how to work safely in a permit- required confined...
TRANSCRIPT
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How to
work safely
in a permit-
required
confined
space
OR-OSHAOregon Occupational Safety & Health Division
THEY’RE NOT DESIGNED TO BE OCCUPIED!
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ADATHE KEY TO ACCESSIBILITY
In compliance with the Americans with Disabilities Act (ADA), this publication is available inalternative formats. Call the OR-OSHA public relations manager, (503) 378-3272 (V/TTY).
Materials contained in this publication are in the public domain and maybe copied and distributed without permission from Oregon OSHA.
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OREGON OCCUPATIONAL SAFETY & HEALTH DIVISION
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ContentsIntroduction ....................................................................................................... 3
What is a permit-required confined space? .................................................... 4
What is §1910.146, and why is it important? .................................................. 5
What do I need to do to work safely in a permit space? ................................. 6
▼ Identify the permit spaces at your workplace .................................................. 7
▼ Identify the hazards in the spaces ..................................................................... 8
▼Decide if workers will enter a permit space .................................................... 10
▼Eliminate or control the hazards in the space ................................................ 11
▼Establish entry procedures .............................................................................. 12
▼Train workers for entry operations .................................................................. 15
▼Make sure workers know their duties and responsibilities ........................... 16
▼Plan for emergencies ........................................................................................ 17
A diagram of the entry process ....................................................................... 19
What is a permit-space program, and do I need one? ................................. 20
A generic permit-space program
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OREGON OCCUPATIONAL SAFETY & HEALTH DIVISION
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Introduction I f you store grain, process raw materials,or work in a large manufacturing plant,
you’re probably familiar with the term,confined space.
Many Oregon workplaces have confinedspaces — enclosed spaces that are diffi-cult to enter and exit, large enough towork in, but not designed to be occupied.Nevertheless, workers need to enter themfrom time to time. For example, they mayneed to inspect equipment, fix leaks, doconstruction work, or rescue someone.
The interior of a confined space may berelatively safe or it may contain life-threatening hazards — such as equipmentthat starts without warning, toxic gases,corrosive chemicals, or flammable solvents.
This guide focuses onconfined spaces that maycontain life-threatening
hazards — the so-called permit-requiredconfined spaces, or permit spaces. Itspurpose is to help you, your coworkers,or your employees work safely in permitspaces. It answers the following questions:
▼ What is a permit space and howcan I identify one?
▼ What is §1910.146, the permit-required confined-space standardfor general industry, and why isit important?
▼ What do I need to know to worksafely in a permit space?
▼ What is a permit-space program,and do I need one for my work-place?
It also offers a generic written permit-space program that you can use todevelop a written program for yourworkplace.
The purposeof this guide
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A confined space hasall of the followingcharacteristics:
▼ It has a restricted opening thatmakes entry and exit difficult.
▼ It’s large enough for one to entercompletely.
▼ It’s not designed to be occupied.
A permit space is aconfined space thatmay contain life-
threatening hazards. No one can enter apermit space without first completing awritten entry permit. (Shown on Page 14.)
A permit space has all of the characteris-tics of a confined space and one or moreof the following characteristics:
▼ It has – or could have – anatmospheric hazard.
▼ It contains material that couldtrap or bury an entrant.
▼ It’s shaped so that an entrant couldbecome trapped or asphyxiated.
▼ It has any safety or health hazard.
Most confined spacesare designed to holdsubstances such as
liquids, gases, and loose materials, or tohouse equipment. Though they comein many sizes and shapes, most can beclassified in one of two ways: those withdepth and open tops and those withnarrow openings. The table below givesexamples of each.
Anyone who entersa permit space mustfirst fill out a written
permit that verifies that the hazards inthe space have been eliminated orcontrolled and that the space is safe toenter. An entry supervisor must sign thepermit and post it on the space so thatworkers can see it, then cancel it whenwork in the space is finished.
What isa permit-requiredconfinedspace ?
Examples ofconfined spaces
The meaning of“permit required”
pits ship compartments
wells silos
vats pipes
hoppers tunnels
bins utility vaults
degreasers casings
kettles sewers
OPEN-TOPPED AND SPACES WITHDEEP SPACES NARROW OPENINGS
Atmospheric hazard: A hazard that affects the air in a permit space.
Entrant: A person who enters a permit space.
What is aconfined space?
Characteristics ofa permit space
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OREGON OCCUPATIONAL SAFETY & HEALTH DIVISION
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Oregon OccupationalSafety and Health Stan-dards’ §1910.146 protects
general industry workers who enterpermit spaces. It requires employers todo the following:
▼ Survey their workplace to identifypermit spaces.
▼ Inform employees about thelocation of each permit spaceand its hazards.
▼ Keep unauthorized workers outof permit spaces.
▼ Develop a written program thatensures the safety of any em-ployee who must enter a permitspace.
In 1998, federal OSHA revised §1910.146and Oregon OSHA adopted the follow-ing changes:
▼ Gives authorized representativesaccess to the same informationas employees regarding permitspaces and the permit-spaceprogram.
▼ Requires employers to provideemployees or their authorizedrepresentatives with the opportu-nity to observe monitoring ofconfined spaces.
▼ Clarifies the criteria for selectingand evaluating a rescue teamor service.
▼ Ensures employee participationin developing and implementingthe permit-space program.
▼ Adds a non-mandatory appendixto guide employers in choosingappropriately trained andequipped rescuers.
Permit spaces are complexenvironments that maycontain many differenthazards. Workers can die
in permit spaces because they don’tknow about hazards or because theyuse the wrong procedures to controlhazards. In fact, many of those whohave died in permit spaces were tryingto rescue others.
You probably wouldn’t board a commer-cial aircraft — even for a short flight — ifyou knew that the pilot and the mainte-nance crew ignored take-off procedures.Nor would you squeeze into a confinedspace if you knew that your coworkershad ignored procedures to eliminate orcontrol the hazards.
§1910.146 is important because itrequires you, your coworkers, and youremployees to follow safe work practices.If you follow those practices, you’ll knowwhen permit-space hazards exist andyou’ll use the right procedures to elimi-nate or control them.
If you’re a general-industry employer andyour workplace has apermit space, you’ll need
a copy of §1910.146. Review it carefully.Keep in mind that this guide is intendedto help you and your employees worksafely in permit spaces — it doesn’t takethe place of §1910.146.
You can request §1910.146 from ourResource Center (see inside back cover),or you can download it from our Website at www.orosha.org.
What is§1910.146
andwhy is it
important?
What is§1910.146?
Where to geta copy of
§1910.146
Why is§1910.146important?
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12345678
T his section describes eight criticalactivities that are part of the entry
process — the activities that take placeas workers prepare to enter and exit apermit space.
They’re critical activities because theyensure that those who enter a permitspace can work and exit unharmed.
In addition, these activities lay thefoundation for an effective permit-spaceprogram.
What do Ineed to do
to worksafely ina permit
space?
▼ Identify the permit spaces
▼ Identify the hazards in the spaces
▼ Decide if workers will enter
▼ Eliminate or control the hazards
▼ Establish entry procedures
▼ Train workers for entry operations
▼ Make sure workers know their responsibilities
▼ Plan for emergencies
A permit space program is an employer’s plan for protecting workers within the entry pro-cess. See Page 20, What is a permit space program, and do I need one?, for more information.
Eight critical activities:
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OREGON OCCUPATIONAL SAFETY & HEALTH DIVISION
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T he first thing you should do isidentify all enclosures at your
workplace that have the characteristicsof a confined space. (A confined space isdifficult to enter and exit and largeenough for one to enter completely, butnot designed to be occupied.)
Next, evaluate each con-fined space to determineif it’s a permit space. Keepin mind that a permit
space has one or more of the followingcharacteristics:
▼ Contains — or could contain —an atmospheric hazard.
▼ Contains material that could trapor bury an entrant.
▼ Is shaped such that an entrantcould become trapped orasphyxiated.
▼ Contains any safety or healthhazard that could harm an en-trant.
Your evaluation should identify allexisting or potential hazards in eachspace. Be especially careful when evalu-ating a confined space that could con-tain an atmospheric hazard! The onlyway to identify an atmospheric hazard isto test for it from outside the space.Never assume a confined space ishazard-free. If you’re not sure how totest for a hazardous atmosphere, give usa call.
Identifythe permit
spacesat your
workplace.Evaluate
the spacesfor hazards
If your workplace has apermit space, employeesmust know where it’slocated, that it’s hazard-ous, and that it’s a permit
space. You can post a sign, such as theone below, to inform them.
Informemployees
about permitspaces
DANGERPERMIT-REQUIREDCONFINED SPACE
Authorized entrantsonly
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T hose who enter a permit space face two kinds ofhazards: atmospheric and non-atmospheric. Atmo-
spheric hazards affect the air in the space and can beflammable, toxic, corrosive, or asphyxiating.
Non-atmospheric hazards, on the other hand, include many different conditions,including mechanical dangers, loose materials, excessive noise, extreme tempera-tures, low light, and difficult access.
The table below identifies common atmospheric hazards, describeshow they occur, and highlights why you should be concerned aboutthem. Always check atmospheric hazards in the following order:
oxygen deficiencies or displacement, flammable atmospheres, toxic atmospheres,and corrosive atmospheres.
Identifythe hazards
in thespaces.
Permit-space hazards:atmospheric andnon-atmospheric
COMMON ATMOSPHERIC HAZARDSHazard How it occurs Why you should be concerned
Oxygen deficiency(less than 19.5percent oxygen)
Oxygen enrichment(greater than 23.6percent)
Chemical or biologicalreactions consume oxygen.
Oxygen-deficient atmospheresaffect heart rate, musclecoordination, and breathing.Eventually, they lead to death.
Oxygen-enriched atmospheresincrease the risk of fire orexplosions.
Results from welding tasksand from the improper useof oxygen for breathing air.
Flammableatmospheres
Fuel, oxygen, and a sourceof ignition cause fires andexplosions.
Flammable gasses such asacetylene, butane, propane,hydrogen, and methane arecommon in permit spaces.Grain, nitrated fertilizers, andground chemicals can producecombustible dusts.
Toxic atmospheres Accumulates through somemanufacturing, biological,or chemical reactions.Released during work ortasks such as welding andcleaning.
Many manufacturingprocesses, stored materials,and work tasks produce toxicgases, vapors, or dusts.
Corrosiveatmospheres
Accumulates from somemanufacturing processes,biological or chemicalreactions.
Corrosive substances destroyliving tissue.Some cause immediate damageto skin and eyes; some haveno immediate effect, but causecancer with prolonged exposure.
Atmospherichazards
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OREGON OCCUPATIONAL SAFETY & HEALTH DIVISION
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COMMON NON-ATMOSPHERIC HAZARDSHazard How it occurs Why you should be concerned
Engulfment Loose materials drawn from thebottoms of storage bins cansuffocate or bury an entrant.Liquids or materials are sud-denly released into the space.
Mechanical and hydraulicequipment start or moveunexpectedly.
Permit spaces amplify soundsproduced by tools and equip-ment.
Liquid or loose materials cantrap or bury a worker in seconds.
Entrants servicing mechanicaland hydraulic equipment can beseriously injured or killed if theenergy isn’t properly controlled.
Noise interferes with essentialcommunication betweenentrants and attendants.
Mechanicaland hydraulicenergy
Noise
Falling objects Objects fall into the space because topside openings are un-guarded or improperly guarded.
Extremetemperatures
The permit space’s locationand the equipment it containsmake it very hot or cold.
Leaks, spills, and condensationmake walking surfaces slippery.
Corrosive chemicals are storedin the space, or entrants usethem to do tasks.
Confined spaces are difficult toenter and exit.
Most permit spaces are darkplaces.
Hot environments put workers atrisk for heat stress, especially ifthey’re doing strenuous work orwearing protective clothing —cold environments make tasksmore difficult to accomplish.
Wet surfaces are usually slippery.They increase the risk of falls.
Corrosive chemicals can causesevere eye or skin irritation ifexposed workers are notwearing protective clothing.
In an emergency, entrants maynot be able to exit quickly.
Poor lighting makes it difficultfor workers to enter, exit, andwork in a permit space.
Slipperysurfaces
Corrosivechemicals
Accessproblems
Illuminationproblems
Most permit-space accidents happen for the following reasons:
▼ Workers haven’t been properly trained to recognize permit-space hazards.
▼ Hazards aren’t eliminated or controlled before workers enter the space.
▼ Rescuers are inexperienced or improperly trained.
If you need help identifying permit-space hazards, talk to yourworkers’ compensation insurer or give us a call.
The table below identifies common non-atmospheric hazards,describes how they occur, and explains why you should beconcerned about them.
Non-atmospherichazards
Keep in mind
Getting help
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IF THENOnlycontractworkersenter
You must tell the contractor about the hazards in the space, thatthe contractor must have a written permit-space program thatmeets §1910.146 requirements, and about any special precau-tions necessary to protect those working in or near the space.
Contractworkersand youremployeesenter
You must have a written permit-space program that describeshow you will eliminate or control the permit-space hazards andensure the safety of those who enter the space.You must coordinate entry operations with the contractorso that the contract workers and your employees worksafely together.
Only youremployeesenter
You must have a written permit-space program that describeshow you will eliminate or control the permit-space hazards andensure the safety of those who enter the space.
I f you have a permit space at yourworkplace, will workers enter it? Are
they contract workers or your employees?
Even if workers don’tneed to enter a permitspace, you must make
sure that they’re aware of the space andknow about its hazards. You can do thatby placing a danger sign like this one ➞on the space, or permanently securingthe entrance to the space — welding itshut, for example.
The table below showswhat you must do beforeemployees or contract
workers enter a permit space at yourworkplace.
If workers don’tneed to enter
If workersneed to enter
DANGERPERMIT-REQUIREDCONFINED SPACE
DO NOTENTER
Decideif workerswill entera permit
space.
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Non-permit space: The space is safe to enter and employees can work in it without a permitas long as it is hazard free.
Alternate procedures: Specific procedures that allow workers to enter and work in a permitspace without a permit if continuous forced-air ventilation controls the hazards.
The space hasno atmospherichazards andyou can eliminateall other hazards.
You can reclassify the spaceas a non-permit space.
You must eliminate all hazardsin the space before workersenter and for the entire timethey are in the space.You must document how youeliminated the hazards andcertify the space hazard-free.
The space hasonly an atmo-spheric hazardand you cancontrol it withforced-airventilation.
You must follow your writtenpermit-space program.The program must includethe method for controllingthe hazards, procedures forentry operations, and anentry permit verifying thatthe space is safe to enter.
You can’teliminatehazards inthe space.
You need to enter a mixingtank that has no atmospherichazards but does have mixingpaddles that could startautomatically.You must lock out and/or tagout the mixing-paddle hazardbefore you enter.
Workers can enter the spaceunder alternate procedures:
You must keep the spacehazard-free with continuousforced-air ventilation beforeworkers enter and for theentire time workers are inthe space.You must have test andinspection data that showforced-air ventilation willkeep the space hazard free.
You need to enter a utility vault.You’ve monitored the space foroxygen displacement andenrichment, flammable atmo-spheres and toxic atmo-spheres. You’ve determined anatmospheric hazard exists —for example oxygen deficiency.Your test and inspection datashow that continuous forced-air ventilation will increaseoxygen content to 19.5 percent.You periodically monitor theatmosphere in the spaceto ensure forced-air ventilationmaintains safe entry condi-tions.
You need to enter a sewersystem that contains pocketsof methane and hydrogensulfide, but you can’t eliminatethese hazards with forced-airventilation.
IF THEN EXAMPLE
B efore allowing workers to enter a permit space, you must either eliminate allhazards in the space or control them so that the workers can accomplish their
tasks and leave the space safely.
The table below summarizes the options and gives an example of each.
Eliminateor control
the hazardsin the
space.
Getting help Talk to your workers’ compensation insurer, or give us a call if you needhelp determining how to eliminate or control permit-space hazards.
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The table below summarizes activities and procedures duringentry operations:
Before workers enter a permit space, you must have safe work procedurescovering all phases of the entry process. You must also complete an entry
permit that verifies the permit space is safe for workers to enter.
The table below summarizes pre-entry activities and procedures. Before workersenter the space
Establishentry
procedures.
Workers place warning signs or barriers to keep out unautho-rized persons and to protect entrants from falling objects.
Workers disconnect, lock out, or tag out hazardous equipmentin the space. Identify who will isolate the space and who willinform entrants about hazardous equipment.
Workers eliminate or control the hazards in the space. Includethe method and the steps necessary to eliminate or controlthe hazards.
The entry supervisor tests for atmospheric hazards in the follow-ing order: first for oxygen, then for flammable gases, and finallyfor toxic gases. Employees must be able to observe the test.
Entrants have the equipment they need to do their tasks(including rescue equipment) and they know how to use theequipment.
Attendants know how to respond to emergencies, includingthe following: whom to contact, how to remove entrants, andhow to perform first aid and CPR.
The entry supervisor certifies that the space is safe to enter,signs the entry permit, and posts it on the space so thatauthorized entrants can see it.
Isolate thespace
Eliminate orcontrol atmo-spheric hazards
Test the spacefor atmospherichazards
Identify neces-sary equipment
Contactemergencyresponders
Complete andpost the entrypermit
Guard the space
ACTIVITY ESTABLISH PROCEDURES TO ENSURE THAT
While workersare in the space
ACTIVITY ESTABLISH PROCEDURES TO ENSURE THATMaintaincommunications
Attendants and entrants keep in contact with each other. Theymust know what communications equipment to use and howto use it effectively.
The entry supervisor and authorized attendants know howthey will keep unauthorized persons away from the space.
Authorized attendants continuously monitor the permit spaceatmosphere while workers are inside.
Keep out unau-thorized persons
Monitor the spacefor hazards
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The table below summarizes activities and procedures thatcomplete entry operations:Establish
entryprocedures.
The entry permit documents acceptable entry conditions andverifies that the space is safe for workers to enter. It contains thefollowing information:
▼ Location of the space.
▼ Purpose of entry.
▼ Entry date and the time workers enter the space.
▼ Authorized entrants’ names.
▼ Authorized attendants’ names.
▼ Entry supervisor’s name and signature.
▼ Hazards in the space.
▼ How workers will control hazards so that the space is safe to enter.
▼ Acceptable entry conditions.
▼ Testing data and testers’ initials, certifying that the space is safe to enter.
▼ Names of emergency responders and instructions for contacting them.
▼ Communication procedures used by authorized entrants and attendants.
▼ A list of all equipment necessary to ensure entrants’ safety.
▼ A description of any other permits entrants need to work in the space.
After workersleave the space
ACTIVITY ESTABLISH PROCEDURES TO ENSURE THATCancel the entrypermit
The entry supervisor cancels the permit when entrants finishentry operations or when a condition arises that isn’tidentified on the permit.
Workers return the space to service properly after entrantsexit.
All problems encountered by entrants are recorded and thatthe permit is kept on file for at least one year.
Return the spaceto service
File the permit
The entrypermit
Enter: Technically, entry occurs when any part of a worker’s body moves through theopening of the space.
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A sampleentry permit
CONFINED SPACE ENTRY PERMIT Permit number ____________ Date ______________
Location and Description of Confined Spaces Purpose of Entry
__________________________________ _________________________________
__________________________________ _________________________________
Scheduleda.m.
Start _________________________p.m.
Day Date Time
Scheduleda.m.
Finish _________________________p.m.
Day Date Time
Employee(s) in charge of entry:
EntrantsAttendants
__________________________________ _________________________________
__________________________________ _________________________________
Pre-Entry Authorization (Check those items below which are applicable to your confined space permit.)
❏ Oxygen-Deficient Atmosphere
❏ Oxygen-Enriched Atmosphere
❏ Welding/Cutting
❏ Engulfment
❏ Toxic Atmosphere
❏ Flammable Atmosphere
❏ Energized Electrical Equipment
❏ Entrapment
❏ Hazardous Chemical
Note: If welding/cutting operations are to be performed, attach form (3039) to entry form.
SAFETY PRECAUTIONS
❏ Self-Contained Breathing Apparatus
❏ Air-Line Respirator
❏ Fire-Retardant Clothing
❏ Ventilation
❏ Protective Gloves
❏ Remarks _________________________________________________________________________
❏ Lifelines❏ Respirators
❏ Lockout/Tagout
❏ Fire Extinguishers
❏ Barricade Job Area
❏ Signs Posted
❏ Clearance Secured
❏ Lighting❏ Ground Fault Interrupter
ENVIRONMENTAL CONDITIONS
Tests to be taken Date/Time
Oxygen ___________________ % _______ a/p
Lower Explosive Limit ________ % _______ a/p
Toxic Atmosphere _________________________
Instruments Used _________________________
Re-TestingDate/Time
Oxygen ___________________ % _______ a/p
Lower Explosive Limit ________ % _______ a/p
Toxic Atmosphere _________________________
Instruments Used _________________________
Employee conducting safety checks signature ______________________________________________
Remark on the overall condition of the confined space: _______________________________________
__________________________________________________________________________________
__________________________________________________________________________________
❏ ENTRY AUTHORIZATION — All actions and/or conditions for safe entry have been performed.
Person in charge of entry _______________________________________________________________
Please print
❏ ENTRY CANCELLATION — Entry has been completed and all entrants have exited permit space.
Person in charge of entry _______________________________________________________________
Please print
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Trainworkersfor entry
operations.
Training and educating workers isthe most effective way to ensure
that they can identify permit-spacehazards, follow entry procedures, andrespond appropriately in an emergency.
Those who do permit-space work must under-stand procedures for
entry, know how to control hazards,and know their roles in an emergency.They must receive training in thefollowing situations:
▼ Before their permit-space dutiesare assigned or changed.
▼ When there is a change inpermit-space operations thatpresents a hazard for whichthey haven’t been trained.
▼ When they don’t follow entry-permit procedures.
Trainingrequirements
Training mustbe certified
If you authorize workersto enter a permit space,you must certify that
they have been trained. The certificationmust contain each worker’s name, thetrainer’s signature, and the trainingdates. It must be available for workers orauthorized representatives to review.
Trainers should understand all parts of§1910.146 and have experience withthe types of permit spaces employeeswill enter.
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W orking in permit spaces is a teameffort involving authorized en-
trants, attendants, and supervisors.These key players’ activities are criticalto a safe, successful project.
Authorized entrants arethose permitted by anemployer to enter a
permit space.
Entrants have the following duties andresponsibilities:
▼ Knowing the permit-space haz-ards, including the symptomsand consequences of exposure.
▼ Using equipment properly.
▼ Communicating regularly withthe attendant.
▼ Notifying the attendant immedi-ately of hazardous conditions.
▼ Leaving the space immediatelyduring a hazardous condition orwhen the attendant orders anevacuation.
Authorized attendants arethose who monitor en-trants’ activities from
outside the space. Attendants have thefollowing duties and responsibilities:
▼ Knowing the permit-space haz-ards, including the symptomsand consequences of exposure.
▼ Knowing how many entrants arein permit space.
Make sureworkers
know theirduties andresponsi-
bilities.
Authorizedentrants
▼ Staying out of the space duringentry operations.
▼ Keeping in contact with entrants.
▼ Ordering an evacuation for ahazardous condition.
▼ Keeping unauthorized personsaway from the space.
▼ Activating rescue procedures.
The entry supervisor makessure attendants and entrantsfollow entry-permit proce-
dures. The entry supervisor is responsiblefor the following:
▼ Knowing the permit-space haz-ards, including the symptomsand consequences of exposure.
▼ Verifying that the entry permit isaccurate and current.
▼ Stopping entry operations andcanceling the entry permit whenpermit-space work is done orduring a hazardous condition.
▼ Ensuring that responders will beavailable in an emergency.
▼ Removing any unauthorizedperson who enters the space.
▼ Ensuring that entry operations areconsistent if another authorizedperson must replace an attendantor an entrant.
Authorizedattendants
The entrysupervisor
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OREGON OCCUPATIONAL SAFETY & HEALTH DIVISION
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Plan foremergencies.
Employer’sresponsibilities
On-site oroff-site
responders?
Responders’responsibilities
Emergency respondershave the followingresponsibilities:
▼ Have the equipment necessaryto perform rescues and knowhow to use it.
▼ Be trained as rescuers and asauthorized entrants.
▼ Practice simulated rescues atleast once a year at each on-sitepermit space.
▼ Keep their first-aid and CPRtraining up to date.
You can choose either anon-site or an off- siteresponder. It’s importantonly that the responder
meet your needs in an emergency. Usethe table on the following page to helpyou decide.
B efore you authorize workers to entera permit space, you must be sure
that experienced emergency responderswill be available if an entrant needs help.Responders must be able to reach yourworksite promptly and know how to dealwith the emergency effectively.
Most permit-space fatalities are causedby those who don’t understand permit-space hazards or who respond inappro-priately during emergencies.
Most fire departments are not equippedto respond to permit-space emergencies.
Employers must tellemergency respondersabout any permit-space
hazards they may encounter during anemergency, must ensure that responderscan reach the space promptly, and mustallow responders to practice rescues atall on-site permit spaces.
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Steps to Take ConsiderationsIdentify your needs Do you anticipate emergencies requiring immediate action
(if ventilation fails, for example)? Or less-than-immediateaction (if the most serious accident would cause a fractureor abrasion)?
Interview them Meet with the responders to find out if they can providethe emergency service you need. Posting an emergency-response number 911 for example isn’t enough.
How quickly can they The response time must be appropriate to the type ofreach your site? potential injury; responders must be standing by when
employees are working under potential IDLH (immediatelydangerous to life and health) conditions.
Will they be available The responders must be available any time your workerswhen you need them? need to enter a permit space.
How will you contact Do you have a way for an authorized attendant or an entrythe responders? supervisor to reach responders immediately?
Can they do technical Do they have the technical knowledge and equipment torescues? perform rope work or elevated-rescue work?
Can they do medical Do your responders have the skills and equipment forevacuations? medical evacuations?
Are they trained as Can the responders recognize the signs, symptoms, andpermit-space consequences of exposure to a hazardous atmosphere in aentrants? permit space at your workplace?
Do they know how to For example, do they know how to determine whether thetest the atmosphere atmosphere is immediately dangerous to life and health?in a permit space?
Will they understand For example, will responders understand the ventilation andthe information on atmospheric testing data on the entry permit?your entry permit?
Plan foremergencies.
IDLH (Immediately Dangerous to Life or Health): atmospheric concentration of any toxic,corrosive, or asphyxiate substance that poses an immediate threat to life or would interferewith one’s ability to escape from a permit space.
CHOOSING AN EMERGENCY RESPONDER
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OREGON OCCUPATIONAL SAFETY & HEALTH DIVISION
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T he diagram below describes the permit-space entry process fromstart to finish.A diagram
of the entryprocess Does the workplace contain confined spaces as defined by §1910.146(b)?
Does the workplace contain permit-required confined spaces as defined by §1910.146(b) Consult otherapplicable OSHAstandards STOP
Inform employees as required by §1910.146(c)(2).
Will permit spaces be entered?Prevent employee entry as required by §1910.146(c)(3).Do task from outside of space.
Will contractors enter?Task will be done by contractor’s employees. Inform contractor asrequired by §1910.146(c)(8)(i), (ii) and (iii). Contractor obtainsinformation required by §1910.146(c)(9)(i), (ii) and (iii) from host.
Both contractors and host employees will enter the work space?
Will host employees enterto perform entry tasks?
Coordinate entry operations as required by §1910.146(c)(8)(iv) and (d)(11). Prevent unauthorized entry.
Prevent unauthorized entry. STOP
STOP
STOP
Audit program and permit based on evaluation of entryby entrants, attendants, testers and preparers.
Does space have known or potential hazards? Not a permit-required confined space. §1910.146does not apply. Consult other OSHA standards.
Can the hazards by eliminated? Employer may choose to reclassify space to non-permitrequired confined space using §1910.146(c)(7)
Can the space be maintained in a condition safeto enter by continuous forced-air ventilation only? Space may be entered under §1910.146(c)(5).
Prepare for entry via permit procedures.
Verify acceptable entry conditions (Test results recorded, space isolated ifneeded, rescuers/means to summon available, entrants properly equipped.)
Permit notvalid untilconditionsmeet permitspecifications.
Permit issued by authorizing signature. Acceptableentry conditions maintained throughout entry?
Emergency exists (prohibited condition).Entrants evacuated entry aborts. (Callrescuers if needed.) Permit is void.Re-evaluate program to correct/preventprohibited condition. Occurrence ofemergency (usually) is proof of deficientprogram. No re-entry until program(and permit) is emended. (May requirenew program.)
Continue.
Entry tasks completed. Permit returned and canceled.
Yes
Yes
Yes
No
No
No
No
Yes
Yes
Yes
No
Yes
Yes
No
No
Yes
No
No
Yes
No
No
Yes
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THEY’RE NOT DESIGNED TO BE OCCUPIED – How to work safely in a permit-required confined space
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A permit-space pro-gram is an employer’splan for protecting
workers who need to enter a permit space.
A written permit-space program docu-ments the plan’s activities and puts themin writing.
These activities should cover all aspectsof working in or near permit spaces —from identifying the locations of thespaces to evaluating the program’seffectiveness.
What is apermit-
spaceprogram,
and do Ineed one?
What is a permit-space program?
If workers need toenter a permit spaceat your workplace,you must have a
written permit-space program. Thisguide highlights the activities you shouldinclude in a written program. (§1910.146covers them in detail.)
Your written permit-space program doesn’tneed to be a massivedocument. It should
clearly tell what activities and procedureswill ensure the safety of those who work
in permit spaces atyour workplace. Itmust be available foremployees to review.
We’ve included ageneric program thatyou can use to de-velop a program foryour workplace.Make it an effectiveone. It shouldreflect the needsof your workplaceand ensure thesafety of yourcoworkers oremployees.
Permit-Space Program
This written program
includes activities and
procedures to identify
permit spaces; evaluate
the spaces for hazards;
and enter, work in, and
terminate entry in accord
with §1910.146.
Program Contents
• Policy statement
• Employer responsibilities
• Permit-space locations
and hazards
• Informing employees and
preventing unauthorized entry
• Entry procedures
• Entry-permit procedure
• Pre-entry training
• Duties of entrants, attendants,
and supervisors
• Emergency response
• Program evaluation
Does yourworkplace need awritten program?
Developing aprogram for
your workplace
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OREGON OCCUPATIONAL SAFETY & HEALTH DIVISION
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1A Generic permit-space program
A generic permit-space program
◆ How to use this generic program
◆ Policy statement
◆ Employer responsibilities
◆ Permit-space locations and hazards
◆ Informing employees and preventingunauthorized entry
◆ Entry procedures
◆ Entry-permit procedure
◆ Pre-entry training
◆ Duties of entrants, attendants,and supervisors
◆ Emergency response
◆ Program evaluation
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2 A Generic permit-space program
Your written permit-space program documents activities and proce-dures that will ensure the safety of those who work in permit spaces atyour workplace.
• First, think about the characteristics of the permit spaces at yourworkplace, the tasks that workers need to accomplish in andaround the spaces, and the workers’ experience in permit spaces.
• Then, use this generic program to help you develop, organize, anddocument the activities that form your own program.
• Remember, this is just an outline for your program. It’s not com-plete until you include all the activities and procedures that make itunique to your workplace.
• If you need help, contact Oregon OSHA:
How to use this generic program
BendRed Oaks Square1230 NE Third St., Ste. A-115Bend, OR 97701-4374(541) 388-6066Consultation: (541) 388-6068
Medford1840 Barnett Rd., Ste. DMedford, OR 97504-8250(541) 776-6030Consultation: (541) 776-6016
Pendleton721 SE Third St., Ste. 306Pendleton, OR 97801-3056(541) 276-9175Consultation: (541) 276-2353
Salem Central Office350 Winter St. NE, Rm. 430Salem, OR 97301-3882
Phone: (503) 378-3272Toll-free: (800) 922-2689Spanish language: 1 (800) 843-8086Fax: (503) 947-7461Visit us on World Wide Web:www.orosha.org
Portland1750 NW Naito Parkway,Ste. 112Portland, OR 97209-2533(503) 229-5910Consultation: (503) 229-6193
Salem1225 Ferry St. SE, U110Salem, OR 97301-4282(503) 378-3274Consultation: (503) 373-7819
Eugene1140 Willagillespie, Ste. 42Eugene, OR 97401-2101(541) 686-7562Consultation: (541) 686-7913
(All phone numbers are voiceand TTY.)
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3A Generic permit-space program
This generic program has the following parts:
• Policy statement
• Employer responsibilities
• Permit-space locations and hazards
• Informing employees and preventing unauthorized entry
• Entry procedures
• Entry-permit procedure
• Pre-entry training
• Duties of authorized entrants, attendants, and supervisors
• Emergency response
• Program evaluation
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4 A Generic permit-space program
[ Company name ] is committed to a safe and
healthful workplace for its employees. The purpose of
this written program is to identify permit spaces at this
workplace and to ensure that all employees will enter,
work in, and exit permit spaces safely.
Policy statement
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5A Generic permit-space program
Employer responsibilities
[ Company name ] will do the following to ensure the health and safety ofthose who work in and around permit spaces.
• Identify all permit spaces
• Inform employees of the location and the hazards in permit spaces
• Prevent unauthorized persons from entering permit spaces
• Train entrants, attendants, entry supervisors, and in-houseemergency responders
• Provide all necessary equipment for permit-space work at no cost toemployees, maintain the equipment, and ensure that employees usethe equipment properly
• Inform contractors about the permit-space program and coordinateentry operations
• [ Company name ] designates the following persons to implementand manage the permit-space program.
Overall program. Overall implementation and mainte-nance of the written program, including employeecertification or training that satisfies the requirementsof 1910.146.
Permit-space locations. Location and identification ofall confined spaces at this workplace.
Training. Ensure that authorized entrants, attendants,entry supervisors, and on-site emergency respondersare properly trained and have periodic refresher train-ing.
Emergency response. Ensure that emergency re-sponders are informed of all permit-required confinedspaces at the workplace and have access to the spacesfor drills and other training exercises.
Equipment. Ensure that all equipment for authorizedattendants and entrants is properly maintained and isavailable when needed.
PERSON’S NAME OR POSITION RESPONSIBILITY
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6 A Generic permit-space program
Permit-space locations and hazards
[ Company representative’s name ] has surveyed the workplace and identi-fied the following permit spaces, the hazards in the spaces, and themethod(s) necessary to eliminate or control the hazards.
Non-permit spaces –no atmospherichazards
LOCATION OF SPACE HAZARD HOW HAZARD PERSON CERTIFYING THATWAS ELIMINATED THE SPACE IS HAZARD FREE
Non-permit spaces –atmospheric hazards
These spaces have atmospheric hazards that canbe eliminated with continuous forced-air ventila-tion before workers enter. Employees can enterand work in them without a permit as long as theyare hazard-free.
Permit-required spaces These spaces have atmospheric hazards thatcannot be eliminated with continuous forced-airventilation. Employees can enter them ONLYunder the entry-permit procedures established inthis written program.
LOCATION OF SPACE ATMOSPHERIC HAZARD PERSON CERTIFYING THATTHE SPACE IS HAZARD FREE
LOCATION OF SPACE HAZARDS METHOD OF RESCUE METHODCONTROLLING HAZARDS
These spaces have no atmospheric hazards and allother hazards have been eliminated. Employeescan enter and work in them without a permit aslong as the spaces are hazard-free.
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7A Generic permit-space program
[ Company name ] will use the following methods to inform employeesabout each permit space in the workplace and to prevent unauthorizedworkers from entering them.
Informing employees & preventing unauthorized entry
LOCATION OF SPACE METHOD TO INFORM METHOD TO PREVENT ENTRY
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8 A Generic permit-space program
Entry procedures
Guarding the space [Identify procedures]
Isolating the space [Identify procedures]
Eliminating or controlling atmospheric hazards [Identify procedures]
Testing the space for atmospheric hazards [Identify procedures]
Identifying necessary equipment [Identify procedures]
Contacting emergency responders [Identify procedures]
Completing and posting the entry permit [Identify procedures]
Beforeemployeesenter thespace
Whileemployeesare in thespace
Afteremployeesleave thespace
All employees involved in entry operations must follow the proceduresbelow for each phase of the entry process.
ACTIVITY PROCEDURES
Canceling the entry permit [Identify procedures]
Returning the space to service [Identify procedures]
Filing the permit [Identify procedures]
Maintaining communication [Identify procedures]
Keeping out unauthorized persons [Identify procedures]
Monitoring the space for hazards [Identify procedures]
ACTIVITY PROCEDURES
ACTIVITY PROCEDURES
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9A Generic permit-space program
No employee will enter a permit-required confined space without firstcompleting an entry permit and having the entry supervisor sign thepermit. The steps of the entry-permit procedure include the following:
Entry-permit procedure
1 Obtain an entry permit from [location or person] before entering the space.
2 Accomplish all pre-permit activities required for entering the space,including atmospheric testing, controlling hazards, having required equip-ment on hand, and providing for emergency services.
3 Complete all items on the entry permit.
4 Have the entry supervisor authorize and sign the permit. If any item on thepermit is checked as “NO” (meaning not yet completed or available), thepermit will not be signed.
5 Attach a copy of the entry permit outside the confined space. Keep it thereuntil the entry operations are finished and the supervisor cancels it.
6 Proceed with entry operations.
STEP ACTION
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10 A Generic permit-space program
Pre-entry training
Only trained and qualified employees will be authorized as entrants,attendants, entry supervisors, or in-house emergency responders.Training will ensure that they have the understanding, knowledge, andskills to perform their duties safely. Workers must receive training:
• Before their duties are assigned or changed.
• When their work presents a hazard for which they haven’t beentrained.
• When they do not follow entry procedures.
The table below certifies the following employees have received pre-entry training.
EMPLOYEE NAME TYPE OF TRAINING TRAINER’S SIGNATURE TRAINING DATE
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11A Generic permit-space program
Working in permit spaces is a team effort involving authorized entrants, atten-dants, and supervisors. Their duties and responsibilities are shown below.
Duties of authorized entrants, attendants, and supervisors
Keep unauthorized entrants away from the space. X X
Remove unauthorized individuals who enter or Xwho attempt to enter the permit space.
Communicate with entrants, monitor their status, Xand tell them when to evacuate.
Inform the entrants and the entry supervisor if Xunauthorized persons enter the permit space.
Communicate with the attendant regularly. X
Remain outside the space during entry Xoperations until relieved by another attendant.
Know the number and identity of authorized Xentrants.
Use all equipment properly. X
Determine that acceptable entry conditions are Xmaintained.
Exit from the permit space immediately given an Xorder to evacuate, an alarm warning, or a sign ofa hazardous condition.
Know permit-space hazards, including the mode, X X Xsymptoms, and consequences of exposure.
Notify the attendant of any signs or symptoms of Xexposure to a hazardous condition
Terminate the entry and cancel the permit when Xentry operations are finished or if a prohibitedcondition arises.
Verify that entry conditions are acceptable before Xsigning the permit and allowing entry.
Perform non-entry rescues if necessary. X
Verify that rescue services are available and the Xmeans for summoning them are effective.
Summon emergency responders when entrants Xneed their services
DUTY/RESPONSIBILITY ENTRANT ATTENDANT SUPERVISOR
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12 A Generic permit-space program
Non-entry rescue is the preferred method for rescuingan entrant from a permit space. Employees must useretrieval systems to rescue an entrant unless the equip-ment would increase the entrant’s risk of injury.
Employees will not enter a permit space to respond toan emergency unless they have been properly trainedand equipped.
If a permit space rescue is necessary, the attendant isresponsible for doing the following:
• Summoning emergency responders.
• Attempting to rescue entrants using only non-entry rescue equipment.
• Monitoring the emergency and informingresponders about the number of victims, theircondition, and the hazards in the space.
Only responders designated by [ Company name ] canenter a permit space during an emergency. Each emer-gency responder must know how to do the following:
• Use personal protective and rescue equipment.
• Perform assigned rescue duties.
• Perform basic first aid and CPR.
Each rescue team member must practice a permit-space rescue at least once every 12 months.
[ Company representative’s name ] has made arrangementswith the following off-site responder to provide rescueand emergency services:
Emergency response
Non-entry rescuerequirements
Entry rescuerequirements
Summoning off-site responders
Name of responder: _____________________________
Phone: _________________________________________
Address: ________________________________________
Approximate response time: ______________________
[ Company representative’s name ] has informed [ Name of off-site rescue service ]of the hazards they may encounter if they are summoned.[ Company representative’s name ] also has provided the rescueservice access to permit spaces to develop appropriaterescue plans and practice rescues.
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13A Generic permit-space program
Within one year of an entry operation, [ Company representative’s name ]
must review canceled entry permits to identify program
deficiencies. The review must be sooner if there is reason to
believe that the program does not adequately protect
employees. Actions to correct deficiencies must be documented
and affected employees must be retrained.
Program evaluation
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14 A Generic permit-space program
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Notes
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OR-OSHA ServicesOR-OSHA offers a wide variety of safety and health services to employers and employees:
Consultative Services• Offers no-cost on-site safety and health assistance to Oregon employers for help in
recognizing and correcting safety and health problems in their workplaces.• Provides consultations in the areas of safety, industrial hygiene, ergonomics, occupational
safety and health programs, new business assistance, and the Safety and HealthAchievement Recognition Program (SHARP).
Enforcement• Offers pre-job conferences for mobile employers in industries such as logging and
construction.• Provides abatement assistance to employers who have received citations and provides
compliance and technical assistance by phone.• Inspects places of employment for occupational safety and health rule violations and
investigates workplace safety and health complaints and accidents.
Standards & Technical Resources• Develops, interprets, and provides technical advice on safety and health standards.• Provides copies of all OR-OSHA occupational safety and health standards.• Publishes booklets, pamphlets, and other materials to assist in the implementation of safety
and health standards and programs.• Operates a Resource Center containing books, topical files, technical periodicals, a video and
film lending library, and more than 200 databases.
Public Education & Conferences• Conducts conferences, seminars, workshops, and rule forums.• Coordinates and provides technical training on topics like confined space, ergonomics,
lockout/tagout, and excavations.• Provides workshops covering basic safety and health program management, safety
committees, accident investigation, and job safety analysis.• Manages the Voluntary Protection Program and the Safety and Health Education and
Training Grant Program, which awards grants to industrial and labor groups to developoccupational safety and health training materials for Oregon workers.
Portland1750 NW Naito Parkway, Ste. 112Portland, OR 97209-2533(503) 229-5910Consultation: (503) 229-6193Salem1225 Ferry St. SE, U110Salem, OR 97301-4282(503) 378-3274Consultation: (503) 373-7819Eugene1140 Willagillespie, Ste. 42Eugene, OR 97401-2101(541) 686-7562Consultation: (541) 686-7913
BendRed Oaks Square1230 NE Third St., Ste. A-115Bend, OR 97701-4374(541) 388-6066Consultation: (541) 388-6068Medford1840 Barnett Rd., Ste. DMedford, OR 97504-8250(541) 776-6030Consultation: (541) 776-6016Pendleton721 SE Third St., Ste. 306Pendleton, OR 97801-3056(541) 276-9175Consultation: (541) 276-2353
For more information, call theOR-OSHA office nearest you.(All phone numbers are voice and TTY.)
Salem Central Office350 Winter St. NE, Rm. 430Salem, OR 97301-3882Phone: (503) 378-3272Toll-free: (800) 922-2689Spanish language: 1 (800) 843-8086Fax: (503) 947-7461Visit us on World Wide Web:www.orosha.org
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440-2864 (6/01) (OR-OSHA/COM)