Confined Spaces

Preface

Bodine has developed a written policy for safe entry into confined spaces. The Company recognizes that certain environmental conditions within confined spaces are capable of causing death to anyone who enters the space without taking precautionary measures. Therefore, each entry into a confined space must be evaluated by the supervisor to determine the hazards involved and appropriate safety measures and controls that must be taken to ensure a safe environment.

Safe entry into a confined space is the responsibility of both the supervisor and the employee who performs the work. Supervisors must ensure that this procedure is followed and that all personnel understand and comply with the safety requirements. The employee must inform the supervisor of any departure from this procedure.

Definitions Of A Confined Space

A confined space is a space that is large enough and so configured that an employee can bodily enter and perform assigned work. It has limited or restricted means for entry or exit, and is not designed for continuous employee occupancy. Additionally, the space may contain a potentially hazardous atmosphere, it may have limited oxygen content, and it may contain mechanical and / or electrical equipment, which upon contact or activation may trap, crush, or electrocute persons in the space.

Some examples of confined spaces include but are not limited to: sewers, septic tanks, sewage digesters, pump stations, wells, manure pits and tanks, silos, vats, ducts, utility vaults, process vessels, boilers, pipelines, pits, ventilation and exhaust units, storage bins, hoppers, and caves.

The Company must evaluate each confined space to determine if that space is to be designated as a Permit-Required Confined Space or a Non-permit Confined Space. Host employers may have already identified spaces as permit required or non-permit space. Always confer with host employers prior to entry.

A permit system is the written procedures for preparing and issuing permits for entry and for returning the permit space to service following termination of entry.

A non-permit confined space 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.

A permit-required confined space is any 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 asphyxia by inwardly converging walls or by a floor, which slopes downward, and tapers to a smaller cross section.

Contains any other recognized serious safety or health hazard.

Requirements

Bodine shall evaluate the workplace to determine if any spaces are permit-required confined spaces.

If the workplace contains permit spaces, the employer shall inform exposed requirements, and that a written certification that contains the date, the location of the space, and the signature of the person providing the certification has been completed.

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 and if necessary reclassify it as a permit-required space.

A space classified by the employer as a permit required confined space may be reclassified as a non-permit confined space under the following conditions:

• 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 and the permit space may be reclassified as a non-permit confined space for as long as the non atmospheric hazard remain eliminated.
• If it is necessary to enter the permit space to eliminate hazards, such entry shall be performed following the entry rules for permit-required area. If testing and inspection during this time demonstrate that the hazards within the permit space have been eliminated, the permit space may be reclassified as a non-permit confined space for as long as the hazards remain eliminated.

The employer shall document the basis for determining that all hazards have been eliminated. If hazards arise within the permit space that changes the classification, the space must be reclassified.

When an employer arranges for another contractor to perform work that involves permit space entry, the host employer shall:

• Inform the contractor that the workplace contains permit spaces that entry is allowed only as a permit-required space.
• Apprise the contractor of the elements of the confined space.
• Co-ordinate entry operations with the contractor when both the owner and the contractor work in the same space.
• Debrief the contractor at the conclusion of the operations regarding any hazards created by the activities of the other.
• Inform the host employer of the permit space program the contractor will follow.

Permit Required Confined Space Program

The following procedures will be followed for permit required confined spaces:

• Implement the measures necessary to prevent the unauthorized entry.
• Identify and evaluate the hazards of permit spaces before employees enter them.
• Develop and implement means, procedures, and practices necessary for safe permit space entry operations, including, but not limited to the following: Specifying acceptable entry conditions;
  • Isolation of the permit space;
  • Purging, inverting, flushing, or ventilating the permit space as necessary to eliminate or control atmospheric hazards:
  • Providing pedestrian, vehicle, or other barriers as necessary to protect entrants from external hazards; and
  • Verifying that conditions in the permit space are acceptable for entry into through out the duration of an entry.

These procedures will be followed for each space and may vary according to the environmental conditions of the space.

Provide to the employee the following equipment and ensure that the employee use that equipment properly:

• Testing and monitoring equipment needed to test and monitor the atmosphere while working in the confined space.
• Ventilating equipment needed to obtain acceptable entry conditions.
• Communications equipment.
• Lighting equipment needed to enable employees to see well enough to work safely and to exit the space quickly in case of an emergency.
• Barrier and shields as needed to protect the opening.
• Equipment such as ladders, needed for safe ingress and egress.
• Rescue and emergency equipment needed to rescue the entrant from the confined space.
• Provide any other equipment necessary for safe entry into and rescue from the permit space.

Evaluate permit space conditions as follows when entry operations are conducted:

• Test conditions in the permit space to determine if acceptable entry conditions exist before entry.
• Test or monitor the permit space as necessary to determine if acceptable entry conditions are being maintained for the course of the entry operations.
• When testing for atmospheric hazards, test first for oxygen, then combustible gases and vapors, then for toxic gases and vapors.
• Provide at least one attendant outside the permit space into which entry is authorized for the duration of entry operations.
• If multiple spaces are to be monitored by a single attendant, include in the permit program the means and procedures to enable the attendant to respond to an emergency affecting one or more of the permit spaces being monitored without distraction from the attendants duties.
• Designate the persons who are to have an active role in entry operations. (for example authorized entrants, attendants, entry supervisors, or persons who test or monitor the atmosphere in a permit space).
• Coordinate with host employer, prior to entry, regarding procedures for summoning rescue and emergency services, for rescuing entrants from permit spaces, for providing necessary emergency services to rescued employees and for preventing unauthorized personnel from attempting a rescue.
• Review entry operations when the employer has reason to believe that the measures taken under the permit space program may not protect employees and revise the program to correct deficiencies found to exist before sub sequent entries are authorized.
• Review the permit-required confined space program using the canceled permits retained for one year and revise the program as required.

Permit System For A Confined Space Entry

• Before entry is authorized, Bodine shall document that the entry permit has been prepared and followed as outlined in the program.
• Before entry begins, the supervisor shall sign the entry permit.
• The complete permit shall be made available and posted at the time of entry.
• The duration of the permit may not exceed the time required to complete the task.
• The entry supervisor shall terminate and cancel the permit when the space and or when the activities have been completed.
• The permit shall be retained for one year.

The Entry Permit For A Confined Space

The entry permit that documents compliance with this section and authorizes entry to a permit space shall identify the following:

• The permit space to be entered.
• The purpose of the entry.
• The date and the authorized duration of the entry permit.
• The authorized entrants within the permit space by name or by other means as will enable the attendant to determine quickly and accurately for the duration of the permit which entrants are inside the permit space.
• The person serving as the attendant.
• The person by name currently serving as supervisor with a space for the signature or initials of the entry supervisor who authorized entry.
• The hazards of the permit space to be entered.
• The measures used to isolate the permit space and to eliminate or control permit space hazards before entry. (Lockout/tagoutisolate hazardous energy).
• The acceptable entry conditions.
• The results of initial and periodic tests performed for atmosphere monitoring and accompanied by the name of the testers and an indication of when the test were performed.
• The rescue and emergency services that can be summoned and the means (such as the equipment to use and the numbers to call) for summoning aid.

Training Requirements

Prior to beginning confined space entry procedures, the following training will be provided for all affected employees and documented.

Authorized Entrants Shall:

• Become knowledgeable of the hazards that may be present during entry, including information on the mode, signs or symptoms, and consequences of the exposure.
• Become knowledgeable in the proper selection and use of personal protective equipment required for entry.
• Learn to communicate with the attendant whenever:
  • The entrant recognizes any warning sign or symptom of exposure to a dangerous situation.
  • The entrant detects a prohibited condition.
  • Need to monitor the entrants status.
• Become knowledgeable in procedures for exiting a confined space including:
  • Understanding an order to evacuate when given by the attendant or the entry supervisor.
  • Understanding when an evacuation alarm is sounded.
  • Recognizing any warning sign or symptom of exposure to a dangerous situation.
  • Detecting a prohibited condition.

Attendants Shall:

• Become knowledgeable of the hazards that may be present during entry, including information on the mode, signs or symptoms, and consequences of the exposure.
• Become aware of the possible behavioral effects of hazard exposure an authorized entrant may exhibit.
• Learn to maintain a continual accurate count of authorized entrants in the permit space and be able to accurately identify who is in the permit space at all times.
• Understand the importance of maintaining a constant vigil outside the permit space during entry operations until relieved by another attendant.
• Learn techniques for communicating with entrants as necessary to monitor entrant status and to alert entrants of the need to evacuate the space.
• Learn to monitor activities inside and outside the space to determine if it is safe for entrants to remain in the space.
• Learn under what circumstances the entrant is to be ordered to evacuate the space. Such circumstances may include:
  • If the attendant detects a prohibited condition.
  • If the attendant detects the behavioral effects of hazard exposure in the authorized entrant.
  • If the attendant detects a situation outside the space that could endanger the authorized entrants.
  • If the attendant cannot effectively and safely perform his duties.
  • Learn when to summon rescue and other emergency services.
  • Learn what actions to take in the event unauthorized persons approach or enter the permit space while entry is underway.

These actions may include the following:

• Warn unauthorized persons to stay away from the permit space.
• Advise unauthorized persons that they must immediately exit the permit space if they have gained entry into the space.
• Inform authorized entrants and the entry supervisor of any unauthorized entrants.
• Learn to perform non-entry rescue procedures.
• Understand that the primary duty is to monitor and protect the authorized entrants and, as such, never to perform duties that will interfere with this objective.

Entry Supervisors Shall:

• Become knowledgeable in the proper selection and use of personal protective equipment and rescue equipment required for making rescues from permit spaces, and will be required to perform practice rescue drills a minimum of once annually.
• Become knowledgeable of the hazards that may be present during entry, including information on the mode, signs or symptoms, and consequences of the exposure.
• Gain thorough knowledge of the information required on the entry permit, and understand his/her role in verifying that tests, if applicable, have been conducted and that equipment is in place prior to endorsing the permit and allowing entry to begin.
• Understand procedures for terminating entry and canceling the permit.
• Understand procedures for verifying rescue services are available and means for summoning them are operable.
• Understand procedures for removing unauthorized individuals from the area.
• Become knowledgeable and take responsibility for determining that entry operations remain, at all times, consistent with the terms of the entry permit and that acceptable entry conditions are maintained.

Rescue & Emergency Services Personnel Shall:

• Become knowledgeable in the proper selection and use of personal protective equipment and rescue equipment required for making rescues from permit spaces.
• Become knowledgeable under the requirements outlined for authorized entrants above.
• Become knowledgeable in performing confined space rescue procedures.
• Become trained in basic first-aid and CPR, and have a minimum of one member of the rescue service holding current certification in first aid and CPR be made available for rescue services.
• If outside services are called in, the employer will arrange to inform rescue service personnel of the hazards they may confront in performing rescue operations.
• Have access to all permit spaces from which rescue may be necessary for developing rescue plans and performing drills.
• Become knowledgeable in retrieval systems or methods that may be employed for non-entry rescue, and understand when using such equipment may increase overall risk and hinder rescue operations.

Annual Review

The Corporate Safety Manager or designee shall conduct an annual review of the program. Canceled permits kept on file shall be utilized to assess the effectiveness of the program. Upon completion of the annual review, the company Confined Space Program shall be updated as necessary.