Permit-Required Confined Spaces - Grainnet€¦ · industry from the hazards of entry into permit-required confined spaces. This section does not apply to agriculture, to construction,

53

Permit-Required Confined Spaces29CFR 1910.146

COMPLIANCE MANUALWritten by Adam Schupp, Safety Consultant, N. Ft. Myers FL, 941-731-5947

INTRODUCTION

OSHA, in continuing to address the hazards of confined space entry, has revised the standardfor entry into Permit-Required Confined Spaces, 29CFR 1910.146/www.osha-slc.gov/OshStd_data/1910_0146.html. The final rule became effective February 1, 1999. It’s impactupon grain handling facilities include such confined spaces as hopper cars, receiving pits,enclosed boot pits, scales and garners, dryers, and some below grade tunnels.

In addressing those areas of change, OSHA now requires that the employer must provideauthorized entrants, or their authorized representatives, an opportunity to observe any pre-entry testing of permit spaces and to share with those persons the results of permit spacetesting and monitoring.

Management written certification that a permit space is safe for entry must also be madeavailable to entrants or their authorized representatives. In addition, Section (l) Employeeparticipation, a new addition to the standard, is added to ensure employee involvement inpermit space program development and implementation.

The purpose of this manual is to assist grain handling management in successfully meetingthe numerous compliance challenges of permit space entry. Included is the complete languageof the standard; an interpretation of each section of the standard; and in the support material,a sample entry permit in Appendix B, and in Appendix C, OSHA’s “Rescue Service EvaluationCriteria,” also a new addition to standard.

TABLE OF CONTENTS

• (a) Scope and Applications ................................................................................ 54• (b) Definitions .................................................................................................... 54• (c) General Requirements ................................................................................. 54• (d) Permit Required Confined Entry Program................................................. 61• (e) Permit System .............................................................................................. 68• (f) Entry Permit ................................................................................................ 70• (g) Training ........................................................................................................ 73• (h) Duties of Authorized Entrants..................................................................... 75• (i) Duties of Attendants .................................................................................... 76• (j) Duties of Entry Supervisors......................................................................... 79• (k) Rescue and Emergency Services ................................................................. 81• (l) Employee Participation ............................................................................... 84• Appendix A...Definitions .................................................................................... 85• Appendix B...Entry Permit ................................................................................ 88• Appendix C...Rescue Team/Service Evaluation Critieria ................................. 89

For additional copies ($25 each, plus s/h), call GRAIN JOURNAL at 800-728-7511All rights reserved by Schupp Consulting and GRAIN JOURNAL

54

Permit-Required Confined Spaces (Revised)29CFR 1910.146

This section contains requirements for practicesand procedures to protect employees in generalindustry from the hazards of entry into permit-required confined spaces. This section does notapply to agriculture, to construction, or toshipyard employment.

See Appendix (A)

(c)(1) The employer shall evaluate theworkplace to determine if any spaces are permit-required confined spaces.

(c)(2) If the workplace contains permit spaces,the employer shall inform exposed employees byposting danger signs or by any other equallyeffective means, of the existence and location ofand the danger posed by the permit spaces.

Note: A sign reading “DANGER-PERMIT-REQUIRED CONFINED SPACE, DO NOTENTER” or using other similar language wouldsatisfy the requirement for a sign.

(c)(3) If the employer decides that itsemployees will not enter permit spaces, the

PERMIT-REQUIRED CONFINED SPACES COMPLIANCE MANUAL

Excluded from coverage are agriculture(farming), construction, or shipyard employ-ment. It does, however, cover certain confinedspaces in the grain handling industry, otherthan bins, silos, tanks and flat storagestructures, all of which are covered by 29CFR1910.272 Section (g) Entry Into GrainHandling Structures and Section (h) Entry IntoFlat Storage Structures. Confined space areasin grain facilities that are covered by 1910.146includes hopper cars, enclosed boot pits, scalesand garners, receiving pits, dryers, and somebelow grade tunnels.

See page 85.

(c)(1) The first requirement of 1910.146 is toinspect the workplace to determine whether ornot the facility contains any PRCS (permit-required confined spaces). See Appendix (A)(page 85) for the definition of a PRCS.

(c)(2) Notice that paragraph (2) requires thatonly “exposed employees” be informed that thefacility has permit spaces and not necessarilythe entire workforce. Additionally, exposedemployees must be informed of the location ofsuch spaces and the danger posed.

Although OSHA mentions posting dangersigns, any EFFECTIVE means the employerchooses to transmit the required informationis acceptable. For example, posting a list of thePRCS’s on an employee bulletin board couldbe considered.

(c)(3) Compliance with (c)(1), (c)(2), (c)(6) and(c)(8) is mandatory even if the employer decides

STANDARD(a) Scope and Application

INTERPRETATION

(b) Definitions

(c) General Requirements

55

STANDARDemployer shall take effective measures toprevent employees from entering permitspaces and shall comply with paragraphs(c)(1), (c)(2), (c)(6), and (c)(8) of this section.

(c)(4) If the employer decides that its employeeswill enter permit spaces, the employer shalldevelop and implement a written permit spaceentry program that complies with this section.The written program shall be available forinspection by employees and their authorizedrepresentatives.

(c)(5) An employer may use the alternateprocedures specified in this paragraph (c)(5)(ii)of this section for entering a permit space underthe conditions set forth in paragraph (c)(5)(i) ofthis section.

(c)(5)(i) An employer whose employees enter apermit space need not comply with paragraphs(d) through (f) and (h) through (k) of this sectionprovided that:

(c)(5)(i)(A) The employer can demonstrate thatthe only hazard posed by the permit space is anactual or potential hazardous atmosphere;

(c)(5)(i)(B) The employer can demonstrate thatcontinuous forced air ventilation alone is sufficientto maintain that permit space for entry;

(c)(5)(i)(C) The employer develops monitoringand inspection data that supports thedemonstrations required by paragraphs(c)(5)(i)(A) and (c)(5)(i)(B) of this section;

(c)(5) (i)(D) If an initial entry of the permitspace is necessary to obtain the data requiredby paragraph (c)(5)(i)(C) of this section, theentry is performed in compliance with

INTERPRETATIONthat his employees will not perform entry intopermit spaces.• See (c)(1) and (c)(2) above.• (c)(6) deals with a possible reevaluation of anon-permit space to a PRCS.• (c)(8) deals with the precautions andprocedures relative to the work of outsidecontractors in a permit space.

(c)(4) If local employees will enter permitspaces, the employer must develop andimplement a written compliance program thatmeets the requirements of the standard. Thestandard further requires that affectedemployees, or their authorized representatives,(such as a union steward) may review thewritten program if they choose to do so.

(c)(5)(i) If the employer can comply with(5)(i)(A) through (F), the “alternate procedures”under (c)(5)(ii) may be used. In other words,compliance with (A) through (F) relieves theemployer of the necessity of complying with (d)through (f) and (h) through (k) of the permitspace entry program. Notice that Section (c)General requirements and Section (g) Trainingis not mentioned, and therefore, those sectionsrequire compliance in any event.

Note: Paragraphs (d) through (f) and (h)through (k) will be reviewed in detail later,butto avoid confusion at this point, those sectionsare as follows;• Secton (d) Permit-required confined space(written) program;• Section (e) Permit system;• Section (f) Entry permit;• Section (h) Duties of authorized entrants;• Section (i) Duties of attendants;• Section (j) Duties of entry supervisors;

56

paragraphs (d) through (k) of this section;

(c)(5)(i)(E) The determination and supportingdata required by paragraphs (c)(5)(i)(A),(c)(5)(i)(B), and (c)(5)(i)(C) of this section aredocumented by the employee who enters thepermit space under the terms of paragraph (c)(5)of this section; and

(c)(5)(i)(F) Entry into the permit space underthe terms of paragraph (c)(5)(i) of this section isperformed in accordance with the requirementsof paragraph (c)(5)(ii) of this section.

(c)(5)(ii)(A) The following requirements applyto entry into permit spaces that meet theconditions set forth in paragraph (c)(5)(i) of thissection. Any condition making it unsafe toremove an entrance cover shall be eliminatedbefore the cover is removed.

(c)(5)(ii)(B) When entrance covers are removed,the opening shall be promptly guarded by arailing, temporary cover, or other temporarybarrier that will prevent an accidental fallthrough the opening and that will protect eachemployee working in the space from foreignobjects entering the space.

(c)(5)(ii)(C) Before an employee enters thespace, the internal atmosphere shall be tested,with a calibrated direct-reading instrument, forthe following conditions in the order given:(c)(5)(ii)(C)(1) Oxygen content,(c)(5)(ii)(C)(2) Flammable gases and vapors,and(c)(5)(ii)(C)(3) Potential toxic air contaminents.

(c)(5)(ii)(D) There may be no hazardousatmosphere within the space whenever anyemployee is inside the space.

(c)(5)(ii)(E) Continuous forced air ventilation


• Section (k) Rescue and emergency services.Thus, the employer is well advised to makeevery effort to comply with (c)(5)(i)(A) through(F), for by so doing he is relieved of theconsiderable compliance burdens of sections (d)through (f) and (h) through (k), whichconstitutes the lion’s share of standard.

(c)(5)(ii)(A) In the preamble to the standard,OSHA states that “some conditions within apermit space, such as high temperature andhigh pressure, may make it hazardous to removea cover from that space”. Paragraph (A)mandates that such conditions, if present, mustbe eliminated before a space cover is removed.

(c)(5)(ii)(B) To again quote from the preamble,OSHA states that “if the opening to the spaceis situated so that employees and objects cannotfall into the space, no additional guarding isnecessary.

(c)(5)(ii)(C) The testing required by paragraph(C) must be performed in the order given, thereason being that some testing instruments relyon the presence of oxygen for accurate readings.

(c)(5)(ii)(D) Paragraph (D) requires nocomment and should be taken as read.

(E) Paragraph (E)(1) requires atmospheric

STANDARD INTERPRETATION

Alternate Entry Procedures

57

shall be as follows:(c)(5)(ii)(E)(1) An employee may not enter aspace until the forced air ventilation haseliminated any hazardous atmosphere;(c)(5)(ii)(E)(2) The forced air ventilation shallbe so directed as to ventilate the immediateareas where an employee is or will be presentwithin the space and shall continue until allemployees have left the space;(c)(5)(ii)(E)(3) The air supply for the forced airventilation shall be from clean source and maynot increase the hazards in the space.

(c)(5)(ii)(F) The atmosphere within the spaceshall be periodically tested as necessary to ensurethat the continuous forced air ventilation ispreventing the accumulation of a hazardousatmosphere. Any employee who enters the space,or that employee’s authorized representative,shall be provided with an opportunity to observethe periodic testing required by this paragraph.

(c)(5)(ii)(G) If a hazardous atmosphere isdetected during entry:(c)(5)(ii)(G)(1) Each employee shall leave thespace immediately;(c)(5)(ii)(G)(2) The space shall be evaluatedto determine how the hazardous atmospheredeveloped; and

testing before entry to ensure that forced airventilation has, in fact, eliminated any hazards.(E)(2) requires no comment and should be takenas read.(E)(3) requires air from a “clean source”, such asfiltered air or air from outside the facility. Theimportant thing here is not to pump unclean airinto the permit space atmosphere that you aretrying to cleanse.

(c)(5)(ii)(F) In the preamble, OSHA elaborateson “periodically testing as necessary” statingthat “the frequency at which testing wouldhave to be performed is dependent upon thenature of the permit space and the results ofthe initial testing performed under paragraph(c)(5)(ii)(C) of the final rule. For example, if theinitial testing is not normally expected topresent the hazards posed by such gases andvapors, no further testing would be necessary.If a flammable gas or vapor is initially detected,frequent or continuous testing would beappropriate”. As in (c)(5)(ii)(C) above,an entrantor his authorized representative has the rightto observe the periodic testing. OSHA believesthat providing employees or their representa-tives with the opportunity to observe thetesting and monitoring of permit spaces willhave the same kinds of benefits that suchobservation has had in the context of OSHA’shealth standards. Knowledgeable employeeswho are given the opportunity to participateactively in protecting their own safety andhealth often identify potentially seriousproblems and help to solve them as well.

(c)(5)(ii)(G) Paragraphs (G)(1), (2), and (3) setsforth what OSHA wants done should ahazardous atmosphere develop while entry isunderway.(G)(1) Requires that all entrants evacuate thespace as soon as the hazard is detected;(G)(2) Directs that management conduct an


58


(c)(5)(ii)(G)(3) Measures shall be implementedto protect employees from the hazardousatmosphere before any subsequent entry takesplace.

(c)(5)(ii)(H) The employer shall verify that thespace is safe for entry and that the pre-entrymeasures required by paragraph (c)(5)(ii) havebeen taken through a written certification thatcontains the date, the location of the space, andthe signature of the person providing thecertification. The certification shall be madebefore entry and shall be made available to eachemployee entering the space or to that employee’sauthorized representative.

(c)(6) When there are changes in the use orconfiguration of a non-permit confined spacethat might increase the hazards to entrants ,the employer shall reevaluate that space and, ifnecessary, reclassify it as a permit-requiredconfined space.

(c)(7) A space classified by the employer as apermit-required confined space may bereclassified as a non-permit space under thefollowing procedures:(c)(7)(i) If the permit space poses no actual orpotential atmospheric hazards and if allhazards within the space are eliminatedwithout entry into the space, the permit spacemay be reclassified as a non-permit confinedspace for as long as the non-atmospherichazards remain eliminated.

investigation to determine how and why thehazard was developed; and(G)(3) Directs that management take whateversteps are necessary to fully protect entrantsBEFORE reentry takes place.

(c)(5)(ii)(H) Paragraph (H) makes managementresponsible for a written certification that mustcontain the following information:• Date of the certification;• Space location; and• The signature of the person providing thecertification.The certification must be completed BEFOREentry takes place and the written certificationmust be available to entrants or to theirauthorized representatives.It is well to remember that the person makingthe certification is, in fact, ATTESTING TOTHE NON-HAZARDOUS CONDITION of thespace; not a responsibility to be taken lightly!

(c)(6) OSHA does not expect management toundertake the reevaluation of a permit spacebecause of trivial or insignificant changes thathave occured that do not affect the nature of thespace or the work performed therein. The intentof paragraph (c)(6) is that a space reevaluationwould be necessary when changes occur thatincrease the risk to the space entrant(s).

(c)(7) OSHA permits the reclassification of apermit-required confined space to non-permitconfined space under the following conditionsand procedures:• There are no identifiable or potentialatmospheric hazards in the space, and all otherhazards, such as mechanical or electical, areeliminated WITHOUT making entry;• Should a condition inside the space make itnecessary to make an entry, the entry must beconducted in full compliance with paragraphs


Conclusion of the Alternate Entry Procedures

59

(c)(7)(ii) If it is necessary to enter the permitspace to eliminate hazards, such entry shall beperformed under paragraphs (d) through (k) ofthis section. If testing and inspection duringthe entry demonstrate that the hazards withinthe permit space have been eliminated, thepermit space may be reclassified as a non-permit confined space for as long as the hazardsremain eliminated.Note: Control of atmospheric hazards throughforced air ventilation does not constituteelimination of the hazards. Paragraph (c) (5)covers permit space entry where the employercan demonstrate that forced air ventilationalone will control all hazards in the space.

(c)(7)(iii) The employer shall document thebasis for determining that all hazards in apermit space have been eliminated, through acertification that contains a date, the locationof the space, and the signature of the personmaking the determine. The certification shallbe made available to each employee entering thespace or to that employee’s authorizedrepresentative

(c)(7)(iv) If hazards arise within a permit spacethat has been declassified to a non-permit spaceunder paragraph (C) (7) of this section, eachemployee in the space shall exit the space. Theemployer shall then reevaluate the space anddetermine whether it must be reclassified as apermit space, in accordance with otherapplicable provisions of this section.

(c)(8) When an employer (host employer)arranges to have employees of another employer(contractor) perform work that involves permitspace entry, the host employer shall:(c)(8)(i) Inform the contractor that theworkplace contains permit spaces and thatpermit space entry is allowed only throughcompliance with a permit space programmeeting the requirements of this section;(c)(8)(ii) Appraise the contractor of the elements,including the hazards identified and the host

(d) through (k). Say, for example, that adisconnecting means for an energy source isinside the space and located in such a mannerthat the space must be entered to deenergizeit. Under that scenario, all provisions of (d)through (k) apply.

(c)(7)(iii) Here again, a written certificationis required to the effect that ALL hazards havebeen eliminated. The certification mustinclude:• The date and location of the space; and• The signature of the certifying person.

(c)(7)(iv) This paragraph tells us that if, inspite of all of the forgoing precautions andprocedures, a hazard does arise in the space,all entrants must evacuate the spaceimmediately. Furthermore, management isthen required to undertake a reevaluation ofthe space and determine whether or not thespace should be upgraded to permit-required.

(c)(8) Paragraph (8) (i) through (8) (v) deal withthe requirements pertaining to work by outsidecontractors. OSHA expresses their concernabout the working relationship between acontractor and the host employer (facilitymanagement) in the preamble where they saythat “a contractor who is unfamiliar with aparticular workplace may experiencedifficulties in identifying and controllingpermit space hazards, especially where thehost employer assumes that the contractor


60


employer’s experience with the space, that makethe space in question a permit space;

(c)(8)(iii) Appraise the contractor of anyprecautions or procedures that the hostemployer has implemented for the protection ofemployees in or near permit spaces wherecontractor personnel will be working;

(c)(8)(iv) Coordinate entry operations with thecontractor, when both host employer personneland contractor personnel will be working in ornear permit spaces, as required by paragraph(d)(11) of this section; and

(c)(8)(v) Debrief the contractor at theconclusion of entry operations regarding thepermit space program followed and regardingany hazards confronted or created in permitspaces during entry operations.

(c)(9) In addition to complying with the permitspace requirements that apply to all employers,each contractor who is retained to performpermit space entry operations shall:

knows how to operate safely in a particularprofessional enterprise”.

In paragraph (c)(8)(i), OSHA states that ifthere are permit spaces in the workplace, thestandard requires the employer to inform thecontractor of that fact and, further, if thecontractor’s employees are to enter permitspaces such entry must be conducted incompliance with this standard, 29CFR1910.146. OSHA does not mandate how theinformation is to be transmitted: it can, forexample, be done verbally and/or in writing.

Again in the preamble, OSHA commentsthat paragraph (c)(8)(ii) “does not require a hostemployer to make a detailed investigation ofany permit spaces, but merely to provide thecontractor whatever information the hostemployer used in identifying a permit space”.

To put it another way, paragraph (8)(ii)requires facility management to share with thecontractor the information that led to thedesignation of a confined space to a permit-required confined space in the first instance.

In paragraph (c)(8)(iii), OSHA employs theterm “in or near”. While the use of the word“in” makes that portion of the rule definite andunambiguous, the concept of “near” is relativeat best and open to a considerable range ofinterpretation. Perhaps a more prudentapproach would be to say that any localprecautious and/or procedures that promotethe safety of permit space entrants should becommunicated to the contractor, whether“near” to a particular permit space or not.

Paragraph (d)(11) mentioned in paragraph(c)(8)(iv) will be addressed in the compliancecomments to section (d) Permit-requiredconfined space program. Paragraph (c)(8)(v)reflects OSHA’s determination that there willbe close communications between managementand contractor and their belief that suchcommunications is essential to the safety of allindividuals who must enter permit spaces.

(c)(9) Paragraph (c)(9) put the shoe on the otherfoot by addressing the compliance requirementsof the outside contractor. The paragraph requiresno interpretation and should be taken as read.


61

(C)(9)(i) Obtain available informationregarding permit space hazards and entryoperations from the host employer;

(C)(9)(ii) Coordinate entry operations with thehost employer, when both the host employerpersonnel and contractor personnel will beworking in or near permit spaces, as requiredby paragraph (d)(11) in the next section of thestandard.

(C)(9)(iii) Inform the employer of the permitspace program that the contractor will followand of any hazards confronted or created inpermit spaces, either through a debriefing orduring the entry operation.

(d) Under the permit space program requiredby paragraph (c)(4) of this section,the employershall:

(d)(1) Implement the measures necessary toprevent unauthorized entry;

(C)(9)(i) Paragraph (c)(9)(i) is the corollary ofthe paragraph (c)(8)(ii) and requires thecontractor to obtain any available informationconcerning permit space hazards and entryoperations from the host employer. As notedearlier, this exchange of information will helpthe contractor to anticipate the permit spacehazards that may be present during entry.

(C)(9)(ii) The purpose of paragraph (c)(9)(ii) isto ensure that employees of one employer donot endanger the employees of any otheremployer. The standard does not prohibit thehost employer from requiring a contractor touse the host’s permit space program, nor doesit require the contractor to use the host’sprogram. The host may choose to condition itscontract on the contractor’s compliance with thehost’s program.

(C)(9)(iii) OSHA feels it is necessary for thehost employer to recieve information on anyhazards found or created within the spaceduring entry operations in order to enable thehost employer to deal with those hazardsduring the current entry and to take measuresto control them in subsequent entries.Additionally, the host employer will have thisinformation available to assist futurecontractors who may be called upon to performpermit space entry.

(d) Paragrah (d) requires no interpretation andshould be taken as read.

(d)(1) OSHA considers it of the upmostimportance to prevent unauthorized access topermit spaces and intends this provision torequire the employer to take administrative


(d) Permit-Required Confined Space Entry Program

62


(d)(2) Identify and evaluate the hazards ofpermit spaces before employees enter them:

(d)(3) Develop and implement the means,procedures, and practices necessary for safepermit space entry operations, including, butnot limited to, the following:

(d)(3)(i) Specifying acceptable entryoperations;

(d)(3)(ii) Provide each authorized entrant orthat employee’s authorized representative withthe opportunity to observe any monitoring ortesting of permit spaces;

(d)(3)(iii) Isolating the permit space;

measures to ensure that all entries into permitspaces are authorized entries. In paragraph (c)(2) above OSHA mandates that “the employershall inform exposed employees, by postingdanger signs or by any other equally effectivemeans, of the exisitence and location of and thedanger posed by permit spaces”. In any event,OSHA requires the employer to use whatevermeasures are necessary to preventunauthorized entry.

(d)(2) The evaluation of the specific hazardsposed by permit spaces identified underparagraph (d)(2) is required “before” entry.Such evaluation may be accomplished, forexample, when the entry permit is prepared.

(d)(3) Paragraph (d)(3) requires no inter-pretation and should be taken as read.

(d)(3)(i) Paragraph (d)(3)(i) means that theemployer has identified the hazards that couldreasonably be expected to be found in the spaceand has limited entry conditions to those thatare safe for entry. For example, if a space couldcontain a flammable gas, the employer shouldset a limit of 10 percent of the LFL of the gasas an entry condition. This would ensure thata flammable mixture is not present upon entryinto the space.

(D)(3)(ii) Paragraph (d)(3)(ii) requires nointerpretation and should be taken as read.

(d)(3)(iii) For example, if energized parts ofelectrical equipment are exposed, the circuitparts must be deenergized and locked out.Mechanical equipment posing a hazard must


63

(d)(3)(iv) Purging, inerting, flushing, orventilating the permit space as necessary toeliminate or control atmospheric hazards.

(d)(3)(v) Providing pedestrian, vehicle, or otherbarriers as necessary to protect entrants fromexternal hazards; and

(d)(3)(vi) Verifying that conditions in thepermit space are acceptable for entrythroughout the duration of an authorized entry.

(d)(4) Provide the following equipment(specified in paragraphs (d)(4)(i) through (d)(4)(ix) of this section) at no cost to employees,maintain that equipment properly, and ensurethat employees use that equipment properly:

(d)(4)(i) Testing and monitoring equipmentneeded to comply with paragraph (d)(5) of thissection;

(d)(4)(ii) Ventilating equipment needed toobtain acceptable entry conditions;

(d)(4)(iii) Communications equipmentnecessary for compliance with paragraphs (h)(3)and (i)(5) of this section:

be locked out or tagged in accordance with1910.147 or guarded in accordance withSubpart O of the General Industry Standards.

(d)(3)(iv) For example, if the space is IDLH(Immediately Dangerous to Life and Health)it must be made safe for employees to enter.This is accomplished by ventilating theatmosphere which cleans the air within thespace so that the space is no longer IDLH andthus, safe for employees to breathe.

(d)(3)(v) Barriers must be provided around thepermit space opening for two reasons:(1) To prevent unauthorized entry; and(2) To protect employees inside the space fromobjects and persons outside the space.

(d)(3)(vi) This is accomplished through the useof test instruments to monitor the atmospherewithin the space, the use of ventilation tomaintain a safe atmosphere, and the use ofinspection to ensure that isolation is beingmaintained for the space.


64


(d)(4)(iv) Personal protective equipmentinsofar as feasible engineering and workpractice controls do not adequately protectemployees:

(d)(4)(v) Lighting equipment needed to enableemployees to see well enough to work safely andto exit the space quickly in an emergency;

(d)(4)(vi) Barriers and shields as required byparagraph (d)(3)(iv) of this section;

(d)(4)(vii) Equipment, such as ladders, neededfor safe ingress and egress by authorizedentrants;

(d)(4)(viii) Rescue and emergency equipmentneeded to comply with paragraph (d)(9) of thissection, except to the extent that the equipmentis provided by services; and

(d)(4)(ix) Any other equipment necessary forsafe entry into and rescue from permit spaces.

(d)(5) Evaluate permit space conditions asfollows when entry operations are conducted:

(d)(5)(i) Test conditions in the permit space todetermine if acceptable entry conditions existbefore entry is authorized to begin, except that, ifisolation of the space is infeasible because the

(d)(4)(ix) Paragraphs (d)(4)(i) through(d)(4)(ix) of the standard requires the employerto provide the equipment necessary for entryinto and rescue from permit spaces, as well asmaintain it and ensure its safe use. The list ofequipment contained in the standard indicatesthat these are among the types of equipmentwhich the employer may need to have on handfor the purpose of safe entry and egress.

(d)(5) Paragraph (d)(5) requires nointerpretation and should be taken as read.

(d)(5)(i) The testing required here inparagraph (d)(5)(i) is important in order todetect any hazards in the atmosphere or otherhazards that may be present in the permit


65

space is large or is part of a continuous system(such as a sewer), pre-entry testing shall beperformed to the extent feasible before entry isauthorized and, if entry is authorized, entryconditions shall be continuously monitored in theareas where authorized entrants are working;

(d)(5)(ii) Test or monitor the permit space asnecessary to determine if acceptable entryconditions are being maintained during thecourse of entry operations; and

(d)(5)(iii) When testing for atmospherichazards, test first for oxygen, then forcombustible gases and vapors, and then fortoxic gases and vapors.

(d)(5)(iv) Provide each authorized entrant or thatemployee’s authorized representative anopportunity to observe the pre-entry and anysubsequent testing or monitoring of permit spaces.

(d)(5)(v) Reevaluate the permit space in thepresence of any authorized entrant or thatemployee’s authorized representative whorequests the employer conduct such evaluationbecause the entrant or representative has

space. The type of testing that needs to beperformed is, of course, dependent upon thehazards that are identified within the space.

For permit spaces posing atmosphericproblems, atmospheric testing would benecessary. For other hazards, different testingwill be necessary. For example, if the spaceposes thermal hazards, the temperature in thespace would need to be tested. Be advised thatin the case of atmospheric contamination,atmospheric monitoring is necessitatedvirtually from the time pre-entry testing is doneuntil the last entrant leaves the permit space.

In any event, OSHA requires the employerto conduct whatever tests are necessary toensure that acceptable entry conditions arepresent and maintained.

(d)(5)(ii) To eliminate any possible confusionon the part of grain handling industrymanagement, OSHA, in paragraph (d) (5) (ii),states that appropriate testing and/or monitoringduring entry operations is specifically mandatedby the permit space standard.

(d)(5)(iii) A test for oxygen must be performedfirst because most combustible gases areoxygen dependent and will not provide reliablereadings in an oxygen deficient atmosphere.Combustible gases are tested for next becausethe threat of fire or explosion is both moreimmediate and more life threatening, in mostcases than exposure to toxic gases.

(d)(5)(iv) Paragraph (d)(5)(iv) requires nointerpretation and should be taken as read.

(d)(5)(v) Paragraph (d)(5)(v) requires theemployer to reevaluate a permit space shouldan entrant feel that initial evaluation wasinadequate. Notice also that the reevaluation


66


reason to believe that the evaluation of thatspace may not have been adequate;

(d)(5)(vi) Immediately provide each authorizedentrant or that employee’s representative withthe results of any testing conducted in accordwith paragraph (d) of this section.

(d)(6) Provide at least one entrant outside thespace into which entry is authorized for theduration of entry operations;Note: Attendants may be assigned to monitormore than one permit space provided the dutiesdescribed in paragraph (i) of this section canbe effectively performed for each permit spacethat is monitored. Likewise, attendants may bestationed at any location outside the permitspace to be monitored as long as the dutiesdescribed in paragraph (i) of this section canbe effectively performed for each permit spacethat is monitored.

(d)(7) If multiple spaces are to be monitored bya single attendant, include in the permitprogram the means and procedures to enablethe attendant to respond to an emergencyaffecting one or more of the permit spaces beingmonitored without distraction from theattendant’s responsibilities under paragraph (i)of this section;

(d)(8) Designate the persons who are to haveactive roles (as, for example, authorizedentrants, attendants,entry supervisors, orpersons who test or monitor the atmosphere ina permit space) in entry operations, identify theduties of each such employee with training

must be conducted “in the presence” of anauthorized entrant or his/her authorizedrepresentative (such as a union official), andthe selection of that “authorized representative”is the sole prerogative of the affected employee.

(d)(5)(vi) Paragraph (d)(5)(vi) requires nointerpretation and should be taken as read.

(d)(6) OSHA insists that the stationing of anentry attendant OUTSIDE the space is acritical element of an effective permit spaceprogram. In the “NOTE” to paragraph (d)(6),OSHA goes on to say that an attendant ispermitted to monitor more than one permitspace at a time as long as the duties describedin paragraph (i), (Duties of Attendants) can be“effectively performed”. Those duties includekeeping an accurate count of authorizedentrants, communicating with those entrants,monitoring activities inside the space forhazards, summoning rescue services, andkeeping unauthorized persons out of the space.

(d)(7) I don’t believe this requirement will posemuch of a problem in the grain handlingindustry. Be that as it may, I can think of severalreasons why it would not be wise to assign morethan one permit space per attendant. Forexample, how does even the best of attendantsrespond to an emergency in each of two permitspaces at the same time? The employer has theoption, however, so long as the employer candemonstrate that the attendant can fulfill ALLof the duties of section (i) Duties of Attendants.

(d)(8) This paragraph requires the employerto designate which employees will perform thevarious functions assigned by the standardand to identify their duties under the permitspace program. This will enable employers,employees, and OSHA to identify the specific


67

required by paragraph (g) of this section;

(d)(9) Develop and implement procedures forsummoming rescue and emergency services, forrescuing entrants from permit spaces, forproviding necessary emergency services torescued employees, and for preventingunauthorized personnel from attempting arescue;

(d)(10) Develop and implement a system for thepreparation, issuance, use, and cancellation ofentry permits are required by this section.

(d)(11) Develop and implement procedures tocoordinate entry operations when employees ofmore than one employer are workingsimultaneously as authorized entrants in apermit space, so that employees of one employerdo not endanger the employees of any otheremployer.

(d)(12) Develop and implement procedures(such as closing off a permit space andcancelling the permit) as necessary forconcluding the entry after entry operations havebeen completed;

(d)(13) Review entry operations when theemployer has reasons to believe that themeasures taken under the permit spaceprogram may not protect employees and revisethe program to correct deficiencies found to existbefore subsequent entries are authorized:

training required, an evaluation of the trainingrecieved, follow-up training, and thequalifications of the trainers.

(d)(9) Please refer to OSHA’s “Non-MandatoryAppendix—Rescue Team or Rescue ServiceEvaluation Criteria” provided in Appendix C(page 89).

(d)(10) A detailed explaination of the standard’srequirements for an entry permit can be found inSection (e) following.

(d)(11) This requirement is a direct outgrowthof the recognition, as reflected in the OSHArecord, that coordination of entry operationsbetween host employers and contractors is anessential element in promoting the safety of allemployers who must enter permit spaces.

(d)(12) This paragraph reflects OSHA’sdetermination that employers need to conducttheir entry operations in a carefully planned andsystematic manner from start to finish, so thatauthorized entrants and other employees affectedby entry operations are protected from permitspace hazards. In particular, the cancellation ofthe permit would alert the employer to takeappropriate measures for the shut down of thespace, the closing of the entry portal, and thereturn of the space to normal operatingconditions.

(d)(13) OSHA, in the language of the standard,offers several examples of circumstancesrequiring the review of the permit spaceprogram:• Any unauthorized entry of a permit space;• The detection of a permit space hazard not


68


(d)(14) Review the permit space program, usingthe cancelled permits retained under paragraph(e) (6) of this section within one year after entryand revise the program as necessary, to ensurethat employees participating in entry operationsare protected from permit space hazards.

(e)(1) Before entry is authorized, the employershall document the completion of measuresrequired by (d)(3) of this section by preparingan entry permit.

(e)(2) Before entry begins, the entry supervisoridentified on the permit shall sign the entrypermit to authorize entry.

(e)(3) The completed permit shall be madeavailable at the time of entry to all authorizedentrants or their authorized representatives, by

covered by the permit;• The occurence of an injury or near-missduring entry;• A change in the use or configuration of apermit space; and• Employee complaints about the effectivenessof the program.

(d)(14) In the language of the standard, OSHApermits employers to perform a single annualreview covering all entries performed duringa 12-month period. If no entries were madeduring the previous 12-month period, no reviewis necessary.

(e)(1) Paragraph (e)(1) sets forth therequirements for the implementation of apermit system. OSHA considers the use of theentry permit the single most important featureof a permit system, and in the preamble to thestandard they state “that the preparation of apermit will help the employer determine ifconditions in a permit space are safe foremployee entry. A permit will also present aconcise summary of the entry procedure thatwill be useful to the personnel who areconducting the entry operations after entry hasbeen completed”.

(e)(2) To quote again from the preamble, OSHAstates that paragraph (e)(2) “requires theinvolvement of a person (the entry supervisor)who authorizes the entry and has theresponsiblity for entry operations. Thisinvolvement will ensure that a person with thequalifications to identify permit space and theauthority to order corrective measures for theircontrol will oversee entry operations”.

(e)(3) Paragraph (e)(3) directs that, prior toentry, entrants must be given the opportunityto review the permit in order to assurethemselves that all pre-entry safety measures


(e) Permit System

69

posting it at the entry portal or by any otherequally effective means, so that the entrants canconfirm that pre-entry preparations have beencompleted.

(e)(4) The duration of the permit may notexceed the time required to complete theassigned task or job identified on the permit inaccordance with paragraph (f)(2) of this section.

(e)(5) The entry supervisor shall terminateentry and cancel the entry permit when:

(e)(5)(i) The entry operations covered by thepermit have been completed; or

(e)(5)(ii) A condition that is not allowed underthe entry permit arises in or near the permitspace.

have, in fact, taken place. Posting the permitat the entry site is specifically mentioned aspermit availability-all well and good. But asOSHA is aware that posting is not alwayssuitable, such as in inclement weather, they goon to state that “any other equally effectivemeans” of making the permit available toauthorized entrants or their representatives isacceptable. The operative word here is“effective” and any action that gets that jobdone will be OK!

(e)(4) Paragraph (e)(4) follows OSHA’s one job-one permit policy making a permit valid onlyfor the period of time required to complete theassignment for which the permit was obtainedin the first place. In complying with paragraph(e)(4), management need not state a specificperiod of time on the permit. OSHA’s intent hereis to merely restrict the permit to the job at hand.

(e)(5)(ii) Here OSHA requires the entrysupervisor to cancel the permit when the jobfor which the permit was issued has beencompleted; again one job-one permit. Thestandard further requires the entry supervisorto cancel the permit should a condition arisein or near the space in question that is notallowed under the permit. An example of sucha condition could be a fire in the near area ofthe space being occupied. Notice that inparagraph (e)(5)(ii) OSHA uses the phrase “inor near”. The point is that the entrysupervisor’s judgement is not tested if theunsafe condition is “in” the space, but “near”the space is an entirely different matter, andthe entry supervisor’s perception of what is“near” and what is not is going to require that


70


(e)(6) The employer shall retain each cancelledpermit for at least 1 year to facilitate the reviewof the permit-required confined space programrequired by paragraph (d)(14) of this section.Any problems encountered during an entryoperations shall be noted on the permit so thatappropriate revisions to the permit spaceprogram can be made.

(f) The entry permit that documentscompliance with this section and authorizesentry to a permit space shall identify:

(f)(1) The permit space to be entered;

(f)(2) The purpose of the entry;

(f)(3) The date and the authorized duration ofthe entry permit;

(f)(4) The authorized entrants within the permitspace, by name or by such other means (forexample, through the use of rosters or trackingsystems) as will enable the attendant todetermine quickly and accurately, for theduration of the permit, which authorizedentrants are inside the permit space;Note: This requirement may be met by insertinga reference on the entry permit as to the meansused, such as a roster or tracking system, to keep

individual to make a decision as the word “near”is debatable at best!

(e)(6) Remember that in (d)(14), the standardrequires the employer to conduct an annualreview of the permit space program. Cancelledpermits, which are to be retained for at least ayear, serve as the documentation to facilitatethat review.

(f) As the preparation of an entry permit isthe central part of management’s determ-ination as to whether conditions in a permitspace are safe for entry, this section specifiesthe information that must be documented on awritten permit.

(f)(1) For example, an enclosed boot pit, scalesand garners, hopper cars, recieving pits, or aboiler.

(f)(2) Cleanup, for example, or scheduledmaintenance;

(f)(3) As said previously, it is not necessary tostate the duration of the permit in terms ofactual time, but it may be stated in terms ofcompletion of the job for which the entry isbeing undertaken.

(f)(4) OSHA considers an accurate trackingsystem of permit space program entrants anessential part of a permit space program. Sucha tracking system must ensure that allentrants have been rescued in an emergencysituation and secondly, to provide assurancethat all entrants have evacuated the space atthe conclusion of an entry operation. In thepreamble to the standard, OSHA offers severalexamples of acceptable tracking methods that


(f) Entry Permit

71

track of the authorized entrants within thespace.

(f)(5) The personnel, by name, currently servingas attendants,

(f)(6) The individual, by name, currentlyserving as entry supervisor, with a space for thesignature or initials of the entry supervisor whooriginally authorized entry

(f)(7) The hazards of the permit space to beentered;

(f)(8) The measures used to isolate the permitspace and to eliminate or control permit spacehazards;

(f)(9) The acceptable entry conditions;

(f)(10) The results of initial and periodic testsperformed under paragraph (d)(5) of thissection,accompanied by the names or initials ofthe testers and by an indication of when the

includes the listing of entrants names on thepermit, tag boards, entry bandages, sign-insheet, and electronic tracking systems. On theother hand, a system that merely keeps asimple count of entrants will not satisfy thelanguage of (f)(4) that requires a system thatwill enable the attendant to determine whichentrants are in the space.

(f)(5) This paragraph requires no interpretationand should be taken as read.

(f)(6) The paragraph requires no interpretationand should be taken as read.

(f)(7) OSHA considers the documentation of theidentified hazards, within the space, on theentry permit vital to the safety of the entrants.

(f)(8) Paragraph (f)(8) does not requiremanagement to document the exact step-by-step procedures that will be used to eliminateor control the identified hazard(s). For example,if there is a mechanical hazard in the permitspace that must be deengerized to satisfy therequirements for acceptable entry conditions,the permit need only reference lockout/tagoutas the control measures that will be used.

(f)(9) Acceptable entry conditions includesoxygen, flammable gas and vapors, and toxicsubstance levels that must be met andmaintained before and during entryoperations. Also to be included are any energycontrol considerations that may apply.

(f)(10) In the preamble to the standard, OSHAcomments on paragraph (f)(10) stating that“recording the results of initial and periodictesting is a necessary feature of permit spaceprograms. If the results of the testing are


72


tests were performed;

(f)(11) The rescue and emergency services thatcan be summoned and the means (such as theequipment to use and the numbers to call) forsummoning those services;

(f)(12) The communication procedures used byauthorized entrants and attendants to maintaincontact during entry;

(f)(13) Equipment, such as personnel protective

entered on the permit, the entry supervisor hasbefore him readily available evidence that pre-entry conditions have been checked and whatthe test results were. Additionally, the entrantsthemselves will be able to check the permit tobe assured that the testing has been done andthat safe conditions exist”.

(f)(11) The identification of the facilityemergency and rescue services (in-plant oroutside services) and the means for summoningthem on the permit enables the attendant to callor signal for assistance in the event of anemergency. In addition to the service that is tobe employed, the permit should identify otherpertinent resources, such as an ambulanceservice and the fire department.

(f)(12) Paragraph (f)(12) requires that entrantsand the entry attendant “maintain contact” insome effective manner. This may not be as easyas it sounds, if for no other reason than anentrant, not visible to the entry attendant, maybecome disabled and may not be able to holdup his end of the communications plan. Itfollows that if an entrant is not observable bythe attendant, is down and unconscious, he willbe unable to maintain the contact that thestandard requires. Perhaps a good way toaddress the problem would be to set upprocedures that require a pre-agreed responsefrom either party, if contacted, and if the agreedupon response is not forthcoming, theprocedures should establish an appropriatecourse of action. Of course, the properequipment must be provided, such as poweredcommunications, or some type of audio signal.In any event, if anyone gets in trouble duringentry it will surely be the entrant and anymeans that enables the entry attendant toeffectively “maintain contact” with his entrantis acceptable.

(f)(13) Notice in the sample entry permit


73

equipment, testing equipment, communicationsequipment, alarm systems, and rescueequipment, to be provided for compliance withthis section;

(f)(14) Any other information whose inclusion isnecessary, given the circumstances of the particularconfined space, in order to ensure employee safety;and any additional permits, such as for hot work,that have been issued to authorize work in thepermit space.

(g)(1) The employer shall provide training sothat all employees whose work is regulated bythis section acquire the understanding,knowledge, and skills necessary for the safeperformance of the duties assigned under thissection.

(g)(2) Training shall be provided to eachaffected employee:

(g)(2)(i) Before the employee is first assignedduties under this section;

(g)(2)(ii) Before there is a change in assignedduties;

provided in the appendix includes spaces tocheck-off the equipment required by thestandard.

(f)(14) Due to the wide range of hazards thatcan be found in permit spaces there may becertain unsafe conditions that are not tocovered in a written permit. Take, for example,the possibility of an entrant falling in amultilevel permit space! In any event,paragraph (f)(14) mandates that “any otherinformation” that helps to ensure the safety ofentrant be documented on the appropriatepermit. By definition, any other workauthorization, such as a hot work permit,becomes a necessary addition to an entrypermit and must be included on the permit oras an attachment.

(g)(1) Notice that paragraph (g)(1) does notdictate a specific course of training for thoseemployees who perform permit space work.OSHA’s performance oriented approach hereallows management to develop and implementa training program that meets the needs of aparticular facility, so long as the training meetsthe requirements of the standard. OSHA will,for example, accept OJT (on-the-job training)as long as the trainer has had sufficentexperience and instruction to be qualified toteach the job.

(g)(2)(i) Paragraph (g)(2) and (g)(2)(i) requiresno interpretation and should be taken as read.

(g)(2)(ii) Such changes could be the result of anew equipment or techniques introduced into


(g) Training

74


(g)(2)(iii) Whenever there is a change in permitspace operations that presents a hazard aboutwhich an employee has not previously beentrained;

(g)(2)(iv) Whenever the employees has reasonto believe either that there are deviations fromthe permit space entry procedures required byparagraph (d)(3) of this section or that there areinadequacies in the employees knowledge or useof these procedures.

(g)(4) The employer shall certify that thetraining required by paragraphs (g)(1) through(g)(3) of this section has been accomplished. Thecertification shall contain each employeesname, the signature or initials of the trainers,and the dates of training. The certification shallbe available for inspection by employees andtheir authorized representatives.

(h) The employer shall ensure that allauthorized entrants:

the entry operations, promotions, or simplereassignments.

(g)(2)(iii) Such changes, for example, couldinclude new methods of atmospheric testing, orperhaps changes in the method of communicationbetween an entrant and the entry attendant.

(g)(2)(iv) In paragraph (g)(3), all that OSHArequires is that the training provided to permitspace entrants be of a quality that establishes alevel of employee skill and proficiency that willenable entrants to perform the job in a mannerconducive to their own safety.Be advised that GOOD training is not all thateasy to come by. One needs a trainer withexperience, skill, and a goodly amount of purejob knowledge. It’s not as simple as it sounds! I’veknown very few so called trainers who, in truth,had all of the requisite skills and communicationability needed to do an adequate job, and theemployer is cautioned to assure himself that histrainer really knows what he is about.

(g)(4) OSHA strongly believes that certi-fication of training provides a valuable recordto employers, employees, and OSHA indetermining whether or not the requiredtraining has been accomplished. The employerneed not fill out extensive forms or individualcertificates to meet this requirement. Theemployer could certify the training of anynumber of employees on a list or roster just aseffectively as through the use of individualcertificates.


75

(h)(1) Know the hazards that may be facedduring entry, including information on themode, signs or symptoms, and consequences ofthe exposure.

(h)(2) Properly use equipment as required by(d)(4) of this section;

(h)(3) Commmunicate with the attendant asnecessary to enable the attendant to monitorentrant status and to enable the attendant toalert entrants of the need to evacuate the spaceas required by paragraph (i)(6) of this section:

(h)(4) Alert the attendant whenever:

(h)(4)(i) The entrant recognizes any warning

(h)(1) The hazards faced during entry shouldbe the same as those that required the space tobe designated permit-required in the firstinstance. It is, of course, possible that a newand different hazard may have been introducedinto the space in the interim and thatconsideration must be taken into account incomplying with paragraph (h)(1). It onlyremains for the employer to communicate thatinformation to authorized entrants by way ofthe entry permit space. Information on toxicsubstances can be readily found in the MaterialSafety Data Sheet that is required to be presentat the workplace as part of the HazardCommunication standard, 29 CFR 1910.1200.

(h)(2) Paragraph (h)(2) merely reiterates whathas already been said in paragraph (d)(4), i.e.,that the employer is responsible for ensuringthat entrants use the equipment identified asnecessary for the safe performance of a permitspace assignment and, further, use it properly.

(h)(3) OSHA places a great deal of importanceon good communications between entrants andentry attendant as they address the issue inno less than four instances in the standard.(h)(3) requires entrants to communicate withentry attendant “as necessary” so that theattendant can expedite the evacuation of apermit space, if that need should arise, andfurther, to enable the attendant to be quicklyaware of any difficulties entrants may beexperiencing in order to summon neededassistance in the form of emergency and rescueservices.


(h) Duties of Authorized Entrants

76


sign or symptom of exposure to a dangeroussituation, or

(h)(4)(ii) The entrant detects a prohibitedcondition; and

(h)(5) Exit from the permit space as quickly aspossible whenever:

(h)(5)(i) An order to evacuate is given by theattendant or the entry supervisor,

(h)(5)(ii) The entrant recognizes any warningsign or symptom of exposure to a dangeroussituation,

(h)(5)(iii) The entrant detects a prohibitedcondition, or

(h)(5)(iv) An evacuation alarm is activated.

(i) The employer shall ensure that each attendant:(i)(1) Knows the hazards that may be facedduring entry, including information on themode, signs or symptoms, and consequences ofthe exposure;

(h)(4)(ii) OSHA’s concern in (h)(4)(i) and (ii) isthat in an entry operation involving more thanone entrant it is possible that criticalevacuation time could be lost while one entrantis attempting to contact another, especially ifthey are not close together. The end result isthat OSHA feels that the quickest and mosteffective means of ordering an evacuation isthrough the entry attendant and that is whatthis part of the standard requires.

(h)(5)(iv) Given the speed with which permitspace hazards can incapacitate and killentrants, it is essential that as soon as any oneof the four conditions set out in paragraphs(h)(5)(i) through (h)(5)(iv) exist, emergencyevacuation should begin. Therefore,OSHAbelieves that self-rescue will often provide theentrant’s best chance of escaping a permit spacewhen a hazard is present.

(i)(1) OSHA has worded paragraphs (h)(1),(i)(1), and (j)(1) of the standard identicallybecause it is important that attendants,authorized entrants, and entry supervisorsreceive the same training on hazards andhazard recognition.


(i) Duties of Attendants

77

(i)(2) Is aware of possible behavorial effects ofhazard exposure in authorized entrants;

(i)(3) Continuously maintains an accuratecount of authorized entrants in the permit spaceand ensures that the means used to identifyauthorized entrants under paragragh (f)(4) ofthis section accurately identifies who is in thepermit space;

(i)(4) Remains outside the permit space duringentry operations until relieved by anotherattendant;

(i)(5) Communicates with authorized entrantsas necessary to monitor entrant status and toalert entrants of the need to evacuate the spaceunder paragraph (i)(6) of this section:

(i)(6) Monitors conditions inside and outsidethe space to determine if it is safe for entrantsto remain in the space and orders theauthorized entrants to evacuate the permitspace immediately under any of the followingconditions:

(i)(2) Subtle behavioral changes, for example,in entrants speech, and/or deviation fromcommunication procedures could alert theattendant that it may be necessary to evacuatethe space or perhaps initiate an emergencyrescue.

(i)(3) Notice here in paragraph (i)(3) thestandard requires that the entry attendant notonly “maintain an accurate count” of thenumber of entrants in a permit space, but alsowho they are. In other words, a count will notsatisfy the rule. OSHA does not dictate howthe employer is to accomplish that, but onlythat it must be done.

(i)(4) The standard is specific that there willbe an entry attendant on duty at all timeswhen entry operations are in progress. It isimportant to remember that as long as theentry attendant is on duty, that person is NON-ENTRY personnel. For example, the attendantmay not attempt to affect an emergency rescueunless and until that person is properlyrelieved, and then only if the person has beentrained and equipped to do so. The attendantcan, however, attempt an emergency rescuefrom outside the space if and only if, theattendant can effectively perform all of theduties required of him.

(i)(5) Paragraph (i)(5) requires nointerpretation and should be taken as read.


78


(i)(6)(i) If the attendant detects a prohibitedcondition:

(i)(6)(ii) If the attendant detects the behavioraleffects of hazard esposure in an authorizedentrant;

(i)(6)(iii) If the attendant detects a situationoutside the space that could endanger theauthorized entrants; or

(i)(6)(iv) If the attendant cannot effectively andsafely perform all the duties required underparagraph (i) of this section;

(i)(7) Summon rescue and other emergencyservices as soon as the attendant determinesthat authorized entrants need assistance toescape from permit hazards;

(i)(8) Takes the following actions whenunauthorized persons approach or enter apermit space while entry is underway:

(i)(8)(i) Warn the unauthorized persons thatthey must stay away from the permit space;

(i)(8)(ii) Advise the unauthorized persons thatthey must exit immediately if they have entered thepermit space;

(i)(8)(iii) Inform the authorized entrants andthe entry supervisor if unauthorized personshave entered the permit space;

(i)(9) Performs non-entry rescue as specified bythe employer’s rescue procedures; and

(i)(6)(i) Such as an oxygen level less than19.5% in the space.

(i)(6)(ii) Such as exposure to residual airbornefumigants.

(i)(6)(iii) Such as a fire in the near vicinity ofthe space.

(i)(6)(iv) Such as a breakdown in the plannedcommunications between entrant andattendant.

(i)(7) In paragraph (i)(7) the entry attendant isrequired to summon help if the attendant believesthat an entrant “may” need emergency rescueassistance. The intent in using the word “may”is that if the attendant is confident that self-rescuecannot be successfully carried out, the attendantmust immediately summon help.

(i)(8)(iii) Paragraph (i)(8) through (i)(8)(iii)requires no interpretation and should be takenas read.


79

(i)(10) Performs no duties that might interferewith the attendants primary duty to monitor andprotect the authorized entrants.

(j) The employer shall ensure each entrysupervisor:

(j)(1) Knows the hazards that may be facedduring entry, including information on themode, signs or symptoms, and consequences ofthe exposure;

(j)(2) Verifies, by checking that the appropriateentries have been made on the permit, that alltests specified by the permit have been conductedand that all procedures and equipment specifiedby the permit are in place before edorses thepermit and allowing entry to begin;

(i)(10) In the preamble to the standard, OSHAstates that “it has decided to allow attendantsto perform only such duties as will not hindertheir primary function of monitoring andprotecting authorized entrants. Passing toolsand monitoring the atmosphere of a permitspace are among the types of duties that wouldbe permitted, provided the attendant does notbreak the plane of an opening into the space.The repair of equipment, on the other hand,would distract the attendant, so that he or shecould not adequately monitor or protectauthorized entrants, and would be prohibited”.

(j)(1) OSHA places the burden of employeesafety on the management sector by requiringpermit space entry operation to have anassigned entry supervisor. This is the personwho has overall responsibility for safe entryoperations.

In the preamble to the standard, OSHAstates “that paragraphs (h)(1) and (j)(1) thatauthorized entrants and attendantsrespectively are required to know what hazardsmay be faced during a permit space entryoperation. Since the entry supervisor isresponsible for all aspects of entry operation itis only reasonable that he or she be expectedto know as much, if not more, than authorizedentrants and attendants”.

(j)(2) Paragraph (j)(2) directs entry supervisorto ensure that entry conditions are acceptableand that all of the requirements specified onthe permit have been met. Having said that,the employer is well advised to select the bestperson available to fill to the entry supervisorposition because that individual is the key tosafe entry operations!


(j) Duties of Entry Supervisors

80


(j)(3) Terminates the entry and cancels the permitas required by paragraph (e)(5) of this section;

(j)(4) Verifies that rescue services are availableand that means for summoning them areoperable;

(j)(5) Removes unauthorized individuals whoenter or who attempt to enter the permit spaceduring entry operations; and

(j)(6) Determines, whenever responsibility for apermit space entry operations is transfered andat intervals dictated by the hazards andoperations performed within the space, that entryoperations remain consistent with the terms of theentry permit and that acceptable entry conditionsare maintained.

(j)(3) Paragraph (j)(3) requires no inter-pretation and should be taken as read.

(j)(4) Since the employer has the finalresponsibility for safe permit operations, OSHAconsiders it reasonable and consistent that theentry supervisor must ensure that availabilityof designated emergency rescue services and,further, that the means for summoning themis operable;

(j)(5) Recall that paragraphs (8)(i) and (8)(ii)require the entry attendant to “warn” and to“advise” unauthorized individuals to stay awayfrom a permit space or to evacuate the space ifthey have entered it. Now note here paragraph(j)(5) requires the entry supervisor to “remove”unauthorized individuals who enter or attemptto enter the permit space while entry isunderway. It goes without saying that there isa considerable difference in meaning betweenthe entry attendant’s “warn” and “advise” andthe entry supervisor’s “remove”. The end resultis that unless the entry attendant is successfulin dealing with the issue of unauthorized peoplein a permit space operation, OSHA has placedthe end responsibility of that burden squarelyon the shoulders of the entry supervisor.

(j)(6) OSHA has determined that thereevaluation of conditions within a permit spacemust occur whenever responsibility for entryoperations is transfered and, additionally, atintervals consistent with the nature of theidentified hazard(s) in the space and kind of workbeing performed therein. If the original entrysupervisor is relieved at shift end, OSHA intendsthat the new entry supervisor will review thepermit to determine whether or not acceptableentry conditions have been maintained.


81

(k)(1) An employer who designates rescue andemergency services, pursuant to paragraph (d)(9)of this section shall:

(k)(1)(i) Evaluate a prospective rescuer’s abilityto respond to rescue summons in a timelymanner considering the hazard(s) identified;

Note to paragraph (k)(1)(i): What will beconsidered timely will vary according to thespecific hazards involved in each entry. Forexample, 1910.134, Respiratory Protection,requires that employers provide a standbyperson or persons capable of immediate actionto rescue employee(s) wearing respiratoryprotection while in work defined as IDLHatmospheres.

(k)(1)(ii) Evaluate a prospective rescue service’sability, in terms of proficiency with rescue-related task and equipment, to functionappropriately while rescuing entrants from theparticular permit space or types of permit spacesidentified;

(k)(1)(iii) Select a rescue team or service fromthose evaluated that:

(k)(1)(iii)(a) Has the capability to reach thevictim(s) within a time frame that is appropriatefor the permit space hazard(s) identified;

(k)(1)(iii)(b) Is equipped for and proficient inperforming the needed services;

(k)(1)(iv) Inform each rescue team or service ofthe hazards they may confront when called on torescue at the site; and

(k)(1)(v) Provide the rescue team or serviceselected with access to all permit spaces fromwhich rescue may be necessary so that therescue service can develop appropriate rescueplans and practice rescue operations.

SPECIAL NOTE: When OSHA revised thePermit-required Confined Space standard, themost extensive revisions occured in the

STANDARD INTERPRETATION(k) Rescue and Emergency Services

82


(k)(2) An employer whose employees have beendesignated to provide permit space rescue andemergency services shall take the followingmeasures:

(k)(2)(i) Provide affected employees with thepersonal protective equipment (PPE) need toconduct permit space rescues safely and trainaffected employees so they are proficient in theuse that PPE, at no cost to those employees;

(k)(2)(ii) Train affected employees to performassigned rescue duties. The employer mustensure that such employees successfullycomplete the training required to establishproficiency as an authorized entrant, asprovided by paragraph (g) and (h) of thissection;

(k)(2)(iii) Train affected employees in basic first

Emergency and Rescue service section. For thebenefit of those who are covered by the standard,the agency saw fit to include a “Non-MandatoryAppendix-Rescue Team or Rescue ServiceEvaluation Criteria”The above paragraphs (k) through (k)(1)(v) setsforth the criteria for the selection andemployment of an outside rescue service and theemployer is directed to review our designatedAppendix C in it’s entirety.

(k)(2)(i) Hopefully, an employer whose permitspace entry program complies with this standardmay never need to call upon an emergencyrescue team. Confined space entry, however, isan animal like no other and in spite of efforts inthe way of procedures, testing, training, andother preventative measures, the unexpectedcan come about so quickly that in many casesentrants are unable to evacuate a permit spacewithout rescue assistance.Paragraph (k)(2)(i) merely requires theemployer to provide PPE to affected employeesand to train those employees until they areproficient in that propers use of that PPE.

(k)(2)(ii) Paragraph (k)(2)(i) merely reiteratesthat appropriate emergency rescue trainingmust be provided, but adds that each memberof the rescue team must be trained as if theyare an authorized entrant. Indeed, anytimerescue personnel invades a permit space, thatis exactly what they are i.e., a personauthorized by the employer to enter a permitspace in order to perform a specific task, albeitnot a conventional one. The employer is advisedto always keep in mind that response time is thesingle most important factor in permit spacerescue, and personnel that are expected to actefficiently and with controlled speed must begiven the training that prepares them to do so!

(k)(2)(iii) Paragraph (k)(2)(iii) requires no


83

aid and cardiopulmonary resuscitation (CPR).The employer shall ensure that at least onemember of the rescue team or service holding acurrent certification in first aid and CPR isavailable; and

(k)(2)(iv) Ensure that affected employees practicemaking permit space rescues at least once every12 months, by means of simulated rescueoperations in which they remove dummies,manequins, or actual persons from the actualpermit spaces or from representative permit spaces.Representative permit spaces shall, with respectto opening size, configuration, and accessibility,simulate the types of permit spaces from rescue isto be performed.

(k)(3) To facilitate non-entry rescue retrievalsystems or methods shall be used whenever anauthorized entrant enters a permit space, unlessthe retrieval equipment would increase theoverall risk of entry or would not contribute tothe rescue of the entrant. Retrieval systems shallmeet the following requirements.

(k)(3)(i) Each authorized entrant shall use achest or full body harness, with a retrieval lineattached at the center of the entrant’s back nearshoulder level, above the entrants’s head, or atanother point which the employer can establish

interpretation and should be taken as read.

(k)(2)(iv) As per paragraph (k)(2)(iv), theemployer must ensure that rescue personnelare made familiar with the type of permit spacefrom which rescue may be required by way ofat least one practice rescue annually. OSHAconsiders it essential that the mock rescue beconducted utilizing representative spaces,especially with regard to means of access andegress. In the preamble OSHA states “that aperiod demonstration of on-site rescue service’sability to extract authorized entrants frompermit spaces will provide the necessaryfeedback regarding the adequacy of the rescueequipment, and the rescue procedures and thetraining provided for the performance of rescuefrom permit spaces”.

(k)(3) In making a determination as to whetheror not a retrieval system is called for, OSHAenforcement personnel will use the followingguidelines;• A permit space with obstructions or turns thatprevent pull on the retrieval line from beingtransmitted to the entrant does not require theuse of a retrieval system.• A permit space from which an employee beingrescued with the retrieval system would beinjured because of forceful contact with projectionsin the space does not require the use of a retrievalsystem; and• A permit space that was entered by an entrantusing an air supplied respirator does not requirethe use of a retrieval system if the retrieval linecould not be controlled so as to prevententanglement hazards with the air line.

(k)(3)(i) In paragraph (k)(3)(i), OSHA isselective in requiring the positioning of theretrieval line attachment “at the center of theentrant’s back near the shoulder level, or abovethe entrant’s head” so that the smallest possible


84


presents a profile small enough for the successfulremoval of the entrant. Wristlets may be usedin lieu of the chest or full body harness isinfeasible or creates a greater hazard and thatthe use of wristlets is the safest and most effectivealternative.

(k)(3)(ii) The other end of the retrieval line shallbe attached to a mechanical device or fixed pointoutside the permit space in such a manner thatrescue can begin as soon as the rescuer becomesaware that rescue is necessary. A mechanical deviceshall be available to retrieve personnel from verticaltype permit spaces more than 5 feet (1.52 M) deep.

(k)(4) If an injured employee is exposed to asubstance for which a Material Safety DataSheet (MSDS) or other similar writteninformation is required to be kept at theworksite, that MSDS or written informationshall be made available to the medical facilitytreating the exposed entrant.

(l)(1) Employers shall consult with affectedemployees and their authorized representativeson the development and implementation of allaspects of the permit space program requiredby paragraph (c) of this section.

(l)(2) Employers shall make available to affectedemployees and their authorized representatives allinformation required to be developed by this section.

entry profile can be achieved during removalshould removal become necessary. Wristletsmay be used instead of the chest or full bodyharness if they are deamed the safer method.

(k)(3)(ii) The mechanical device required inparagraph (k)(3)(ii) must be appropriate for theintended use, i.e., emergency rescue. OSHA willnot permit the use of equipment, such as a forklift, that could injure an entrant during rescueoperations. Notice that a mechanical devicemust be on hand anytime vertical entry of 5feet or more is made. OSHA’s definition of a“vertical type permit space” is one whoseopening is above the entrant.

(k)(4)OSHA considers it important thatmedical treatment personnel are supplied withany available information concerning anentrant’s exposure to a hazardous substance.

(l)(2) Paragraph (l)(1) and (l)(2) reflect OSHA’sintention that affected employees and theirauthorized representatives are to be fullyinformed concerning all aspects of theemployers permit space program


(l) Employee Participation

85

ACCEPTABLE ENTRY CONDITIONS means the condition that must exist in a permitspace to allow entry and to ensure that employee involved with a permit-required confinedspace can safely enter into and work within the space.

ATTENDANT means an individual stationed outside one or more permit spaces who monitors theauthorized entrants and who performs all attendant’s duties assigned in the employer’s permitspace program.

AUTHORIZED ENTRANT means an employee who is authorized by the employer to enter apermit space.

BLANKING OR BLINDING means the absolute closure of a pipe, line, or duct by fasteningof a solid plate (such as a spectacle blind or a skillet blind) that completely covers the bore andthat is capable of withstanding the maximum pressure of the pipe, line, or duct with no leakagebeyond the plate.

CONFINED SPACE means a space that:(1) Is large enough and so configured that an employee can bodily enter and perform assignedwork; and(2) Has limited or restricted means for entry or exit (for example, tanks, vessels, silos, storagebins, hoppers, vaults, and pits are spaces that may have limited means of entry,) ; and(3) Is not designed for continuous employee occupancy.

DOUBLE BLOCK AND BLEED means the closure of a line, duct, or pipe by closing andlocking or tagging two in-line valves and by opening and locking or tagging a drain or vent inthe line between the two closed valves.

EMERGENCY means any occurence (including any failure of hazard control or monitoringequipment) or event internal or external to the permit space that could endanger entrants.

ENGULFMENT means the surrounding and effecting capture of a person by liquid or finelydivided (flowable) solid substance that can be aspirated to cause death by filling or pluggingthe respiratory system or that can exert enough force on the body to cause death by strangula-tion, constriction, or crushing.

ENTRY means the action by which a person passes through an opening into a permit-requiredconfined space. Entry includes ensuring work activities in that space and is considered to haveoccured as soon as any part of the entrant’s body breaks the plane of an opening into the space.

ENTRY PERMIT (permit) means the written or printed document that is provided by theemployer to allow and control entry into a permit space and that contains the informationspecified in paragraph (f) of this section.

ENTRY SUPERVISOR means the person (such as the employer, foreman, or crew chief) respon-sible for determining if acceptable entry conditions are present at a permit space where entry isplanned, for authorized entry and overseeing entry and overseeing entry operations, and forterminating entry as required by this section.NOTE: An entry supervisor also may serve as an attendant or as an authorized entrant, aslong as that person is trained and equipped as required by this section for each role he or she

Appendix A-DEFINITIONS

86


fills. Also, the duties of entry supervisor may be passed from one individual to another duringthe course of an entry operation.HAZARDOUS ATMOSPHERE means an atmosphere that may expose employees to the riskof death, incapacitation, impairment of ability to self-rescue (that is, escape unaided from apermit space), injury, or acute illness from one or more of the following causes:(1) Flammable gas, vapor, or mist in excess of 10 percent of its lower flammable limit (LFL) ;(2) Airborne combustible dust at a constration that meets or exceeds its LFL;NOTE: This concentration may be approximated as a condition in which the dust obscures visionat a distance of 5 feet (1.52 m) or less.(3) Atmospheric oxygen concentration below 19.5 percent or above 23.5 percent;(4) Atmospheric concentration of any substance for which a dose or a permissable exposurelimit is published in Subpart G, Occupation Health and Environment Control, or in subpart Z,Toxic and Hazardous Substances, of this part and which could result in employee exposure inexcess of its dose or permissable exposure limit;NOTE: An atmospheric concentration of any substance that is not capable of causing death,incapacitation, impairment of ability of self-rescue, injury, or acute illness due to its healtheffects is not covered by this provision.(5) Any other atmospheric condition that is immediately dangerous to life or health.NOTE: For air contaminants for which OSHA has not determined a dose or permissible expo-sure limit, other sources of information such as Material Safety Data Sheets that comply withthe Hazard Communications Standard, 1910. 1200 of this part, published information, andinternal documents can provide guidance in establishing acceptable atmospheric conditions.

HOT WORK PERMIT means the employer’s written authorization to perform operations (forexample, riveting, welding, cutting, burning, and heating) capable of providing a source ofignition.

IMMEDIATELY DANGEROUS TO LIFE OR HEALTH (IDLH) means that any conditionthat poses an immediate or delayed threat to life or that would cause irreversible health effects orthat would interfere with an individual’s ability to escape unaided from a permit space.NOTE: Some materials - hydrogen flouride gas and cadmium vapor, for example- may produceimmediate transient effects that, even if severe, may pass without medical attention, but arefollowed by sudden, possibly fatal collapse 12-72 hours after exposure. The victim “feels nor-mal” from recovery from transient effect until collapse. Such materials in hazardous quantitiesare considered to be “immediately” dangerous to life or health.

INERTING means the displacement of the atmosphere in a permit space by a noncumbustible gas(such as nitrogen) to such an extent that the resulting atmosphere is noncombustible.NOTE: This procedure produces an IDLH oxygen-deficient atmosphere.

ISOLATION means the process by which a permit space is removed from service and com-pletely protected against the release of energy and material into the space by such means as :blanking or blinding; misaligning or removing sections of lines, pipes, or ducts ; a double blockand bleeding system; lockout or tagout of all sources of energy ; or blocking or disconnecting allmechanical linkages.

LINE BREAKING means the intentional opening of a pipe, line, or duct that is or has beencarrying flammable, corrosive, or toxic material, an inert gas, or any fluid at a volume, pres-sure, or temperature capable of causing injury.

87

NON-PERMIT CONFINED SPACE means a confined space that does not contain or, with respectto atmospheric hazards, have the potential to contain any hazard capable of causing death or seriousphysical harm.OXYGEN DEFICIENT ATMOSPHERE means an atmosphere containing less than 19.5percent oxygen by volume.

OXYGEN ENRICHED ATMOSPHERE means an atmosphere containing more than 23.5percent oxygen by volume.

PERMIT-REQUIRED CONFINED SPACE (per space) means a confined space that hasone or more of the following characteristics:(1) Contains or has a potential to concentrate a hazardous atmosphere;(2) Contains a material that has the potential for engulfing an entrant;(3) Has an internal configuration such as an entrant could be trapped or asphyxiated by in-wardly converging walls or by a floor which slopes downward and tapers to a smaller cross-section; or(4) Contains any other recognized serious safety or health hazard.

PERMIT-REQUIRED CONFINED SPACE PROGRAM (PERMIT SPACE PROGRAM)means the employer’s overall program for controlling, and, where appropriate, for protecting em-ployees from, permit space hazards and for regulating employee entry into permit spaces.

PERMIT SYSTEM means the employer’s written procedure for preparing and issuing permitsfor entry and for returning the permit space to service following termination of entry.

PROHIBITED CONDITION means any condition in a permit space that is not allowed by thepermit during the period when entry is authorized.

RESCUE SERVICE means the personnel designated to rescue employees from permit spaces.

RETRIEVAL SYSTEM means the equipment (including a retrieval line, chest or full-bodyharness, wristlets, if appropriate, and a lifting device or anchor) used for non-entry rescue ofpersons from permit space.

TESTING means the process by which the hazards that may confront entrants of a permitspace are identified and evaluated. Testing includes specifying the tests that are to be per-formed in the permit space.NOTE: Testing enables employers both to devise and implement adequate control measuresfor the protection of authorized entrants and to determine if acceptable entry conditions arepresent immediately prior to, and during entry.

88

ÿþýüûú ø÷öûõ ôóý ò ñóðýï óîöíì ëöö êóéûþï óô éþýüûú èûöö ýþü÷ûî ÷ú çóæ ïûúþ ðîúûö çóæ ûï êóüéöþúþõì�ûúþ öóê÷úûóî ÷îõ õþïêýûéúûóî�� ÿðýéóïþ óô þîúýí�� ðéþýøûïóý�ï� ûî êñ÷ý�þ óô êýþèï�� íéþ óô �ýþè�� ÿñóîþ �� ðóúþï õþîóúþ üûîûüðü ýþ�ðûýþüþîúï úó æþ êóüéöþúþõ ÷îõ ýþøûþèþõ éýûóý úó þîúýí�þ�ðûýþüþîúï �óüéöþúþõ �÷úþ �ûüþ� �óê�óðú� �þ� þîþý�û�þ� �ýí� óðú�� ûîþ�ï� �ýó�þî� �÷ééþõ� �ö÷î�þõ�� ÿðý�þ� �öðïñ ÷îõ �þîú�� þîúûö÷úûóî�� þêðýþ ëýþ÷ �ÿóïú ÷îõ �ö÷�� ýþ÷úñûî � ëéé÷ý÷úðï�� þïðïêûú÷úóý� � îñ÷ö÷úóý�� ú÷îõæí �÷ôþúí ÿþýïóîîþö�� ðöö �óõí �÷ýîþïï è�� ýûî�� üþý�þîêí �ïê÷éþ �þúýûþø÷ö ��ðûé�� ûôþöûîþï��ûýþ �� úûî�ðûïñþýï�û�ñúûî� ��éöóïûøþ ÿýóóô�ÿýóúþêúûøþ �öóúñûî��þïéûý÷úóý�ï� �ëûý ÿðýûôíûî��ðýîûî� ÷îõ � þöõûî� ÿþýüûú

�þïú�ï� úó æþ ú÷�þî ÿþýüûïï÷æöþ �îúýí �þøþö ��

� ÿþýêþîú óô � �í�þî� ��ì�� úó ��ì�� óèþý �ö÷üü÷æöþ �ûüûú� �îõþý �� ÷ýæóî �óîó�ûõþ� ��ÿÿ� �� ëýóü÷úûê �íõýóê÷ýæóî �ÿÿ� ��ÿÿ� �� íõýó�þî �í÷îûõþ �� ûî� ��ÿÿ� �� íõýó�þî �ðöôûõþ ��ÿÿ� ��ÿÿ� �� ðöôðý �ûó�ûõþ �ÿÿ� ��ÿÿ� �� ëüüóîû÷ � ��ÿÿ� �� ñóýú� úþýü þ� éóïðýþ öûüûú��ü éöóíþþ ê÷î èóý�ûî úñþ ÷ýþ÷ ð é úó ��üûîðúþïì�ò �óðý �ûüþ � þû�ñúþõ ëøþý÷�þ��üéöóíþþ ê÷î èóý�ûî ÷ýþ÷ ò ñóðýï �öóî�þý èûúñ ÷ééýóéýû÷úþ ýþïéûý÷úóýí éýóúþêúûóî�

�þü÷ý�ï�

��

��

�÷ôþúí �ú÷îõæí ÿþýïóî � ï �þ�ðûýþõ �óý ëöö �óîôûîþõ �é÷êþ � óý��ñþê��

��

�ðéþýøûïóý ëðúñóýû� ûî� �îúýíëöö ëæóøþ �óîõûúûóîï �÷úûïôûþõ�� ÷ï �óóýõûî÷úóý

�� ò��þé÷ýúüþîú�� ÿñóîþ �ýû�ûî÷ö úó ÿûî��óéí

�þ é÷ýúüþîú úó �÷ôþú í

�÷ôþú í �� ëüæðö÷îêþ �ò� � �ûýþ ��

�÷ôþú í �ú÷îõæ íÿþýïóî� ï�

�÷üþ óô �÷ôþú í �ñþê� ��ú÷îõæ í ÿþýïóî� ï�

�þýû÷ö �� îûú �

�÷ï �þïúþý�÷üþ � �ñþê� � �ïþõ

� îïúýðüþîúï �óõþö �� íéþ

� � �þêóýõ �óîúûîðóðï �óîûúóýûî � �þïðöúï �øþý í � �óðýï

ÿþþýüûúù ÷öõüôóò ñýóðúô�óîôûîþõ � é÷êþ �÷�÷ýõóðï ëýþ÷

�� úþüï úñ÷ú õó îóú ÷ééöí þîúþý �� ë ûî úñþ æö÷î�ì

89

Rescue Team/Service Evaluation CriteriaA P P E N D I X C (N O N - M A N D A T O R Y)

(1) This appendix provides guid-ance to employers in choosing anappropriate rescue service. It containscriteria that may be used to evaluatethe capabilities both of prospectiveand current rescue teams. Before arescue team can be trained or chosen,however, a satisfactory permit pro-gram, including an analysis of all per-mit-required confined spaces to iden-tify all potential hazards in those spaces,must be completed. OSHA believesthat compliance with all the provi-sions of S1910.146 will enable em-ployers to conduct permit space op-erations without recourse to rescueservices in nearly all cases. However,experience indicates that circum-stances will arise where entrants willneed to be rescued from permit spaces.It is therefore important for employ-ers to select rescue services or teams,either on-site or off-site, that areequipped and capable of minimizingharm to both entrants and rescuers ifthe need arises.

(2) For all rescue teams or services,the employer’s evaluation should con-sist of two components: an initialevaluation, in which employers de-cide whether a potential rescue serviceor team is adequately trained andequipped to perform permit spacerescues of the kind needed at thefacility and whether such rescuers canrespond in a timely manner, and aperformance evaluation, in whichemployers measure the performanceof the team or service during an actualor practice rescue. For example, basedon the initial evaluation, an employermay determine that maintaining anon-site rescue team will be more ex-pensive than obtaining the services ofan off-site team, without being sig-nificantly more effective, and decideto hire a rescue service. During aperformance evaluation, the employercould decide, after observing the res-cue service perform a practice rescue,that the service’s training or prepared-ness was not adequate to effect a timely

or effective rescue at his or her facilityand decide to select another rescueservice, or to form an internal rescueteam.

A. Initial Evaluation1. The employer should meet with

the prospective rescue service to facili-tate the evaluations required byS1910.146(k)(1)(i)andS1910.146(k)(1)(ii). At a minimum, if an off-siterescue service is being considered, theemployer must contact the service toplan and coordinate the evaluationsrequired by the standard. Merely post-ing the service’s number or planningto rely on the 911 emergency phonenumber to obtain these services at thetime of a permit space emergencywould not comply with paragraph(k)(1) of the standard.

II. The capabilities required of arescue service vary with the type ofpermit spaces from which rescue maybe necessary and the hazards likely tobe encountered in those spaces.

Answering the questions below willassist employers in determiningwhether the rescue service is capableof performing rescues in the permitspaces present at the employer’sworkplace.

1. What are the needs of the em-ployer with regard to response time(time for the rescue service to receivenotification, arrive at the scene, andset up and be ready for entry)? Forexample, if entry is to be made into anIDLH atmosphere, or into a spacethat can quickly develop an IDLHatmosphere (if ventilation fails or forother reasons), the rescue team orservice would need to be standing byat the permit space. On the otherhand, if the danger to entrants isrestricted to mechanical hazards thatwould cause injuries (e.g., brokenbones, abrasions) a response time of10 or 15 minutes might be adequate.

2. How quickly can the rescue teamor service get from its location to thepermit spaces from which rescue may

be necessary? Relevant factors to con-sider would include: the location ofthe rescue team or service relative tothe employer’s workplace, the qualityof roads and highways to be traveled,potential bottlenecks or traffic con-gestion that might be encountered intransit, the reliability of the rescuer’svehicles, and the training and skill ofits drivers.

3. What is the availability of therescue service? Is it unavailable at cer-tain times of the day or in certainsituations? What is the likelihood thatkey personnel of the rescue servicemight be unavailable at times? If therescue service becomes unavailablewhile an entry is underway, does ithave the capability of notifying theemployer so that the employer caninstruct the attendant to abort theentry immediately?

4. Does the rescue service meet allthe requirements of paragraph (k)(2)of the standard? If not, has it devel-oped a plan that will enable it to meetthose requirements in the future? Ifso, how soon can the plan be imple-mented?

5. For off-site services, is the servicewilling to perform rescues at theemployer’s workplace? (An employermay not rely on a rescuer who de-clines, for whatever reason, to providerescue services.)

6. Is an adequate method for com-munications between the attendant,employer and prospective rescuer avail-able so that a rescue request can betransmitted to the rescuer withoutdelay? How soon after notification cana prospective rescuer dispatch a rescueteam to the entry site?

7. For rescues into spaces that maypose significant atmospheric hazardsand from which rescue entry, patientpackaging and retrieval cannot be safelyaccomplished in a relatively short time(15-20 minutes), employers shouldconsider using airline respirators (withescape bottles) for the rescuers and tosupply rescue air to the patient. If the


90

employer decides to use SCBA, doesthe prospective rescue service have anample supply of replacement cylin-ders and procedures for rescuers toenter and exit (or be retrieved) wellwithin the SCBA’s air supply limits?

8. If the space has a vertical entryover 5 feet in depth, can the prospec-tive rescue service properly performentry rescues? Does the service havethe technical knowledge and equip-ment to perform rope work or elevatedrescue, if needed?

9. Does the rescue service have thenecessary skills in medical evaluation,patient packaging and emergency re-sponse?

10. Does the rescue service have thenecessary equipment to perform res-cues, or must the equipment be pro-vided by the employer or anothersource?

B. Performance EvaluationRescue services are required by para-

graph (k)(2)(iv) of the standard topractice rescues at least once every 12months, provided that the team orservice has not successfully performeda permit space rescue within thattime. As part of each practice session,the service should perform a critiqueof the practice rescue, or have anotherqualified party perform the critique,so that deficiencies in procedures,equipment, training, or number ofpersonnel can be identified and cor-rected. The results of the critique, andthe corrections made to respond tothe deficiencies identified, shold begiven to the employer to enable it todetermine whether the rescue servicecan quickly be upgraded to meet theemployer’s rescue needs or whetheranother service must be selected.

The following questions will assistemployers and rescue teams and ser-vices evaluate their performance.

1. Have all members of the servicebeen trained as permit space entrants,at a minimum, including training inthe potential hazards of all permitspaces, or of representative permitspaces, from which rescue may beneeded? Can team members recog-nize the signs, symptoms, and conse-quences of exposure to any hazardous

atmospheres that may be present inthose permit spaces?

2. Is every team member providedwith, and properly trained in, the useand need for PPE, such as SCBA or fallarrest equipment, which may be re-quired to perform permit space res-cues in the facility? Is every teammember properly trained to performhis or her functions and make rescues,and to use any rescue equipment,such as ropes and backboards, thatmay be needed in a rescue attempt?

3. Are team members trained in thefirst aid and medical skills needed totreat victims overcome or injured bythe types of hazards that may beencountered in the permit spaces atthe facility?

4. Do all team members performtheir functions safely and efficiently?Do rescue service personnel focus ontheir own safety before consideringthe safety of the victim?

5. If necessary, can the rescue ser-vice properly test the atmosphere todetermine if it is IDLH?

6. Can the rescue personnel iden-tify information pertinent to the res-cue from entry permits, hot workpermits, and MSDSs?

7. Has the rescue service been in-formed of any hazards to personnelthat may arise from outside the space,such as those that may be caused byfuture work near the space?

8. If necessary, can the rescue ser-vice properly package and retrieve vic-tims from a permit space that has alimited size opening (less than 24inches (60.9 cm) in diameter), lim-ited internal space, or internal ob-stacles or hazards?

9. If necessary, can the rescue ser-vice safely perform an elevated (highangle) rescue?

10. Does the rescue service have aplan for each of the kinds of permitspace rescue operations at the facility?Is the plan adequate for all types ofrescue operations at the facility?Teamsmay practice in representative spaces,or in spaces that are “worst-case” ormost restrictive with respect to inter-nal configuration, elevation, and por-tal size.

The following characteristics of a

practice space should be consideredwhen deciding whether a space istruly representative of an actual per-mit space:

(1) Internal configuaration.(a) Open-there are no obstacles,

barriers, or obstructions within thespace. One example is a water tank.

(b) Obstructed-the permit spacecontains some type of obstructionthat a rescuer would need to maneu-ver around. An example would be abaffle or mixing blade. Large equip-ment, such as a ladder or scaffold,brought into a space for work pur-poses would be considered an ob-struction if the positioning or size ofthe equipment would make rescuemore difficult.

(2) Elevation.(a) Elevated-a permit space where

the entrance portal or opening is abovegrade by 4 feet or more. This type ofspace usually requires knowledge ofhigh angle rescue procedures becauseof the difficulty in packaging andtransporting a patient to the groundfrom the portal.

(b) Non-elevated-a permit spacewith the entrance portal located lessthan 4 feet above grade. This type ofspace will allow the rescue team totransport an injured employee nor-mally.

(3) Portal size.(a) Restricted-A portal of 24 inches

or less in the least dimension. Portalsof this size are too small to allow arescuer to simply enter the space whileusing SCBA. The portal size is also toosmall to allow normal spinal immobi-lization of an injured employee.

(b) Unrestricted-A portal of greaterthan 24 inches is the least dimension.These portals allow relatively freemovement into and out of the permitspace.

(4) Space access.(a) Horizontal-The portal is lo-

cated on the top of the permit space,so that rescuers must climb down, orthe bottom of the permit space, sothat rescuers must climb up to enterthe space. Vertical portals may requireknowledge of rope techniques, or spe-cial patient packaging to safely re-trieve a downed entrant.


91

92

93

94

95

96

97

Documents

Permit-Required Confined Spaces - Grainnet€¦ · industry from the hazards of entry into permit-required confined spaces. This section does not apply to agriculture, to construction,