmonary Resuscitation

Hot Work -  Any work involving burning, welding, riveting, or similar fire
or heat producing operations, as well as work that produces a source of
ignition such as drilling, abrasive blasting, and space heating.

Hydrogen Sulfide (H2S) -  An easily detectable gas which, at low
concentrations, has an odor similar to rotten eggs.  H2S desensitizes the
olfactory sense; therefore, to those people who have been exposed to it
for extended periods of time, the gas may seem to have dissipated even
though the concentration may have remained constant or even increased.  Low
concentrations cause eye irritation, while slightly higher concentrations
may cause upper respiratory tract irritation. If exposure is prolonged,
pulmonary edema or asphyxiation may occur. The danger increases when high
concentrations go undetected.

Isolation - The process by which a confined space is removed from service
and completely protected against the inadvertent release of potentially
hazardous material.  The following methods are commonly used to isolate a
confined space:

Blanking off (skillet type metal blank between flanges)
Removal or misalignment of sections of all lines and pipes
Bleed system                                                  
Electrical lockout of all sources of power
Blocking or disconnecting all mechanical linkages

LEL (Lower Explosive Limit) or LFL (Lower Flammable Limit) - of a       
combustible Gas, vapor, or mist is the minimum concentration of the    
material in air which will propagate flame on contact with an ignition  
source.  Below the LEL there is insufficient fuel to support combustion.

UEL (upper explosive Limit) - above the UEL, the mixture is too "rich"  
to support combustion so ignition is not possible.

Concentrations between the LEL and the UEL are considered flammable.    

Lockout/Tagout -  The placement of a lock or 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 or
tag.  Refer to the site Lockout Tagout Policy.

Methane - Presents a multiple atmospheric hazard, depending on their
concentration.  Methane, is an odorless substance that is non toxic and
is harmless at some concentrations.  Methane, however, can displace all
or part of the atmosphere in a confined space; and the hazards presented
by such displacement can vary greatly, depending on the degree of
displacement.  With only 10% displacement, methane produces an atmosphere
which, while adequate for respiration, can explode violently.  By contrast,
with 90% displacement, methane will not burn or explode, but it will
asphyxiate an unprotected worker within about 5 minutes.

Oxygen deficient atmosphere -  Contains less than 19.5% oxygen by volume.
Oxygen deficiency can occur even after an area has been purged of toxic
gases.  The gases may emanate from porous walls and sludge.  Undetected
leaks, organic decomposition, bacterial action, combustion, and cleaning
processes can lead to the displacement of oxygen by other gasses, causing
the atmosphere to become toxic.  As other gas level(s) increase, oxygen 
levels decrease, creating the potential for injury and fatality.  Oxygen
can also be absorbed by the wall of areas being repaired or cleaned,
causing further oxygen deficiency.  The importance of monitoring for
adequate oxygen levels is as critical as sampling for the presence of
other gasses.  Failure to monitor properly may result in an undetected
increase in toxic gasses or a reduction in  oxygen.

Oxygen enriched atmosphere -  Contains more than 25% oxygen by volume.  The
presence of too much oxygen in a confined space can be fatal in certain
situations.  In the correct concentration, oxygen, fuel, and an ignition
source can result in explosion or fire.  When oxygen rises above its normal
level of 21%, the flammability range of combustible gases increase.  To
avoid the possibility of oxygen enrichment explosions, confined areas shall
not be purged with oxygen in place of air.  Proper procedures for blanking
of oxygen lines, where applicable, shall be followed.

Respirator - An approved device that has been designed to protect the
wearer from inhalation of hazardous atmospheres.  Refer to Middlebury College's
Respiratory Protection Policy.

SCBA - Self contained breathing apparatus                                

Standby person (or attendant) -  A person trained in emergency rescue
procedures, who is stationed outside the confined space, monitors the
authorized entrants inside the confined space, and is in communication with
those authorized entrants.  The standby person also ensures non authorized
personnel do not enter the confined space.  The  Standby Person DOES NOT 
enter the confined space. In case of an emergency the fire department shall be       
notified.

2  PROGRAM  REQUIREMENTS

2.1 IDENTIFICATION OF CONFINED SPACES

All confined spaces within site boundaries shall be identified.         
Procedures about how to control the identified confined spaces and any
potential hazards shall be identified.

2.2 Training

Anyone requesting entrance into a confined space must be able to show that
they have received the proper/required training for confined space entry. 

o  College employees engaged in confined space entry will follow the policy and training
requirements set forth in this document.

o  Outside contractors must have a written statement or proof from their
employer that they have been trained in entry and rescue procedures, 
contractors must also be able to demonstrate understanding in Confined
Space regulations.  A certificate of training or written  note on      
company letterhead confirming training by a company official would be
sufficient.  Middlebury College does not provide training or equipment to outside contractors
except in special circumstances.

o  "Process to retrieve" training is also required of the standby person
stationed outside the confined space.  Training shall include summoning
rescue  or other emergency services and proper use of equipment
used to communicate and retrieve.

*  Confined Space training will be provided for Middlebury College employees and employees under 
contract only.  This does not preclude training with local government agencies or Porter Medical
Center.  Retraining will be held yearly at a  minimum, or more frequently if  personnel or job
requirements  change.

2.3  Campus Emergency Response

The Emergency Response Team (ERT) is the designated emergency
response  for confined space rescue entries.  Confined space entry
and rescue procedures shall be part of their annual training.
They are trained and certified in CPR, First Aid and Respiratory       
Protection.

o  To contact the ERT for confined space emergencies the standby person will notify         
Middlebury College’s Public Safety Department via portable radio and request an emergency 
response to the location of the confined space emergency.  This may require a rescue entry on the 
part of the ERT.   911 may also be called if direct communication to the College is unavailable.

o  Upon Public Safety receiving a request to notify the ERT for a confined
space emergency, they will notify and direct them to the location of the emergency.  
Public Safety will then notify the Facilities Manager and  EH&S of the emergency and location. The
MVAA, Middlebury Police and Fire Departments should also be notified.

2.4  Entry

Confined space entry is by permit only.  All confined spaces shall be evaluated using the permit prior 
to entering.  Permits may be obtained from EH&S or at a location designated by Facilities 
Management.

o  Permits are good only for the duration of the task.                    

o  Prior to entering a confined space, potential hazards shall be
identified.  Hazards shall be evaluated with the respect to their scope
and magnitude, likelihood of a hazard occurrence, consequences of that
occurrence, potential for changing conditions, strategies for
controlling the hazards, and potential emergency response requirements.

o  Pre-entry atmospheric monitoring and visual evaluation will be done
prior to entering a confined space, if applicable.  Corrective action will be required
to correct the unsafe condition.

o  Any condition making it unsafe to remove an entrance cover shall be
eliminated before the cover is removed.

o  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.

o  No entry is permitted when the confined space atmosphere levels are
unsafe without proper Personal Protective Equipment (PPE), or when a
area is flooded.  Water must be pumped out first.

o  Before an employee enters the space, the internal atmosphere shall be  
tested.  A calibrated direct-reading instrument shall be used, for the 
following contaminants: 
1. Oxygen content  (below 19.5% or above 23.5%)                       
2. Flammable gases and vapors, (in excess of 10% of LFL) and           
3. Potential toxic air contaminants (H2S)(in excess of its dose or    
(PEL) limit.                                                        

o  If a hazardous atmosphere is detected during entry:
1. Each employee shall leave the space immediately
2. The space shall be evaluated to determine how the hazardous
atmosphere developed; and
3. Measures shall be implemented to protect employees from the hazardous
atmosphere before any subsequent entry takes place.

o  As required by the permit, each authorized entrant shall be equipped
with: a 2-way radio (not needed if standby person is in audible & visual
contact with entrant), retrieval harness, safety shoes,  hard hat,
safety glasses, personal air monitor and coveralls/outer work clothes. 
In addition, a tri-pod with at least a 50' length of cable for a
retrieval line will be set up.  The entrant shall be hooked up to this
retrieval line at all times.  A trained stand-by person is required for
all confined space entries.

o  It is suggested that only one person enter a confined space at one
time.  However, if more than one needs to enter at one time it should
be so stated in the permit.  The second entrant shall also wear the same
protective equipment as stated in (a.) above.  Because of the
possibility of entanglement and the difficulty of setting up two
retrieval systems at the same time, only one  entrant will be required
to be hooked up to a retrieval line.  Both are required to wear harnesses.

A life line shall be on site in the event the retrieval line is unavailable.

The personal air monitors will be worn by each of the entrants (if possible),
but at least by one entrant.  External air monitors attended by the standby
person will also  provided.

o  The stand-by person shall not enter the confined space (breaking the plane of the opening) at any time.                 They are responsible for space  monitoring, staying in radio/or visual communication, summoning help                    if needed, securing the area, and retrieving the entrant (retrieval system only) if required.

o  Off shift entries when response time is of critical importance, a
trained facilities employee may issue a confined space permit when
approved by a trained supervisor.  Such an entry must be in
compliance with this policy.

Permits will be located in a Facilities approved area and with EH&S.

All routine entries shall be done during first shift on a regular work 
week schedule.  No routine entries are to be done on weekend or holidays
unless special provisions are made and approved by EH&S (an      
example would be during a maintenance shutdown).

2.5   Confined Space Permit

All entries into a confined space require a permit.  Additional   
provisions for emergency situations are noted in 2.4 "Entry".

You may consult the Confined Space Permit (Appendix A) for additional
entry requirements.

Potentially hazardous environments requires  continuous monitoring while the confined space is
occupied. 

o Only emergency unplanned entries are permitted off shift, when the safety
of the campus, its employees,  or students  are in jeopardy.  All conditions of this policy
shall be  maintained at all  times.  Stand-by assistance can be obtained from     
any trained certified personnel.                                       

o The permit must be completed (at job site) indicating members of the crew
and results of the air monitoring test.  The  permit shall then be
posted outside the confined space (in a weather proof envelope).

o Upon completion of the job, the permit shall be kept
on file in the department for 12 months.

o Any problems with equipment should be immediately reported to the
appropriate authority (EH&S or Facilities).

2.6 Confined Space Rescue

Any safety regulation that requires a plan for executing a rescue from the environment being regulated, speaks volumes about the dangers of working in that environment, will require a rescue team.  Regulations for confined space entry fall into this category.  According to OSHA, in general, for every 1,400 accidents reported, one results in death or serious injury.  In confined spaces, it is one in 10.  Also, for every person dying in a confined space, almost two people die trying to execute a rescue.

 

The regulations were introduced to improve injury statistics by mandating that companies not only recognize, but inventory and label all confined spaces within their operations.  They also mandate that workers understand the hazards of working in confined spaces; are properly trained and equipped to handle those hazards; and have access to a fully equipped rescue team in the event of a problem.

 

CONFINED SPACE CHARACTERISTICS

* Its size and shape allow a person to enter it.
* It has limited openings for workers to enter and exit
* It contains a material that has the potential for engulfing the entrant.
* Its internal configuration is such that an entrant could be trapped or asphyxiated by inwardly converging walls or by a floor which slopes downward to a smaller cross-section.
* It contains any other recognized serious safety or health hazard.

If the confined space you work in meets these conditions the college will use a variety of methods to protect you:

* Lockout procedures
* Authorized entry and attendant supervisor.
* Atmospheric testing
* Ventilation systems
* Non-entry rescue procedures.
* Training in permit space hazards, use of required equipment, safe work practices and rescue procedures.

RESCUE TRAINING

Each member will be expected to maintain current certification in CPR and appropriate training in First Aid.

During training you will learn how to:

* Recognize confined space hazards.
* Communicate in a confined space.
* Use personal protective equipment in rescues
* Perform rescue techniques geared to the confined spaces in our workplace.
* Know when to perform self rescue in a confined space

2.7 Reference:

VOSHA 29 CFR 1910.146 "Permit Required Confined Space"
VOSHA 29 CFR 1910.147  " The Control of Hazardous Energy" 
VOSHA 29 CFR 1910.331 - 1910.335 "Electrical Safety Related Work Practices"

 

 

 

 

CONFINED SPACE ENTRY PERMIT
EMERGENCY  CALL 5911

DATE:____________________________        TIME:______________________________

Shift ISSUED: ____________________         Hazardous Entry?  Yes ( )   No ( )

PERMIT EXPIRES:__________________        LOCATION:__________________________

POTENTIAL HAZARD(S):________________________________________________________

REASON FOR ENTRY:___________________________________________________________

SPECIAL REQUIREMENTS

YES                NO
PRCS Trained ........................................       _____          ______
Atmospheric Testing ...........................           _____          _____
Lockout/De-energize............................         ______          _____  
Lines Blinded or Blanked.......................         _____           ______
Purged-Flush and Vent..........................         _____           ______
Ventilation................................................    ______         ______
Area Secured............................................     ______         ______
Escape Harness........................................      ______         ______
Tripod External Rescue.........................          ______          ______
Life Lines..................................................    ______          ______
Fire Extinguishers....................................      ______          ______
Protective Clothing................................._       ______         _______
Respiratory Protection.........................            ______         _______

TEST TO BE TAKEN  (PRIOR TO ENTRY)

Instrument Type: _______________________  Calibration Date:_________________

% of Oxygen (19.5 - 23.5) ______________  % of LEL ________________

Other Contaminants (PPM)____________________________________________________

Person Conducting Test  ____________________________________________________

Authorized Entrant(s)   ____________________________________________________

Standby Person          ____________________________________________________

Comments: PERMIT MUST BE POSTED IN THE VICINITY OF THE CONFINED SPACE.     
PERMIT MUST BE RETURNED TO THE SAFETY OFFICER BY EXPIRATION DATE/TIME

CREW CHIEF: ________________________________________________________________
(THE UNDERSIGNED ACKNOWLEDGES UNDERSTANDING OF PERMIT CONDITIONS)

 

APPENDIX  B

Hazardous Conditions Requiring a Permit

Confined Space - A space that, by design, has limited openings for entry
and exit, has unfavorable natural ventilation that could contain or produce
dangerous air contaminant levels, and is not intended for continuous
employee occupancy.

1.  Entry into an area that would make it difficult to
exit in an emergency (medical, fire, environmental)

2. Potential fall hazards

3. Potential environmental hazards

4. Potential Mechanical, electrical, chemical or thermal hazards

 

 

 

 

 

 

 

 

 

 

 

 

Appendix C
Middlebury College
Confined Space Listings

Rev:  5/24/02                                                                                 (PR) Permit required

 

All campus manholes (PR)
All steam & electrical vaults (PR)
All crawl spaces & Attics (PR)
All pits & trenches (elevator pits)
All Cupola’s
All duct work (PR)
All Cooling Towers (PR)
All Boilers/furnaces (PR)

 

In Addition:

CFA
Pond Pump Tank  (PR)
Hadley House
Basement by Boiler Floor Cistern
H, M, K, L
Ross Mechanical Room Under Ross  (PR)
Kenyon Mechanical room (bleacher level)
McCullough Transformer Access
Memorial Field House Fitness Center Tunnel (dead end)
Natatorium Perimeter Tunnel (PR)
Surge Tank        (PR)
Backwash Tank (PR)
Proctor Store Room by Lower Dishroom Tank in Floor
Space Behind Coolers
Dragone Track Sewer Pumps (PR)
Harris Farm Cistern

 

 

Appendix D

MIDDLEBURY COLLEGE
MIDDLEBURY, VERMONT 05753

CHARTER
EMERGENCY RESPONSE TEAM

PURPOSE

The Emergency Response Team (ERT) was established June 16, 1999 for the purpose of providing emergency rescue capabilities for employees engaged in confined space or other activities consistent with their training and expertise, and to comply with VOSHA regulation 29 CFR 1910.146.

TEAM RULES

Membership

The ERT is open to permanent full time Middlebury College employees.  Any employee may request membership by submitting a written request to any member of the team.  Current members may nominate new members.  It is recommended that new openings be posted, or noted in Middpoints.  Current team members in good standing may vote on accepting a new member into the team.  All prospective members must have the approval of their supervisor or manager.  A medical clearance  is also required by a physician to wear a SCBA.  The current active membership ceiling is 13 with an associated membership possible in the future.

EMS members must be Vermont certified ECAs or EMTs associated with an active ambulance squad or first response organization.

Member in Good Standing

In order to be a member in good standing you must attend monthly meetings and be willing to respond to emergencies when called upon.  Any member unable to attend 3 meetings during the calendar year may be asked to reconsider their membership.  Their name will be forwarded to the risk manager for review.

Remuneration

The ERT does not offer any additional pay benefit for the employee.  The ERT will conduct training during regular work hours.  Off shift employees will be paid for coming in off shift by their department.
At the College’s discretion the ERT will be given perks or gratuities during the year for their services.  This will be managed by the College’s Environmental, Health & Safety Coordinator.   The College would determine the type and amount of gratuity each year.  Only members in good standing would be eligible for these gratuities.

Training

Monthly training exercises will be planned in order that the team may be familiar with all types of confined spaces on campus.  In addition,  First Aid and CPR, annually or as required by regulations.  All members are required to maintain their training in basic first aid and certification in adult CPR.  A minimum of 10 training sessions should be planned per year.  Business meetings should also be included during these sessions.

No employee may participate in ERT training or activities unless they are first qualified as a confined space entrant and standby person.  The College’s EH&S Coordinator will provide this training or other qualified person approved by the College (EH&S Coordinator or Risk Manager).  No employee may perform duties requiring the use of a SCBA unless a medical clearance is on file with EH&S.

For Middlebury College:

Thomas Corbin                                                   Edmund Sullivan
Risk Manager                                                      Environmental, Health & Safety

 

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