Confined Space Program

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Confined Space Program

CONFINED SPACE PROGRAM

1. Purpose

The purpose of the confined space program is to set into place, procedures to protect workers whenever entry into a confined space is required for inspection, maintenance or other reasons. Adherence to the standards in this program is imperative to ensure safe entry, safe work and safe egress. This program is in accordance with the Washington Industrial Safety and Health Administration’s (WISHA), Confined Spaces standard, WAC 296-809.

All persons preparing to enter a confined space must identify the procedure for the specific space and follow all procedures as detailed in this program. This school district will provide all personal protective equipment, operating equipment and supervision necessary when employees must enter a confined space. Employees of this school district will not enter permit-required confined spaces. District employees will not enter a non-permit required confined space unless they have been trained in, and are following the requirements set forth in this program. For outside contractors, the District will provide all pertinent information and their confined space program to enable the contractor to provide for safe working conditions for the contractors employees.

2. Definitions

Confined Space: A space defined by the concurrent existence of all of the following conditions: 1. Large enough and so configured that a person can enter and perform work. 2. Has limited or restricted means for entry or exit. 3. Is not designed for continuous occupancy.

Permit-Required Confined Space (PRCS): A confined space that has one or more of the following characteristics: 1. Contains or has a potential to contain a hazardous atmosphere. 2. Contains a material that has the potential for engulfing an entrant. 3. Has an internal configuration such that an entrant could be trapped or asphyxiated by inwardly converging walls or by a floor which slopes downward and tapers to a smaller cross-section. 4. Contains any physical hazard. This includes any recognized health or safety hazards including engulfment in solid or liquid material, electrical shock, thermal hazards, chemical contact hazards or moving parts. 5. Contains any other recognized serious safety or health hazard that could either impair the ability to self-rescue or result in a situation that presents an immediate danger to life or health.

Non-Permit Confined Space (NPCS): Any confined space not having any of the four characteristics of a Permit-Required Confined Space as listed above, i.e. does not contain actual hazards or potential hazards capable of causing death or serious physical harm. Enter (entry) The action by which a person passes through an opening into a permit-required confined space and includes work activities in that space. Entry is considered to have occurred as soon as any part of the entrant’s body breaks the plane of an opening into the space. Note: If the opening is large enough for the worker to fully enter the space, a permit is required even for partial body entry. Permits aren't required for partial body entry where the opening isn't large enough for full entry, although other rules such as Lockout-Tagout, WAC 296-24-110 or Respiratory Hazards, chapter 296-841 WAC may apply. Hazardous atmosphere An atmosphere that may expose employees to the risk of death, incapacitation, impairment of ability to self-rescue (that is, escape unaided from a permit-required confined space), injury, or acute illness caused by one or more of the following:

 Flammable gas, vapor, or mist in excess of 10% of its lower flammable limit (LFL).  Airborne combustible dust at a concentration that meets or exceeds its LFL. Note: This concentration may be approximated as a condition in which the dust obscures vision at a distance of 5 feet (1.52 m) or less.

 Atmospheric oxygen concentration below 19.5% or above 23.5%.  Atmospheric concentration of any substance which may exceed a permissible exposure limit. - Any other atmospheric condition that is immediately dangerous to life or health.

3. Program Responsibilities

The district Safety Officer and the district’s Maintenance Department Manager are responsible for managing the confined space program. Their duties include:  Identification of all confined spaces in the workplace  Classification of confined spaces as permit or non-permit required  Documentation of the classification process  Informing affected employees about the existence, location, and danger of any permit- required confined spaces  Taking effective measures to prevent unauthorized employees from entering permit- required confined spaces  Working closely with contractors who enter district confined spaces (see WAC 296- 809-20006)  Reevaluation of non-permit required spaces if hazards develop. 4. Confined Space Identification/Evaluation

The district Safety Officer and the district Maintenance Manager shall ensure a survey of the workplace is conducted to identify confined spaces. The purpose of the survey is to develop an inventory of those locations and/or equipment that meet the definition of a confined space. This information shall be documented and communicated to personnel, and appropriate confined space procedures shall be followed prior to entry. Examples of confined spaces often found in schools include:  Tunnels for steam or hot water pipes  Crawl spaces under buildings  Crawl spaces in attic areas of buildings  Vaults for mechanical equipment and/or valves, meters, etc.  Air handler units  Supply and return air plenums sawdust collection cyclones  Water towers, chillers, and tanks  Boilers  Tanks of any type, size, or location Once all confined spaces have been identified it is determined which of them are by definition, a permit-required confined space. Identified confined spaces will be evaluated using the criteria listed for permit-required confined spaces as found in Section 2. The district will assume that a confined space is a permit-required confined space, until it has been determined to be a non-permit confined space. If there are changes in activities or changes in physical or environmental conditions that could alter the hazards of a confined space, the Safety Officer and/or the Maintenance Manager will reevaluate the space.

5. Training

Awareness training is provided to all employees potentially exposed to permit spaces and covers the following:  The location and hazard of each space  The district program for confined spaces  Emphasis on not entering the space for any reason. There is no training requirement for employees who only enter non-permit required confined spaces. (Training is required for permit-required confined space entry). However the district will strive to provide employees who enter non-permit confined spaces information that might include: 1. Explanation of the general hazards associated with confined spaces. 2. Discussion of specific confined space hazards associated with the facility, location, or operation. 3. Reason for, proper use, and limitations of personal protective equipment and other safety equipment required for entry into confined spaces. 4. A clear understanding of what conditions would prohibit entry. 5. Procedures for responding to emergencies. 6. Duties and responsibilities of the confined space entry team. 7. Description of how to recognize symptoms of overexposure to probable air contaminants in themselves and co-workers, and method(s) for alerting the Attendant(s).

Refresher training shall be conducted as needed to maintain employee competence in entry procedures and precautions.

6. Entry (Non-permit Confined Space)

Prior to entry into an NPCS all workers must observe conditions in the area to determine if there are any changes or conditions that suggest an unsafe work environment. If there are concerns about the safety of the NPCS, the worker must not enter the space and report his/her concerns to the district Safety Officer or their supervisor. Qualified personnel will inspect the area and determine if any hazards exist. Employees entering an NPCS must take actions to assure maintenance of safe working conditions. Materials that could cause a hazard must not be taken into the space. Likewise the worker must not perform any work that would create a hazard. It is essential to follow good work practices at all times. Depending on the conditions present and the work to be performed, it may be necessary to:  Lock out/Tag out equipment—Prevent unwanted operation of fans in duct areas, protect against flow of liquid or steam in pipes being worked on in confined area.  Erect barriers to direct pedestrian & vehicular traffic away from site. Block or tie boiler doors open to prevent accidental closure.  Wear personnel protective devices such as clothing, eye protection, hard hat, hearing protection, and/or respiratory protection. If asbestos is present, comply with all asbestos-handling regulations.  Provide additional ventilation as needed for personal comfort.  Wear personal air monitoring device to detect possible change in air quality.  Establish ongoing communication with someone outside the confined space. Check- in/check-out calls to the Maintenance Department or use of a maintenance helper outside the confined space should be considered.  Be alert to changes in yourself—Headaches, dizziness and other feelings of discomfort may be warning signs of something wrong. IF IN DOUBT, GET OUT.

7. Contractors

When a contractor is hired to perform work in a district confined space, the district will provide the contractor with the following information:  The location of the permit spaces at our facility.  Entry into permit spaces is only allowed by following the written entry program.  The reasons for listing the space as a permit space, including both of the following:  The identified hazards  Our experience with the particular space.  Precautions we have implemented to protect employees working in or near the space.  Who will debrief the contractor at the completion of entry operations, or during entry if needed, on whether any hazards were confronted or created during their work.

PERSONAL PROTECTIVE EQUIPMENT Certain confined spaces have conditions that require the use of Personal Protective Equipment (PPE) to protect workers from injury. All entrants shall use PPE as specified by the person authorizing entry. Additional PPE may be worn at the discretion of the worker. This includes protective clothing, respirators, eye protection, hearing protection, hard hats, or other PPE as required.

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