The purpose of this policy is to provide a safe and healthy
environment for employees required to enter confined spaces.
This policy shall cover all Western Michigan University
(WMU) employees entering and working in a confined space. All
contractors must have their own confined space entry policy which
is comparable to this policy. Contractors must be familiar with
the Western Michigan University policy and Western Michigan University
must be familiar with the contractor's policy.
Acceptable entry conditions:
The conditions that must exist in a permit space to allow entry
and to ensure that employees involved with a permit-required confined
space entry can safely enter into and work within the space.
Attendant: An individual
stationed outside one or more permit spaces who monitors the authorized
entrants and who performs all attendant's duties as noted in the
WMU confined space policy.
Authorized entrant:
An employee who is authorized by the employer to enter a permit
space.
Alternate permit space:
An alternate permit space exists when the following conditions
are met:
1. The only hazard posed by the permit space is an actual
or potential hazardous atmosphere.
2. Continuous forced air ventilation alone is sufficient
to maintain the space safe for entry.
3. Monitoring and testing (inspection data) verify that
the above two conditions are met.
Confined space:
Confined spaces may include, but are not limited to storage tanks,
process vessels, bins, boilers, ventilation or exhaust ducts,
sewers, trenches, tunnels, pits, tubs, vaults, vessels, silos,
and hoppers. A confined space has the following three characteristics:
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.
3. Is not designed for continuous employee occupancy.
Engulfment: Engulfment
means 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 can exert enough force on the body to cause death by strangulation,
constriction, or crushing.
Entry Supervisor:
The person (such as the employer, foreman, crew chief, or other
trained person) responsible for determining if acceptable entry
conditions are present at a permit space where entry is planned.
The entry supervisor authorizes entry, oversees entry operations,
and terminates entry.
Non-permit confined space:
A confined space that does not contain or, with respect to atmospheric
hazards, have the potential to contain any hazard capable of causing
death or serious physical harm.
Permit-required confined
space (permit space): A permit space must have all three
characteristics of a confined space as listed above and the space
must have at least one of the following characteristics:
1. Contains or has a potential to contain a 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;
or
4. Contains any other recognized serious safety or health
hazard.
Prohibited condition:
Any condition in a permit space that is not allowed by the permit
during the period when entry is authorized.
1. Environmental Safety and Emergency Management (ES&EM) shall evaluate
the workplace to determine if any spaces are permit-required confined
spaces.
2. WMU shall inform exposed employees by posting of danger
signs or by a listing (made available to all exposed employees)
of the existence and location of and the danger posed by the permit
spaces.
3. (ES&EM) shall conduct training or oversee training
performed by qualified individuals selected by (ES&EM) for all
exposed employees on safe entry procedures, atmospheric monitoring,
and rescue procedures.
4. (ES&EM) shall also conduct training whenever there
is a change in permit space operations that presents hazard(s)
about which an employee has not been previously trained, or whenever
the employer has reason to believe that there are deviations from
permit entry procedures or that there are inadequacies in the
employee's knowledge or use of these procedures.
5. WMU shall provide and maintain the equipment necessary
to work safely in confined spaces.
6. The WMU contract administrator shall inform contractors
of the existence of confined spaces at WMU. The WMU contract administrator
shall provide a copy of this confined space entry policy to contractors
who will be entering confined spaces at WMU and receive a copy
of the contractor’s confined space policy. The contract
administrator shall inform the contractor that entry into the
confined space is allowed only through compliance with a permit
space program meeting the MIOSHA Part 90/OSHA 29CFR1910.146 requirements.
7. The WMU contract administrator shall coordinate entry
when both WMU and contractor personnel will be entering the same
confined space during the same time frame. Anytime a permit space
will be entered by a contractor, the contract administrator must
contact the WMU manager or supervisor of the area in which the
permit space is located, prior to the entry. The manager or supervisor
shall inform the contractor of the hazards identified, and any
precautions or procedures that they have implemented for the protection
of employees in or near permit spaces. The WMU manager, or supervisor
shall also debrief the contractor at the conclusion of the entry
operations regarding the permit space program followed and any
hazards confronted or created during entry operations.
8. A file containing a copy of each of the authorized
Confined Space Entry Permits shall be maintained by the office
of Environmental Safety and Emergency Management.
All persons involved in an operation requiring entry
into permit-required confined spaces (PRCS) must adhere to the
PRCS entry procedures listed in Section VIII. Alternate entry
into permit spaces must follow the alternate entry procedure list
in Section IX.
Failure to comply with this policy shall result in a
violation of Western Michigan University Human Resources Rules
of Conduct, Section 1F.
Authorized Entrant:
1. Know the hazards that may be faced during entry.
2. Recognize signs and symptoms of exposure.
3. Properly use equipment.
4. Communicate with the Attendant as necessary to enable
the Attendant to monitor Authorized Entrant status and to enable
the Attendant to alert Authorized Entrants of the need to evacuate
the space.
5. Alert the Attendant whenever warning signs or symptoms
of exposure to a dangerous situation are recognized or a prohibited
condition is detected.
6. Exit from the space as quickly as possible whenever:
a. An order to evacuate is given by the Attendant or
the Entry Supervisor.
b. Any warning signs or symptoms of exposure to a dangerous
situation are recognized.
c. A prohibited condition is detected.
d. An evacuation alarm is activated.
Attendant:
1. Know the hazards that may be faced during entry.
2. Be aware of possible behavioral effects of hazard
exposure in Authorized Entrants.
3. Continuously maintain an accurate count of Authorized
Entrants in the confined space.
4. Remain outside the permit space during entry operations
until relieved by another Attendant.
5. Communicate with Authorized Entrants as necessary
to adequately monitor their status.
6. Monitor activities inside and outside the confined
space and order Authorized Entrants to evacuate when necessary.
7. Summon rescue services if needed (use portable radio
or phone).
8. Keep unauthorized persons out of the permit space.
9. Perform non-entry rescues as specified by the employer's
rescue procedure.
10. Do not perform any duties that might interfere with
monitoring duties.
Entry Supervisor:
1. Know the hazards that may be faced during entry.
2. Verify by checking that the appropriate entries have
been made on the permit, that all tests specified by the permit
have been conducted, and that all procedures and equipment are
in place before endorsing the permit and allowing entry to begin.
3. Terminate entry and cancel the permit as required.
4. Verify rescue services are available and that the
means for summoning them are operable.
5. Remove unauthorized individuals who enter or attempt
to enter the permit space during operations.
6. See that entry operations remain consistent with the
permit.
1. Before any Authorized Entrant is allowed to enter
a confined space, a Confined Space Entry Permit must be issued
by the Entry Supervisor (see attached permit).
2. Before entering the confined space the Confined Space
Entry Permit shall be posted at the site. The permit shall remain
posted at all times until the entry is terminated. The confined
space opening shall be promptly guarded by a railing 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.
3. Prior to authorization of the entry permit, and after
every unattended period, before re-entry, appropriate atmospheric
testing is to be conducted. A minimum of two persons are required
to test every permit confined space prior to entry. The individuals
must be trained in the use of the testing instruments. Two test
meters must be used for each test. The readings on both meters
must register acceptable criteria. Test meters shall be maintained
properly and calibrated as required by the manufacturer. The individuals
performing the monitoring shall do so from outside the confined
space.
4. The atmosphere inside the space shall be measured
at three levels: top, middle, and bottom. The following atmospheric
criteria must be met prior to entering a confined space:
a. Oxygen concentration is between 19.5%-22% by volume.
b. Flammability characteristics are no more than 10%
LEL.
c. Carbon Monoxide levels are < 35 ppm.
d. Toxicity levels do not exceed contamination levels
referenced in 29CFR Part 1910 Subpart Z.
e. Temperature does not exceed 120o F.
5. In house entry rescue teams must be put on notice
of a PRCS entry prior to the entry. All rescue equipment will
be in place at the PRCS site prior to entry. The rescue team shall
be summoned by the Attendant or Entry Supervisor whenever the
Authorized Entrant inside the confined space is unable to exit
on his own or with the assistance of another Authorized Entrant
inside the space. The Attendant may assist with the rescue only
from outside the confined space. The Attendant may not enter the
confined space for any reason.
6. An atmospheric monitor shall be worn continuously
by at least one of the employees in the confined space. If the
space is compartmentalized, then at least one employee in each
compartment shall wear a monitor.
7. If the initial monitoring is acceptable but the space
is unpredictable, for instance where atmospheric conditions can
change (active sewers, sumps, organic wastes, hot work or tasks
which might generate gases, fumes, vapors, or dust), then continuous
forced air ventilation shall be supplied.
8. If tests indicate that the atmosphere is unsafe, the
confined space shall be supplied with fresh air from a continuous
forced air ventilation device adequate for the volume of the space
to bring the atmospheric conditions within permissible ranges.
9. After ventilating the space the atmosphere must be
re-tested and no person shall be allowed to enter the confined
space until the tests indicate the atmosphere meets the criteria
set forth in VIII. 4.
10. If at any time a hazardous atmosphere is detected
during entry: a. The Authorized Entrants shall exit immediately.
b. The space shall be evaluated to determine how the hazardous
atmosphere developed. c. Measures shall be implemented to protect
employees from the hazardous atmosphere before any subsequent
entry takes place.
11. A new entry permit must be issued and authorized
if any changes are to be made in the type of work to take place
inside the confined space that were not noted on the initial entry
permit. For instance a decision to perform hot work or tasks which
might generate gases, fumes, vapors, or the entry of another Authorized
Entrant not listed on the initial permit would require that a
new permit be issued.
12. Each Authorized Entrant entering the confined space
shall follow the University lockout procedure for all applicable
energy sources. All fluid and gas lines into the space must be
disconnected and/or blanked prior to work being performed in the
space. If discharge lines present a backflow possibility than
those lines must be disconnected or blanked.
13. Each Authorized Entrant must use a full body harness
with attached retrieval lines. The retrieval lines must be attached
to appropriate rescue devices and anchor points. The full body
harness and retrieval lines must be worn for all PRCS entry unless
the Entry Supervisor has determined that retrieval lines are impractical,
would increase the overall risk of entry, or would not contribute
to the rescue of the Entrant.
14. Each Authorized Entrant shall wear personal protective
equipment appropriate to the conditions in the space.
15. Upon termination of the entry the department issuing
the permit shall forward a copy of the permit to Environmental Safety and Emergency Management.
16. The Division of Environmental Safety and Emergency Management shall
be consulted if chemicals will be used or fumes or gases will
be generated in the space.
1. Continuous forced air ventilation adequate for the
space must be maintained.
2. Rescue equipment need not be on site for alternate
entry.
3. Before any Authorized Entrant is allowed to enter
an alternate permit space, an Alternate Confined Space Entry Permit
must be issued by the Entry Supervisor (see attached permit).
4. Before entering the alternate permit space the Alternate
Confined Space Entry Permit shall be posted at the site. The permit
shall remain posted at all times until the entry is terminated.
The confined space opening shall be promptly guarded by a railing
or other temporary barrier that will prevent an accidental fall
through the opening and that will protect each Authorized Entrant
working in the space from foreign objects entering the space.
5. Prior to authorization of the alternate entry permit,
and after every unattended period, before re-entry, appropriate
atmospheric testing is to be conducted. The individual(s) must
be trained in the use of the testing instruments. The readings
on the meter must register acceptable criteria. Test meters shall
be maintained properly and calibrated as required by the manufacturer.
The individual(s) performing the monitoring shall do so from outside
the confined space.
6. The atmosphere inside the space shall be measured
at three levels: top, middle, and bottom. The following atmospheric
criteria must be met prior to entering a confined space and during
the confined space entry:
a. Oxygen concentration is between 19.5%-22% by volume.
b. Flammability characteristics are no more than 10%
LEL.
c. Carbon Monoxide levels are < 35 ppm.
d. Toxicity levels do not exceed contamination levels
referenced in 29CFR Part 1910 Subpart Z.
e. Temperature does not exceed 120o F.
7. An atmospheric monitor shall be worn continuously
by at least one Authorized Entrant in the confined space. If the
space is compartmentalized, at least one Authorized Entrant in
each compartment shall wear a monitor. The Authorized Entrant
shall record monitor readings on the alternate entry permit at
the time intervals indicated.
8. If at any time a hazardous atmosphere is detected
during entry:
a. The Authorized Entrants shall exit immediately.
b. The space shall be evaluated to determine how the
hazardous atmosphere developed.
c. Measures shall be implemented to protect employees
from the hazardous atmosphere before any subsequent entry takes
place.
9. A new alternate entry permit must be issued and authorized
if any changes are to be made in the type of work to take place
inside the confined space that were not noted on the initial entry
permit. For instance a decision to perform hot work or tasks,
which might generate gases, fumes, vapors, or the entry of another
Authorized Entrant not listed on the initial permit would require
that a new permit be issued.
10. Each Authorized Entrant entering the confined space
shall follow the University lockout procedure for all applicable
energy sources. All fluid and gas lines into the space must be
disconnected and/or blanked prior to work being performed in the
space. If discharge lines present a backflow possibility than
those lines must be disconnected or blanked.
11. Each Authorized Entrant shall wear personal protective
equipment appropriate to the conditions in the space.
12. An Attendant must be stationed outside the space
and maintain communication with the Authorized Entrant.
13. Upon termination of the entry the department issuing
the permit shall forward a copy of the permit to Environmental Safety and Emergency Management.
14. The Division of Environmental Safety and Emergency Management shall
be consulted if chemicals will be used or fumes or gases will
be generated in the space.