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

Purpose

The purpose of this program is to provide a means by which employees can be protected from the hazards associated with entry into confined/enclosed spaces and to develop procedures by which employees shall enter such spaces. This program establishes the minimum requirements for entering confined/enclosed spaces in accordance with the following OSHA Standards: Permit Required Confined Space, 29 CFR 1910.146; Telecommunications, 29 CFR 1910.268; and Electrical Power Generation, Transmission, and Distribution, 29 CFR 1910.269.

Scope

The confined space program applies to all University employees and contractors that are involved in confined space entries on campus. The program includes entry into non-permit, permit required confined spaces (permit spaces) and enclosed spaces.

Procedures

All spaces owned or operated by UNC-CH that meet the definition of confined space shall be identified and access to such spaces shall be controlled. Permit spaces shall be appropriately marked. These terms are defined in the “Definitions” section which is the last section of this document.

Employees are prohibited from entering any space meeting the definition of confined space, unless the following conditions are met:

  1. The appropriate UNC-CH department determines that employees must enter confined spaces to perform the mission of the Work Unit and/or the duties of the employee.
  2. The employees are trained in the entry duties under this program which they are to perform.
  3. The space is rendered safe for entry by:
    1. Issuance and compliance with the conditions of the entry permit;
    2. The space is classified as a non-permit space.
    3. The space is a permit space reclassified as a non-permit space prior to entry; or
    4. Alternate Entry Procedures are performed.

Identification of Confined Spaces

UNC-CH departments shall identify each space under their jurisdiction which meets the definition of a confined space, if any exist, and shall provide a list of such spaces to EHS. EHS will maintain a campus-wide list of confined spaces. The list shall be available to all affected managers and employees. The current list is in Appendix A.

Each confined space on the list shall be designated as a non-permit or permit space. The hazards of each permit space shall be catalogued on the list. UNC-CH departments are encouraged to contact EHS for assistance with classifying confined spaces. Confined spaces shall be considered hazardous until an evaluation is completed.

Departments shall notify EHS if additional confined spaces are identified or if new ones are installed or created. For each newly identified space, a “Confined Space Hazard Evaluation Form” must be completed and sent to EHS.

Departments shall inform employees of the existence and location of permits by posting danger signs or by any other equally effective means approved by EHS. A Danger sign posted at the means of ingress to each identified permit space meets this requirement. The legend on the signs for permit spaces shall state: “PERMIT REQUIRED CONFINED SPACE. DO NOT ENTER WITHOUT AUTHORIZATION AND PERMIT”.

Re-evaluation of Identified Confined Spaces

UNC-CH departments shall re-evaluate identified confined spaces within their jurisdiction to determine if such spaces should be added, deleted, or reclassified. Each classification change must be documented on the “Confined Space Hazard Evaluation Form”. The form shall be provided to EHS.

Re-Evaluation shall be performed:

  1. After review during the annual inspection; and
  2. After notification of changes in hazards in a confined space by employees, managers, or any other source.

Department Responsibilities

Each department shall determine by job title any employees that may enter permit spaces, or perform work within non-permit spaces that may cause the space to meet the definition for permit-required confined space during the work activities. The departments shall document the determination. Departments shall also designate a departmental Program Records Coordinator that is responsible for maintaining cancelled permits and documentation. Supervisors of employees authorized to enter permit spaces shall:

  1. Procure the equipment necessary for entry testing and develop procedures to provide entry supervisors with the equipment as necessary;
  2. Designate Entry Supervisors, Attendants, and Entrants and ensure they are properly trained.
  3. Develop a Confined Space Entry Plan that outlines the departmental policies and procedures involving entries.

Departmental Confined Space Entry Plan

Each department is to develop written entry procedures and practices necessary for safe confined space entry, to be included in a confined space entry plan. Plans must be approved by EHS and must meet all the requirements of 29 CFR 1910.146, 29 CFR 1910.268, or 29 CFR 1910.269, as applicable. The plan shall:

  1. Identify non-permit confined spaces and permit required confined spaces within the department’s jurisdiction;
  2. Evaluate the hazards of the confined spaces.
  3. Describe procedures and practices necessary for safe permit space entry;
  4. Identify required equipment for entry; and
  5. Designate persons by job title that are authorized as entrants, attendants, or supervisors.

Entry Procedures for Non-permit Spaces

Prior to each entry into a non-permit space, the designated Entry Supervisor shall review the work to be performed.

  1. If the work will introduce a hazard into the space that will cause it to meet the definition for permit required confined space, the supervisor shall:
    1. Temporarily reclassify the space as a permit space;
    2. Follow the procedures for entry into a permit space;
    3. Upon termination of the permit, reinspect the space and take actions necessary to remove the hazards created during the work; and
    4. If all hazards are removed, reclassify the space as a non-permit space. If the hazards will remain, the space is now a permit space. Document the change on the “Confined Space Hazard Evaluation Form” and send to EHS.
  2. If the work does not introduce a hazard, the Entry Supervisor may authorize entry into the space according to the following requirements:
    1. Prior to entry, the entry participants shall perform initial atmospheric testing in the order indicated below. Entry may proceed only if the tests indicate:
      1. The percentage of oxygen in the permit space is between 19.5% and 23.5%.
      2. The percentage of flammable gases is at or lower than 10 percent of the Lower Flammable Limit.
      3. The parts per million parts (ppm) of carbon monoxide is at or lower than 25.
      4. The ppm of hydrogen sulfide is at or lower than 1 ppm.
    2. To ensure that air contaminant concentrations have not changed during the entry, EHS requires that continuous monitoring is conducted throughout the entry. Documentation of the continuous monitoring readings is not required. However, if the gas monitor alarms the entrant must evacuate the space and reclassify the space as a permit space until the source of the contaminant is identified and eliminated.
    3. The entry participants shall document the type of entry on the permit/form and proceed with the entry.

Entry Procedures for Permit Spaces

General Duties of Entry Participants

  1. For each entry into a permit space, the designated Entry Supervisor shall:
    1. Perform the pre-entry duties of the entry supervisor on the permit space to be entered;
    2. Prepare an entry permit, reclassify the space as a non-permit space, or authorize alternate entry procedures, in compliance with the relevant procedures of this program;
    3. Document the type of entry on the permit/form;
    4. Perform the post-entry duties of the entry supervisor;
    5. Collect the permit from the attendant at the end of entry; and
    6. Maintain the permit or documentation for the required retention period.
  2. For the duration of each entry into a permit space, the entrants and attendants shall perform the duties outlined in these procedures, and shall return the permit or documentation to the Entry Supervisor upon termination of entry.
  3. Employees entering a permit space may be both the Entry Supervisor and the Entrant, or the Entry Supervisor and the Attendant.
  4. Employees serving as an Attendant for a permit space entry shall not be an Entrant during that entry unless relieved by another authorized attendant.

Pre-Permit Duties of the Entry Supervisor

  1. The Entry Supervisor shall record on the permit a descriptive identification of the permit space and its location.
  2. The Entry Supervisor shall record on the permit the date of entry, the time of issuance, and the time of expiration. The permit duration may not exceed the time required to complete the assigned task or job identified on the permit. Periodic atmospheric monitoring is required for the entire permit duration.
  3. The Entry Supervisor shall record on the permit the reason for the entry.
  4. The Entry Supervisor shall identify the authorized entrants and at least one attendant, and shall record their names on the permit.
  5. The Entry Supervisor shall survey the permit space without entry and review the work to be performed, to identify the existing or potential hazards. The following hazards shall be recorded on the permit:
    1. Gases or vapors which could displace the oxygen or processes which could consume oxygen;
    2. Flammable gases;
    3. Any other chemicals, gases, fumes, or mists which could be present or released by entry activities;
    4. A potential for low levels of oxygen from a lack of adequate ventilation;
    5. A potential for high levels of oxygen;
    6. Liquids or flowable solids which could engulf an entrant;
    7. Inwardly converging walls, sloped floors that taper to a smaller cross-section, pits or holes in the floor into which an entrant could stumble into and become wedged, and/or other characteristics of the configuration of the space which could trap or asphyxiate an entrant;
    8. Radiation;
    9. Bare, exposed, or ungrounded conductive parts of electrical equipment, machinery, wiring, fixtures, or installations;
    10. Unguarded points of operation or moving parts of machinery; and
    11. Any other recognized hazard that could result in accidental injury or occupational illness requiring treatment greater than first aid.
  6. The entry supervisor shall determine the actions necessary prior to entry to eliminate or control the hazards, and shall record them on the permit.
    1. Atmospheric Hazards
      1. If a potential or actual atmospheric hazard exists, testing shall be required.
        1. Oxygen, flammable gas, hydrogen sulfide and carbon monoxide tests shall be conducted.
        2. Contact EHS if additional air contaminants are identified. EHS shall list the required Occupational Exposure Limit (OEL) for each identified air contaminant on the permit.
        3. EHS shall provide assistance for the testing of any additionally identified air contaminants.
        4. Initial testing shall be conducted prior to entry. During the entry, testing shall be conducted every 5 mins for the first 20 minutes, then every 20 minutes thereafter. All tests must be documented on the permit.
      2. Required initial atmospheric testing shall be performed in the order indicated below to address atmospheric hazards. Entry may proceed only if the tests indicate:
        1. The percentage of oxygen in the permit space is between 19.5% and 23.5%.
        2. The percentage of flammable gases is at or lower than 10 percent of the Lower Flammable Limit.
        3. The parts per million parts (ppm) of carbon monoxide is at or lower than 25.
        4. The ppm of hydrogen sulfide is at or lower than 1 ppm.
        5. The amount(s) of other identified air contaminants is/are at or lower than the PEL or other more stringent OEL prescribed by EHS. Where more than one air contaminant is observed, those contaminants will be reviewed for additive effects.
      3. If an atmospheric hazard is present, the Entry Supervisor shall determine if the atmospheric hazard can be eliminated or controlled by purging, venting, inerting, continuous forced air ventilation, or a combination of methods.
      4. If the only hazard in a space is a hazardous atmosphere that can be controlled and Alternate Entry Procedures are the desired means of entry, forced air ventilation is required. Alternate Entry Procedures are discussed in the next section.
    2. Eliminate or control engulfment hazards by blanking, binding, double block and bleed, line braking, or other methods.
    3. Eliminate or control configuration hazards. Configuration hazards usually cannot be eliminated.
    4. Eliminate or control other serious hazards by lock-out/tag-out or other means.
    5. Consider the need for traffic control devices to isolate the permit space from vehicular and pedestrian traffic.
  7. The Entry Supervisor shall determine the type of entry that is allowed for the permit space. The three entry options are provided below.
    1. Alternate Entry Procedures
      If the pre-entry survey proves that the only hazard existing in the space is atmospheric and continuous forced air ventilation alone is sufficient to maintain the permit space safe for entry, the Entry Supervisor may authorize Alternate Entry Procedures under the stipulation that:

      1. The initial atmospheric tests with the ventilation indicate the atmosphere meets the entry requirements;
      2. Forced Air Ventilation continues for the duration of the entry;
      3. The Attendant performs atmospheric tests every 5 mins for the first 20 minutes, then every 20 minutes thereafter, and records them on the permit;
      4. The percentage of flammable gases must be maintained at or lower than 5 percent of the Lower Flammable Limit.
      5. Document the type of entry on the form;
      6. Place a barricade around the entrance cover during entry. Entrants are encouraged to wear a harness to aid in rescue during medical emergencies such as heart attacks. Entrants are not required to be connected to a retrieval device but a device should be in the vicinity of entry activities.
      7. If a hazardous atmosphere is detected during entry:
        1. Each employee shall leave the space immediately;
        2. The space shall be evaluated to determine the source of the hazardous atmosphere.
        3. Measures shall be implemented to protect employees from the hazardous atmosphere before any subsequent entry takes place.

        OSHA believes that these practices can be adopted to ensure safe entry into confined spaces that merely have the potential to contain hazardous atmospheres. Testing the atmosphere and providing adequate ventilation can normally eliminate the hazardous atmosphere, producing the equivalent of a non-permit confined space. These procedures are not appropriate for work that introduces hazards in the space such as welding or the use of toxic or flammable materials.

    2. Reclassify as a Non-Permit Space
      If the pre-entry survey proves that there are no atmospheric or configuration hazards in the permit space, and that all other identified hazards can be eliminated (as opposed to controlled) from outside the space prior to entry, the Entry Supervisor may reclassify the space as Non-Permit contingent upon the completion of all hazard elimination activities. The goal of this entry option is to encourage employers to eliminate (as opposed to control) hazards within permit spaces. OSHA expects that this option will apply primarily to spaces containing hazardous energy sources or containing engulfment hazards.

      1. If hazards arise within a permit space that has been declassified to a non-permit space, the Attendants shall exit the space. The Entry Supervisor shall reevaluate the space and determine if the space must be reclassified as a permit space.
      2. Place a barricade around the entrance cover during entry. Entrants are encouraged to wear a harness to aid in rescue during medical emergencies such as heart attacks. Entrants are not required to be connected to a retrieval device but a device should be in the vicinity of entry activities.
    3. If a non-permit entry is approved, record the entry type on the permit for documentation.
    4. If no other type of entry is obtainable or selected, entry shall be by the permit process.
  8. The Entry Supervisor shall determine and record the required equipment for entry.
    1. Equipment and method (i.e., phone, radio, etc.) for the Attendant to summon rescue is required for all permit entries.
    2. Equipment designed to test oxygen, flammable gases, carbon monoxide and hydrogen sulfide shall be required for all permit spaces with hazardous atmospheres.
    3. Equipment designed to test levels of identified airborne contaminants shall be required where such contaminants have been identified.
    4. A forced air ventilation system is required for Alternate Entry Procedures, or if otherwise required by the Entry Supervisor.
    5. Personal protective equipment is required where hazards cannot be effectively eliminated or controlled.
    6. Traffic control equipment is required if the permit space is not effectively isolated from vehicle or pedestrian traffic.
    7. Mechanical rescue equipment is required unless its use creates a greater hazard or would not effectively contribute to rescue.
      1. Body Harness with retrieval line attached at the upper back should be used whenever feasible.
      2. Wristlets may be used where body harnesses are not feasible.
      3. Mechanical retrieval devices shall be used for vertical entries into spaces deeper than five feet. Mechanical devices or fixed point connection may be used otherwise.
    8. Communication equipment is required where entrants will be out of voice range with the Attendant.
      1. Other equipment shall be selected as need requires.
  9. The Entry Supervisor shall indicate any other permits issued for simultaneous work within the space, and shall indicate the means to contact rescue personnel.
  10. Each pre-entry requirement successfully met shall be checked off in the block provided on the permit. When all requirements are completed, the responsible employee shall verify the actions by signing the permit. The Entry Supervisor shall sign and issue the permit, effective upon the date issued and contingent upon completion of all pre-entry activities, and expiring on the date indicated on the permit.
  11. The permit shall be posted at the point of entry into the space, and each authorized employee shall review it to become familiar with the hazards of the space and the acceptable entry conditions.

Entry Duties

  1. The Entrants primary function is to perform work inside the confined space. Entrants shall:
    1. Know the hazards that may be encountered during entry, including signs or symptoms and consequences of exposure.
    2. Enter the space and perform the assigned work.
    3. Wear and use all equipment required by the permit.
    4. Notify the Attendant periodically or upon request that all is well.
    5. Inspect for unidentified hazards during the entry.
    6. Immediately evacuate the space and alert the Attendant whenever any of the following occurs:
      1. The development of a condition not in compliance with the permit;
      2. The development of a sign or symptom of exposure to a dangerous situation;
      3. Failure of any required equipment; and/or
      4. Loss of communication with the Attendant.
      5. The Attendant orders an evacuation.
  2. The Attendant’s primary function is to protect the entrants in the confined space. Attendants shall:
    1. Station themselves outside the permit space at the opening to the space, and remain in place throughout the duration of the entry or until relieved by another authorized Attendant.
    2. Perform no other duties beyond those stated for Attendants.
    3. Understand the hazards that may be encountered during the entry.
    4. Maintain an accurate count of entrants within and without the space, by use of the Entry Log on the permit;
    5. Perform periodic atmospheric monitoring of spaces during entry, and record on the monitoring log on the permit;
    6. Communicate with entrants by voice or communication equipment periodically to assure that all is well;
    7. Order an immediate evacuation of the space:
      1. Upon becoming aware of the development of a sign or symptom of an exposure to a dangerous situation;
      2. Upon becoming aware of the development of a condition out of compliance with the permit;
      3. Upon failure of an entrant to answer an attempt at communication; and/or
      4. If unable to continue the performance of functions as an Attendant.
    8. Summon rescue services if needed;
      1. Warn unauthorized persons away from the permit space; and
      2. Summon the Entry Supervisor if unauthorized persons refuse to leave the space.
  3. The Entry Supervisor has overall responsibility for the entry and ensures that the job is performed correctly and safely. The Entry Supervisor shall:
    1. Understand the hazards that may be encountered in the space.
    2. Know the signs and symptom of exposure to physical and chemical hazards present in the space.
    3. Assure team members perform their duties in accordance with the training they have received.
    4. Assure that acceptable entry conditions are maintained while the space is occupied.
    5. The Entry Supervisor shall remove unauthorized persons from the permit space, as needed.

Completion of Entry Duties

  1. The Attendant shall assure that all entrants have exited the space.
  2. If the space was evacuated prior to completion of work:
    1. The Attendant shall immediately terminate the permit by indicating in the appropriate area on the permit and describing the reasons for evacuation on the permit, then contacting the Entry Supervisor;
    2. The Entry Supervisor shall:
      1. Determine if reentry is required to complete work, eliminate a created hazard, or return the space to normal operation.
        1. If reentry must be performed:
          1. Resurvey the space to determine the cause of the evacuation; and
          2. Issue another permit which includes the elimination or control of the hazard causing the evacuation. Alternate Entry Procedures and Reclassification to Non-Permit Space shall not be approved.
        2. If reentry is unnecessary:
          1. Oversee the completion of the post-entry activities indicated on the permit; and
          2. End the entry activities.
  3. If the entry was successfully completed, the Attendant shall:
    1. Indicate such by checking the appropriate block on the permit;
    2. Oversee the completion of post-entry actions indicated on the permit, and verify by signing in the appropriate location;
    3. Add any pertinent information concerning the entry on the permit; and
    4. Return the permit to the Entry Supervisor.

Procedures for Joint Permit Required Spaces

There are confined spaces that are under the jurisdiction of various campus departments. There may be situations in which a department must perform work in a confined space controlled by another department. The Entry Supervisor or department representative must coordinate with the UNC-CH department controlling the space prior to entry. The requesting department is prohibited from entering a confined space controlled by another department without approval from that department.

  1. If the controlling entity has a permit required confined space program:
    1. The entry participants shall conform to the requirements of that program;
    2. Upon request by the controlling department, the requesting department shall obtain and provide the proof of their program and training for entry participants.
  2. Upon completion of the entry, the Entry Supervisor shall immediately meet with the controlling entity to provide information on:
    1. Hazards within the space of which the controlling entity was unaware, and/or
    2. Any unexpected problems occurring during entry procedures.
  3. The Entry Supervisor shall submit the canceled permit and/or any documentation prepared as a result of entry to the departmental Program Records Coordinator, who shall retain the document for the required retention period. The Entry Supervisor shall also report any emergencies, evacuations, or other unexpected events related to the entry, which shall be recorded in writing by the Program Records Coordinator.

Contractors

  1. UNC-CH departments shall ensure that the following actions are taken for every contract for work within an identified permit space, or work within a non-permit space that will introduce a reclassifying hazard:
    1. Apprise the contractor that the space is a permit-required confined space and of the hazards within the space;
    2. Require the contractor to control entry into the space by the contractor’s permit system meeting the requirements of 29 CFR 1910.146 or other applicable standard;
    3. Verify that the contractor and their employees have received training that meets the requirements of 29 CFR 1910.146 or applicable standard; and
    4. Require the contractor to eliminate any temporary hazards created by the work, or notify the UNC-CH supervisor responsible for the space of any permanent hazards created by the work.
  2. The Contractor or its designee shall notify the responsible UNC-CH supervisor prior to entry.
    1. The UNC-CH supervisor shall notify any employees near or affected by entry; and
    2. If University employees shall enter the space with contracted employees, the UNC-CH supervisor shall ensure that entry operations are coordinated with the contractor or designee to assure that:
      1. All entrants of both employers can be accounted for during the entry;
      2. The work of one employer does not endanger the employees of the second employer;
      3. There is a properly trained attendant in place whenever employees of either employer have entered the space; and
      4. Temporary hazards are eliminated, and the supervisor is apprised of new permanent hazards.
  3. The Contractor or designee shall meet with the responsible UNC-CH supervisor after completion of the entry to provide notification of:
    1. Any new permanent hazards created by the work; and/or
    2. Any unidentified hazards encountered during the entry.

Rescue Operations

If an emergency arises that requires a rescue team, the South Orange Rescue Squad, Inc. is to be contacted by calling 911. The caller should state that the incident has occurred in a confined space to ensure SORS is dispatched immediately. The caller should also provide the address of the incident, number of people injured, types of injuries, a contact number, and hazardous conditions that could result in injury or death to anyone entering the space for rescue.

The Energy Services Department procures the agreement for the campus with the South Orange Rescue Squad, Inc. The Squad provides 24-hour on-call rescue services for permit required confined spaces at the University. The rescue service is to be provided access to all permit spaces from which rescue may be necessary so that the rescue service can develop appropriate rescue plans and practice rescue operations. The Squad provides documentation of the training to Energy Services.

Training Requirements

All Employees

  1. UNC-CH departments shall ensure that each employee receives awareness training on:
    1. The identifying characteristics of a confined space;
    2. The identifying characteristics of a permit space;
    3. The authorization or prohibition of their job classification to enter permit spaces;
    4. Required actions when working around or near a permit space entry; and
    5. The authority of authorized Attendants and Entry Supervisors.
  2. Training documents/rosters must be sent to EHS (CB#1650) so that individuals who have completed the confined space training will receive proper credit.

Program Records Coordinators

  1. Departments shall ensure that the designated Program Records Coordinator receives training in:
    1. The requirements of this program; and
    2. The duties the Coordinator shall perform.
  2. Training shall be provided:
    1. After designation as a Program Records Coordinator; and
    2. Within two months of revisions to this program and departmental policies and/or procedures.

Entry Supervisors, Attendants, and Entrants

  1. The Supervisor shall ensure that employees designated as Entry Supervisors, Attendants, and/or Entrants receive training in:
    1. The requirements of this program and any departmental procedures;
    2. The duties, authority, and responsibilities of Entry Supervisors, Attendants, Lead Entrants, and Entrants;
    3. The types of hazards expected to be encountered in permit spaces;
    4. The calibration, use, care and cleaning of equipment expected to be used during entry operations; and
    5. The performance of pre-entry actions expected to be required in permit spaces.
  2. Training shall be provided:
    1. Prior to assignment or authorization of duties within permit spaces;
    2. Within three months after revisions of this program or departmental procedures. Assignment or authorization for permit space entry shall be suspended until training is completed;
    3. Whenever the supervisor becomes aware that an employee is deviating from the procedures of this policy. Assignment or authorization for permit space entry shall be suspended until training is completed; and
    4. Annually.
  3. The supervisor shall develop a written record that each affected employee has successfully completed training.
    1. Certification shall include:
      1. Employee Name;
      2. Authorized Duty of trainee (Entry Supervisor, Attendant, and/or Entrant);
      3. Name of the Trainer; and
      4. Synopsis of topics covered.
    2. A copy of the certification shall be provided to the employee and Program Records Coordinator.

Telecommunications Employees

While work is being performed in the manhole, a person with basic first aid training shall be immediately available to render assistance if there is cause for believing that a safety hazard exists, and if temporary barriers and traffic control devices do not adequately protect the employee(s). Examples of manhole worksite hazards which shall be considered to constitute a safety hazard include, but are not limited to:

  1. Manhole worksites where safety hazards are created by traffic patterns that cannot be corrected by traffic cones.
  2. Manhole worksites that are subject to unusual water hazards that cannot be abated by conventional means.
  3. Manhole worksites that are occupied jointly with power utilities.

Electric Distribution Systems Employees

While work is being performed in the enclosed space, an attendant with first aid training shall be immediately available outside the enclosed space to render emergency assistance if there is reason to believe that a hazard may exist in the space or if a hazard exists because of traffic patterns in the area of the opening used for entry. When employees are performing work on or associated with exposed lines or equipment energized at 50 volts or more, persons trained in first aid including cardiopulmonary resuscitation (CPR) shall be available.

Program Review

  1. The Program Records Coordinator/Entry Supervisor shall review the effectiveness of the Program upon the annual inspection, using the canceled permits and other documentation from the preceding twelve months, Entry Supervisor comments, and other available information. Departments may choose to perform a single annual review covering all entries performed during a 12-month period.
  2. The Program Records Coordinator/Entry Supervisor may make recommendations to management at any time to make changes in procedures to address and correct weaknesses in the procedures.
  3. The Program Records Coordinator/Entry Supervisor and/or Unit Manager may notify the department at any time of potential weaknesses in policy and/or procedures. The department shall view and initiate whatever changes necessary to address confirmed weaknesses.

Retention of Records

  1. Canceled Permits and other documentation shall be retained by the departmental Program Records Coordinator not less than one year following the date of entry. If departments conduct a single annual review covering all entries during a 12-month period, then the permits have to be retained for the duration between reviews. After the annual review, provide the canceled permits to EHS. EHS shall retain the permits as employee exposure records.
  2. Employee training records shall be retained by EHS for the length of employment.

Other Applicable Standards

OSHA 1910.268 Telecommunications Standard

The OSHA 1910.268 Telecommunications Standard covers entries into underground manholes and unvented vaults entered routinely by employees of the telecommunications industry. OSHA believes these confined spaces do not have the potential to contain any hazard capable of causing death or serious physical harm, except in very rare circumstances. The hazard of concern is the potential to contain hazardous atmospheres. OSHA outlines practices in paragraph (o) of this standard that ensures safe entry into these confined spaces. However, if the work area cannot be made safe before entry, through compliance with 1910.268(o), entry must be performed under the provisions of 1910.146.

UNC-CH Telecommunications Department has internal procedures for compliance with 1910.268.

OSHA 1910.269 Electric Power Generation, Transmission and Distribution Standard

The UNC-CH Electric Distribution Systems (EDS) Department must comply with the OSHA 1910.269 Electric Power Generation, Transmission and Distribution Standard when entering enclosed spaces. Paragraph (e) of the standard addresses the type of enclosed spaces that are routinely entered by employees engaged in electric power generation, transmission, and distribution work and are unique to underground utility work. Work in these spaces is part of the day-to-day activities performed by employees protected by this standard. Enclosed spaces include manholes and vaults that provide employees access to electric generation, transmission, and distribution equipment. This paragraph does not address other types of confined spaces, such as boilers, tanks, and coal bunkers, that are common to other industries as well. These locations are addressed in OSHA’s generic permit-required confined space standard, 1910.146, which applies to all of general industry, including industries engaged in electric power generation, transmission, and distribution work. However, entries into enclosed spaces conducted in accordance with 1910.146 are considered as complying with paragraph (e) of 1910.269. If hazards remain after performing the practices outlined in 1910.269, the entry shall meet the requirements of 1910.146.

EDS has developed internal procedures for compliance with 1910.269 that have been reviewed by EHS. The procedures outline the requirements for pre-entry activities, hazardous atmosphere monitoring, safety and rescue equipment, and contractors.

OSHA 1910.252 Welding, Cutting, and Brazing Standard

This standard specifies the safe practices and ventilation requirements for welding and cutting activities in confined spaces.

Definitions

Confined Space Definitions

Confined Space
a space that meets all three of the following conditions:

  1. Large enough for a person to bodily enter and perform work;
  2. Has only means of entry/egress that requires a person to enter by a means other than normal walking, such as crawling, squatting, climbing, bending, or use of devices; and
  3. Is not designed for people to continually occupy the space.

Examples of confined spaces include but are not limited to tanks, silos, Vessels, pits, sewers, pipelines, boilers, utility vaults, tank cars, and other mobile containers.

Enclosed Space
a working space, such as a manhole, vault, tunnel, or shaft that has limited means of egress or entry, that is designed for periodic employee entry under normal operating conditions, and that under normal conditions does not contain a hazardous atmosphere, but that may contain a hazardous atmosphere under abnormal conditions.
Non-Permit Space
a confined space that does not contain any actual or potential hazards capable of causing death or serious physical harm.
Permit Required Confined Space (Permit Space)
a confined space which has one or more of the following characteristics:

  1. Contains or has the potential to contain a hazardous atmosphere;
  2. Contains a material that has the potential for engulfing an entrant;
  3. Has an internal configuration that could trap or asphyxiate an entrant, such as inwardly converging walls or a floor that slopes downward and tapers to a smaller cross-section; and/or
  4. Contains any other recognized serious safety and/or health hazard such as radiation, exposed electrical hazards, or asbestos.

Entry Team Definitions

Attendant
the trained individual stationed outside the permit space who monitors the authorized entrants and who performs all attendant duties.
Entrant
the trained individual who enters the permit space.
Entry Supervisor
the trained individual with the responsibility to:

  1. Assure that acceptable entry conditions are present within a permit space under his/her jurisdiction;
  2. Issue a permit authorizing entry;
  3. Overseeing entry operations; and
  4. Terminating the entry and permit.

Hazard Definitions

Configuration
the internal design of a space is such that it could trap or asphyxiate an entrant, such as inwardly converging walls or a floor that slopes downward and tapers to a smaller cross-section.
Engulfment
the surrounding and effective capture of a person by a liquid or finely divided (flowable) solid substance that can be aspirated to cause death by filling or plugging the respiratory system, or that can exert enough force on the body to cause death by strangulation, constriction, or crushing.
Hazardous atmosphere
an atmosphere that may expose employees to the risk of death, incapacitation, impairment of the ability to escape unaided from a permit space, injury, or acute illness. Hazardous atmospheres may be created by conditions such as, but not limited to:

  1. Flammable gas, vapors, or mists in excess of ten percent of the lower flammable limit (LFL). The LFL is the lowest concentration of a substance in air that will sustain combustion when elevated to its ignition temperature.
  2. Airborne combustible dusts at a concentration that:
    1. Meets or exceeds its LFL; and/or
    2. Obscures vision at a distance of five feet or less. (This statement is a “rule of thumb” for estimation of the LFL since there is no reliable equipment available to provide on-site LFL measurements for dust.)
  3. Atmospheric oxygen concentration below 19.5 percent (oxygen deficient) or above 23.5 percent (oxygen enriched).
  4. Atmospheric concentrations at or above the Permissible Exposure Limit (PEL) of substances identified in Subpart Z of 29 CFR 1910.
  5. Any other atmospheric conditions which are immediately dangerous to life and health.
Immediately Dangerous to Life and Health (IDLH)
any condition that:

  1. Poses an immediate or delayed threat to life;
  2. Would cause irreversible adverse health effects; and/or
  3. Would interfere with an individual’s ability to escape unaided from a permit space.
Physical Hazard
A factor within the environment that can reasonably be expected to cause personal injury, property damage or both. Examples include noise, mechanical, and electrical hazards.

Hazard Control Definitions

Conditions of Entry
the conditions that must exist in a permit space to allow employees to safely enter and perform duties within the space.
Blanking, Binding
absolute closure of a pipe, line, or duct by fastening a solid plate that completely covers the bore and that is capable of withstanding the maximum pressure of the pipe, line, or duct with no leakage beyond the plate.
Double Block and Bleed
the closure of a line, duct, or pipe by closing and locking/tagging out two in-line valves, and opening and locking/tagging out a drain or vent in the line between the two closed valves.
Inerting
the displacement of the atmosphere in a permit space by a noncombustible gas to such an extent that the resulting atmosphere is noncombustible, producing an IDLH oxygen-deficient atmosphere.
Isolation
the complete removal of a permit space from service and the complete protection of that space from the release of energy or material.
Line Breaking
the intentional opening of a pipe, line, or duct that is or has been carrying flammable, corrosive, or toxic material, an inert gas, or any fluid at a volume, pressure, or temperature capable of causing injury.

Permit Definitions

Alternate Entry Procedures
the use of continuous forced air ventilation and atmosphere monitoring in lieu of a permit to enter a permit required confined space that:

  1. Has an actual or potential hazardous atmosphere that can be demonstrably controlled by continuous forced air ventilation alone; and
  2. Has no other hazards of any kind.
Emergency
any occurrence (including the failure of hazard control or monitoring equipment) or event, internal or external to the permit space, which could endanger entrants.
Entry
the action of breaking the plane of an opening of a permit space with any part of the body. Entry includes all periods of time in which the confined space is occupied.
Permit
the written or printed document authorizing entry into a permit space and designating the requirements for entry.
Prohibited Condition
any condition in a permit space that is not allowed by the permit during the period when entry is authorized.
Testing
the process by which the hazards that may confront entrants are identified and evaluated. This term includes the specification of tests that are to be performed in the permit space.