Environmental Health & Safety

Confined Space Guidelines


January 2010
General Requirements
A List of Confined Space and Hazards, Confined Space Signs, or Confined Space Permit is available from Amherst College Environmental Health and Safety upon request.

Scope:

In accordance with the Amherst College Environmental Health & Safety Policy, the following Confined Space, guidelines have been designed to provide the appropriate health and safety requirements that are to be followed when entering, exiting and working in confined spaces. The guidelines have been established in order to comply with all local, state and federal regulations, including that of the Occupational Health & Safety Administration (OSHA), 29 CFR 1910.146 and all applicable nationally recognized standards.

Purpose:

To establish guidelines and performance objectives for the health and safety of Amherst College Physical Plant employees and outside contractors that are to perform work in both permit and non-permit required confined spaces at Amherst College.

Application:

The Amherst College Confined Space Guidelines and other applicable requirements found here-in shall at least comply with if not exceed local, state and federal requirements. It is the responsibility of all companies and personnel working in both permit and non-permit required confined spaces at Amherst College to adhere to this Confined Space guideline, unless the use of a more strict guideline, policy or program is utilized.

Definitions:

Acceptable Entry Conditions - conditions that must exist in a confined space to allow entry and to ensure that employees involved in a confined space entry can safely go into and work within the space.

Attendant(s) - one or more persons stationed outside a "permit required" confined space who monitor the authorized entrants, provide appropriate support services, assist in non-entry rescues and perform all other duties of the attendant as indicated herein.

Authorized Entrant - an employee who is authorized (with the appropriate knowledge and training) by the employer to enter a confined space, both permit and non-permit required.

Blinding /Blanking - the absolute closure of a duct, line or pipe by the fastening of a solid plate (i.e. spectacle blind or skillet blind) that completely covers the diameter and that is capable of withstanding the maximum pressure of the duct, line or pipe with no leakage beyond the blind or plate.

Confined Space - a space that:Confined Space 3

(1) is large enough and so configured that an employee can bodily enter and perform assigned work.
(2) has limited or restricted means of ingress or egress, such as, but not limited to:

(a) boilers
(b) ductwork
(c) elevator hoistways, overheads and pits
(d) pits
(e) stacks
(f) tanks
(g) tunnels
(h) vaults

(3) is not designed for continuous occupancy.

Non-Permit Required Confined Space (NPRCS) - a confined space that does not contain known or potential hazards (atmospheric or otherwise) that might or will cause serious illness, injury or death.
 

Permit Required Confined Space (PRCS) - a confined space that contains one or more actual or potential hazards that pose a threat to the health and safety of the workers who will enter the space and for which a written authorization to enter (a permit) is required. A PRCS has one or more of the following characteristics:

(a) contains or has the potential to contain a hazardous atmosphere
(b) contains a material that has the potential for engulfing an entrant
(c) 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
(d) has air, gas, steam or water under pressure
(e) is found to have excessively high temperatures that may cause dehydration
(f) has the potential to cause injury by electrocution
(g) contains any other recognized health and safety hazard


Double Block and Bleed - the closure of a duct, line or pipe by closing and locking and/or tagging two (2) in-line valves and by opening and locking and/or tagging a drain or vent valve in the line between the (2) closed valves.

Engulfment - the surrounding and effective capture of a person by a liquid or finely divided (flowable) solid substance that can be aspirated to cause death by filling or plugging the respiratory system or that which can exert enough force on the body to cause death by strangulation, constriction or crushing.

Entry - whenever a person places any portion of their body (i.e. arm, face, foot, hand or head) into the opening of a confined space, it is to be considered an entry.

Entry Permit - the printed or written document that is provided by the employer to allow and control entry into a "permit required" confined space. The entry permit shall indicate all appropriate, applicable information that will provide safe entry into a "permit required" confined space.

Entry Supervisor - the person responsible for determining if acceptable entry conditions are present at a "permit required" confined space where entry is planned, for authorizing entry and overseeing entry operations, and for terminating entry or work in the space as required in these guidelines.

Hazard Evaluation - assessment of a confined space to determine hazards, known or potential.

Hazardous Atmosphere - an atmosphere that may expose personnel to the risk of death, incapacitation, impairment of ability to self rescue, illness, injury or one or more of the following:

(a) flammable gas, mist or vapor in excess of 10% of the lower explosive limit (LEL) or lower flammable limit (LFL)
(b) air-borne combustible dust at a concentration that meets or exceeds the LEL or LFL (the dust obscures vision at a distance of 5' or less)
(c) atmospheric oxygen is below 19.5% or is greater than 23.5%
(d) hydrogen sulfide (odor of rotten eggs) in concentrations greater than 10 ppm
(e) carbon monoxide (colorless and odorless gas) in concentrations greater than 35 ppm
(f) any other substance that may exceed the exposure level (i.e. PEL, STEL or TWA)
(g) any other atmospheric condition that is immediately dangerous to life or health (IDLH)

Hot Work Permit - the host employer's written authorization to perform operations such as burning, cutting, heating, soldering or welding that would be capable of providing a source of ignition.

Immediately Dangerous to Life and Health (IDLH)
- any condition that poses an immediate or delayed threat to life or that which would cause irreversible adverse health effects or that would interfere with an individuals ability to escape unaided from a confined space. (See the ACGIH manual, MSDS or similar for information on chemicals or gases that may be classified as IDLH.)

Inerting - displacement of the atmosphere in a confined space by a non-combustible gas such as argon, carbon dioxide or nitrogen in order to make the space incombustible.

Isolation - the process of completely protecting or removing the release of energy and material into a confined space by such means as: blanking or blinding, misaligning or removing sections of ducts, lines or pipes, a double block and bleed system, lockout and/or tagout of all sources of energy; or blocking or disconnecting all mechanical linkages.

Lock Out/Tag Out - the placement or a lock and/or tag on an energy isolating device in order to separate the energy source(s), including potential or stored energy from the equipment, machine or process being maintained or serviced. (An energy isolating device is any device that prevents the transmission or release of energy, including but not limited to: blocks, circuit breakers, disconnects, line valves, slip blinds, etc.)

Qualified Person - a person who has the appropriate education, experience and training to work in and around confined spaces, and who is accomplished and knowledgeable in the various operations of confined space work. This includes, but is not limited to, having the ability to properly evaluate and recognize hazards that may be part of the confined space and having the ability to mitigate hazards found.

Rescue Service - the company, personnel or service designated to rescue employees from confined spaces.

Retrieval System -
equipment such as a full body harness, lifeline, rope and tripod used for non-entry rescue of persons from a confined space.

Testing - the identification and evaluation of hazardous conditions inside a confined space using equipment such as that which is used for monitoring hazardous atmospheres.

Toxic Atmosphere - the atmosphere in or around a confined space that contains a concentration of a substance (gas, liquid or solid) above the published or recognized safe levels. (See IDLH.)

General Requirements:

Confined Space IdentificationConfined Space 2
(a) It is the responsibility of the Amherst College Physical Plant to identify all confined spaces and to determine whether or not the spaces are "permit" or "non-permit" required.
• confined spaces shall be identified by number, building, area or room, driveway or street, as "non-permit" or "permit" required and list of all known or potential hazards
(b) If the confined spaces are determined to be "permit required", then Amherst College Physical Plant shall post signage or other equally effective means of space(s).
• the sign or other identification shall inform entrants that the confined space contains known or potential hazards, possibly including atmospheric
(c) Signs shall be posted at each entrance to the "permit required" confined space and shall read something similar to:
Exceptions
• in those areas where signs cannot be posted because of adverse elemental conditions, the confined spaces determined to be "permit-required" shall be identified in Appendix A of this standard operating guidelines
• without exception, sewers and storm drains shall at all times be considered "permit required" confined spaces
(d) In those locations where Amherst College Physical Plant has decided no person shall enter a particular confined space, appropriate measures to prevent entry shall be incorporated.

These measures may include:
1. welding or otherwise securing the cover in place
2. filling the confined space with a cementitious or similar material
3. removal of the confined space
(e) In some cases an initial evaluation of the confined space may be needed to determine whether or not the confined space is "permit" or "non-permit" required. If this initial assessment is required, the entry shall be made as if the confined space is "permit required."

(f) Confined spaces that have been identified as "non-permit" required confined spaces, that now must be entered for the purpose of cleaning, brazing, cutting, heating, soldering and welding or which contains water or other known or potential hazard shall now be classified as a "permit required" confined space.
(g) If forced or exhaust ventilation alone is maintaining acceptable atmospheric conditions within the confined space, the space shall remain "permit required."

Confined Space SurveyConfined Space Photo 2

(a) Each confined space survey shall be performed by a qualified person.

(b) The survey shall determine whether the space is to be considered a "permit" or "non-permit" required confined space.

(c) The survey shall identify:

1. building, area, room or other location of the confined space

2. known or potential hazards including:

  • mechanical and physical characteristics
  • past and present uses of the confined space
  • atmospheric conditions (i.e., carbon monoxide, flammable vapors, hydrogen sulfide, oxygen deficiency or enrichment, etc

3. a number specific to that location

(d) A hazard evaluation shall be performed as part of the survey to determine:
1. hazard exposure
  • who and how many people would be affected
2. hazard potential
  • how much energy could be released
  • what are the potential effects of the chemicals being used
3. hazard consequences
  • what is the likelihood of illness or injury
  • what is the potential for explosion or fire
4. hazard conditions
  • what activities or conditions in the confined space could change, making it more hazardous for the entrants:
- electricity
- fall potential
- gas
- hot works
- steam
- water (rising)
5. hazard control
  • what strategies are available to control hazards:
- block and bleed
- hot work permits
- lock out/tag out
- ventilation emergency response
6. emergency response
  • who is available for a confined space rescue

Acceptable and Unacceptable Atmospheric Conditions4 Gas Meter

(a) After evaluation by a qualified person, the atmospheric conditions of a confined space shall be considered acceptable provided:

Oxygen - is between 19.5% and 23.5%

Flammability - is less than 10% of the LEL or LFL

Carbon Monoxide - is less than 35 ppm

Hydrogen Sulfide - is less than 10 ppm Toxicity - is less than recognized exposure limits (i.e. PEL or TWA)

Airborne Dusts - are less than the LEL or LFL concentrations

(b) If the atmospheric conditions do not meet the above referenced environmental factors, then the space is considered to be hazardous and entry into the space shall be prohibited or existing work within the space shall be immediately halted and personnel evacuated.

  •  if a hazardous condition such as a flammable/toxic gas or oxygen deficiency/enrichment is discovered, then the following should be investigated to correct or evaluate the situation:
  • check to see if the ventilation system is operational
  1. is contaminated air being pulled in from an exterior source
  2. if the atmospheric hazard is being created within the confined space, should the ventilation be exhaust rather than supply
  • if the hazardous condition(s) has been rectified and the space now appears to be ready for re-entry, the following shall be performed:
  1. insure operation of the ventilation system
  2. insure the supplied air is from a clean source
  3. if cleaning, cutting, soldering or welding in the confined space, utilize exhaust ventilation, pulling contaminants away from the point of origin
  4. monitor the confined space:
- before entry and
- continuously while working within the confined space
  • if the "permit required" confined space was purged with argon, carbon dioxide, nitrogen or other similar inerting gas, the confined space shall be ventilated and re-tested before entry
  • if after re-testing the atmosphere remains unsafe or unacceptable for entry, the permit for the confined space entry must be revoked and entry prohibited
contact the Amherst College Physical Plant Environmental Health and Safety Office at 542-8189

Confined Space Permit

(a) Prior to entering a "permit required" confined space, an entry permit must be prepared and signed by the entry supervisor. The entry supervisor can represent either Amherst College or an approved contractor working for the College.

(b) The entry permit shall be made available to all entrants, attendants, entry supervisors and inspectors (local, state and federal) by posting the permit near the entry of the confined space.

(c) The permit shall be on NCR or similar paper with at least 4 copies. Each copy of the permit shall identify the intended recipient. Before work is started in the confined space, a copy of the permit should be posted or given to the following:

  1. posted on site near the entrance of the confined space
  2. copy to the Amherst College Police Department
  3.  copy to the EH&S department within the Physical Plant for notification and record-keeping purposes

(d) The permit shall include the following information:

  1. the confined space to be entered and its corresponding number
  2. the purpose of the entry
  3. the date and time of entry
  4. the authorized entrants, attendants, rescue service and supervisors
  5. the hazards (known or potential) within the space
  6. the hazard control measures used
  7. acceptable entry conditions
  8. testing and monitoring results
  9. communication procedures
  10. equipment and PPE used on the site of entry
  11. any other information considered to be pertinent to the entry

(e) All applicable requirements of the permit shall be met before entry is made. This may include, but is not limited to:

  1. eliminating atmospheric hazards by purging or ventilating
  2. isolating hazardous energy (lock-out/tag-out)
  3. monitoring the space prior to entry and continuously thereafter
  4. requiring the use of PPE
  5. providing communication equipment, lighting barriers, water, etc.

(f) The permit can be revoked at any time by the attendant, entry supervisor or other qualified person if a condition arises or exists that may cause illness, injury or death to the confined space entrants.

  1. the person that revokes the permit shall make sure that all confined space entrants have been evacuated and accounted for
  2. they shall then indicate on the permit the reasons for revocation
  3. they shall then notify the entry supervisor and the EH&S department

Permit Required Confined Space EntryConfined Space 1

The following requirements apply to entry of a "permit" required space:

(a) Any conditions making it unsafe to remove an entrance cover/opening(s) shall be eliminated before the cover is disturbed/removed. Examples include:

  • gasoline tanks
  • oil tanks
  • propane tanks
  • sewers
  • other potentially flammable confined spaces
(b) After opening the confined space, the area or opening should be immediately guarded by:
  • railing with upper, middle and lower rails as well as toe boards
  • temporary cover
  • other appropriate barrier that will prevent accidental fall into the space and/or keep items from entering the confined space
(c) Before the employee enters the confined space, he/she must:
  •  make sure all the appropriate permits have been received and distributed
  • make sure the Amherst College Police Department has been notified about the entry. After hour emergency entry included.
  • make sure all appropriate rescue, personal protective equipment, communication equipment and personnel are on site
  • test the space for atmospheric conditions, using a calibrated, direct reading instrument that will check for the following:
  1. oxygen content
  2. flammable gases and vapors
  3. carbon monoxide
  4. hydrogen sulfide
  5. potential toxic air contaminants specific to the site
  • make sure that proper inerting, purging and ventilation of the confined space has been completed by:
  1. using supply ventilation to introduce fresh air into the space
  2. using exhaust ventilation when a hazardous atmosphere is being created within the space and removal from the point of generation is required
  • if the source of the contaminant cannot be identified, precautions shall be adequate to deal with the worst possible condition within the confined space
  • insure that while work within a "permit required" confined space continues, constant monitoring of the space is being performed to prevent the accumulation of a hazardous atmosphere
Exception - if the an atmospheric hazard does not exist and there is no introduction of chemicals, gases, hot work, etc., then the confined space can be monitored periodically

Elevators

(a) Elevators, including hoistways, overheads and pits are confined spaces that are often deemed "permit required."

(b) If the following three conditions are discovered in the hoistway, overhead or pit, the area will be classified as a confined space:

  1.  if greater than 3' deep or a ladder is required to egress/ingress the pit
  2.  if the pit is not designed for continuous human occupancy
  3. if the area is large enough for a person to enter and perform work

(c) If a known or potential hazard is present within the space at the time of entry, the space will be considered "permit required." Examples of these hazards include:

  1. using chemicals including those for cleaning in the confined space
  2. hazardous energy to the elevator or surrounding area that has not been locked or tagged out
  3. hot works (brazing, cutting, soldering, welding, etc.)
  4. painting (excluding non-toxic latex)

(d) If the elevator technician must work atop or under the elevator car(s) in the hoistway or pit with the car and/or shaft still energized, then the hoistway, overhead and/or pit shall be considered "permit required."

Exception -provided the elevator car has been properly de-energized (locked and/or tagged out) and the technician is not in the hoistway or pit, but on top of the car with the doors open to the lobby or other landing, the requirements of the confined space can be eliminated

1. in addition to lock-out/tag-out requirements, the technician working inside the elevator hoistway, overhead or pit shall insure that the following has also been incorporated, as applicable:

  • fall protection
  • personal protective equipment
  • hot work permit
(e) Elevator repair and service companies must coordinate with the Amherst College Physical Plant before initiating work in confined spaces. The purpose of the meeting is to permit the College to identify the known and potential hazards to the contractor performing work so that the elevator company can evaluate or re-evaluate the confined space including the hoistway, pit and overhead.

(f) Elevator contractors shall inform the Amherst College Physical Plant Electrical Supervisor before beginning work, so that he/she can:
1. notify the contractor that the workplace may contain "permit required" confined spaces and that the permit for the confined space must be utilized
2. make the contractor aware of all known and potential hazards specific to that confined space and why it might be "permit required"
3. advise the contractor of any precautions or procedures that the College has implemented for the protection of the contractors, faculty, staff, students and visitors in or near the confined space where the elevator company is working
4. coordinate entry requirements with contractor before initial entry is made
5. debrief the contractor when work has been completed to determine if hazards were created or identified in the confined space

Contractor Safety for Confined SpacesConfined Space Photo 4

(a) When Amherst College arranges to have an outside contractor or person perform work on the campus, the contractor shall:

1. request a copy of the Amherst College Construction Management Safety Manual, permits and appropriate health and safety policies

2. notify the College of the "permit required" confined space program they will be using

  • the program used shall be at least as stringent as that which is required by Amherst College
(b) When the work of the outside contractor or person involves a "permit required" confined space, Amherst College shall:
1. inform the contractor that the workplace contains "permit required" confined spaces and that all requirements of the confined space policy must be followed
2. notify the contractor of any known or potential hazards that make the space(s) being worked in "permit required"
3. inform the contractor of any precautions or procedures that the College has implemented for the protection of contractors, faculty, staff, students and visitors in or near confined spaces where the contractor will be working
4. coordinate entry operations with the contractor when both the employees of the College and the outside contractor or person will be working together in or near the confined space
5. debrief the contractor at the conclusion of the work regarding any hazards that were created or identified within the "permit required" confined space

Permit Required Confined Space Site Preparation

In accordance with the requirements of the "permit required" confined space policy, the employer shall:

1. prevent unauthorized entry into the confined space

2. identify and evaluate hazards of the space before entry is made

3. develop and implement the means, procedures and practices required for a healthy and safe confined space entry operation including, but not limited to the following:

  • isolating the permitted space
  • flushing, inerting, purging or ventilating the confined space
  • providing suitable barriers to prevent injuries of persons in and around the confined space
  • maintaining and verifying safe entry and work conditions at all times for the duration of the project
  • testing and monitoring equipment which is operating properly and has been calibrated and labeled by an authorized representative of the equipment manufacturer as outlined in the equipment specifications
  • ventilation equipment, exhaust or supply, depending on the application
  • communications equipment including a portable radio or phone with appropriate emergency numbers available to the attendant and any other person that the supervisor or health & safety personnel deems appropriate
  • personal protective equipment appropriate for the work being performed
  • lighting equipment needed to work in and allow for evacuation of the confined space
  • electrical equipment shall be properly protected to prevent potential injury to the persons working in and around the confined space including the use of GFCIs (Ground Fault Circuit Interrupters)
  • ladders which are appropriate for the job being performed
  • all applicable emergency and rescue equipment
  • testing is required prior to entry to determine if conditions are acceptable
  • continuous testing is required while work involving an introduced hazard is ongoing
  • periodic monitoring is acceptable if no hazards are being introduced and supplemental ventilation is not initially required
  • the number of attendants will be determined by the entry supervisor or the health and safety officer
  • the attendant(s) shall always remain in constant communication with the entrants by voice or portable radio
  • the attendant may not for any reason leave or enter the "permit required" confined space while an entrant remains inside unless conditions are acceptable for entry and the attendant has been relieved by another qualified attendant
7. identify the emergency space rescue and shall have already developed a means to summon same before an incident and rescue services available for confined occurs
8. have a means previously established to prepare, issue, use, and when necessary, revoke a permit for a confined space
9. review entry operations when the employer has reason to believe that measures taken have not adequately protected the employees and revise entry operations to correct those adverse conditions
10. completely fill out and sign the permit before work is initiated (entry supervisor or other qualified person can sign the permit to initiate the project)
11. post a copy of the permit at the confined space entry point with attached copies presented to the police department and the Physical Plant before job initiation
12. not allow the permit to exceed an 8-hour duration
13. ensure that after each break and lunch that the confined space has been re-tested for atmospheric conditions which may have deteriorated
14. monitor the confined space for other environmental conditions such as heat and humidity (employer must develop the proper work/rest ratio for the employees working in that space and provide them with adequate refreshment such as water, Gator-Aid, Power-Aid or similar beverage)
15. If after hours entry into a confined space is necessary, the employee recalled shall request another Amherst College "qualified attendant" to assist.

Personnel Responsibilities for Permit Required Confined Spaces

The employer shall ensure that all personnel who are to be considered for confined space entry, monitoring and associated work are authorized, trained and periodically evaluated to perform the work. The responsibilities for each position are identified below.

Authorized Entrants:

shall be familiar with the known or potential hazards before entry and while working in the confined space - hazards might include:

  • asbestos
  • electrical
  • environmental conditions
  • fire
  • signs and symptoms of exposure
  • steam
2. shall not enter the confined space until the appropriate equipment is on site and placed into operation:
  • tripods and rescue equipment
  • ventilation equipment
  • portable radios or cellular phones
3. shall learn and become familiar with the operation of equipment such as the air monitors, tripod, harnesses, lifelines, portable radios, etc.
4. shall remain in communication with the attendant at all times in case there is a need to evacuate the confined space
5. shall alert the attendant whenever:
  • the entrant recognizes a dangerous condition or possible exposure
  • the entrant detects a prohibited condition
6. shall exit the confined space as quickly as possible whenever:
  • an order to evacuate is given by a "qualified" Amherst College employee
  • the entrant recognizes a dangerous condition or possible exposure
  • the entrant detects a prohibited condition

Attendants:

1. shall be familiar with the known or potential hazards before entry and while entrants are working in the confined space - hazards may include:
  • equipment malfunction
  • loss of communication
  • pedestrian and vehicle hazards
  • supply or exhaust ventilation shut-down
  • vehicle exhaust infiltration
2. shall maintain an accurate count of the authorized entrants in and out of the confined space and their well being
3. shall maintain constant communication with entrants of the confined space, monitoring for hazard exposure and behavioral abnormalities
4. shall monitor conditions in and around the confined space, using and interpreting the meter readings and alarms
5. shall warn unauthorized persons to remain clear of the confined space and immediately discharge those who may have already entered
6. shall remain outside the "permit required" confined space unless relieved by another qualified attendant
7. shall be familiar with summoning the rescue service for a confined space incident
8. shall be able to assist entrants from the confined space, either verbally or with the aid of the rescue equipment
9. shall never enter a "permit required" confined space unless all hazards have been eliminated and attendant has officially been relieved by another qualified attendant

Entry Supervisor:

  • air quality abnormalities
  • asbestos
  • chemicals and cleaning materials
  • electrical
  • environmental conditions
  • fire
  • flammable and combustible material
  • high and low pressure steam and water
  • signs and symptoms of exposure
  • sewer

3. shall make sure that all aspects of the confined space permit have been addressed and properly filled out before entry is made

4. shall be familiar with the monitor and testing equipment and the alarms and how to interpret the readings indicated

5. shall provide operational and appropriate communication equipment such as a portable radio or cellular phone with the appropriate emergency numbers

6. shall insure that each "permit required" confined space has been properly assessed by a qualified person before entry into the space is made

7. shall insure that all appropriate equipment, including G.F.C.I.'s, intrinsically safe tools, and rescue and safety apparatus are on site before work is initiated

8. shall supply an MSDS for each chemical or cleaning agent that the entrant is using or may be exposed to while working in or around the confined space

9. shall make sure that the permit is posted at the entrance to the confined space

10. shall verify that the appropriate agencies have been contacted before entry
11. shall make sure that all attendants and entrants are familiar with the use and set up of equipment including that used for rescue

12. shall make sure that the appropriate work/rest ratio is being implemented

13. shall provide adequate liquid refreshment (i.e., Gator-Aid, Power-Aid or water) to help maintain vital body fluids and prevent dehydration

14. shall revoke the permit for the confined space entry and require the evacuation of all entrants at any time he/she feels an unsafe condition exists

15. shall enforce all appropriate provisions of the Confined Space Guidelines and, when necessary, initiate disciplinary measures to prevent reoccurrence - disciplinary action may include:
  • verbal warning- 1st offense
  • verbal warning with letter to personnel file- 2nd offense
  • written reprimand- 3rd offense
  • suspension- 4th offense
  • termination- 5th offense

Downgrade from "Permit Required" to "Non-Permit Required" Confined Space

A space designated as "permit required" confined space can be reclassified as "non-permit required" if:

1. the permit space does not pose an actual or potential atmospheric hazard

2. hazards within the space are eliminated without having to make entry (if entry has to be made to eliminate hazards before the downgrade, then the space shall be considered "permit required" until all the hazards and atmospheric concerns have been eliminated)

3. the employer (Amherst College or outside contractor) shall document the basis for determining that the area was evaluated and found to be free of all hazards - documentation shall contain:

  • date of survey
  • the specific confined space location
  • the signature of the qualified person
-a confined space permit shall meet the requirements for the above documentation
Please note: until proven otherwise, all confined spaces should be considered "permit required" until a test and removal of all hazards including lock out/tag out have rendered the confined space safe
4. the only potential hazard in the confined space is atmospheric and the space proves to be hazardous but the ventilation is sufficient to maintain a safe condition, the exhaust or supply circulation of air should remain on and the area continuously monitored
5. the atmospheric test at anytime indicates a condition that is not safe, all persons should vacate the confined space - unless the situation can be corrected, the space must be classified "permit required"

Rescue and Emergency Services

(a) Emergency and rescue services for Amherst College are provided by the Amherst Fire Department

(b) Amherst College shall ensure that the rescue team is provided with and is trained to use the appropriate rescue and personal protective equipment.

(c) The attendant, entry supervisor and other qualified personnel from Amherst College shall assist the Amherst Fire Department with confined space rescue by:

  • providing the necessary rescue equipment including tripod, harness, lifeline, monitors and ventilation equipment
  • helping to secure the site and preventing unauthorized persons from entering the area
(d) The rescue team and qualified Amherst College personnel shall practice confined space rescue at least once every 12 months.

(e) Amherst College must inform the Amherst Fire Department about any hazards that they may come in contact with before entering the confined space for the purpose of rescue.

(f) The rescue team must don SCBA, Type C airline, or a combination of both. A minute escape bottle or other appropriate back-up is also required in case of primary system failure.
Exception
  • if the confined space does not contain a hazardous atmosphere, and the patient/entrant can communicate verbally with the attendant/rescue team, the breathing equipment may not be necessary
(g) Rescue equipment must be inspected and, if necessary, calibrated and/or repaired by qualified personnel in accordance with manufacturers' specifications to insure proper working order.

Training

(a) All Amherst College personnel who may or will serve as entrants, attendants, supervisors and qualified personnel at a confined space shall receive the appropriate required training.

(b) Initial training will be given to all affected employees. Refresher training with all new updates will be provided annually unless re-familiarization with the guidelines is warranted.

(c) Training shall be provided by the Physical Plant Environmental Health & Safety Committee, the Environmental Health & Safety Office and outside consultants, when necessary. The training will incorporate the use of:

  • overheads
  • videos
  • slides specific to Amherst College
  • practical exercises
  • written exercises
  • course evaluations
(d) The training will focus on:
1. Amherst College Policy and Standard Operating Guidelines for Confined Space
2. identifications of hazards
3. maintenance, storage and use of equipment
4. personnel responsibilities
5. confined space recognition
6. emergency response and rescue
(e) A certificate for the Confined Space training will be given to each employee who successfully completes the course. Successful completion is dependent upon the employees' understanding of the entrants, attendants, supervisors and qualified personnel responsibilities.
(f) Records of the training program and employee understanding shall be kept in the office of Environmental Health & Safety as required.
Confined Space Evaluation