CONFINED SPACES  POLICY

DOUGLAS COUNTY

This Confined Spaces Policy was prepared in compliance with OR/OSHA General Occupational Safety and Health Standards – OAR 437, Division 2, (29 CFT 1910) Subdivision J; (1910.146)

http://www.cbs.state.or.us/external/osha/

FOR CLARIFICATION OR CONSULTATION REGARDING PERSONAL PROTECTIVE EQUIPMENT POLICY / WORKSITE HAZARD ASSESSMENT PLAN,

PLEASE CONTACT:

DEPARTMENT OF HUMAN RESOURCES

Office of Risk Management

1036 SE Douglas, Room 322

Roseburg, OR 97470

www.co.douglas.or.us/hr

Telephone:  (541) 957-4896

          Fax:   (541) 440-6292

TABLE OF CONTENTS

• Section 1:     Introduction to the Confined Spaces Plan                  Page 3  

                              Douglas County Human Resource Department’s Administrative

                              Guidelines / Policy Statement – in support of the Confined Spaces

                              Plan, key definitions.

• Section 2:     Job Classifications                                                            Page  9

                                    This listing provides job classifications involved and the types of

                                    potential confined spaces, and confined space hazards.

• Section 3:     Employee Training                                                                        Page 10

                              The training program includes a detailed assessment of work                                         activity and tools utilized in the performance of the job, what the

                              potential confined spaces may be, hazards, retrieval from hazards,

                              removing hazards, training materials, signage.

• Section 4:     Compliance guidelines                                                     Page 11                                
• Hazard assessment and criteria.

• Section 5:     General Requirements                                                      Page 13  

                                    Responsibilities, common and non-common atmospheric hazards

                                    (how they occur and concerns, employees entering and exiting                                           space, entry permit, responder’s responsibilities, considerations in determining an emergency responder.

• Section 6:     Forms                                                                                    Page 19

                              Douglas County – Confined Space Entry Permit

                              Douglas County Confined Space Entry Hot Work Permit

                              Documentation of Plant Space Assessment Alternative                                                                Procedures / Reclassification

                                    Contractor Confined Space Notification Checklist

                                    Employee Training Confined Space

 (ALSO REFERENCE:          PERSONAL PROTECTIVE EQUIPMENT POLICY)

SECTION 1   INTRODUCTION

As an employer, Douglas County is responsible under the Occupational Safety and Health Administration to provide a hazard-free work environment for employees.  This responsibility is supplemented by specific regulations of OAR 437, Division 2, Section J (29 CFR 1910, 146 – Confined Spaces / Permit-Required Confined Spaces).  This standard requires that employers evaluate the workplace to determine if hazards are present or likely to be present that necessitate the need to test and protect employees from hazardous environments in confined spaces that may be dangerous to life or health, to post applicable signage to danger, to provide training for employees, and have a rescue service designated in the event that a rescue retrieval system is necessary.  In addition, employers must provide employees with appropriate protective equipment to use when there is a reasonable probability that they may have to enter a permit-required confined space. 

This plan has been developed based on the Federal Permit Required Confined Space standard that is in effect in Oregon.  In it there are two types of confined spaces.

            1.  Permit required spaces, and

            2.  Non-permit required confined spaces.

The Douglas County Risk Manager is designated the responsibility to maintain the overall plan and oversee plan implementation.

The Douglas County Safety Manger is designated the responsibility to provide training to employees working within this category.

Coordinators/supervisors will work with the Risk Manager to ensure implementation of the plan and will be a part of the annual program plan process.

Department Heads will notify the Risk Manager as to who the coordinators are for ongoing communication regarding this plan.

Safety Committees:  Both the Central Safety Committee and affected departmental safety committees will review the plan procedures and will include the safety and health requirements as part of their routine inspection review.

Employees are responsible to follow these procedures and bring any problems or concerns to their supervisors, safety manager, the Risk Manger or safety committee representatives.

The plan will be monitored by the Risk Manager.  All employees designated in this plan as having a need for protection from serious workplace injury or illnesses resulting from confined workplace hazards that cannot be eliminated are to follow the established procedures as addressed in this plan.

This plan will be reviewed annually by the Risk Manager to ensure that the plan is adequate.  If major changes are needed prior to the annual plan review, then the Risk Manager, in conjunction with the departmental coordinators, will initiate the review process and appropriate changes will be implemented.

Copies of this plan will be kept by department heads, departmental coordinators, the Safety Manager, and the Risk Manager.  Employees will be notified of the specific location during their annual training and information sessions. In addition, this plan can also be located on the Douglas County website at www.co.douglas.or.us.

The Confined Spaces Plan provides guidance and information to all County employees; and requirements for practices and procedures to protect employees in the workplace from the hazards of entry into permit-required confined spaces during the course of their work duties

The training required by the plan will be provided by departments to their staff with assistance from the Safety Manager. This training will occur at the time of the initial assignment where serious Permit-Required Confined Space hazards might take place and annually thereafter.

Acceptable Entry Conditions

            Refers to 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.

Alternate Procedures

            Specific procedures that allow workers to enter and work in a permit space            without a permit if continuous forced-air ventilation controls the atmospheric hazard and no other hazards exist.

Attendant

            This is an individual who is stationed outside one or more permit spaces who      monitors the             authorized entrants and who performs all attendant’s duties             assigned in the County’s permit space program.

Authorized Entrant

            An employee who is authorized by the County to enter a permit space.

Blanking or Blinding

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

Confined Space

• A space that is large enough and so configured that an employee can bodily       enter and perform assigned work
• A space that has limited or restricted means for entry or exit (i.e., vessels, silos,     storage bins, vaults, pits, tunnels, trenches)
• A space that is not designed for continuous employee occupancy.

Double Block and Bleed

            This is a closure of a line, duct, or pipe by closing and locking or tagging two in-  line valves and by opening and locking or tagging a drain or vent valve in the          line between the two closed valves.

Emergency

            Emergency means any occurrence (including any failure of hazard control or      monitoring equipment) or event internal or external to the permit space that could        endanger entrants.

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 can exert enough force on the body to            cause death by strangulation, constriction, or crushing.

Entry

            Entry means the action by which a person passes through an opening into a       permit required confined space.  Entry includes ensuing work activities in that         space and is considered to have occurred as soon as any part of the entrant’s    body breaks the plane of an opening into the space.

Entry Permit

            This is a written or printed document that is provided by the County to allow and control entry into a permit space and that contains specified information.

Entry Supervisor

            This is the person 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 this section.

Hazardous Atmosphere

            An atmosphere that may expose employees to the risk of death, incapacitation,    impairment of ability to self-rescue (escape unaided from a permit space), injury,   or acute illness from one or more of the following causes:

            (Flammable gas, vapor, mist in excess of 10 percent of it’s lower flammable           limit; airborne combustible dust at a concentration that meets or exceeds it’s LFL;   atmospheric concentration of any substance for which a dose or a permissible       exposure limit could result in employee’s exposure in excess of its dose or            permissible exposure limit; any other atmospheric condition that is immediately dangerous to life or health.)

Hot Work Permit

            A hot work permit allows the County’s written authorization to perform operations            (riveting, welding, cutting, burning, and heating) capable to providing a source of       ignition.

Immediately Dangerous to Life or Health (IDLH)

            Any condition that poses an immediate or delayed threat to life or that would        cause             irreversible adverse health effects or that would interfere with an     individual’s ability to escape unaided from a permit space.

Inerting

            Inerting is the displacement of the atmosphere in a permit space by a non-            combustible gas to such an extent that the resulting atmosphere is non-          combustible.

Isolation

            The process by which a permit space is removed from service and completely      protected against the release of energy and material into the space by such     means as: blanking or blinding; misaligning or removing sections of lines, pipes,        or ducts; a double block and bleed system; lockout or tagout of all sources of            energy; or blocking or disconnecting all mechanical linkages.

Line Breaking

            Line breaking is the intentional opening of a pipe, line, or duct that is or has been           carrying flammable, corrosive, or toxic material, an inert gas, or any fluid at a            volume, pressure, or temperature capable of causing injury.

Non-permit Confined Space

            This is 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.

Oxygen Deficient Atmosphere

            An oxygen deficient atmosphere is an atmosphere containing less than 19.5       percent oxygen by volume.

Oxygen Enriched Atmosphere

            Oxygen enriched atmosphere is an atmosphere containing more than 23.5           percent oxygen by volume.

Permissible Exposure Limits (PEL)

            An airborne chemical exposure limit established by Oregon OSHA which cannot            be exceeded without proper respiratory protection and the implementation of             feasible engineering controls.

Permit-required Confined Space (Permit Space)

            A confined space that has one or more of the following characteristics:

            (Contains or has a potential to contain a hazardous atmosphere; contains a            material that has the potential for engulfing an entrant; 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, contains any other recognized serious safety or health hazard.)

Permit-required Confined Space Program (Permit Space Program)

            The County’s overall program for controlling and, where appropriate, for    protecting employees from permit space hazards and for regulating employee         entry into permit spaces.

Permit System

            The County’s written procedure for preparing and issuing permits for entry and    for returning the permit space to service following termination of entry.

Prohibited Condition

            A prohibited condition is any condition in a permit space that is not allowed by the          permit during the period when entry is authorized.

Rescue Service

            Personnel designated to rescue employees from permit spaces.

Retrieval System

            Equipment (including a retrieval line, chest or full-body harness, wristlets, if         appropriate, and a lifting device or anchor) that is used for non-entry rescue of           persons from permit space.

Testing

            Testing is the process by which the hazards that may confront entrants of a          permit space are identified and evaluated. Testing includes specifying the tests         that are to be performed in the permit space. 

SECTION 2  JOB CLASSIFICATIONS

This listing provides job classifications involved with potential permit required confined spaces.

Public Works                                               Bridge/Special Projects

(Has site specific plans)                           Box Beam Areas on Bridges (ventilation)

                                                                        Ditches and Trenches (evacuation need)

                                                                 Larger plugged culverts

                                                                        Solid Waste

                                                                        Reedsport Landfill (tanks and vault)

                                                                        Roseburg Landfill (tanks)

                                                                        Glide (vault)

Parks

(Has site specific plans)                           Septic Tanks and vaults (limited entry areas,                                                                                         toxic gases)

                                                                        Pits and sumps (sewage tanks, toxic gases)

                                                                        Ditches and trenches (evacuation need)            

Salmon Harbor                                           Tanks (limited entry areas)

Building Facilities                                      Crawl Spaces (ventilation, asbestos)

(Has site specific plans)                           Tunnels (ventilation, evacuation need)

                                                                        Man-holes  (ventilation, evacuation need)

                                                                        Vaults (limited entry areas)

Fairgrounds                                                 Vaults (limited entry areas)

SECTION 3.  EMPLOYEE TRAINING

The County shall provide training so that all employees whose work is regulated by this section acquire the understanding, knowledge, and skills necessary for the safe performance of the duties assigned.  Trainers must understand all parts of 1910.146 and have experience with the types of permit spaces employees will enter.

Training shall be provided to each affected employee

• Before the employee is first assigned duties
• Before there is a change in assigned duties
• Whenever there is a change in permit space operations that presents a hazard    about which an employee has not previously been trained
• Whenever the employer has reason to believe that there are deviations from the permit space entry procedures required  
• Whenever there are inadequacies in the employee’s knowledge or use of correct             procedures.

Training shall establish employee proficiency in the duties required by this plan and shall introduce new or revised procedures for compliance with this plan.

Training shall cover the following elements:

• Critical activities that are part of the entry process involving permit-required           confined spaces.
• Identification of permit spaces at the County
• Identification of the hazards in those spaces
• Decisions as to whether or not an employee will enter a permit space
• Process of elimination or control of confined space hazards
• Establishment of entry procedures
• Employee entry operations
• Verification of employee knowledge of duties and responsibilities
• Emergency plans for removal of employees in dire situations
• Necessary PPE  (Reference County’s Personal Protective Equipment Policy)
• Employer responsibility
• Employee responsibility
• Care and maintenance of equipment
• Cautionary Signs
• Overview and distribution of County’s Confined Spaces/ Permit Required             Confined Spaces Policy
• Opportunity for interactive questions and answers

The County shall certify that the training required has been accomplished.  The certification shall contain each employee’s name, the signatures or initials of the trainers, and the dates of training.  The certification shall be available for inspection by employees and their authorized representatives.

SECTION 4   COMPLIANCE GUIDELINES

The County must be able to demonstrate that the only hazard posed by the permit space is an actual or potential hazardous atmosphere wherein continuous forced air ventilation alone is sufficient to maintain that permit space safe for entry; County develops supportive monitoring and inspection data; required determinations and supporting data are documented by the County and made available to each employee who enters the permit space under the terms of that employee’s authorized representative; and, that entry into the permit space is performed in accordance with the requirements of this plan.

The following requirements apply to entry into permit spaces: any conditions making it unsafe to remove an entrance cover shall be eliminated before the cover is removed; 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; before an employee enters the space, the internal atmosphere shall be tested, with a calibrated direct-reading instrument, for oxygen content, for flammable gases and vapors, and for potential toxic air contaminants, in that order; any employee who enters the space, or that employee’s authorized representative, shall be provided an opportunity to observe the pre-entry testing required by this paragraph; there may be no hazardous atmosphere within the space whenever any employee is inside the space; and continuous forced air ventilation shall be used.

The atmosphere within the space shall be periodically tested as necessary to ensure that the continuous forced air ventilation is preventing the accumulation of a hazardous atmosphere. If a hazardous atmosphere is detected during entry, each employee shall leave the space immediately; the space shall be evaluated to determine how the hazardous atmosphere developed; and measures shall be implemented to protect employees from the hazardous atmosphere before any subsequent entry takes place.  The County will verify that the space is safe for entry and that the pre-entry measures required have been taken through a written certification that contains the date, the location of the space, and the signature of the person providing the certification.  The certification shall be made before entry and shall be made available to each employee entering the space or to that employee’s authorized representative.  When there are changes in the use or configuration of a non-permit confined space that might increase the hazards to entrants, the employer shall re-evaluate that space and, if necessary, reclassify it as a permit-required confined space.

Contract workers only: Contractor must be informed regarding hazards in the confined space. County must ensure that the contractor has a written permit-space program that meets ORS 1910.146 requirements and that he is informed about any special precautions necessary to protect those working in or near the confined space.

Contract Workers and County Employees:  A written permit-space program must be established that describes how the County will eliminate or control the permit-space hazards and ensure the safety of those who enter the space.  County will coordinate entry operations with the contractor so that the contract workers and County employees work safely together.

County Employees only: County must have a written permit-space program that describes how to eliminate or control the permit-space hazards and ensure the safety of those who enter.

Prior to the supervisor authorizing employees to enter a permit space, it is essential that experienced emergency responders will be available if an entrant needs help.  Responders must be able to reach the site promptly and know how to deal with the emergency. It is crucial to know if responders are equipped to respond appropriately during an emergency; therefore, it is essential to accurately communicate to the responder any permit-space hazard that they may encounter during an emergency, ensure that the responder can reach the space promptly, and allow the responders to practice rescues at all on-site permit spaces.

SECTION 5.              GENERAL REQUIREMENTS

The County shall evaluate the workplace to determine if any spaces are permit-required confined spaces.  If the workplace contains permit spaces, the County shall inform exposed employees – by posting danger signs or by any other equally effective means – of the existence and location of and the danger posed by the permit spaces.  If the County decides that its employees will not enter permit spaces, the County shall take effective measures to prevent its employees from entering the permit spaces in compliance with ORS standards.

If the County decides that its employees will enter permit spaces, the County will develop and implement a written permit space program that complies with this plan, and be available for inspection by employees and their authorized representatives. 

In addition to the County’s responsibility to survey the workplace, conduct a hazard assessment, to identify potential hazards and to eliminate potential hazards in a permit-required confined space making it safe for employee entry, a written document that certifies that the work place has been evaluated, the date of the hazard assessment, and who performed the evaluation will be completed. 

The County will provide appropriate equipment to employees who work in confined spaces.  All employees who enter permit-required confined spaces will also be provided with necessary PPE to protect them from potential hazards.  PPE selection decision will be communicated to employees. 

It is the employee’s responsibility to properly wear and care for PPE which is appropriate to the work performed and conditions encountered.   It is additionally the responsibility of the employee to exercise caution in permit-required confined spaces where potential hazards may be present.  Employee is to be aware of non-atmospheric hazards which might include conditions such as mechanized equipment, loose materials, excessive noise levels, extreme temperatures, low visibility, and difficult, constrained area access, and to leave a space immediately during a hazardous condition or when the attendant orders an evacuation.

Employees are responsible for knowing safety measures, policy on confined spaces, recognizing potential dangers, understanding their training prior to entering confined spaces.  If there are concerns at a work place, employees are required to identify same with their supervisors, Safety Manager, or safety committee member.  (For additional information on PPE inspection and maintenance, please refer to Douglas County’s Policy on Personal Protective Equipment.)

It is the attendant’s responsibility to monitor the entrant’s activities from outside the confined space.

Attendants duties and responsibilities involve knowing the permit-space hazards, including the symptoms and consequences of exposure, knowing how many entrants are in the permit space, staying out of the space during entry operations, keeping in contact with entrants, ordering an evacuation for a hazardous condition, keeping unauthorized persons away from the space, and starting rescue procedures when and if necessary.

It is the entry supervisor’s responsibility to ensure that attendants and entrants follow entry-permit procedures for knowing the permit-space hazards, including the symptoms and consequences of exposure, verifying that the entry permit is accurate and current, stopping entry operations and canceling the entry permit when permit-space work is done or during a hazardous condition, ensuring that responders will be available in an emergency, removing any unauthorized person who enters the space, and ensuring that entry operations are consistent if another authorized employee must replace an attendant or an entrant.

Prior to employees entering a permit space, safe work procedures covering all phases of the entry process must be followed.  An entry permit that verifies the permit space is safe for employees to enter must be completed.  Entry occurs when any part of a worker’s body moves through the opening of this space.

Pre-entry Operations prior to Employees Entering a Permit Space

After Employees leave the Space:  Completing Entry Operations

The entry permit documents acceptable entry conditions and verifies that the space is safe for employees to enter. Required permit information:

• Location of the permit space.
• Purpose of entry.
• Entry date and the time employees will enter.
• Authorized entrants’ names.
• Authorized attendants’ names.
• Entry supervisor’s name and signature.
• Hazards in the space.
• How hazards will be controlled so that the space is safe to enter.
• Acceptable entry conditions.
• Testing data and tester’s initials that certify the space is safe to enter.
• Names of emergency responders and instructions for contacting them.
• Communication procedures used by entrants and attendants.
• A list of all equipment necessary to ensure entrants’ safety.
• A description of any other permits that entrants need to work in the space.

Responders must have the equipment necessary to perform rescues and know how to use rescue equipment, be trained as rescuers and as authorized entrants, practice simulated rescues at least once a year at each on-site permit space, and keep First Aid and CPR training up to date.

Considerations in Determining an Emergency Responder

Determine if responder       Responder must be able to determine if atmosphere is IDLH

knows how to test the         in a permit space.

Determine if responder       Responder must be able to comprehend ventilation and

can recognize and               atmospheric testing data on entry permit.

SECTION 6:             FORMS

See Form #1.This permit requires that the entry be evaluated for safety and health hazards and             necessary controls.

            Instructions for completing form are as follows:

            1.         Identify permit space or location of work.

            2.         Purpose or nature of job

            3.         Date and approximated time of entry permit. (The individual authorizing                                          the entry shall sign the permit prior to entry.)

            4.         Entrants must all be listed and given instructions prior to or during entry.

            5.         Attendants must be listed.

            6.         Entry Supervisors must be listed and time of on-duty status listed.

                                    Initial authorizing entry supervisor must also be listed.

            7.         All hazardous work in permit space must be listed

            8.         Check/list measures used to isolate permit space and eliminate/control                                          permit space hazards prior to entry.

            9.         List acceptable entry conditions

            10.       Hazards testing

            11.       Rescue and Emergency Services listed by name and phone number in the                                  event of urgent evacuation need.

            12.       Indicate any / all communication procedures / equipment used by                                                   authorized workers and attendants to maintain contact

            13.       Note all equipment that has been supplied to the employee.

            14.       Note any additional procedures that have been made to ensure employee                                                safety.

            15.       List additional permits that have been required for this work area (i.e. hot                                       work permit,   etc.)

            16.       Confined space permit cancellation must be signed by entry permit                                                             supervisor.  Date and time included.

See Form #2.  This permit is in addition to the hazardous work permit when workers will be welding or using some type of an open flame / hot work in a confined space. The permit is to ensure that proper planning and precautions have been taken because hot work in a confined space is inherently dangerous.

Instructions for completing form are as follows:

            The first section is self explanatory asking for department issuing permit, location            of job site, reason for the job, name of on-site supervisor, any special fire          hazards that may  present and type of hazardous work needing to be performed

            1.         Special measures taken to ensure tank or basin has been properly purged                       by specifying methods of flushing and ventilating.

            2.         Measures for isolation of other hazards that may be effected by hot work                           (i.e. electrical lock-out, gas / hazardous-chemical line blanking)

            3.         Measures for respirator / PPE due to welding fumes.

            4.         Indicate measures by which a permit space is removed from service and                            protected against release of energy into space.

            5.         List PPE that have been provided to the worker for safety purposes.

                        Enter date and time of authorized duration, signatures of employee and                            entry supervisors are required.

See Form #3.          

See Form #4.  The Contractor Confined Space Notification Checklist will be completed by the Department’s Project Manager and / or Supervisor. This notification is to ensure that Douglas County complies with Rule 1910.146(c)(8) of the Confined Space regulations.  If the Department contracts for confined space entry work as the host employer, the Department is responsible to:

• Inform the contractor that a permit required space is involved in the work.  This includes information about any chemicals in the space per hazard communication requirements.

• Apprise the contractor of the hazards the department has identified and any experience the department’s employees have had with the space.

• Apprise the contractor of any precautions the department employees have taken for entry.

• Coordinate entry operations with the contractor if more than one contractor or the department’s employees will also be entering the space.

• Debrief the contractor to determine if any problems were encountered requiring changes in procedures.

See Form #5.