This section has been reviewed and updated as needed: May 2014

Introduction

The goal of the Confined Space Policy is to provide a means by which employees can be protected from the hazards associated with entry into confined spaces and to develop procedures by which employees shall enter such spaces. It will ensure that the identified hazards are controlled or eliminated prior to individuals entering confined spaces. The Confined Space Policy is administered by the Department of Environment, Health and Safety (EHS).

Regulatory Authority

NC OSHA regulates occupational exposure of employees who are involved in confined space entries.

Responsibilities

Environment, Health and Safety

EHS assists with the development and review of departmental confined space entry plans and training programs, conducts periodic inspections to verify departmental compliance with the Confined Space Policy, and updates the policy and program as necessary. EHS also maintains a campus-wide list of confined spaces.

Directors and Department Chairs

Directors or department chairs make necessary provisions, in collaboration with EHS, to ensure employees are protected from all actual or potential hazards during any confined space activity. They provide the resources and personnel necessary to comply with the Confined Space Policy and Program.

Assistant Directors, Department Managers, Superintendents and Principal Investigators

Assistant Directors, department managers and superintendents determine the applicability of the confined space program to activities conducted in their areas. They designate individuals responsible for the implementation of the confined space program and ensure compliance with the program.

Work Unit Supervisors

Work Unit Supervisors are responsible for the implementation of the Confined Space Policy and Program. They develop, enforce and update departmental confined space entry plans/procedures. They designate entry supervisors, attendants, and entrants and ensure they have the appropriate level of training. Supervisors evaluate the needs of their areas and equip employees with the materials required to safely perform confined space entries. With the assistance of the Program Coordinator, supervisors conduct annual reviews of the departmental procedures.

Program Coordinators

Program Coordinators are responsible for retention of the canceled permits, the list of confined spaces under the jurisdiction of their department and other appropriate documentation related to confined space entries for the department. They, along with the work unit supervisor, conduct annual program reviews. They provide EHS with training records, confined space evaluation forms and any changes associated with the hazard status of confined spaces.

Employees

All employees involved in confined space activities are responsible for understanding and following the requirements of the Confined Space Program. Employees not involved with the program must understand that they are not allowed to enter confined spaces without proper training, approval or a permit, if required, under any circumstances.

Contractors

Contractors performing confined space entries on the campus must inform UNC of their procedures. The contractor must work in conjunction with UNC to determine the appropriate joint entry procedures. They must ensure their employees understand and comply with all requirements of the approved joint procedures. Upon completion of the entry, contractors must notify UNC of any new permanent hazards created during the work and/or any unidentified hazards encountered during the entry.

Rescue Operations Provider

The current rescue operations provider for campus confined space entries is the South Orange Rescue Squad, Inc. The Squad is responsible for providing 24-hour on-call rescue services for emergencies involving confined space entries. They must provide on-site training for its members and provide documentation of such training to UNC.

Complaint Response

Occasionally employees raise concerns about the hazards associated with confined space entries. Employees are encouraged to call EHS at 919-962-5507 with any concerns about their work areas. The investigation of these concerns is confidential and may be anonymous, if the employee wishes. The investigation includes an inspection of their work areas and an evaluation of their potential exposure.

Resources

OSHA Permit-Required Confined Space Standard. 29 CFR 1910.146, General Industry Standard

The Confined Space Program outlines in detail how to implement the Confined Space Policy.

OSHA Electrical Power Generation, Transmission, and Distribution Standard. 29 CFR 1910.269, General Industry Standard.

The 1910.269 standard applies specifically to the UNC-CH Electric Distribution Systems (EDS) Department. EDS has an internal Manhole Entry Procedure that addresses their unique hazards and requirements associated with routine entry into enclosed spaces by qualified employees performing operations or maintenance work as outlined by the standard.

OSHA Telecommunications Standard. 29 CFR 1910.268, General Industry Standard.

The 1910.268 standard applies specifically to the UNC-CH Telecommunications Department. This department has internal procedures that address their unique hazards and requirements associated with manhole and unvented entry by telecommunications employees.

Questions about confined space entry management on campus should be directed to EHS at 919-962-5507.