| Related Documents |
| Confined Space Permit and Evaluation Contractor Confined Space Notification General Campus CS List |
16.1 Introduction #
This program and the procedures outlined are intended to assure the safety of employees whose job activities may require them to recognize, evaluate, and enter confined spaces. Note: For enclosed space entry procedures, refer to Primary Systems enclosed space section of this program. Only staff that have received Confined Space Entry Training conducted by Environment, Health & Safety (EHS) may enter permit-required confined spaces, or serve as an attendant, entry supervisor or conduct air monitoring.
Reference Regulations: Permit Required Confined Space (MiOSHA General Industry Part 90)
16.2 Training #
All exposed employees are trained on the recognition of confined spaces. All employees whose work requires them to enter or evaluate a Permit Required Confined Space shall be provided with training in order to acquire the knowledge and skills necessary for the recognition and evaluation of confined spaces and to safely perform assigned duties.
Training/retraining shall be provided to each affected employee:
- Before the employee is first assigned duties of being an entry Supervisor, Attendant, Entrant or Rescue Personnel.
- 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.
- If the Supervisor has reason to believe either that there are deviations from the permit space entry procedures or that there are inadequacies in the employee’s knowledge or use of these procedures.
The training shall cover at least the following topics:
- MIOSHA standard
- Permitting
- Definitions
- Hazards of confined spaces
- Employee duties – attendant, entrant, entry supervisor
- Controlling hazards
- Atmospheric testing
- PPE
- Types of confined spaces
- Rescue and emergency services
- Retrieval systems
Each employee shall be tested to verify their understanding of the training provide
16.3 Confined Space Evaluation and Classification #
Identification of confined space
Other than a few exceptions listed in the table in the General Listing of Campus Confined Spaces document, the University’s utility tunnel system is not considered a confined space and does not fall under this program. Safe practices for working in the utility tunnel system are outlined in the Facilities & Operations Tunnel Safety Program. Confined spaces can be identified utilizing:
- General Listing of Campus Confined Spaces document for the list of confined spaces on campus and at the Hospital.
- Signage, where feasible
Evaluation of Confined Space Hazards #
Following the identification of a confined space, all potential, actual, or work induced hazards in the space must be identified. Any hazards identified must be evaluated to determine entry requirements. The Confined Space Evaluation Form shall be used to document identified hazards. Refer to section below IMPLEMENTATION OF CONTROL MEASURES for potential confined space hazards controls.
Non-Permit Required Confined Space Entry #
Confined space evaluations that do not identify any actual, potential, or work induced hazards are classified as non-permit required confined space (NPRCS). The supervisor is required to ensure that a NPRCS will not be converted into a PRCS due to the creation or existence of work induced hazards such as hot work, painting, coating, spraying, etc. A minimum of two workers are required while working in a NPRCS.
Permit-Required Confined Space Entry #
Confined space evaluations that identify actual, potential, or work induced hazards are considered permit required confined spaces (PRCS). Efforts should be made to eliminate, isolate, or control hazards prior to entry following recommended controls in implementation of control measures section. Before entry is authorized for a PRCS, the entry supervisor shall verify:
- Acceptable entry conditions .
- Each authorized entrant, or that employee’s authorized representative, has the opportunity to observe any atmospheric monitoring or testing of permit-required confined spaces.
- Hazardous energy sources are controlled (e.g., locked out) and all exposed employees are included in Lockout/Tagout.
- Purging, inerting, flushing, or ventilating are used as necessary to eliminate or control atmospheric hazards.
- Access is restricted to only authorized employees on the permit.
- Pedestrian, vehicle, or other barriers are provided as necessary to protect entrants from external hazards.
- Personnel rescue inside the confined space is provided. Refer to the evacuation and rescue plan section for procedures on evacuation and rescue planning.
Alternate Entry #
An alternate entry procedure may be used if the only hazard posed is an actual or potential hazardous atmosphere and portable/temporary continuous forced air ventilation alone is sufficient to maintain safe entry after monitoring is completed. Onsite rescue team or set-up of rescue equipment is not required. Entrants shall wear a retrieval harness and rescue equipment should be available and on site. The confined space entry permit must still be completed.
Monitor atmospheric conditions prior to entry and continuously during entry to assure safe conditions. Periodically record monitoring results on permit. See the MONITORING OF HAZARDOUS ATMOSPHERES section below for additional requirements for monitoring hazardous atmospheres.
Reclassification #
If the permit space poses no actual or potential atmospheric hazards and if all hazards within the space are eliminated without entry into the space, the permit space may be temporarily reclassified as a NPRCS for as long as the hazards remain eliminated. Control of potential atmospheric hazards through forced air ventilation does not constitute elimination of the hazards and will not be considered for reclassification.
If it is necessary to initially enter the permit space to eliminate hazards, the PRCS entry process shall be followed. If testing and inspection during that initial entry demonstrates that the hazards within the permit space have been eliminated, the permit space may be reclassified as a NPRCS for as long as the hazards remain eliminated and no work induced hazards are created.
16.4 Monitoring of Hazardous Atmospheres #
When it has been determined that a known or potential hazardous atmosphere may be present, test (monitor) the air in the space to determine if acceptable conditions exist before entry is made, using the following procedure:
- Only employees who have received EHS confined space training can perform air monitoring.
- Ensure that the monitoring equipment has been calibrated according to the manufacturer’s instructions and your department’s procedures.
Monitor remotely for:
- Oxygen (O2)
- Combustible vapors and gases (lower & upper explosive/flammable limits)
- Hydrogen sulfide (H2S)
- Carbon monoxide (CO)
- Other toxic gases and vapors .
- Test first for oxygen, then for combustible gases and vapors, and then for toxic gases and vapors, in that order.
- Use a direct reading electronic monitoring to continuously monitor for all three of the constituents (oxygen, combustibles, toxics) listed above
- When monitoring for entries involving a descent into atmospheres that may be stratified, the atmosphere should be tested approximately every 4 feet vertically. If a sampling probe is used, the entrant’s rate of progress should be slowed to accommodate the sampling speed and detector response.
The minimum acceptable air quality prior to confined space entry is:
- Oxygen level: between 19.5% and 23.5%, by volume
- Combustible vapor or gas: concentration less than 10% of the lower explosive limit (LEL)
- Carbon Monoxide (CO): Below 35 PPM
- Hydrogen Sulfide (H2S): Below 10 PPM
- Other toxic contaminants: concentrations shall not exceed the MIOSHA regulatory limit, or other recommended exposure limit, to ensure the safety and health of the authorized entrants.
Electronic monitoring equipment should be fitted with audible and visual alarms that will activate when any one of these three criteria is exceeded.
If it is determined that unacceptable air quality exists, do not enter the space. Implement appropriate control measures as outlined in this program and re-test to assure acceptable entry conditions are obtained.
Record initial readings obtained on the Permit and any changes in the readings as the preparation or work proceeds. Air monitoring must be continuous while authorized entrants are working in the space to assure that acceptable conditions are being maintained. The attendant will document results every 30 minutes on the confined space permit.
16.5 Implementation of Control Measures #
Hazardous Atmospheres (or potentially hazardous atmospheres): #
After the confined space has been determined to contain or potentially contain a hazardous atmosphere, steps must be taken to ventilate the space and eliminate the hazard before entry. Control methods include:
| Ventilation Options | Description | Notes |
|---|---|---|
| Mechanical dilution ventilation | Use of fans or blowers to provide positive pressure, uncontaminated air to the space. Assure that the fan is located away from any source of contamination, and use explosion-proof fans if there is a potential combustible atmosphere. | Ventilation in either application must be continuous during the entire entry procedure. Continuous air monitoring will help ensure that the ventilation remains adequate and atmospheric hazards do not develop. |
| Local exhaust ventilation | Designed to capture contaminants at or near their point of generation using hoods or enclosures with ductwork connected to an exhaust fan. The contaminated air is discharged outside the confined space to a safe area. This method is especially effective for welding, cutting, burning, brazing and other operations where the work induces the atmospheric hazard. | |
| Cleaning or purging | If there are residues of hazardous chemicals or materials present which are capable of generating a hazardous atmosphere, or may cause sufficient eye or skin irritation, or sufficient to impair self-rescue, they must be removed, and the space purged with an appropriate agent, to the extent feasible. Continuous monitoring must still be conducted after this process, and continuous ventilation may also be needed. |
Other Hazards #
To achieve acceptable entry conditions, any identified hazards must be eliminated, isolated or controlled. Indicate on the Permit all control measures implemented.
| Hazard | Methods to Eliminate, Isolate or Control Hazards |
|---|---|
| Mechanical, moving parts | Deenergize and lockout/tagout all equipment following department specific program in accordance with the University Lockout/Tagout Program, or otherwise physically isolate the equipment through guarding, partitions or barriers. |
| Electrical equipment | Deenergize and lockout/tagout all electrical equipment following department specific program in accordance with the University Lockout/Tagout Program or physically isolate the equipment by use of barriers or partitions of non-conductive material. |
| Electrical equipment used in damp or wet space | Use ground fault circuit interrupters (GFCI). |
| Chemical or gas lines | Isolate by one or more of the following methods: Blanking and blinding Double-block and bleed Line breaking or misalignment Lockout/tagout |
| Heat stress | Use mechanical dilution ventilation as described above, as well as other appropriate safe work practices as per the Heat Stress Program. |
| Hot work operations | Control the potential for fire by using a Hot Work Safety Permit in addition to the confined space permit and follow the U-M Comprehensive Safety Plan. |
| Lighting | Install appropriate temporary lighting. If there is a potential flammable/explosive atmosphere, use explosion-proof or intrinsically safe equipment approved for the location. If water or damp conditions are, or will be, present, use a ground fault circuit interrupter (GFCI). All temporary lighting must be grounded. |
| Engulfment | Remove the liquid or bulk material from the space, and the space must be isolated by double blanking and bleeding or line breaking/misalignment to keep out any potential hazardous substances, whether solid, liquid or gas. Isolation cannot be accomplished simply by closing or locking out a valve or switch. |
| Entrapment or configuration | Extra care must be taken in properly air monitoring and ventilating all areas of the space, especially where the space configuration becomes smaller and gas pockets may develop. Retrieval or lifelines may be necessary so that employees can be easily located and remotely rescued. |
| Ladders/falling/tripping hazards | Maintain clear access to and from the space; use good housekeeping practices; check ladders for slippery rungs, cracks or defects before using; tie off ladders; use a full body harness fall protection device if there is a danger of falling; use other appropriate personal protective equipment, e.g., hard hat, safety shoes, etc. |
| Noise | Noise levels may be higher than normally expected, due to sound reverberation within the space, and may interfere with communication. In this situation, supplement voice/radio communication with visual hand signals or lifelines. Hearing protection in the form of earplugs and/or ear muffs may also be required to protect the entrants’ hearing. |
16.6 Establish Communication #
Decide how entrants will communicate with each other and with attendants on the outside of the space. Communication may be voice, radio, hand signals or lifelines, etc., or a combination of, as long as it enables the employees to monitor each other and to alert entrants if needed to evacuate the space. Indicate on the Permit the method(s) of communication to be used.
If the planned communication method is disrupted, entrants will immediately evacuate the space until the problem is corrected.
16.7 Other Entry Precautions #
The entry supervisor is responsible for ensuring all other necessary precautions are taken to address site safety and health concerns, including:
- Removal of entrance covers: Any condition making it unsafe to remove an entrance cover (such as high temperature and pressure) must be eliminated before removing the cover. Conditions may be such that the cover can be loosened gradually to release the pressure. Ventilation may be needed during this process.
- Guarding entrance covers: When ground level entrance covers are removed, the opening will be guarded by a temporary barrier to prevent accidental falls and protect entrants from foreign objects dropping into the space.
- Ensure that all equipment is in good repair and functioning properly prior to entering the confined space.
16.8 Hot Work #
When hot work will be conducted in a confined space, the entry supervisor will ensure the hot work program requirements are followed including the completion of a hot work permit.
The following provisions will be followed in addition to the permit requirements stated in this program:
- Exhaust ventilation will be required in addition to continuous forced air ventilation. If the exhaust is not through an alternate access, necessary precautions will be taken so the exhaust is not affecting another work team that may be in the area.
NOTE: Pressurized sources of oxygen shall never be used for ventilating purposes, and compressed gas cylinders and welding machines must be secured and left outside the confined space.
- Consult with EHS on the use of respiratory protection if ventilation controls are insufficient.
16.9 Enclosed Space #
An enclosed space is a working space, such as a manhole, vault, tunnel, or shaft, that has a limited means of egress or entry, that is designed for periodic Utilities-Primary Systems employee entry under normal operating conditions, and that, under normal conditions, does not contain a hazardous atmosphere, but may contain a hazardous atmosphere under abnormal conditions.
Only trained and authorized employees and contract workers may enter enclosed spaces under an enclosed space permit. All others must utilize a PRCS permit in coordination with the Primary Systems group.
The following work practices are acceptable only during the routine operation and maintenance of electrical power generation, transmission, and distribution facilities.
- Before any entrance cover to an enclosed space is removed, the employer shall determine whether it is safe to do so by checking for the presence of any atmospheric pressure or temperature differences and by evaluating whether there might be a hazardous atmosphere in the space. Any conditions making it unsafe to remove the cover shall be eliminated before the cover is removed.
- When covers are removed from enclosed spaces, the opening shall be promptly guarded by a railing, temporary cover, or other barrier designed to prevent an accidental fall through the opening and to protect employees working in the space from objects entering the space.
- Employees may not enter any enclosed space while it contains a hazardous atmosphere. The hazardous atmosphere shall be controlled or eliminated prior to entering and the PRCS entry process will need to be performed.
- Where the PRCS process is not required, utilize an Enclosed Space Permit.
- While work is being performed in the enclosed space, an attendant with first-aid training shall be immediately available outside the enclosed space to provide assistance if a hazard exists because of traffic patterns in the area of the opening used for entry.
- The attendant is not precluded from performing other duties outside the enclosed space if these duties do not distract the attendant from monitoring employees within the space or ensuring that it is safe for employees to enter and exit the space.
16.10 Evacuation and Rescue Plan #
Evacuation #
Under the following circumstances, all entrants must leave the confined space immediately:
- If a hazardous atmosphere is detected, i.e., if the audible/visual alarm on the air monitor activates, or there is any other indication of a problem.
- Entrant(s) are experiencing signs and symptoms of possible exposure to a hazardous atmosphere or feel that they may become incapacitated in anyway.
- Conditions in the space change that would require re-evaluation of the potential hazards (i.e., the conditions listed on the Permit are no longer accurate).
- Whenever an attendant is unable to perform the duties of attendant.
- Whenever the entrants are notified to evacuate by the attendant or entry supervisor or by evacuation alarm.
- Whenever communication between the entrant(s) the attendant is disrupted.
Rescue #
Rescue measures may be necessary if the authorized entrant in the confined space becomes incapacitated and is unable to exit the space without assistance. Under these circumstances the authorized entrants or the attendant at the site should follow these procedures:
- Off-Site Rescue — At the first indication of a problem, contact the DPSS by calling 911 (from a campus phone) or radio channel 1A and request assistance.
- Non-Entry Rescue — If vertical space greater than 5 feet then non-entry rescue retrieval system must be utilized if feasible. If the problem is due to an atmospheric hazard and the entrants are wearing a retrieval harness, the attendant should attempt to activate the retrieval system to remove the entrant from the space. If the lifting device fails to lift the entrant out of the space, the attendant should wait outside the space for off-site rescue to arrive.
Under no circumstances should the attendant enter the confined space.
- If it can be ascertained that the entrant is incapacitated due to causes not related to the atmosphere in the space (such as a fall or other injury), they should not be moved until the appropriate off-site rescue personnel arrive and direct the removal. If other entrants are in the space, first aid, if appropriate, should be rendered.
- On-Site Rescue – May be required for entries where all hazards cannot be controlled or eliminated.
16.11 Procedures for Outside Contractors #
Notification #
When outside contractors will perform work that involves permit-required confined space entry, the University is required to inform the contractor of the following:
- The location of any permit-required confined spaces.
- The hazards identified and why the University classifies it as a permit-required space.
- Precautions or procedures that the University has in place to protect nearby personnel.
The notification requirements can be accomplished by using the University of Michigan Contractor Confined Space Entry Notification Form, located in the “Documents” header for this program.
Coordination with U-M Authorized Entrants #
If University personnel will be working in or near the permit spaces(s) where the contractor will be working, then the University and the contractor will coordinate entry operations. Issues to be addressed during these discussions include:
- Review permits to ensure each other’s programs do not conflict.
- Scheduling of entry into the space.
- Procedures that will be used to evaluate the hazards and implement controls.
- Establishment of lines of communication between the contractor and University personnel working in the area.
- Review of evacuation and rescue plans
- The shared use of equipment.
Contractor Confined Space Program #
The contractor will provide the University representative a copy of the confined space permit program that will be used. If the contractor encounters or creates any hazards during the entry operation, this information will be communicated to the University representative. The program must meet or exceed all requirements of this confined space program. Contractors shall provide their own monitoring, rescue, and PPE equipment for confined space entry.
Debriefing #
At the conclusion of the entry operation, the University representative and the contractor will hold a debriefing where they will share information about any problems encountered during the work. The University representative may request EHS representation at this meeting. Closed permits should be sent to the UM Representative and forwarded to EHS.
16.12 Confined Space Evaluation Form and Confined Space Entry Permit #
See the “Documents” header of this program for the Confined Space Evaluation and Confined Space Entry Permit form.
