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St. Lawrence University Confined Space Policy Table of Contents 1. Introduction ................................................................................................................................. 2 2. Identifying Confined Spaces ....................................................................................................... 3 3. Identifying Confined Space Hazards .......................................................................................... 5 4. Confined Space Entry Procedures .............................................................................................. 7 5. Personnel Responsibilities ........................................................................................................ 10 6. Emergency Protocol .................................................................................................................. 11 7. Training ..................................................................................................................................... 12 8. Recordkeeping .......................................................................................................................... 12 9. Contractors ................................................................................................................................ 13 10. Permits .................................................................................................................................... 13 Appendix A: Definitions ............................................................................................................... 14 Appendix B: Confined Space Recognition Form ......................................................................... 17 Appendix C: Confined Space Pre-Entry Checklist ....................................................................... 19 Appendix D: Confined Space Entry Permit .................................................................................. 20 Appendix E: St. Lawrence University Confined Space List......................................................... 23 Appendix F: Copy of Standard St. Lawrence University Confined Space Policy 10/20/06 (Rev 2) 1

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St. Lawrence University

Confined Space Policy

Table of Contents

1. Introduction................................................................................................................................. 2 2. Identifying Confined Spaces....................................................................................................... 3 3. Identifying Confined Space Hazards .......................................................................................... 5 4. Confined Space Entry Procedures .............................................................................................. 7 5. Personnel Responsibilities ........................................................................................................ 10 6. Emergency Protocol .................................................................................................................. 11 7. Training..................................................................................................................................... 12 8. Recordkeeping .......................................................................................................................... 12 9. Contractors................................................................................................................................ 13 10. Permits .................................................................................................................................... 13 Appendix A: Definitions............................................................................................................... 14 Appendix B: Confined Space Recognition Form ......................................................................... 17 Appendix C: Confined Space Pre-Entry Checklist....................................................................... 19 Appendix D: Confined Space Entry Permit .................................................................................. 20 Appendix E: St. Lawrence University Confined Space List ......................................................... 23 Appendix F: Copy of Standard

St. Lawrence University Confined Space Policy 10/20/06 (Rev 2) 1

1. Introduction

Scope: In accordance with the St. Lawrence University Confined Space Policy, thefollowing confined space guidelines have been designed to provide theappropriate health and safety requirements that are to be followed whenentering, exiting, and working in our confined spaces. The guidelinescontained herein describe the reasonable and necessary policies andprocedures for any and all facilities, departments, and individuals who areassociated with confined space entry operations. This program and all partsof 29 CFR 1910.146 shall apply to all confined space entry operationsconducted at St. Lawrence University. The responsible department for thispolicy is EH&S.

Purpose: To establish guidelines and performance objectives for the health and safetyof St. Lawrence University employees and contractors that are to perform workin both permit and non-permit required confined spaces at St. LawrenceUniversity.

Application: The St. Lawrence University Confined Space Guidelines and other applicablerequirements found herein shall at least comply with, if not exceed, local,state and federal requirements. It is the responsibility of all Collegepersonnel and contractors working in all confined spaces at St. LawrenceUniversity to adhere to this confined space guideline; unless the use of astricter guideline, policy or program is utilized.

St. Lawrence University Confined Space Policy 10/20/06 (Rev 2) 2

2. Identifying Confined Spaces

Recognition is an important aspect of making a safe entry into a confinedspace. It is the responsibility of St. Lawrence University to identify allconfined spaces and determine whether or not they are permit or non-permitrequired. An inventory of all permit-required confined spaces will bemaintained and on file at Facilities Operations, Safety & Security and theoffice of Environmental Health & Safety. All permit-required confined spaceswill be appropriately identified, example, conspicuously posted sign reading,“DANGER – CONFINED SPACE – ENTER BY PERMIT ONLY”. To clarify whatconstitutes a confined space, the following definition will be used(Additional definitions are found in Appendix A).

A Confined Space is any space that has the following characteristics:

1. It is large enough or so configured that an employee can bodily enter andperform assigned work.

2. It has limited or restricted means for entry or exit. Confined-spaceopenings are limited primarily by size and location. Openings may be small insize and may be difficult to move through easily. However, in some cases,openings may be very large; for example, open-topped spaces such as pits orexcavations. Entrance and exit may be required from top, bottom, or side. Insome cases, having to access the work area by a fixed ladder may constitutelimited or restricted entry or exit. Size or location will generally makerescue efforts difficult.

3. It is not designed for continuous employee occupancy. Most confined spacesare not designed for employees to enter and work on a routine basis. Becausethey are not designed for continuous occupancy, frequently they will not havegood ventilation or lighting. Therefore, occasional employee entry forinspection, maintenance, repair, cleanup, or similar tasks, can be difficultand dangerous. The danger associated with entry may come from chemical orphysical hazards within the space.

Non-Permit vs. Permit Required Confined Spaces - The areas deemed to bepermit-required shall have signage or other equally effective means ofidentification at any and all entrances to the confined space. Areas thathave been identified as “non-permit” required confined spaces, that must beentered for the purpose of cleaning, brazing, cutting, heating, soldering andwelding or which contains water or other known or potential hazard shall beclassified either temporarily or permanently as a “permit required” confinedspace.

A Non-Permit Confined Space is a confined space that does not contain, norhas the potential to contain, any hazard capable of causing death or seriousphysical harm. Examples of non-permit required confined spaces might includethe interiors of HVAC units, boilers, tanks, certain air plenums and pipechases, attics, walk-in freezers or refrigerators, and some building crawlspaces.

The confined space recognition form is located in Appendix B.

St. Lawrence University Confined Space Policy 10/20/06 (Rev 2) 3

A Permit-Required Confined Space has one or more of the followingcharacteristics:

1. Contains or has a potential to contain a hazardous atmosphere.2. Contains a material that has the potential for engulfing an entrant.3. Has an internal configuration such that an entrant could be trappedor asphyxiated by inwardly-converging walls or by a floor thatslopes downward and tapers to a smaller cross-section; or4. Contains any other recognized serious safety or health hazard.Examples of serious safety or health hazards might include: fallhazards, unguarded machinery, extreme heat or cold, steam pipes orchemical lines, electrical hazards, asbestos, or hazardous levels ofdust. Examples of permit-required confined spaces at St. LawrenceUniversity might include steam tunnels, sewers, electrical vaults,boilers, tanks and vessels, excavations greater than 5 ft. deep, andother types of enclosures. Without exception, any space that isaccessed by lifting a manhole cover shall be considered a permit-required confined space.

St. Lawrence University Confined Space Policy 10/20/06 (Rev 2) 4

3. Identifying Confined Space Hazards

Acceptable and Unacceptable Atmospheric Conditions - Once a confined spacehas been identified, the hazards that may be present within this area must beidentified. Confined-space hazards can be grouped into the followingcategories: 1) Oxygen deficient atmospheres, 2) flammable atmospheres, 3)toxic atmospheres, and 4) mechanical and physical hazards.

Every confined space must be evaluated for these four types of hazards. Thetypes of atmospheric hazards are often the most difficult to identify sincethey are normally invisible. The most common toxic atmospheres are carbonmonoxide, methane, and hydrogen sulfide (sewer gas). Carbon monoxide iscolorless and odorless and will readily mix with the air thus making itimpossible to detect without the use of equipment. Methane gas is lighterthan air and will rise to its highest level. Hydrogen sulfide can beinitially detected by the “rotten eggs” odor and it is heavier than air andwill seek its’ lowest point. After evaluation by a qualified person, theatmospheric conditions of a confined space shall be considered acceptableprovided:

Oxygen - is between 19.5% and 23.5%Flammability - is less than 10% of the LEL or LFLCarbon Monoxide - is less than 35 ppmHydrogen Sulfide - is less than 10 ppm Toxicity - is less thanrecognized exposure limits (i.e. PEL or TWA)

1. Oxygen-Deficient Atmospheres - The normal atmospheric conditions arecomprised of approximately 21% oxygen and 79% nitrogen. An atmospherecontaining less than 19.5% oxygen shall be considered oxygen-deficient. Theoxygen level inside a confined space may be decreased as the result of eitherconsumption or displacement. There are a number of processes which consumeoxygen in a confined space. Oxygen is consumed during combustion of flammablematerials, as in welding, cutting, or brazing. Oxygen can also be consumedduring chemical reactions such as in the formation of rust on the exposedsurfaces of a confined space. The number of people working in a confinedspace and the amount of physical activity can also influence oxygenconsumption. Oxygen levels can also be reduced as the result of oxygendisplacement by other gases.

2. Flammable Atmospheres - Flammable atmospheres are generally the result offlammable gases, vapors, and dust mixed in certain concentrations with air,or an oxygen-enriched atmosphere. Oxygen-enriched atmospheres are thoseatmospheres which contain an oxygen concentration greater than 23.5%. Anoxygen-enriched atmosphere will cause flammable materials such as clothingand hair to burn violently when ignited. Combustible gases or vapors canaccumulate within a confined space when there is inadequate ventilation.Gases that are heavier than air will accumulate in the lower levels of a confined space. Therefore, it is especially important that atmospheric testsbe conducted near the bottom of all confined spaces. The work being conductedin a confined space can generate a flammable atmosphere. Work such as spraypainting, coating, or the use of flammable solvents for cleaning can resultin the formation of an explosive atmosphere. Welding or cutting withoxyacetylene equipment can also be the cause of an explosion in a confinedspace and shall not be allowed without a hot work permit. The atmosphereshall be tested continuously while any hot work is being conducted within theconfined space.

St. Lawrence University Confined Space Policy 10/20/06 (Rev 2) 5

3. Toxic atmospheres may be present within a confined space. Toxicatmospheres can be generated as the result of work being conducted inside theconfined space. Examples of such work include: Welding or brazing with metalscapable of producing toxic vapors, painting, scraping, sanding, etc. Many ofthe solvents used for cleaning and/or degreasing produce highly toxic vapors.

Areas Adjacent to the Confined Space - Toxic fumes produced by processes nearthe confined space may enter and accumulate in the confined space. Forexample, if the confined space is lower than the adjacent area and the toxicfume is heavier than air, the toxic fume may "settle" into the confinedspace.The product stored in the Confined Space - When a product is stored in aconfined space, the product can be absorbed by the walls and give off toxicvapors when removed or when cleaning the residual material. The product canalso produce toxic vapors which will remain in the atmosphere due to poorventilation.

4. Mechanical and Physical Hazards -Problems such as rotating or movingmechanical parts or energy sources can create hazards within a confinedspace. All rotating or moving equipment such as pumps, process lines,electrical sources, etc., within a confined space must be identified andlocked/tagged out.Physical factors such as heat, cold, noise, vibration, and fatigue cancontribute to accidents. These factors must be evaluated for all confined spaces entry operations. Excavations could present the possibility ofengulfment. Employees shall be protected from cave-ins by sloping, benching,or shoring systems when the depth of the excavation is more than five feet,in accordance with 29 CFR 1926.652.

St. Lawrence University Confined Space Policy 10/20/06 (Rev 2) 6

4. Confined Space Entry Procedures

Prior to entering a “permit required” confined space, an entry permit must beobtained from the Security and Safety Office by the appropriate departmentmanager (i.e. manager overseeing the work). A copy of the permit is locatedin Appendix D. After obtaining the permit, the individual(s) must determineif the area requires alarm de-activation. If so, an official of St. LawrenceUniversity (i.e. F.O.,EH&S, Fire Safety or Security) must be summoned to doso. Safety & Security will notify and coordinate with the Canton FireDepartment (CFD) all permit required confined space entries. Without exception, prior to entering into any permit required confined space the St.Lawrence University Security Department shall be notified of the entry. In addition, security will also be provided the completed entry permit which hasbeen filled out by the appropriate department manager. Upon exiting thespace for an extended period of time (end of work) notification will also bemade to the Security Department. After notification, the single mostimportant procedure before entering any confined space is to use a meter totest the atmospheric hazards present.

Entry Specific Procedures: All confined spaces at St. Lawrence University must have a written procedurethat must be followed before entering. The pre-entry checklist is located inAppendix C. A list of confined spaces at St. Lawrence University is locatedin Appendix E.

Vertical entries - for all vertical entries a tripod or other appropriatesupporting device, along with a manual winch with a minimum 25:1 ratiosecurely attached to a full body harness, must be used.

Tunnel Entry - All tunnels are to be considered permit-required; they arelocked to prevent regular access and must be opened by an Official of St.Lawrence University. When entering/re-entering a tunnel the three readingrule shall always apply. Atmospheric readings must be recorded outside,immediately inside (i.e. break the plane), and at the final destinationwithin the tunnel. If at any point prior to entry, a determination is madethat the atmosphere is not suitable for entry, as prescribed herein, theappropriate manager must be notified. All applicable requirements of thepermit shall be met before entry is made. This may include, but is notlimited to eliminating atmospheric hazards by purging or ventilating,isolating hazardous energy (lock-out/tag out), requiring the use of PPE,providing communication equipment, etc.. In certain situations, entrants maybe required to have a Scott Skat-Pac with them during any operations in the tunnels. Light sticks are also provided in the event of a power failure.1. Confined Space Entry Permit in hand to enter, (Sewer, Storm Drains, andElectrical)2. Air testing to be done at 1ft. intervals all the way to the bottom of thearea. Testing before and during operations in these areas is essential.3. Tripod to be set up before entering.4. Full body harness to be worn during operations.5. Ventilation equipment to be on the job.6. If ventilation is required, Appropriate manager to be present beforeentering.7. Attendant to be on stand-by outside the hole at all times, equipped with aradio/phone for communication. A backup signaling system must also beestablished, ie: number of pulls on rope, etc. The attendant may not leavetheir post while a co-worker is in the confined space. Trained attendants can rotate but all must be named on the permit and must sign in and out.

St. Lawrence University Confined Space Policy 10/20/06 (Rev 2) 7

Boilers 1. Confined Space Entry Permit required before entering.2. Attendant outside the boiler with a radio/phone at all times. Same as for tunnels. 3. Lock out all electrical power to boiler during this operation using theproper lockout/tag out procedures.

Tanks & Vessels (none existing 10/06)1. Permit required for entry.2. Air testing to be done before and during operations in these areas.3. Ventilation equipment will be required and closely monitored.4. Attendant required with a radio/phone for communication, (supervisorshould be present during these operations). Same as for tunnels. 5. Supplemental oxygen breathing equipment or a PAPR will be required for anyduties performed.6. Proper lighting for safe operations.

Electrical Vault or Rooms 1. Permit required to enter underground vaults, no permit needed for electricrooms. 2. Attendant required outside electrical room with a radio/phone at alltimes. Same as for tunnels. 3. An electrical vault is permit required area, follow manhole procedures.

Manhole Entry - Sewers, storm drains, and electrical manholes are to beconsidered permit-required confined spaces. In addition to the initialtraining, initial site specific manhole entry training will be provided uponthe first request for entry.

St. Lawrence University Confined Space Policy 10/20/06 (Rev 2) 8

5. Personnel Responsibilities

The employer shall ensure that all personnel who are to be considered forconfined space entry, monitoring and associated work are authorized, trainedand periodically evaluated to perform the work. The responsibilities for eachposition are identified below. The permit can be revoked at any time by theattendant, entry supervisor or other qualified person if a condition arisesor exists that may cause illness, injury or death to the confined spaceentrants. Responsibilities are:1. The person that revokes the permit shall make sure that all confined spaceentrants have been evacuated and accounted for. 2. They shall then indicate on the permit the reasons for revocation.3. They shall then notify Security Office or if warranted summon 5555 via theSecurity Radio or cell phone provided to the attendant.Entry Supervisors: 1. Ensuring that the required atmospheric tests are performed at the confinedspace and results recorded on the permit prior to entry authorization.2. Obtaining and maintaining all equipment necessary to complete theconfined-space entry project.3. Authorizing entry by signing the Entry Authorization space on the entrypermit after all conditions for a safe entry have been met.4. Terminating the entry and canceling the permit when:

a. Entry operations covered by the entry permit have been completed.b. A condition that is not allowed under the entry permit arises in ornear the permit space.c. Determining, whenever responsibility for a permit space entryoperation is transferred, and at intervals dictated by the hazards andoperations performed within the space, that entry operations remainconsistent with terms of the entry permit and that acceptable entryconditions are maintained.

Authorized Entrants: 1. Shall be familiar with the known or potential hazards before entry andwhile working in the confined space - hazards might include: asbestos,electrical, environmental conditions, fire, signs and symptoms of exposure,and steam. 2. Shall not enter the confined space until the appropriate equipment is onsite and placed into operation:

. manual winch – minimum 25:1 ratio • Tripods and rescue equipment• Ventilation equipment• Portable radios or cellular phones

3. Shall learn and become familiar with the operation of equipment such asthe air monitors, tripod, harnesses, lifelines, portable radios, etc.4. Shall remain in communication with the attendant at all times in case there is a need to evacuate the confined space5. Shall alert the attendant whenever:

• The entrant recognizes a dangerous condition or possible exposure• The entrant detects a prohibited condition

6. Shall exit the confined space as quickly as possible whenever:• An order to evacuate is given by a “qualified” St. LawrenceUniversity employee• The entrant recognizes a dangerous condition or possible exposure• The entrant detects a prohibited condition

St. Lawrence University Confined Space Policy 10/20/06 (Rev 2) 9

Attendants: 1. Shall be familiar with the known or potential hazards before entry andwhile entrants are working in the confined space - hazards may include:

• Equipment malfunctions• Loss of communication • Pedestrian and vehicle hazards • supply or exhaust ventilation shut-down• Vehicle exhaust infiltration

2. Shall maintain an accurate count of the authorized entrants in and out of the confined space and their well being3. Shall maintain constant communication with entrants of the confined space,monitoring for hazard exposure and behavioral abnormalities4. Shall monitor conditions in and around the confined space, using andinterpreting the meter readings and alarms5. Shall warn unauthorized persons to remain clear of the confined space andimmediately discharge those who may have already entered6. Shall remain immediately outside the “permit-required” confined spacewhile occupied unless relieved by another qualified attendant7. Shall be familiar with initiating the rescue procedures for a confinedspace incident8. Shall be able to assist entrants from the confined space, either verballyor with the aid of the rescue retrieval equipment.9. Shall never enter a “permit required” confined space unless all hazardshave been eliminated and attendant has officially been relieved by anotherqualified attendant

6. Emergency Protocol

In the event of an emergency, the attendant should:1. Immediately summon the St. Lawrence University Security Department, viathe College supplied radio or cell phone, for 911 activation. The rescueprovider for all confined spaces on campus is the St. Lawrence UniversitySecurity Department (229-5555). 2. Attempt to remove the victim by use of the retrieval line from outside theconfined space if this can be accomplished without creating further hazardfor the entrant or the attendant. 3. If the attendant is able to remove the victim with the retrieval line,he/she should administer aid within the limits of his/her training untilemergency medical services (EMS) arrive.4. If the standby person is unable to remove the victim by using theretrieval line, he or she must wait for help to arrive. The standby person(s)is not to enter the confined space for any reason.5. Give EMS personnel any information they request.6. The Canton Fire Department is our designated emergency response agency.

St. Lawrence University Confined Space Policy 10/20/06 (Rev 2) 10

7. Training

The Office of Environmental Health & Safety and/or Facilities Operations willprovide the initial and in-service training for all employees. If there is achange in the design or condition(s) of a confined space, refresher trainingwill be necessary. If required, the annual refresher training will be theresponsibility of the managers/supervisors involved with the confined spaceentry. Written tests will be administered to all employees who are trainedand a proficient understanding must be achieved before the employee isconsidered eligible and be involved in a permit required confined spaceproject. All contractors hired to perform work in the College confinedspaces are required to follow established confined entry procedures. Permitsare issued on a daily basis from the Office of Security and Safety. When atall possible, employees and contractors working for an extended period oftime must provide a schedule of confined space work in order to facilitatethe use of the equipment. Records of the training/awareness/testing, etc.shall be kept in the Office of Environmental Health & Safety as required.

8. Recordkeeping

St. Lawrence University’s Environmental Health & Safety office will maintaina written record of training, including safety drills, inspections, tests andmaintenance. All records will be sent to and maintained by the Office ofEnvironmental Health & Safety as required. Environmental Health & Safetywill distribute records as necessary. Where atmospheric testing indicatesthe presence of a toxic substance, records will be maintained in accordancewith Federal regulations. These records will include the dates and times of measurements; duties and locations of the employees within the confinedspace; sampling and analytical methods used; number, duration, and results ofthe samples taken; PEL concentrations estimated from those samples; type ofpersonal protective equipment used, if any; and employees’ names. These records will be made available to the designated representatives of theSecretary of Health, Education and Welfare; of the employer; and of theemployee or former employee. Copies of Permits issued will be sent to theOffice of Environmental Health & Safety.

St. Lawrence University Confined Space Policy 10/20/06 (Rev 2) 11

9. Contractors

Any contractor expecting to enter a designated Confined Space in theperformance of their work is expected to comply with the owner’s program,state and federal regulations. Compliance will be handled in the followingmanner.

Contractor will provide a written Confined Space Entry/Rescue Program. The program must include the following:. policy. responsibilities. permit space identification. prevention of unauthorized entry. permit required confined space – defined. reclassification to a non-permit required. authorized entrants/attendants – duties. entry supervisor – duties. rescue personnel (must have current First Aid/CPR, respiratory clearancephysical along with qualification/certification to wear SCBA and performentry and rescue)

Each entrant/attendant will submit proof of training.

Contractor will present a form that will give data to determine air qualityand equipment requirements to enter space. (Confined Space Survey & Permit)

Contractor will present all necessary equipment for entry and rescueincluding air handler, 3-4 gas air monitor with calibration certification,barricade/barrier system, explosion-proof lighting, harness in good workingcondition for each entrant, life line, tripod (if necessary), andcommunication equipment (if necessary).

Each contractor will be given a copy of the owner’s survey of the space theyare required to enter.

10. Permits

A completed entry permit must be completed by the responsible manager andpresented to the Office of Security and Safety at the beginning of eachworkday for that day’s work or for a longer period depending on therequirements of the job. All permits must be terminated at the end of eachjob. If there are any unusual occurrences during an operation it must be sonoted on the permit and reviewed prior to any future work in that location.Before entry begins you must have a signed permit to authorize entry into aconfined space area to work. The permit must be located at the entry to theconfined space (or in another location visible to all employees). Noemployees shall enter any confined space or electrical vault outlined in thiswritten standard for any reason without a permit, or without an authorizedattendant. If there is an emergency of any type in the confined space, employees willleave their work area and the permit becomes void. A new permit will thenhave to be completed, following the protocol detailed above before anyemployee can re-enter this space.

St. Lawrence University Confined Space Policy 10/20/06 (Rev 2) 12

Appendix A: Definitions

Acceptable Entry Conditions - conditions that must exist in a confined spacethat allow for and ensure that employees involved in a confined space entry,can safely go into and work within the space.

Attendant(s) - one or more persons stationed outside a “permit required”confined space who monitors the authorized entrants, provides appropriatesupport services, assists in non-entry rescues and performs all other dutiesof the attendant as indicated herein.

Authorized Entrant - an individual who is authorized (with the appropriateknowledge and training) by the employer to enter a confined space, bothpermit and non-permit required.

Confined Space - a space that:1) is large enough and so configured that an employee can bodily enter andperform assigned work.2) Has limited or restricted means of ingress or egress, such as, but notlimited to: boilers, ductwork, elevator hoist ways, overheads and pits,stacks, tanks, tunnels, vaults.3) Is not designed for continuous occupancy.

Non-Permit Required Confined Space - a confined space that does not containknown or potential hazards (atmospheric or otherwise) that have the potentialto cause serious illness, injury or death.

Permit Required Confined Space - a confined space that contains one or moreactual or potential hazards that pose a threat to the health and safety ofthe workers who will enter the space and for which a written authorization toenter (a permit) is required. A PRCS has one or more of the followingcharacteristics:

a) Contains or has the potential to contain a hazardous atmosphereb) Contains a material that has the potential for engulfing an entrantc) Has an internal configuration such that an entrant could be trappedor asphyxiated by inwardly converging walls, or by a floor which slopesdownward and tapers to a smaller cross sectiond) Has air, gas, steam or water under pressuree) Is found to have excessively high temperatures that may causedehydrationf) Has the potential to cause injury by electrocutiong) contains any other recognized health and safety hazard Entry -whenever a person places any portion of their body (i.e. arm, face,foot, hand or head) into the opening of a confined space, it is to beconsidered an entry.

St. Lawrence University Confined Space Policy 10/20/06 (Rev 2) 13

Entry Permit - the printed or written document that is provided by St.Lawrence University to allow and control entry into a “permit required”confined space. The entry permit shall indicate all appropriate, applicableinformation that will provide safe entry into a “permit required” confinedspace.

Entry Supervisor - the person responsible for determining if acceptable entryconditions are present at a “permit required” confined space where entry isplanned, for authorizing entry and overseeing entry operations, and forterminating entry or work in the space as required in these guidelines.

Hazard Evaluation – the assessment of a confined space to determine known orpotential hazards.

Hazardous Atmosphere - an atmosphere that may expose personnel to the risk ofdeath, incapacitation, impairment of ability to self rescue, illness, injuryor one or more of the following:

a) Flammable gas, mist or vapor in excess of 10% of the lower explosivelimit (LEL) or lower flammable limit (LFL)b) air-borne combustible dust at a concentration that meets or exceedsthe LEL or LFL (the dust obscures vision at a distance of 5’ or less)c) Atmospheric oxygen is below 19.5% or is greater than 23.5%d) Hydrogen sulfide (odor of rotten eggs) in concentrations greaterthan 10 ppme) Carbon monoxide (colorless and odorless gas) in concentrationsgreater than 35 ppmf) Any other substance that may exceed the exposure level (i.e. PEL,STEL or TWA)g) Any other atmospheric condition that is immediately dangerous tolife or health (IDLH)

Hot Work Permit – St. Lawrence University's written authorization to performoperations such as burning, cutting, heating, soldering or welding that wouldbe capable of providing a source of ignition.

Immediately Dangerous to Life and Health (IDLH) - any condition that poses animmediate or delayed threat to life or that which would cause irreversibleadverse health effects or that would interfere with an individual’s abilityto escape unaided from a confined space. (Check the MSDS or with the Officeof EH&S for information on chemicals or gases that may be classified asIDLH.)

Isolation - the process of completely protecting or removing the release ofenergy and material into a confined space by such means as: blanking orblinding, misaligning or removing sections of ducts, lines or pipes, a doubleblock and bleed system, lockout and/or tag out of all sources of energy; orblocking or disconnecting all mechanical linkages.

Lock Out/Tag Out - the placement or a lock and/or tag on an energy isolatingdevice in order to separate the energy source(s), including potential orstored energy from the equipment, machine or process being maintained orserviced. (An energy isolating device is any device that prevents thetransmission or release of energy, including but not limited to: blocks,circuit breakers, disconnects, line valves, etc...)

Qualified Person - a person who has the appropriate training to work in andaround confined spaces and who is accomplished and knowledgeable in the

St. Lawrence University Confined Space Policy 10/20/06 (Rev 2) 14

various operations of confined space work. This includes, but is not limitedto, having the ability to properly evaluate and recognize hazards that may bepart of the confined space and having the ability to mitigate hazards found.

Retrieval System - equipment such as a full body harness, lifeline, rope andtripod used for non-entry rescue of persons from a confined space.

Testing - the identification and evaluation of hazardous conditions inside a confined space using equipment such as that which is used for monitoringhazardous atmospheres.

Toxic Atmosphere - the atmosphere in or around a confined space that containsa concentration of a substance (gas, liquid or solid) above the published orrecognized safe levels.

St. Lawrence University Confined Space Policy 10/20/06 (Rev 2) 15

Appendix B

CONFINED SPACE AND PERMIT-REQUIREDCONFINED SPACE RECOGNITION FORM

Part I YES NO

1 Is the space large enough so an employee can bodily enterand perform work?

2 Does the space have limited or restricted means for entryand exit?

3 Is the space designed for occupancy?

If the answers to Items 1 and 2 are yes and Item 3 is no, then you haveidentified the space as a confined space. If these criteria have not been met, then the space is not considered a confined space and no further actionis needed. Continue to Part II if a confined space has been identified todetermine if it is a permit-required confined space.

Part II YES NO

1 Does the space contain or potentially contain a hazardousatmosphere?

2 Does the space contain any chemicals or chemical residues?3 Does the space contain any flammable/combustible substances? 4 Does the space contain or potentially contain any

decomposing organic matter?5 Does the space have any pipes which bring chemicals into it? 6 Does the space have any materials that can trap or

potentially trap, engulf, or drown an entrant?7 Is vision obscured by dust at 5 feet or less? 8 Does the space contain any mechanical equipment?9 Does the space have converging walls, sloped floors or

tapered floor to smaller cross-sections which could trap orasphyxiate an entrant (Entrapment Hazard)?

10 Does the tank or vessel contain rested interior surfaces? 11 Does the space contain thermal hazards e.g.; extreme hot or

cold)?12 Does the space contain excessive noise levels which could

interfere with communication with an attendant? 13 Does the space present any slip, trip, or fall hazards?14 Are there any operations conducted near the space opening

which could present a hazard to entrants? 15 Are there any hazards from falling objects?16 Are there lines under pressure servicing the space?17 Are cleaning solvents or paints going to be used in the

space?18 Is welding, cutting, brazing, riveting, scraping, or sanding

going to be performed in the space?19 Is electrical equipment located in or required to be used in

the space?20 Does the space have poor natural ventilation which would

allow an atmospheric hazard to develop?

St. Lawrence University Confined Space Policy 10/20/06 (Rev 2) 16

Part II YES NO

21 Are there any corrosives which could irritate the eyes inthe space?

22 Are there any conditions which could prevent any entrants’self rescue from the space?

23 Are there any substances used in the space which have acutehazards?

24 Is mechanical ventilation needed to maintain a safe environment?

25 Is air monitoring necessary to ensure the space is safe forentry due to a potential hazardous atmosphere?

26 Will entry be made into a diked area where the dike is 5feet or more in height?

27 Are residues going to be scraped off the interior surfacesof the vessel?

28 Are non-sparking tools required to remove residues?29 Does the space restrict mobility to the extent that it could

trap an entrant?30 Is respiratory protection required because of a hazardous

atmosphere?31 Does the space present a hazard other than those noted above

which would make it a permit space?

Note: If any of the questions in Part II have been checked yes, the confinedspace is a permit-required confined space. As such, entry into these spacesmust be performed under the protection of a full permit-required confinedspace program. Note that in some situations, alternative procedures orreclassifying to a non-permit space may be possible in lieu of a full permit-Required confined space program.

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Appendix C: Confined Space Pre-Entry Checklist

LOCATION: _________________________ DATE: _____________ TIME: ___________

ENTRY SUPERVISOR: ___________________________ PHONE: __________________

Mark the appropriate column: X Yes, X No, or X N/A (Not Applicable)

Yes No N/A

1. Is a “DANGER CONFINED SPACE” sign posted to identify the site as requiring aconfined space entry permit to occupy the area?

2. Is a written permit space entry program developed and implemented thatcomplies with Section 1910.146 (c)(4)?

3. Is the written program available for inspection by employees and theirrepresentatives?

4. Have all ENTRANTS been provided training and acquired the understanding,knowledge and skills necessary for the safe performance of the duties assignedin Section 1910.146(h)?

5. Have all ATTENDANTS been provided training and acquired the understanding,knowledge and skills necessary for the safe performance of the duties assignedin Section 1910.146(I)?6. Have all ENTRY SUPERVISORS been provided training and acquired theunderstanding, knowledge and skills necessary for the safe performance of theduties assigned in Section 1910(j)?

7. Is the only hazard an actual or potential hazardous atmosphere?

8. Will continuous forced air ventilation alone be sufficient to maintain the permit space safe for entry?9. Has monitoring and inspection data been developed to eliminate the hazardousatmosphere through forced air ventilation?

10. Has the permit space been isolated?

11. Have steps been taken for purging, inerting, flushing or ventilating thepermit space to eliminate or control atmospheric hazards?

12. Is monitoring available to verify that conditions are acceptable for entrythrough-out the duration of an authorized entry?

13. Are employees trained on how to maintain and properly use testing andmonitoring equipment?

14. Is ventilating equipment needed to obtain acceptable entry?

15. Is communication equipment necessary and available for use between attendantand entrant?

16. Are the entrants provided with personal protective equipment to beadequately protected insofar as feasible engineering and work practice controlsallow?

17. Has adequate lighting equipment been supplied to allow a safe work area andallow a quick exit in an emergency?

18. Has the area been secured with barriers and shields from pedestrian, vehicleor other barriers to protect the entrants from external hazards?

19. Is the confined space provided with equipment, such as ladders, needed forsafe ingress and egress by authorized entrants?

20. Is there other training, equipment or services needed to provide safeconfined space entry?

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Appendix D: Confined Space Entry Permit

Available on EHS Web Page:

http://www.stlawu.edu/ehs/healthsafety/confinedspace_entrypermit.pdf

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Appendix E

St. Lawrence University Confined Space List

Building Name Location Potential Hazards Dean Eaton Hall Tunnel - Heating Plant Entrance Steam, Entrapment

Dean Eaton Hall Entrance in Floor by room #1098 Steam, Electrical, Sewer, Entrapment (combustible/toxic gases & vapors)

Dean Eaton Hall Entrance in stairwell near room 1108 Steam, Electrical, Sewer, Entrapment (combustible/toxic gases & vapors)

Dean Eaton Hall Entrance in custodial break room #10 Steam, Electrical, Sewer, Entrapment (combustible/toxic gases & vapors)

Dean Eaton Hall Quad side - Grate to right of main entrance Steam, Electrical, Sewer, Entrapment (combustible/toxic gases & vapors)

Sykes Hall Tunnel entrance in Faculty Staff Dining Hall

Steam, Electrical, Natural gas, Sewer, Entrapment (combustible/toxic gases & vapors)

Sykes Hall Tunnel entrances (2) below Dana Dining Hall

Steam, Electrical, Natural gas, Sewer, Entrapment (combustible/toxic gases & vapors)

Sykes Hall Tunnel entrance in South side stairwell (by Recycle rm.)

Steam, Electrical, Natural gas, Sewer, Entrapment (combustible/toxic gases & vapors)

Sykes Hall Tunnel entrance in NE side stairwell (2600-3600 stairwell)

Steam, Electrical, Natural gas, Sewer, Entrapment (combustible/toxic gases & vapors)

Sykes Hall Tunnel entrances (4) within mechanical room B0100

Steam, Electrical, Natural gas, Sewer, Entrapment (combustible/toxic gases & vapors)

Eben Holden Entrance in floor within room #50

Steam, Electrical, Natural gas, Sewer, Entrapment (combustible/toxic gases & vapors)

Chapel Tunnel entrance within mechanical room 102 Steam, Electrical, Entrapment

Continued on next page

St. Lawrence University Confined Space Policy 10/20/06 (Rev 2) 20

St. Lawrence University Confined Space List (Cont.)

Building Name Location Potential Hazards

Heating Plant Boilers 2,3,4

Steam, Natural gas, Extreme temperatures, Entrapment (combustible/toxic gases & vapors)

Madill Hall Tunnel entrance within room 001 Steam, Electrical, Entrapment

Brown Hall Tunnel entrance within room 103 Steam, Electrical, Sewer, Entrapment (combustible/toxic gases & vapors)

Valentine Hall Tunnel entrance within room 110 Steam, Electrical, Sewer, Entrapment (combustible/toxic gases & vapors)

Valentine Hall Tunnel entrance within room 119 Steam, Electrical, Sewer, Entrapment (combustible/toxic gases & vapors)

NOTE: All spaces that are accessed by lifting a manhole cover are designated as permit required spaces throughout our campus.

St. Lawrence University Confined Space Policy 10/20/06 (Rev 2) 21

9797

Appendix F: Copy of Standard

OSHA Standards for Permit Required Confined Spaces – 1910.146:

http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=

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