TITLE:	ES&H Manual
DOCUMENT ID:	6160 Confined Space Entry

1.0 Introduction

Hazardous confined spaces have a long record of KILLING people – not only workers who were unaware of the hazards involved, but also would-be rescuers whose good intentions cost them their lives. Confined spaces are among the most unforgiving of workplace hazards. Compared to other workplace hazards, confined space mishaps are unusually deadly. If there is an incident, odds are someone dies.

· About 60% involve would-be rescuers.

· Multiple deaths are common.

· Oxygen deficiency is the usual culprit.

· One-third of all deaths are supervisors

· Only 25% of spaces were toxic before entry; the rest became deadly while work was in progress.

In most cases the basic problem is that the hazards are recognized too late, and there are delays in summoning effective rescue.

Jefferson Lab identifies all known hazardous and potentially hazardous confined spaces on site, and they may be entered only under well-controlled conditions. These areas are designated Permit-Required Confined Spaces (PRCSs). No one on site may enter a PRCS unless he or she has been appropriately trained and authorized for the task, has the necessary equipment for safe entry, and the PRCS hazards have been assessed and mitigated prior to entry.

This chapter provides the information necessary to recognize a PRCS, and it establishes the responsibilities of staff involved with entry into hazardous confined spaces.

For many confined space entries at Jefferson Lab, the Ventilated Entry Procedure found in ES&H Manual Chapter 6160 Appendix T2 Ventilated (or Alternate) Entry Procedure is adequate and appropriate. In a few circumstances, however, the more involved procedures – found in ES&H Manual 6160 Appendix T4 General Procedure for Entry into Permit-Required Confined Spaces – must be used.

2.0 Hazard Avoidance

You can avoid confined space hazards by:

• observing all warning signs
• remaining outside all PRCS

You can minimize risks associated with an entry into a confined space by following the procedures established by the approved confined space entry permit.

A sign reading: DANGER – PERMIT REQUIRED CONFINED SPACE, DO NOT ENTER or similar language will be posted at the entrances to all PRCSs.

You may also encounter areas that are normally not PRCSs, but work activities within or nearby the space, or changes to equipment configuration could transform them into a PRCS. These areas may be posted with an informational notice such as this one:

CAUTION

Non-Permit-Required Confined Space

This area has limited egress and is not intended for normal occupancy. Avoid introducing hazards such as:

• oxygen deficiency
• flammable or toxic gases or vapors
• engulfment or entrapment hazards

Any of these will change this area to a permit-required entry confined space, and special precautions and entrant training are required.

For more information see ESH&Q Manual Chapter 6160 Confined Space Entry or contact ____________________

3.0 Responsibilities

3.1 Everyone at Jefferson Lab

· Observe all warning signs for confined spaces, and stay out unless you have the training and equipment to enter safely.

3.2 Line managers

· Ensure that all PRCSs in your areas of responsibility are identified and marked.

· Whenever possible, avoid creating potentially hazardous confined spaces when designing new facilities or reconfiguring existing facilities.

3.3 Supervisors/ Subcontracting Officer’s Technical Representative (SOTR)/ Sponsors

· Before assigning tasks that may entail PRCS entry, ensure that all authorized entrants, attendants, and entry supervisors are aware of present and potential hazards and are familiar with procedures to be followed. Training must be provided before these individuals assume their responsibilities.

· Determine the need for entering a PRCS and assign an entry supervisor.

· Provide specialized equipment for entry and rescue.

· Provide PRCS briefings to subcontractors, as appropriate.

· Notify Facilities Management of changes needed to “Confined Space Locations” drawing.

· Inform employees exposed to a PRCS in the workplace by posting danger signs at the space entrance or by any other equally effective means.

3.4 Environmental Safety, Health, and Quality (ESH&Q) Staff

· Assist in the identification and characterization of confined space hazards when entry is required by Lab and subcontractor personnel.

· Assist managers and supervisors in devising procedures and control measures for safe PRCS entries.

· Ensure appropriate instruments are available to monitor the atmosphere for PRCS entries. Coordinate this with Safety Lab staff.

· Assist line management in identifying PRCSs. Site drawings noting PRCSs are available from Facilities Management. The current list of PRCSs is available at: ES&H Manual Chapter 6160 Appendix T1 List of Permit Required Confined Spaces.

· Maintain a file of completed entry permits to aid in ongoing self-assessment and annual review of the PRCS entry process.

· When so assigned, assist in post-entry rescue investigations.

3.5 Facilities Management Director

· Ensure that the “Confined Space Locations” drawing is kept up-to-date based on input from line managers. Each time the drawing is updated, provide copies to all Division Safety Officers and safety wardens in the affected areas.

· If the scope of work includes confined space entry, specify confined space entry training and a written program as a condition for subcontractors working on site. Use ESH&Q staff as a resource in evaluating company training and programs.

3.6 Entry supervisors

· Assess the hazards for each confined space entry, and specify suitable control measures. Enlist the assistance of ESH&Q staff or other subject matter experts for any hazard unfamiliar to you.

· Discuss all aspects of the entry with entrants and attendants, and solicit their input in designing mitigation measures. Ensure entrants have the opportunity to witness atmospheric testing.

· Verify that rescue services are available and the means for contacting them are operating reliably.

· Prepare, coordinate, verify and approve the permit, and authorize entry.

· Terminate an entry and cancel the permit as required.

· Ensure that entry operations remain consistent with the terms of the permit, and that acceptable entry conditions and work operations continue throughout the entry.

· If responsibility for a PRCS entry operation is transferred, ensure that all participants are completely familiar with the hazards, mitigation measures, and other information noted on the permit. Amend the permit as necessary to note personnel changes, mitigation measures, or intended work.

· Coordinate entry operations with others working in the vicinity or inside a PRCS under another permit.

· Prevent unauthorized individuals from entering the PRCS area during entry operations.

3.7 Attendants

· Remain outside. Do not enter the PRCS during entry operations until relieved by another attendant.

· Maintain an accurate count of authorized entrants in the permit space. In multi-staff entries, use the permit or an attached log sheet to document who is within at any given time.

· Communicate with authorized entrants as necessary to monitor entrant status and to alert entrants of the need to evacuate the space.

· Pay constant attention to activities inside and outside the space to determine if it is safe for entrants to remain in the space. Order the authorized entrants to evacuate the PRCS immediately if any of the following conditions occur:

1. You detect a condition prohibited or not addressed by the permit.

2. You detect the behavioral effects of hazard exposure to an entrant.

3. You detect a situation outside the space that could endanger the entrants.

4. You cannot effectively and safely perform all duties required.

· Call Newport News Emergency Services (911) for help as soon as you determine that authorized entrants may need assistance to escape from PRCS hazards.

· When unauthorized persons approach a permit space when entry is underway, warn them that they must stay out of the PRCS and not impede operations.

· Perform non-entry rescues as required.

· Perform no duties that might interfere with monitoring and protecting the entrants.

3.8 Authorized entrants

· Know the hazards of the space you will enter.

o Ask questions about hazards and their controls; insist on answers that you understand and agree with.

o If someone else performs atmospheric testing, observe it and discuss any concern you have about technique or instruments.

· Use your training and Jefferson Lab procedures to protect yourself.

· Be aware of any medical or physical condition that may be aggravated by conditions in a particular PRCS. Inform your line supervisor or consult with Occupational Medicine if you have questions or concerns.

· Maintain communication with the attendant and/or entry supervisor. Alert them to undetected/ uncontrolled hazards or changed conditions. Alert the attendant whenever:

o You recognize any warning sign or symptom of exposure to a dangerous situation.

o You detect a condition prohibited or not addressed by the permit.

· Evacuate immediately and as quickly as possible from the PRCS whenever:

o An order to evacuate is given by the attendant or the entry supervisor.

o You recognize any warning sign or symptom of exposure to a dangerous situation.

o An evacuation alarm is activated.

o You recognize a condition prohibited or not addressed by the permit.

4.0 Program Summary

Jefferson Lab line management, with the assistance of ESH&Q staff and subject matter experts, ensure that all PRCS are identified, characterized, and posted. See ES&H Manual Chapter 6160 Appendix T1 List of Permit-Required Confined Spaces.

Entry into a PRCS always requires careful planning and oversight. Conditions that may be minor hazards or mere annoyances in open areas can be lethal in a confined space.

4.1 Training

Jefferson Lab provides confined space entry training for Lab staff. This training focuses on confined spaces found here at Jefferson Lab, our procedures for entry, and emergency response actions should they be needed. It is mandatory for entrants, attendants, and entry supervisors.

Subcontractors that have documented training for their staff and a formal written confined space entry program may, in certain situations, be allowed to make entries here under their procedures and with general supervision of their SOTR. They shall use precautions at least as protective as Jefferson Lab’s.

4.2 Hazard Assessment

The entry supervisor shall evaluate a confined space for potential hazards, specify suitable mitigation measures on the permit, and ensure entrants are qualified and prepared for the work.

Actual or potential confined space hazards can be grouped into three general categories:

4.2.1 Hazardous atmospheres have one or more of the following characteristics:

· Oxygen deficiency (concentrations <19.5% by vol.)

· Oxygen enrichment (concentrations >23.5%)

· Flammable gases or vapors (concentrations >10% Lower Flammable Limit or LFL)

· Toxic substances (concentrations > OSHA Permissible Exposure Limit – PEL – or other published safe level)

· Any condition Immediately Dangerous to Life or Health (IDLH)

· Airborne combustible dust (concentration > 10% LFL)

4.2.2 Physical hazards associated with the space itself, apparatus within it, or that are a potential consequence of the work to be performed. Examples:

· Engulfment by liquid or loose material

· Entrapment

· Electrical shock

· Hazardous chemicals

· High pressure gases, fluids, steam

· High noise levels

· Structural failure, collapse

· Falling objects

· Moving machinery

4.2.3 Other environmental conditions:

· Temperature extremes, high humidity

· Polluted water

· Decaying organic matter and associated microorganisms

· Slippery surfaces and cramped working space

4.3 Entry Permits

Entry into PRCSs is made in strict conformance to the precautions specified on the permit.

· The objective of the entry permit is to stimulate evaluation of potential hazards, and document their assessment and the controls used to mitigate them.

· It also assigns responsibilities for personnel involved.

· It becomes a record of the activity used to aid the planning of future entries in the same or similar spaces (kept by the Division Safety Officers).

4.4 Key Requirements for PRCS Entry:

ES&H Manual Chapter 6160 Appendix T4 General Procedure for Entry into Permit-Required Confined Spaces describes in detail the requirements for permit entry. They include:

1. training for entrants, qualified persons, and rescuers Jefferson Lab’s designated rescue service is the N.N. Fire Dept.

2. a written permit, posted at the entrance, specifies hazards, mitigation measures, and authorized entrants

3. hazard assessment by qualified person - usually the entry supervisor

4. hazard controls in place prior to entry

5. regular re-testing of air

6. attended entry in many situations

7. retrieval gear

4.5 Ventilated Entry Procedure

If the only actual or potential hazard is inadequate air quality, an alternative entry procedure may be used: ES&H Manual Chapter 6160 Appendix T2 Ventilated (or Alternate) Entry Procedure. Experience at Jefferson Lab over the years indicates that the majority of our routine confined space entries are candidates for Ventilated Entry procedures.

Key requirements:

· Ventilation must operate during the entire entry.

· Air must be tested prior to entry and regularly thereafter to ensure the ventilation is effective.

A full permit is not required, only a log of atmospheric-testing results.

Air quality can deteriorate – sometimes rapidly – due to work activities, by disturbing contamination sources within the space, even by entrants’ respiration. In addition, generous amounts of fresh air are welcome in spaces that are often humid, stuffy, and malodorous. For these reasons, it is Jefferson Lab policy that effective ventilation shall be used for all PRCS entries on site – even if air testing indicates acceptable conditions.

4.6 Testing for Air Quality

There are two atmospheric characteristics that must always be tested before confined space entry:

· Oxygen within acceptable upper and lower limits: 19.5 to 23%

· Presence of flammable gases or vapors above 10% of the lower flammable limit (LFL)

In addition, if there is a potential for toxic or irritant contaminants, these must be tested for also.

ES&H Manual Chapter 6160 Appendix T3 Atmospheric Testing of Confined Spaces contains procedures for testing the atmosphere before and during a PRCS entry. This appendix gives general guidance for the entry supervisor to establish the need for and types of atmospheric monitoring and, when appropriate, to request assistance from ESH&Q staff. The appendix also provides a procedure for the monitor who takes the readings and the method to record the results.

Specially designed, calibrated instruments are required, and proper techniques for testing are necessary to ensure valid measurement. A selection of instruments is maintained in the Safety Lab, Building 35. They are available for use by any qualified Lab staff member and by subcontractors so authorized by their SOTR.

4.7 Permit-Required Entry

When there are actual or potential hazards in addition to potentially unsafe air, the full permit entry procedure shall be used. Jefferson Lab’s permit is a product of our experiences with confined space entry on site, and it directs attention to issues especially relevant here. It serves as a checklist and memory-jogger for the entry supervisor, and it provides a place to record the precautions taken, air quality readings, and activities of the entrants.

The general procedure for entering a PRCS is provided in ES&H Manual Chapter 6160 Appendix T4 General Procedure for Entry into Permit-Required Confined Spaces.

4.8 PRCS Rescue Procedures

Non-entry rescue is the safest method, because the rescuer(s) stays outside the PRCS and operates a retrieval system connected to the entrants. For this reason, retrieval gear and a hoist system is usually specified for all PRCS entries unless the gear itself poses a hazard.

Entry rescue is used when a PRCS presents obstacles that make non-entry retrieval ineffective or dangerous to the entrant.

Entering a confined space and extracting an injured or incapacitated person safely requires special equipment and extensive training in technical rescue methods. Moreover, rescuers are at risk from the same hazards that may have claimed the first victim. Lastly, delaying rescue even a few minutes can mean loss of life.

For these reasons Jefferson Lab relies upon the City of Newport News Fire & Rescue Services as our designated responders. They are trained and equipped for any foreseeable confined space event at the Lab and have a quick response time.

4.9 High-Hazard PRCS

Not all PRCSs present the same degree of risk to entrants. Confined spaces that are subject to unpredictable or uncontrollable changes in conditions are especially hazardous.

At Jefferson Lab these are most likely to be sewers, sewage pump pits, wastewater manholes, and related areas. These systems are often interconnected and cannot be effectively isolated. This makes it possible for atmospheric conditions to change suddenly and unpredictably. Organic material decay generates toxic and flammable gases. In addition, interconnected underground systems are subject to flooding from rain and are subject to collecting flammable and toxic discharges from industrial and transportation accidents.

These possibilities make entry into a sewer or manhole different from other PRCS, special precautions are essential. It is rare that Jefferson Lab staff would need to enter such spaces. These areas are generally accessed only by specialized utility workers or subcontractors that have well-developed confined space procedures. Consult with ESH&Q staff or Jefferson Lab Facilities Management if you anticipate a need to enter such a space. In the interim, STAY OUT.

4.10 Hot Work in Confined Spaces

Welding, torch-cutting, and metal grinding and cutting introduces additional hazards to confined space entry:

· fire hazard from fuel gases (especially acetylene) ignition of other combustibles

· wet, electrically conductive floor

· potential for oxygen enrichment

· potential for oxygen depletion

· air contaminants from arc, flame, or grinder

· arc lights reflected into shield opening from sides and rear.

· extremely high noise levels from grinders and similar equipment

Hot work may transform a non-permit-required space into a PRCS. Whenever possible, avoid hot work in confined spaces. If feasible, remove components with mechanical means and perform the hot work outside of the space.

· A Jefferson Lab Fire Hazard Work Permit is required in addition to the confined space entry permit.

· Use greater caution in evaluating the work area.

· Ventilation is even more critical; provide more frequent monitoring of air quality.

· Be alert to reflection of welding arc from walls.

· Keep gas cylinders out of the space, and turn off the cylinder valves promptly. Remove hoses from the PRCS when they are not in actual use: during lunch, extended breaks, etc.

· Do not use CO₂ or dry chemical fire extinguishers within a confined space. If a pressurized water extinguisher is not adequate, evacuate and call for help.

4.11 Subcontractor Confined Space Entry

Jefferson Lab management shall inform subcontractors who need to work in the vicinity of or inside a PRCS of its existence and the need to follow prescribed procedures before and during entry. More specifically, if entry is necessary, the SOTR or other knowledgeable person must inform the subcontractor about:

· Jefferson Lab experience with the PRCS

· Known hazards in that PRCS

· Special precautions and procedures Jefferson Lab has imposed for the specific PRCS

The subcontractor shall:

· Inform the SOTR not less than 24 hours prior to an intended PRCS entry when the need for entry can be anticipated

· Learn about expected hazards by talking to the Jefferson Lab SOTR, cognizant ESH&Q staff, and other designated Lab staff with special knowledge about the space in question

· Coordinate entry operations with the designated Jefferson Lab entry supervisor when both Jefferson Lab staff and subcontractor personnel plan to work in or near a PRCS

· Use PRCS entry procedures at least as stringent as Jefferson Lab’s

· Inform Jefferson Lab management about any unexpected hazards or events that were encountered or occurred during the entry

On occasion Jefferson Lab and subcontractor staff may both be working in a PRCS, and there may be separate permits in effect. The Jefferson Lab entry supervisor coordinates entry operations with the subcontractor for both Jefferson Lab staff and subcontractor personnel working together. Upon completion of the entry, the Jefferson Lab entry supervisor meets with the subcontractor to ascertain if any unexpected hazards were encountered or if events of importance occurred during the entry.

ISSUING AUTHORITY	CHAPTER AUTHOR	APPROVAL DATE	EFFECTIVE DATE	EXPIRATION DATE	REV.
ESH&Q Division	John Kelly	08/30/06	08/30/06	08/30/09	0

This document is controlled as an on line file. It may be printed but the print copy is not a controlled document. It is the user’s responsibility to ensure that the document is the same revision as the current on line file. This copy was printed on 8/19/2009.