Office or Environmental Health and Safety

Confined Space Entry Policy

Introduction

Over 1 1/2 million workers enter confined spaces on an annual basis.  Serious injury or death in a confined space can be the result of asphyxiation, engulfment, electric shock, falls, and heat stress.  The Occupational Safety and Health Administration (OSHA) estimates that 85 percent of these accidents can be prevented if proper safety precautions at job sites are initiated.  This poses a serious problem for exposed workers and their employer.  The OSHA Confined Space Standard establishes uniform requirements to ensure that the hazards of confined spaces in U.S. workplaces are evaluated, safety procedures implemented, and that the proper hazard information is transmitted to all affected workers.

A confined space is any space that is large enough for an employee to enter, that has a restricted means of entry or exit, and that is not designed for continuous employee occupancy. All of these criteria must be met for a space to be classified as confined. Examples of confined spaces include tanks, pits, certain tunnels, utility vaults, and boilers. The physical and atmospheric hazards often associated with confined spaces can cause serious injury or death to workers. The major factors that lead to injuries in confined spaces include failure to recognize and control these hazards, and inadequate or incorrect emergency response.

Scope and Application

The Occupational Safety and Health Administration (OSHA) requirements apply to most activities that require entry into a confined space. Examples of specific activities include, but are not limited to, the following:

• Maintenance and cleaning of boilers
• Cutting or welding in confined spaces
• Telecommunications and electrical utility work performed in manholes and unvented vaults
• Work in excavations or trenches that could develop hazardous atmospheres
• Work in sewers, manholes, pits, traps, and the like

Program Description

Workplace Survey and Evaluation of Confined Spaces

The Director of Environmental Health & Safety has conducted a survey of the campus to document confined spaces, and has used that information to compile a confined space inventory.. As part of the survey, confined spaces have been evaluated to determine if any physical or atmospheric hazards are associated with them.

Phyiscal Plant employees must be able to identify confined spaces, as it is their responsibility to notify the Director of EH&S whenever a confined space is discovered which is not listed on the inventory .

Protective Equipment and Material

Several types of protective equipment and material are usually necessary for safe entry into confined spaces. These may include equipment for atmospheric testing, ventilation, communication, lighting, and rescue. Personal protective equipment (PPE) appropriate for the hazards of the space must also be provided to workers.

Training

Training is required for all those involved with confined space entry. The Director of Environmental Health & Safety will provide this training, and will include such topics as: Recognition of confined spaces and their hazards, duties and responsibilites of supervisors, entrants and attendants, atmospheric testing procedures, personal protective equipment (PPE), rescue and retrieval requirements, confined space entry permits, and provisions of the written Confined Space Entry Policy. Supervisors are responsible for ensuring that no employee enters a permit required confined space without being properly qualified.

In addition to confined space training, other required training may include provisions from other programs, such as lockout/tagout, electrical safety-related work practices, or cutting and welding, depending upon the hazards of the space and the work to be performed.

Rescue and Emergency Services

Rescue from confined spaces must be carefully planned. Those responsible for confined space rescue must receive specialized training and be properly equipped. If rescue operations at Connecticut College require physical entry into the confined space, the New London Fire Department will be summoned. Under no circumstances is the attendant or other personnel to enter a confinde space at any time. For this reason, all entrants will wear a rescue harness attached to a tripod and winch. Attendants must be equiped with a campus radio, so they can contact Campus Safety to request emergency assistance from the NLFD.

Contractors

Physical Plant must inform outside contractors of the potential hazards that may be encountered during their work at Connecticut College. This includes giving the contractor access to any information available on the confined spaces involved in their project.

Similarly, the contractor must inform Physical Plant of any changes made to a confined space in the course of their work. Any change, no matter how minor, would require a re-evaluation of the space before entry would again be allowed.

Roles and Responsibilities:

Director of Environmental Health & Safety

• Survey workplace to identify any confined spaces.
• Evaluate confined spaces found during the workplace survey.
• Develop a written Confined Space Entry Program.
• Provide Confined Space Entry training to supervisors, entrants and attendants.
• Evaluate program and procedures at least annually.

Physical Plant Supervisors (Mechanical Trades, Building Trades, Grounds and Energy Systems Manager)

• Recognize confined spaces in the workplace. Report confined spaces not listed on the inventory to the Director of EH&S.
• Identify workers who may be expected to enter confined spaces.
• Ensure workers receive general and specific training.
• Ensure employees follow all appropriate procedures during confined space entries.
• Provide necessary protective equipment, rescue/retrieval equipment, tools and materials.
• Provide contractors with information on any confined spaces that are involved in a project.

Campus Safety

• Act as liaison between Emergency Services providers and Connecticut College.

Employees

• Attend training.
• Never enter a confined space unless trained and properly equipped.
• Always follow proper confined space procedures.
• Report potentially hazardous conditions to supervisors or the Director of EH&S.

Tools and Links:

• Confined Space Program Self-Audit Checklist (MS Word document.)
• Related Connecticut College policies:
  • Lockout/Tagout
• Electrical Safety
• Welding Safety
• Respiratory Protection
• Personal Protective Equipment (PPE)
• References:
  • Permit Required Confined Spaces , 29 CFR 1910.146
  • The Control of Hazardous Energy Sources (Lockout/Tagout), 29 CFR 1910.147
  • Electrical Safety-Related Work Practices, 29 CFR 1910. 331, 332, 333, 334, 335
  • Personal Protective Equipment , 29 CFR 1910 Subpart I
  • Welding, Cutting and Brazing , 29 CFR 1910 Subpart Q
    

Click here for the Connecticut College Confined Space Entry Policy.

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