Confined Space Entry

The purpose of this program is to establish confined space entry procedures in accordance with OSHA regulations 1910.146 and 1926.1200 in order to protect employees who are required to enter confined spaces from hazards that could cause accidental injury or illness. 

The Confined Space Entry Program Coordinator, known hereafter as CSE Coordinator, shall be an ESCO Group Safety team member.

The CSE Program Coordinator’s responsibility shall include the implementation, administration and evaluation of the Confined Space Entry Program. These responsibilities shall include, but not be limited to, the following:

1. Responsibilities

a) Conduct a survey to identify all possible or potential confined spaces at a facility, or jobsite that could at some time be entered by an employee (Consider such spaces as sewers, vaults, ducts, boilers, pits, truck or rail tanks, etc.). 

b) Determine the best method of entering and performing work in each confined space and potential safety and/or health hazards of those confined spaces.

c) Determine Safety Equipment and Supplies required to perform safe and efficient work within confined spaces. 

d) Determine types of Personal Protective Equipment required to be worn by employees entering confined spaces. 

e) Establish a time-table for periodic inspection of the confined space entry program to ensure that procedures are being followed and employees understand the program. 

f) Establish a Training Agenda for all employees who may enter, work in, or be involved in confined space operations. 

g) Utilize a Confined Space Entry Permit and instruct all workers in proper use of the permit. 

h) Establish a Record keeping System for the purpose of issuing confined space entry permits and maintaining files of the permits that have been completed. 

2. ESCO Group Confined Space Entry Policy

a) Policy:

i. It is the policy of ESCO Group that when work is being performed in a confined space, standard safety procedures shall be followed to prevent accidental injury or death to an employee.

b) Purpose:

i. It is the purpose of the Confined Space Entry Program to establish minimum requirements and procedures for the safety and health of employees who may enter, work in and in connection with confined spaces.

c) Scope:

i. Occasionally, confined spaces may be entered for purposes of inspection, performing electrical duties, cleaning and/or maintenance. This policy is mandatory for the protection of individuals from injury due to an unsafe atmosphere, mechanical/electrical equipment, or limited means of escape. Therefore, all ESCO Group employees, visitors, vendors, and contractors are subject to the confined space entry standard and shall comply with the requirements set forth by this policy.

d) Definitions:

i. Attendant:  An individual stationed outside of a permitted space to monitor authorized entrants and perform all attendant duties outlined in the confined space program.

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

iii. “Confined Space” means a space that:

1. Is large enough and so configured that an employee can bodily enter and perform assigned work

2. 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.)

3. Is not designed for continuous human occupancy

iv. Double Block and Bleed: A method used to isolate a confined space from a line, duct or pipe by physically closing two in-line valves on a piping system; and opening a “vented-to-atmosphere” valve between them.

v. Engulfment: Means the surrounding and effective capture of a person by a liquid or finely divided 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.

vi. Entrant:  Means an employee who is trained and authorized by the employer to enter a permit space.

vii. Entry: Means the action by which an individual breaks the plane of an opening of a confined space with any part of the individuals body

viii. Entry Supervisor: Means the individual (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 the confined space system.

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

x. Hazardous Atmosphere: An atmosphere that may be or is injurious to occupants by reason of: oxygen deficiency or enrichment, flammability or explosive or toxicity.

xi. Hot Work: Work within a confined space that produces arcs, sparks, flames, heat or other sources of ignition.

xii. Isolation: A process of physically interrupting or disconnecting (or both), pipes, lines and energy sources from the confined space.

xiii. LEL/LFL and UEL/UFL: Acronyms for “Lower Explosive Limit/Lower Flammable Limit” and “Upper Explosive Limit/Upper Flammable Limit”

xiv. Lockout/Tagout: The placement of a lock/tag on the energy isolating device in accordance with an established procedure. The term “lockout/tagout” allows the use of a lockout device, a tag or a combination of both.

xv. Non- Permit Required Confined Space: A confined space does not contain nor, with respect to atmospheric hazards, have the potential to contain any hazard capable of causing death or serious harm.

xvi. Oxygen Deficient Atmosphere: Means an atmosphere containing less than 19.5 percent oxygen by volume.

xvii. Oxygen Enriched Atmosphere: Means an atmosphere containing more than 23.5 percent oxygen by volume

xviii. PEL: An acronym for “Permissible Exposure Limit” which is the allowable air contaminant level established by the U.S. Department of Labor, Occupational Safety and Health Administration.

xix. Permit required Confined Space (PRCS):  A confined space which after evaluation has actual or potential hazards which have been determined to require written authorization for entry.

1. Contains or has potential to contain 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;

4. Contains any other recognized serious safety or health hazard. 

xx. Prohibited condition: Any condition in a permit space that is not allowed by the permit during the period when entry is authorized. 

xxi. Qualified Person: A person who by reason of training, education and experience is knowledgeable in the operation to be performed and is competent to judge the hazards involved.

xxii. Rescue service: The personnel designated to rescue employees from permit space. 

xxiii. Retrieval System: Equipment (including a retrieval line, chest or full-body harness, wristlets, if appropriate, and lifting device or anchor) used for non-entry rescue of persons in permit spaces. 

xxiv. Toxic Atmosphere: An atmosphere containing a concentration of a substance above the published or otherwise known safe levels.

e) Responsibilities:

i. Facility Management

1. Conduct initial and follow-up employee training and maintain documentation of such training.

2. Utilize a permit system for entry into confined spaces and ensure that all individuals who work in, and in connection with confined spaces are trained in the use of this system. 

3. Identify all potential confined spaces and its associated hazards at the facility where an employee, vendor or contractor may enter under normal or unusual conditions.

4. Each employee shall comply fully with all provisions and requirements of the Confined Space Entry Program.  TEAM INVOLVEMENT IS IMPORTANT!

5. Prior to entering a confined space, the employee shall be knowledgeable in all aspects of the confined space entry procedure including use of proper personal protective equipment and devices.

6. Employees shall consult with their CSE Coordinator, or other knowledgeable personnel, whenever there are any questions regarding the confined space entry program.

7. Employees shall be responsible for the care of personal protective equipment and other confined space entry devices assigned for their use.

8. Establish communication between facility owners for all coordinated confined space entry projects.

9. Establish communication between all contractors affected by confined space entry project and properly inform contractor(s) of hazards associated with confined space including proper permit notation.

ii. Duties of Authorized Entrant:

1. Properly use all of the designated confined space equipment, including atmospheric air monitoring equipment.

2. Know the hazards that may be faced during entry, including information on the signs, symptoms and consequences of the exposure

3. Communicate with the attendant as necessary to enable the attendant to monitor the entrant status.

4. Recognize any warning signs or symptoms of exposure to a dangerous situation

5. Ability to exit when an order to evacuate is given by the attendant or entry supervisor or an evacuation alarm is detected.

6. Exit confined space when a prohibited condition is detected.

7. Trained at a minimum annually for confined space entry duties as an entrant. 

iii. Duties of Attendant (Stand By):

1. Know the hazards that may be faced during entry, including information on the signs, symptoms and consequences of the exposure.

2. Aware of possible behavioral effects of hazard exposure in the entrant.

3. Continuously maintain an accurate count of authorized entrants in the permit space.

4. Remain outside the space at all times until relieved by another authorized attendant.

5. Monitors activities inside and outside the space to determine if it is safe for entrants to remain in the space and order the authorized entrants to evacuate immediately if any of the following conditions exist:

a. Detects a prohibited condition.

b. Detects the behavioral effects of hazard exposure.

c. Detects a situation outside the space that could endanger the entrants.

d. If the attendant cannot effectively and safely perform their duties.

e. Summon rescue and other emergency services as soon as they detect the entrant may need assistance.

6. Takes action when unauthorized persons approach or try to enter a space while entry is in progress and immediately have the unauthorized person exit the space and immediately notify the entry supervisor. 

7. Perform non-entry rescue in accordance with this policy and within training plan.

8. Monitor the attendants in only one permitted space at a time.

9. Perform no duties that might interfere with the primary duties they have been assigned.

10. Confirm that all entrants are attached to a lifeline prior to entry and remain attached at the line at all times.

11. Records all atmospheric readings on appropriate permit periodically/before each entry/during entry (not to exceed a duration of 30 minutes) with properly calibrated atmospheric monitor.

12. Properly trained and current on standard first aid and cardiopulmonary resuscitation (CPR) practices.

13. Trained at a minimum annually for confined space entry duties as an attendant.

iv. Entry Supervisor:

1. Understands the hazards that may be faced during entry, including information on the signs, symptoms and consequences of the exposure.

2. Verifies by checking that the appropriate entries have been made on the permit. 

3. Confirms all tests have been conducted prior to entry and during the entry.

4. Authorize and sign all permits to assure all procedures and equipment are in place prior to entry.

5. Ensures that all entry conditions stay current with what is dictated on the permit by periodic visits during the entry.  Has the authority to terminate the entry and cancel the permit.

6. Assist in removing any unauthorized entrants that enter the space.

7. Verifies that rescue services are available during the entry and the means to summon help is in place.

8. Confirms all assigned employees are properly trained and current for required duties.

f) Procedure:

i. Hazard Determination

1. Hazards shall be identified for each confined space to include, but not limited to, the following:

a. Past and current use of the confined spaces which may adversely affect the atmosphere of confined space.

b. Physical characteristics, configuration, and location of the confined space.

c. Existing of potential hazards in the confined spaces, such as:

i. Oxygen deficient or enriched atmosphere

ii. Flammable/explosive atmosphere

iii. Toxic atmosphere

iv. Mechanical hazards (i.e.: augers, blenders, etc.)

ii. Hazard Evaluation

1. Hazards identified shall be evaluated by the CSE Coordinator or other qualified person with respect to:

a. Scope of hazard exposure (i.e.: how many, and/or which employees are exposed or may be affected).

b. Magnitude of the hazard (i.e.: How much energy may be released? How toxic are the contents Quantity of materials which could be inadvertently introduced? Etc.)

c. Likelihood of hazard occurrence.

d. Consequences of the hazard occurrence.

e. Potential for changing conditions/activities that were not identified (i.e.: introduction of hot work or cleaning agents, weather changes, etc.).

f. Confined space participants shall be protected by external hazards while performing work in confined spaces.  Hazards shall include but are not limited to pedestrian and vehicle traffic.

g. Methods for controlling the hazards.

h. Other employees (customer, co-workers, or fellow contractors) working nearby that could pose a hazard or be effected by confined space hazards.

iii. Hazard Re-evaluation

1. The CSE Coordinator shall determine the need for periodic identification and re-evaluation of the hazards based on possible changes in activities in the confined spaces, or other physical and/or environmental conditions, which could adversely affect the space.

iv. Confined Space Entry Permit

1. The entry permit documents compliance with the entire program and authorizes entry to a permit space and shall identify the following:

a. The permit space to be entered

b. Purpose of the entry

c. Date and the authorized duration of the permit

d. Name of the authorized entrants

e. Name of the personnel attending the confine space

f. Individual serving as the entry supervisor and a space to initial or sign the permit authoring entry

g. Hazards or the permit space to be entered

h. The measures used to isolate the permit space and to eliminate or control permit space hazards during entry

i. Means of emergency rescue

2. Acceptable entry conditions:

a. The permit space to be entered

b. Purpose of the entry

c. Date and the authorized duration of the permit

d. Name of the authorized entrants

e. Name of the personnel attending the confined space

f. Individual serving as the entry supervisor and a space to initial or sign the permit authorizing entry

g. Hazards or the permit space to be entered

h. The measures used to isolate the permit space and to eliminate or control permit space hazards during entry

3. Before entry is authorized, the employer shall document the completion of the measures to ensure employee safety by:

a. Confirming before entry begins the entry supervisor identified on the permit shall sign the permit to authorize entry.

b. Requiring the completed permit to be made available at the time of entry to all authorized entrants by posting the permit at the entry point or by any other equally effective means so that the entrants can confirm that pre-entry preparations have been completed.

c. Confirming the assigned task or job identified on the permit is in accordance with the program.

d. Authorizing entry supervisor to terminate entry and cancel the permit when:

i. Entry conditions covered by the permit have been completed or a condition that is not allowed under the permit arises in or near the space where the work is being performed.

e. Retaining each cancelled permit for at least 1 year to facilitate the review of the confined space program. 

f. Documenting any problems encountered during an entry on such permit so that appropriate revisions can be made to the program.

g. Confirming the confined space owner has reviewed the program on an annual basis and periodically throughout the year to make necessary revisions to the program.

4. Before each re-entry into the confined space the following steps are recommended:

a. Ensure atmospheric test results are within acceptable Permissible Exposure Limits (PEL).

b. Verify that all precautions and other measures called for on the permit are still in effect.

c. Ensure that only operations or work originally approved on the permit are conducted in the confined space.

d. When conditions or work activities are different than those specified on the permit and could introduce a new hazard to the confined space, the permit shall be immediately revoked.

5. A new permit shall be issued whenever changing conditions or work activities introduce new hazards into the confined space.

6. Coordinate entry operations if there are multiple contractors working in the same space so that employees of one company do not endanger the employees of the other company.

a. Host employer must review the entire program with the other company.

b. All employees will receive the same level of training as the host employer employees.

c. All procedures of the host employer will be followed.

d. The host employer will provide the attendant and entry supervisor duties.

v. Atmospheric Testing

1. Before entry into a confined space, testing shall be conducted for hazardous atmospheres by the CSE Coordinator or qualified person.

2. Initial testing of atmospheric conditions shall be done with the ventilation system shutdown.

3. Further testing of the atmospheric conditions shall be done with the ventilation system shutdown.

4. An employee may request additional monitoring or continuous monitoring of the confined space at any time.

5. If the confined space is vacated for any significant period of time, the atmosphere shall be re-tested before re-entry is permitted.

6. The atmosphere of the confined space shall be considered within acceptable limits when the following conditions are maintained:

a. Oxygen content: Oxygen must be between 19.5 to 23.5%.

b. Explosive/Flammability: Flammable gases or vapors must be less than 10% of the Lower Explosive Limit (LEL).

c. Toxic Gases: Toxic Gases must be less than the recognized OSHA Permissible Exposure Limit (PEL).

d. Testing must be representative of the entire confined space.  Use extension probes to safety sample several layers of the confined space.

e. Calibration and use of monitoring equipment: Monitoring equipment shall be calibrated to ensure accurate test results before entering a confined space. When opening a manhole cover, the employee shall be trained to check for the monitoring hole; if not available, open it just enough to get a reading. Checks must be made for oxygen contents, flammability and toxicity - in that order.

vi. Isolation and Lockout/Tagout

1. All requirements of ESCO Group’s lockout/tagout program “Energy Control Procedures” must be followed accordingly.

2. All energy sources must be controlled to prevent the unexpected energization, start-up, or release of stored energy which may cause injury to workers. Energy sources may include the following: electrical, mechanical, hydraulic, and pneumatic (air), chemical and thermal.

3. Methods and means shall be selected to prevent accidental introduction of material into the confined space such as: blinding, disconnecting, removal or double block and bleed of lines.

4. Equipment or processes shall be locked out and tagged.

vii. Ventilating the Confined Space

1. Gases that may leak into, or otherwise enter, the confined space during work or where an oxygen deficient atmosphere may be created, either natural or forced air ventilation must be continued as long as workers are in the confined space.

2. Safety precautions are necessary when using mechanical ventilation.

a. Prevent recalculation of contaminated air.

b. Prevent contaminating other areas with concentrations of flammable or toxic materials which have been removed from the confined space.

c. Be aware of possible pockets of trapped contaminants remaining in the confined space.

3. Natural ventilation is permitted if all atmospheric tests are within acceptable limits.

viii. Personal Protective Equipment (PPE)

1. Employees shall wear PPE selected in accordance with the requirements of the job to be performed:

a. Head protection

b. Eye and face protection

c. Hand protection

d. Foot protection

e. Protective clothing

f. Respiratory protection

g. Fall protection – where a potential exists for persons or objects falling into a confined space, warning systems or barricade shall be employed at the entrance.

h. Boatswain/Bosun chair

2. All Individuals entering a confined space from shall wear a full body harness with a life-line attached.  Confined space entry will not be performed when full body harness and life-line impose an increased hazard unless other safety means for rescue or locating employee are made prior to entry. 

3. Appropriate retrieval equipment methods shall be used when a person enters a confined space.

ix. Cutting/Welding (Hot Work)

1. All requirements of ESCO Group’s hot work program located within “Welding Operations” must be followed accordingly.

2. Any hot work requires assurance that fire hazards and explosive atmospheres are controlled.

3. Hot work permits are required prior to entry.

4. When hot work involves the generation of toxic gases, vapors, or fumes, local exhaust blowers shall be used in conjunction with proper respiratory protection.

5. Compressed gas cylinders are not allowed in a confined space and gas lines should be protected from rupture or damage.

6. Compressed gas cylinders and electrical generators shall be attached by the stand-by person.  Sources of compressed gases or arc welding power should be turned off immediately when an emergency arises or when work is interrupted or completed.

x. Use of Hazardous and/or Flammable Materials

1. Quantities of hazardous or flammable materials brought into the confined space shall be limited to the smallest amount consistent with efficient use.

2. Containers used should be designed to minimize evaporation or spillage.  Safety cans or small squeeze bottles are recommended.

3. When using flammable materials, all sources of ignition shall be eliminated.

xi. Tools

1. All tools, extension cords and air hoses must be in good operating condition.

2. All electrical equipment used in a confined space shall be equipped with ground-fault circuit interrupters (GFCI).  Electrical tools shall be grounded or double insulated.

3. It is recommended that spark resistant tools be used when working in a confined space (i.e.: shovels, picks, hammers, wrenches, etc.) where an explosive atmosphere may be present.

xii. Illumination

1. Where portable lamps are used, they shall be equipped with handle, lamp holder, hook, and substantial guard attached to the lamp holder or handle.

2. Where temporary lighting is carried inside the confined space it shall be equipped with heavy-duty flexible cord with the connections and the insulation properly maintained.

3. Cords shall be kept clear of working spaces and walkways.

4. Temporary lighting shall be properly guarded.

5. Battery, low voltage (12v), or lighting systems with properly installed ground-fault circuit interrupters shall be used.

6. Portable lighting shall be explosion proof when used in flammable atmosphere.

xiii. Emergency Response

1. ESCO group will utilize the onsite rescue services that are located on the jobsites. If we are performing work at a site that does not have a rescue team we will notify the local fire department of the confined space entry and their needs to provide rescue services for us.

2. Emergency situations that may occur during the confined space entry include, but are not limited to the following:

a. High concentrations of toxic gases

b. Oxygen deficient or enriched atmosphere

c. Mechanical or physical hazard within the confined space

3. During an emergency situation the following steps shall be followed:

a. Notify emergency response personnel and agencies. Use the radio system at the facilities and the onsite emergency notification practices

b. If the emergency involves IDLH (Immediately Dangerous to Life or Health) conditions entrance into the space shall be performed only with the use of a self-contained breathing apparatus (SCBA). Rescue services must be present at the site at the time of entry to eliminate time constraints. Individuals entering under these conditions must also wear a full body harness attached to a life-line.

4. Other rescue equipment that may be necessary includes, but is not limited to, the following:

a. Mechanical lifting devices, first-aid equipment, communication devices, lighting, etc.

xiv. Training

1. Training shall be provided so that all employees whose work is regulated by the confined space program acquire the understanding, knowledge, and skills necessary for the safe performance of the duties they have been assigned.

2. Training shall be provided to each affected employee.

3. Before the employees is first assigned duties under the confined space program.

4. Before there is a change in assigned duties.

5. Whenever there is a change in permit space operations that presents a hazard about which an employee has not been previously trained.

6. Whenever the employer has reason to believe that there are deviations from the permit space entry procedures required by the program or that there are inadequacies in the employee’s knowledge or use of the these procedures.

7. The training shall establish employee proficiency in the duties they have been assigned and shall introduce new or revised procedures as necessary for compliance to the program.  Training will include the following but not limited to:

a. General hazards associated with confined spaces.

b. Proper use and limitations of PPE and other safety equipment.

c. Explanation of permit system.

d. How to respond to emergencies.

e.Duties and responsibilities of each designated entrant, attendant, and entry supervisor.

f. Proper use of atmospheric testing equipment including field calibration, basic knowledge of the work being performed and the anticipated hazardous contaminants.

g. Use of any emergency rescue equipment.

8. The employer shall certify that the training above has been completed. The records shall contain the employee’s name, signatures or initial of the trainer and dates of training. The training shall be available for all employees and their supervisors for inspection.

9. All employees will receive training pertaining to the basic understanding and hazards associated with confined spaces at time of employment and annually thereafter. 

10. Employees that are associated with the confined space entry team will receive training annually. Retraining will be conducted when periodic assessments reveal that an employee is deviating from the procedures that are put in place or are not performing their duties they have been assigned.

11. All training will be documented and maintained.

xv. Alternate Procedures and Space Reclassification

1. Confined spaces may be entered without the need for a written permit or attendant provided the space can be maintained in a safe condition for entry.

2. All spaces shall be considered permit-required confined spaces until the pre-entry procedures or space classification have been successfully completed.

3. All employees entering a confined space that has alternate procedures or space classification must have successfully completed training required.

4. An alternate procedures and space reclassification periodic atmospheric monitoring documentation sheet must be completed by the lead worker before entry into the space.

5. The atmosphere within the space will be tested before entry to determine whether dangerous air contamination and/or oxygen deficient or oxygen enriched atmosphere exists.  Testing shall be performed by the lead worker who has successfully completed the atmospheric testing equipment training program for the equipment that will be used.

6. Continuous testing if the atmosphere in the immediate vicinity of the workers within the space shall be accomplished.  The workers will immediately leave the space when any of the air-contaminate equipment alarm set points are reached as defined.  Workers will not return to the area until a supervisor who has successfully completed the air contaminate equipment training has used a direct reading gas detector to evaluate the situation and has determined that it is safe to enter.