Confined Space Program

Policy

All confined spaces located at the University of Chicago shall be shall be managed, investigated, and access shall be denied until the location has been cleared for entry in accordance with this policy.

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Authority and Responsibility

Environmental Health and Safety is responsible for the following:

  • Investigating all known and suspected confined spaces;
  • Completing a Confined Space Profile for all confined spaces;
  • Designating confined spaces as permit-required confined spaces or non-permit confined spaces;
  • Implementing the measures necessary to prevent unauthorized entry into a permit-required confined space by posting warning signs or other equally effective means;
  • Determining if a permit-required confined space can be reclassified as a non-permit confined space;
  • Developing, implementing and annually reviewing the Confined Space Program;
  • Initially reviewing and approving all departmental policies for specific permit-required confined spaces prior to implementation;
  • Providing entry supervisors for all permit-required confined space entry procedures;
  • Providing a means of training employees involved with permit-required confined space entry; and
  • Coordinating with the department supervisor and contractor’s entry supervisor to ensure proper procedures are followed prior to entry, during entry operations, and after entry into permit-required confined space(s).

Departments with authority over a permit-required confined space(s) are responsible for the following:

  • Developing and implementing departmental policies specific to each identified confined space;
  • Informing contractors of any permit-required confined space(s);
  • Providing authorized entrants and attendants to perform assigned tasks in permit-required confined spaces;
  • Ensuring that affected employees participate in training programs as prescribed by this policy; and
  • Providing necessary equipment to control permit-required confined space atmospheres at levels that will permit occupancy.

The contractors shall be responsible for the following:

  • Utilizing any available information from the University of Chicago regarding the permit-required confined space hazards and entry operations prior to entry;
  • Informing the University of Chicago of the permit-required confined space program to be followed by the contractor during the aforementioned initial meeting; and
  • Providing an entry supervisor when sole entry into a permit-required confined space consists of their employees.

Employees are responsible for complying with University and departmental policies for permit-required confined spaces.

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Profiling Confined Spaces

To report a known or suspected confined space, contact Environmental Health and Safety at 773.702.9999. To ensure that confined spaces are properly evaluated and designated as permit-required or non-permit required, Environmental Health and Safety shall conduct a visual inspection of the area to determine if:

  • The area is large enough and so configured that an employee can enter and perform assigned work;
  • The area has limited or restricted means for entry or exit;
  • The area is not designed for continuous employee occupancy;
  • The space contains a material that has the potential for engulfing an entrant;
  • The space has an internal configuration such that an entrant could be trapped or asphyxiated by inwardly converging walls or by a floor which slopes downward and tapers to a smaller cross-section; and
  • The space contains any other recognized serious safety or health hazard including, but is not limited to, the following:
  1. Airborne dust;
  2. Grinding/mulching;
  3. Agitators;
  4. Other moving parts;
  5. Steam;
  6. Electrical hazards;
  7. Falling/tripping hazards;
  8. Rodents/snakes/spiders; or
  9. Wind/weather;
  • The space contains or has the potential to contain a hazardous atmosphere. Note: If initial entry of the permit space is necessary to obtain the required monitoring and inspection data, the entry shall be performed in accordance with the “Permit-Required Confined Space Entry Procedures” section of this policy including the presence of an attendant.

Upon completion of the aforementioned evaluation, Environmental Health and Safety shall designate each confined space as a permit-required confined space or non-permit required confined space and thus document the status of each space on the confined space profile. All initial monitoring results shall be documented on the confined space profile and maintained by Environmental Health and Safety.

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Signage

Posting Hazard Warning Signs

If a permit-required confined space is located on the University of Chicago property, Environmental Health and Safety shall inform employees of the existence of such a space by posting a warning sign which reads:

DANGER
Permit-Required Confined Space
DO NOT ENTER

When posting of warning signs is not feasible (e.g., sewers, pits), as determined by Environmental Health and Safety, permit-required confined spaces shall be identified by other equally effective means (e.g., training).

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Confined Space Hazards

The hazards associated with entry into a confined space vary in degree (from least severe to the most severe) as follows:

  • A non-permit space which does not contain any serious safety hazard;
  • A permit-required space in which all hazards are eliminated prior to any entry;
  • A permit space wherein the only hazard is atmospheric, and for which continuous, forced-air ventilation alone is sufficient to control; and
  • A permit space that contains or has the potential to contain, both atmospheric and non-atmospheric (physical) hazards.

Non-Permit Required Confined Space Entry Procedures

A non-permit required confined space, by definition, poses no hazard to an employee more serious than its restricted means of entry and exit. Therefore, provided that the work to be performed lacks any potential to create a prohibited or unacceptable condition, entry to a non-permit-required confined space may proceed as described.

Prior to entry:

  • Review the work to see if personal protective equipment is needed;
  • Establish traffic control barriers at the entry point, if applicable;
  • Eliminate any condition that would make removal of the confined space entry cover unsafe;
  • Once the entry cover is removed, promptly guard the entry point with a temporary barrier to prevent an accidental fall through the opening and protect employees working in the space from foreign objects entering the space;
  • Ensure a safe means of communication is available; and
  • Ensure appropriate lighting and/or equipment (e.g., ladders) for safe entry and exit by entrants is available.

Note: Activities involving chemical processes can result in a change in the atmosphere of a confined space. If these activities are to be performed within a confined space designated as a non-permit confined space, Environmental Health and Safety shall be contacted.

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Permit-Required Confined Space Entry Procedures

Environmental Health and Safety shall be contacted at 773.702.9999 at least 24 hours in advance to the anticipated entry into a permit-required confined space so that the appropriate visual evaluation and atmospheric monitoring of the space can be performed.

EXCEPTION: Environmental Health and Safety shall be notified immediately during an emergency situation involving the anticipated entry into a permit-required confined space to perform the appropriate evaluations of the space.

The following conditions shall be met prior to entry into a permit-required confined space:

  • The entry supervisor from Environmental Health and Safety shall perform a visual inspection of the permit-required confined space and document the general purpose of entry and nature of hazards on the entry permit;
  • Environmental Health and Safety shall conduct pre-entry monitoring to determine if the space contains a hazardous atmosphere and document all results on the Confined Space Permit;
  • If the permit-required confined space is determined by Environmental Health and Safety as safe for entry, then a permit will be issued. If a permit is denied, a representative of Environmental Health and Safety will identify the measures to be taken in order for a permit to be awarded and entry into the permit-required confined space shall be prohibited until Environmental Health and Safety deems the space safe for entry and issues a permit;
  • If an entry permit is awarded, Environmental Health and Safety shall complete and post the entry permit or provide the permit to the supervisor to post at the entry portal of the permit-required confined space;
  • The authorized entrant shall sign-out and wear a personal four gas meter provided by Environmental Health and Safety for continuous air monitoring of the atmosphere in the permit-required confined space. When work is complete, the authorized entrant shall return the personal four gas meter to Environmental Health and Safety;
  • Only the assigned tasks or activities identified on the permit shall be conducted within the permit-required space and the duration of the permit may not exceed the time required to complete those assigned tasks or activities. If the assigned work goes beyond the planned time period or work tasks/activities other than those identified on the permit become necessary, the entrant shall leave the space and inform the supervisor of the expiration of the permit or of the newly proposed work tasks or activities. The department supervisor shall contact Environmental Health and Safety immediately for a re-evaluation of the space in regard to the proposed work task or activity;
  • The entry supervisor shall supervise the entry team’s implementation of the means, procedures and practices necessary for safe entry operations which include, but are not limited to, the following:
  1. Isolating the permit space by blanking or blinding; misaligning or removing sections of lines, pipes, or ducts; using a double block and bleed system; using lockout or tagout procedures; or blocking or disconnecting all mechanical linkages;
  2. Purging, inerting, flushing, or ventilating the permit-required confined space as necessary to eliminate or control atmospheric hazards; and
  3. Providing pedestrian, vehicle, or other barriers (e.g., barricades, tape) to protect entrants from external hazards whenever a permit-required space is entered; and
  • Follow all non-permit required confined space prior to entry procedures.

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Reclassifying Permit-Required Confined Spaces to Non-Permit Required Confined Spaces

Under certain conditions, the entry supervisor may temporarily reclassify a permit-required confined space to non-permit-required. This action can facilitate entry into the space by reducing the entry requirements. The specific conditions necessary to allow this temporary reclassification are as follows:

  • All hazards within the permit space are eliminated prior to entry through isolation techniques (e.g., lockout/tagout, line blocking, purging) which must be accomplished without having to enter the space; and
  • The space poses no atmospheric hazard (actual or potential) during entry. Any atmospheric hazard eliminated shall remain eliminated throughout the duration of the entry operation. Note: The use of continuous forced air ventilation to control an atmospheric hazard does not “eliminate” the hazard and thus does not constitute compliance with this condition.

Environmental Health and Safety shall document this reclassification on the Confined Space Permit and that all hazards in the space have been eliminated. The Confined Space Permit is then made available to all employees entering the space by posting of the permit at the entry point to the space.

The reclassification remains valid only for as long as the hazards remain eliminated. All non-permit required confined space prior to entry procedures shall be followed. If a hazard is detected during entry, all employees will immediately evacuate the space and the entry supervisor will evaluate the space to determine how the prohibited conditions developed and implement measures to eliminate the prohibited conditions and prevent its recurrences before any subsequent re-entry.

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Alternate Entry Procedures for Permit-Required Confined Spaces

Alternate entry procedures can only be used when the only hazard present in a confined space is an actual or potential atmospheric hazard that can be controlled through ventilation alone. In short, this means that a permit is not required before entry, rescue arrangements do not have to be made, and no attendant is required. It is extremely important to follow the procedures below when using the alternate entry procedure:

  • Demonstrate that the only hazard posed by the space is an actual or potential hazardous atmosphere, which means that any hazard involving high noise levels, lockout-tagout, drowning, excessive heat or cold, slips, trips, fall or and other hazards shall be eliminated;
  • Demonstrate that continuous forced air ventilation alone is sufficient for safe entry;
  • Develop monitoring and inspection data to support the above. If initial entry into the space is necessary to collect such data, the entrant shall follow the complete permit program; and
  • Make available to each employee who enters the space, the data collected to prove that the space qualifies for alternate entry procedures.

Even with alternate entry procedures, the following requirements shall be met prior to entry:

  • The internal atmosphere shall be tested for oxygen content, flammable gases and vapors, and potential toxic air contaminants to ensure there is no hazardous atmosphere in the space;
  • Forced air ventilation shall be provided in the area where the employee will be present in order to control any hazardous atmosphere;
  • Authorized entrant shall wear a personal four gas meter for the duration of the work being performed in the space; and
  • All alternate entry requirement have been met and documented on the Confined Space Permit.

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Termination of Work

Individual departments shall contact the entry supervisor to terminate entry and cancel the permit when the work covered by the entry permit has been completed and/or a condition that is not allowed under the entry permit arises in or near the space.

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Contractors

If an outside contractor is hired to perform work within a permit-required confined space at the University of Chicago, the department supervisor shall contact Environmental Health and Safety 72 hours prior to beginning the work.

The entry supervisor from Environmental Health and Safety and the department supervisor shall coordinate entry operations with the entry supervisor of the outside contractor when employees from the University and the Contractor will be working together in or near permit-required confined space(s).

The entry supervisor from Environmental Health and Safety and the department supervisor shall be responsible for the following:

  1. Informing the contractor that the area in question is a permit-required confined space;
  2. Reviewing the permit-required confined space program followed by the contractor;
  3. Informing the contractor of the hazards identified within the space and any past experience with the space;
  4. Informing the contractor of any precautions or procedures that have been implemented for the protection of employees in the permit-required confined space where contractor personnel will be working; and
  5. Debriefing the contractor at the end of the work as needed, to identify hazards discovered or created in the permit-required confined space during operations.

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Rescue and Emergency Services

The Chicago Fire Department shall perform permit-required confined space rescue in accordance with 29 CFR 1910.146 (k) (1).

If in the course of his/her duties outside a permit-required confined space an attendant becomes aware that an entrant needs assistance in escaping from the space, the attendant shall summon rescue and other emergency services by contacting the University Police by dialing 123 from a campus phone or 773.702.8181 from an off campus phone. Attendants shall never enter the space to attempt a rescue and always remain outside the permit-required confined space during entry operations until relieved by another attendant.

The entry supervisor shall inform the Chicago Fire Department of the hazards they may confront when called upon to perform a permit-required confined space rescue.

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Training

Requirements

Environmental Health and Safety shall be responsible for providing appropriate training. This training is provided to each employee serving as an authorized entrant, attendant, and entry supervisor during any type of confined space operation. The purpose of this training is to provide the individual with the understanding, knowledge, and skills necessary for the safe entry into a permit-required and non-permit required confined space.

Frequency

Training shall be provided as follows:

  • Before an employee is assigned to a duty involving entry into a permit- required confined space;
  • Before there is a change in assigned duties (e.g., attendant becomes an entrant);
  • Whenever there is a change in confined space operations that presents a hazard that an employee has not been previously trained on; or
  • Whenever there are deviations from the entry procedures or inadequacies in the employee’s knowledge or use of entry procedures as identified by Environmental Health and Safety during entry procedures.

Training programs shall establish employee proficiency in the duties required of authorized entrants, attendants, and entry supervisors. Training programs and records shall be maintained by Environmental Health and Safety for three years subsequent to the initial training period.

Reviewed: March 2017

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