- Identifying
Permit Space Hazards
Each Department
will identify and evaluate the hazards of permit spaces before
employees enter them.
The following
hazards shall be identified prior to entry into a confined space:
- Atmospheric
hazards
- Asphyxiating
atmospheres
- Flammable
atmospheres
- Toxic
atmospheres
- Burn
hazards
- Heat
stress hazards
- Mechanical
hazards
- Engulfment
hazards
- Physical
hazards (falls, debris, slipping hazards)
- Electrocution
- Danger
of unexpected movement of machinery
- Noise
hazards
- Developing
Safe Entry Practices
Departments
will implement procedures and practices necessary for safe permit
space entry operations. Theses include, but are not limited
to:
- Acceptable
entry conditions(See Appendix B, Atmospheric Testing and Monitoring).
- Isolating
the permit space
- Purging,
inerting, flushing or ventilating the permit space as necessary
to eliminate or control atmospheric hazards.
- Pre-entry
Briefing. The lead worker will conduct a meeting of all employees
who will enter the confined space. Employees will be informed
of the hazards and safety conditions of the particular job
Hazards
shall be controlled by the following mechanisms:
- Lockout
of energy sources
- Cleaning
and purging(See Appendix C, Ventilation of Confined Spaces)
- Personal
protective equipment see (Appendix D, MSU Respiratory Protection
Program)
The following
precautions shall be followed when entering a confined space
located along a roadway, parking lot or any areas where traffic
flow may cause a potential hazard.
- Approach
the area cautiously and activate flashers upon approach to
the confined area to be entered.
- Park
any vehicles in such a way that traffic will flow in the most
unobstructed manner, and where possible, the vehicle should
provide protection for the entry crew.
- Park
the vehicle in such a manner that exhaust fumes are not drawn
down into the manhole, If this is not possible, extend the
exhaust stack above the vehicle.
- Before
uncovering a manhole, place traffic safety cones around the
manhole and vehicle, visible to traffic in all directions.
Place cones to protect the crew and to channel traffic flow.
The cones should be placed at sufficient distances and intervals
to adequately warn oncoming traffic.
- In areas
of high traffic volume or other sites warranting additional
highly visible safety equipment, use illuminating traffic
arrows, barricades, and "Men Working" signs.
- When
placement of the vehicle creates a situation of having only
one open lane of traffic in a congested area, use a flag person
to direct traffic flow. When a flag person is necessary, an
additional crew member is required to attend the employee
in the manhole. Wear traffic safety vests or equivalent at
all times when working on the street or easement surface in
the field.
- In the
case of opening or obstructions in the street or sidewalk
being worked on or left unattended, effectively display danger
signals such as warning signs, cones and flags. Under these
same conditions at night, prominently display warning lights.
Enclose excavations and openings with suitable barricades.
- Equipment
use and maintenance
Equipment,
including testing, ventilating, lighting, monitoring, communication
and personal protective equipment, necessary for the safe entry
into a Permit Space shall be provided, maintained and properly
used by each Department. See Appendix E, Basic Confined Space
Entry and Rescue Equipment.
- Testing
for acceptable entry conditions
Permit space
evaluation will include all testing conducted before an entry
as well as all testing and monitoring activities to ensure that
acceptable entry conditions are maintained throughout the entry.
Atmospheric testing should be conducted in accordance with Appendix
B of the MSU Program.
- Providing
permit space attendants
Each Department
will provide at least one attendant outside a permit space to
be entered for the duration of the entry operations. See Section
IV B 8, Duties of the Attendant for specific responsibilities.
- Attendant
emergency response
To facilitate
non-entry rescue, retrieval systems or methods shall be used
whenever an authorized entrant enters a permit space, unless
the retrieval equipment would increase the overall risk of entry
or would not contribute to the rescue of the entrant.
Retrieval
systems shall meet the following requirements: Each authorized
entrant shall use a chest or full body harness, with a retrieval
line attached at the center of the entrant's back near shoulder
level, or above the entrant's head. Wristlets may be used in
lieu of the chest or full body harness if the employer can demonstrate
that the use of a chest or full body harness is infeasible or
creates a greater hazard and that the use of wristlets is the
safest and most effective alternative. The other end of the
retrieval line shall be attached to a mechanical device or fixed
point outside the permit space in such a manner that rescue
can begin as soon as the rescuer becomes aware that rescue is
necessary. A mechanical device shall be available to retrieve
personnel from vertical type permit spaces more than 5 feet
deep.
If an injured
entrant is exposed to a substance for which a Material Safety
Data Sheet (MSDS) or other similar written information is required
to be kept at the worksite, that MSDS or written information
shall be made available to the medical facility treating the
exposed entrant.
- Training
and duties of entry personnel
There are
three specific members of a confined space entry team:
- Authorized
Entrants
- Attendants
- Lead
Worker
The duties
of each member are specified in Appendix F.
The department
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.
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 department has reason to believe either that there are
deviations from the permit space entry procedures required
by 29 CFR 1910.146 or that there are inadequacies in the employee's
knowledge or use of these procedures.
The training
shall establish employee proficiency in the duties required
by 29 CFR 1910.146 and shall establish new or revised procedures,
as necessary, for compliance with this.
The department
shall certify that the training required by the previously mentioned
paragraphs 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.
Only trained
attendants, authorized entrants and personnel authorizing or
in charge of entry shall work in and around a Permit Space.
- Rescue
and emergency services
The East
Lansing Fire Department is designated as the outside rescue
team. The East Lansing Fire Department will be made aware of
the hazards they may confront when called on to perform rescues.
The East Lansing Fire Department is responsible to equip, train
and conduct itself appropriately. At least annually, MSU and
the East Lansing Fire Department will conduct a practice rescue
drill. MSU will provide the East Lansing Fire Department with
access to all permit spaces from which rescue may be necessary
to that they can develop appropriate rescue plans and practice
rescue operations.
To facilitate
non-entry rescue, retrieval systems or methods shall be used
whenever an authorized entrant enters a permit space, unless
the retrieval equipment would increase the overall risk of entry
or would not contribute to the rescue of the entrant.
Retrieval
systems shall meet the following requirements: Each authorized
entrant shall use a chest or full body harness, with a retrieval
line attached at the center of the entrant's back near shoulder
level, or above the entrant's head. Wristlets may be used in
lieu of the chest or full body harness if the employer can demonstrate
that the use of a chest or full body harness is infeasible or
creates a greater hazard and that the use of wristlets is the
safest and most effective alternative. The other end of the
retrieval line shall be attached to a mechanical device or fixed
point outside the permit space in such a manner that rescue
can begin as soon as the rescuer becomes aware that rescue is
necessary. A mechanical device shall be available to retrieve
personnel from vertical type permit spaces more than 5 feet
deep.
If an injured
entrant is exposed to a substance for which a Material Safety
Data Sheet (MSDS) or other similar written information is required
to be kept at the worksite, that MSDS or written information
shall be made available to the medical facility treating the
exposed entrant.
- Written
permit system
A permit
system shall be utilized for entry into Permit Spaces (See Appendix
G, Confined Space Entry Procedures, Appendix H, Confined Space
Entry Form and Appendix I, Hot Work Permit).
Each canceled
entry permit shall be retained for at least 1 year to facilitate
the review of the permit-required confined space program. Any
problems encountered during an entry operation shall be noted
on the pertinent permit so that appropriate revisions to the
permit space program can be made.
- Coordinating
entry operations
All outside
contractors performing work in confined space entry permit area
shall be informed of any fire, explosion, health or other safety
hazards of that confined space. This information shall be based
on current or past history of the confined space and the nature
of the contractor's work procedure in making such disclosure.
Each Department
shall inform contractors of MSU's safety rules and emergency
plans which may be applicable to the contractor's employees.
Contractors and their employees must not be allowed to enter
a confined space until the provisions of this program have been
satisfied. When both MSU and contractor personnel are working
in or near permit spaces, their entry operations must be coordinated
to avoid endangering any personnel.
At the conclusion
of the entry operations, the contractor must be debriefed regarding
the permit space program that was followed and concerning any
hazards confronted or created in permit spaces during entry
operations.
It is the
responsibility of each contractor who is retained to perform
permit space entry operations to obtain any available information
regarding permit space hazards and entry operations from MSU.
They must also coordinate entry operations with MSU when both
MSU and contractor personnel will be working in or near permit
spaces. MSU must be informed of the permit space program that
the contractor will follow and of any hazards confronted or
created in permit spaces, either through a debriefing or during
the entry operations.
- Concluding
entry
The lead
worker will determine when the entry operations have been completed.
The permit space will be closed and the permit canceled. The
lead worker will write "Permit Canceled" with the
date, time and signature at the bottom of the MSU Confined Space
Permit. Entry into the permit space will only be allowed after
following all aspects of this program.
- Program
review and revision
Each Department
will review entry operations and revise the procedures to correct
any deficiencies before subsequent entries are authorized. Any
revisions will be reported to the ORCBS in order to revise the
written program.
- Annual
compliance review
The ORCBS
will review the program annually in light of actual entry, work
and exit experience to determine how the program can be improved.
Permit
Required Confined Space Program
