Definitions

Identification and Recognition of Confined Spaces

Notification

Confined Space Survey

Limits

Permit Required Confined Spaces

Personnel Responsibilities

Special Considerations and Hazards

Downgrading Permit Required Confined Spaces

Emergency Response

Training

Union Contract

Appendix A

Mission Statement

Scope:

In accordance with the University Policy on Environmental Health and Safety, this program shall provide minimum safety requirements to be followed while entering, exiting and working in confined spaces at the University of Massachusetts at Amherst and other locations to which this campus has responsibilities.

Purpose:

The purpose of this standard is to establish procedures for the health and safety of all University employees who will be working within Confined Spaces (permit and non-permit required).

In addition, outside contractors are responsible for complying with OSHA confined space policy. Contractors need to coordinate their own confined space procedures in accordance with the requirements of this program, as noted in division one of the contract. Their contracts will specifically require the General Contractor to notify the Physical Plant Safety Officer or EH&S whenever Permit Required Confined Space (PRCS) access is required. (Refer to Appendix of PRCS Program.)

Objectives:

This program has been developed to identify confined space, implement an entry permit system, require testing for hazardous atmospheres, provide safety equipment and ventilation guidelines and establish a required training program for confined space entry.

This program will also allow for the reduction of a "permit required confined space" to a "non-permit required confined space" so long as established criteria (identified in this program) have been met.

Definitions

Attendant:

The person who is assigned and responsible for monitoring and overseeing a confined space process or operation. The attendant is also required to provide support services for the confined space activity, provided he/she does not leave the site. The attendant must be able to react to any situation, including an emergency, as required. An attendant is required for both permit & non - permit required confined spaces

Blinding/Blanking:

The insertion of a barrier (obstructing device) across the open end of a pipe which enters or exits a confined space, and securing such a barrier so as to prevent leakage of material into the confined space.

Confined Space:

An area which has the following (3) characteristics:

its primary function is something other than human occupancy

has restricted entry and exit

may contain potential or known hazards including, but not limited to hazardous gases and materials, active electrical and steam supplies, oxygen deficiencies, flammable atmospheres or any other introduced hazards like welding operations that may adversely effect the occupants/workers health and safety.

Non-Permit Required Confined Space (NPRCS):

A space which by configuration, meets the definition of a confined space but which after evaluation is found to have no potential for creation of a hazardous atmosphere or has had such hazardous conditions eliminated by engineering controls.

Permit Required Confined Space (PRCS):

A confined space which as been evaluated and found to have actual or potential hazards that pose a threat to the health and safety of the workers and requires a written authorization to enter.

A Permit Required Confined Space (PRCS) is one that has one or more of the following characteristics

Contains or has a known potential to contain a hazardous atmosphere

gas

heat

toxic vapor

oxygen deficiency or enrichment

Contains a material with the potential for engulfment or drowning of an entrant

particulate matter

liquid (including, but not limited to water)

Has internal configuration such that an entrant could be trapped or asphyxiated by inwardly converging walls or a floor which slopes downward and tapers to a smaller cross section.

Contains any other recognized serious safety and health hazard, including but not limited to:

high water level

steam leak that cannot be isolated from another point

Double Block and Bleed:

A means by which a line, duct or pipe is shut down by physically closing two in-line valves on a piping system, and then opening a vent between them to release excess pressure within the closed lines.

Engulfment:

The capturing and/or drowning of a person in a particulate matter or liquid.

Entry:

Whenever a person places any portion of their head, face or any portion of the body into the opening of a confined space, it is considered to be entry.

Hazard Evaluation:

The assessment of a confined space to determine the potential hazards within. These hazards could be known hazards, real or potential, or a combination of all three (3).

Hazardous Atmosphere:

An atmosphere, outside or within the confined space that could pose the risk of injury or death to the occupants because of flammability, explositivity, toxicity or oxygen deficiency (<19.5%) or enrichment (>23.5%).

Hot Works:

The performance of any work that could or will produce arcs, flames, heat, sparks or other sources of ignition (i.e., cutting, brazing, welding, soldering etc.).

Isolation:

Physically disconnecting or interrupting the flow of service through a confined space. This would include piping for steam, water and gas, lines for telephone, electricity and other energy sources.

Lock Out/Tag Out:

In accordance with requirements of the OSHA Lock Out/Tag Out Program and the University Policy, lock out/tag out shall mean the placement of a lock and tag on the energy isolating device. The energy isolating device shall not be operated, until all lock out/tag out devices have been removed by installer of said locks or tags.

Energy Isolating Device:

Is any device that prevents the transmission or release of energy. For example: A circuit breaker, disconnect switch, a slide gate, a manually operated switch, a line valve, blocks, and other similar devices with a visible indication of the position of the device. Push buttons, selector switches and other circuit controlling type devices are not energy isolating devices.

Qualified Person:

A person who has appropriate education, training and experience to work in and around confined spaces, and is experienced and knowledgeable in the various operations of confined space work. This includes the ability to properly evaluate the hazards that may or may not be involved, and the ability to act/rectify any problem/hazard found.

Toxic Atmosphere:

An atmosphere (in or around) a confined space that contains a concentration of a substance (solid, liquid, or gas) above the published or otherwise known safe levels.

Identification / Recognition

All campus locations which are considered to be permit required confined spaces (PRCS) shall be identified as specifically as possible. Including area or room, the building and its specific address.

Entry into these spaces (including, but not limited to placing of head or face into the opening of a confined space) shall be subject to the provisions of this program.

Signage shall be posted near each permit required confined space.

the signs shall read:

DANGER

Confined Space

DO NOT ENTER

without a permit

Permit Required Confined Spaces that cannot be labelled, because of adverse area or weather conditions shall be identified in this policy:

Sewers shall be considered (PRCS):

• They can not be completely isolated.
• Because the atmosphere can suddenly change, without adequate warning, placing all entrants in danger.
• Other special considerations.

Electrical Pits shall be considered (PRCS), unless

• all internal hazards can be eliminated, before entry

Steam Pits shall be considered (PRCS), unless

• all internal hazards can be eliminated, before entry.

If entrance into an identified (PRCS) will never be necessary, access to the space will be prohibited. Appropriate warning signage shall be posted, or some other means to prevent access shall be provided.

Any person, (regardless of agency) working for the University (i.e.outside company or contractor) shall follow an OSHA compliant "confined space policy."

Whenever outside companies or contractors are working with university employees, the confined space policy used shall not be less stringent than the university policy.

Notification

When it has been determined that entry into a (PRCS) will be necessary, the following agency(s) shall be notified:

• Physical Plant Safety Office at 545-6043 and or
• Env. Health and Safety at 545-2682
• Power Plant(if work is to be performed in the power plant at 545-2263

A verbal notification of PRCS entry can be made. However, the notification shall be made not less than 24 hours prior to the start of work. A copy of the actual permits must then be sent to the appropriate departments for record keeping purposes. The departments are listed at the bottom of the actual permit. See Appendix A.

Exception: Emergency evaluations /repairs are acceptable. However, the Physical Plant Safety Office and/or Environmental Health and Safety must notified before entering a (PRCS).

Outside contractors must notify the Physical Plant Safety Office, EH&S and/or the Facilities Planning Division before entering a PRCS. This notification allows Physical Plant, EH&S and Facilities Planning to notify the other necessary shops that may have knowledge of unsafe conditions within said PRCS.

These shop(s) include, but are not limited to:

• Asbestos
• Electrical
• Steam Fitters/Plumbing Shop
• Work Control

Confined Space Survey

1. Each confined space shall be surveyed for hazards or potential hazards within. The survey shall be done by "qualified" individuals who shall decide which spaces are to be designated Permit Required Confined Space (PRCS) or Non-Permit Required Confined Space (NPRCS).

If identified as a (PRCS), the confined space shall be labeled with appropriate signage, or shall be otherwise indicated as referenced in section 2 (3b).

Hazard Identification: Hazards shall be identified for each confined space. The hazards shall be listed in the hazard section of Appendix E.

The identification shall include:

• Location (exact) of confined space
• Past or current uses of the confined space which may adversely effect the atmosphere of the confined space.
• Physical characteristics
• Existing or potential hazards in the confined space:
• Oxygen deficiency or enrichment
• Flammable or explosive atmosphere
• Toxic Atmosphere
• Biological hazards within the confined space
• Mechanical hazards (ie. augers, ribbon blenders, and piping hazards)
• Other health and safety related concerns

3. Hazard Evaluations: Shall be performed by a "qualified personnel."(

Each hazard (potential or known) shall be examined for:

• Hazard exposure
• Who and how many people would be affected?
• Hazard potential
• How much energy could be released?
• How toxic are the chemicals used or found in place?
• Hazard consequences
• What is the likelihood of injury, explosion or fire within the confined space?
• Hazard conditions
• Steam
• Electricity
• PCB's
• Flooding/weather changes
• Hazard control (Strategies for controlling hazards)
• Block & Bleed
• Isolation
• Utility shutdown
• Ventilation

Emergency response

Which agencies might be called for this confined space?

• Amherst Fire
• Env. Health & Safety
• Electric Shop
• Plumbing Shop
• Work Control

Hazard Re-Evaluation:

When the need for such re-evaluation is determined, a "qualified person" shall conduct the "hazard evaluation" and "hazard identification" process.

When evaluating or re-evaluating a confined space atmosphere, the following shall be incorporated:

All sources of ignition shall be kept to a minimum of twenty-five (25) feet away from the opening, until the space has been tested and found to be free of explosive/flammable gases.

Any manufacturer's recommendations regarding pretesting and calibration of the equipment to be used shall be followed.

Testing shall be done at the opening or cover, first, prior to opening. If no dangerous condition is identified or detected, the cover or door can be partially opened (use caution to avoid sparks).

Testing/continuous evaluation shall be performed, first just inside the opening and then into other areas of the confined space, unless a dangerous condition has been identified.

Monitoring of a PRCS must continue as long as there is someone in the confined space.

If any confined space is vacated for any period of time, the atmosphere of the confined space should be re-evaluated before entry is again permitted.

If isolation of the space is not feasible because the space is too large or is part of a continuous system, (such as a steamline). Entry testing or re-setting shall be performed to the extent possible, before entry into the work area is made.

Limits

Acceptable Limits

After evaluation by a "qualified person," the atmosphere of the confined space shall be considered within the acceptable limits if the following criteria are met:

Oxygen- levels are between 19.5-23.5%

Flammability- is less than 10% of the Lower Explosive Limit

Carbon Monoxide- is less than 35 ppm

Hydrogen Sulfide- levels are less than 10 ppm

Toxicity- is less than the recognized exposure limits

Airbourne Dusts- levels less than 10% of the Lower Explosive Level-see NFPA Handbook, 14th edition for particular dusts

Unsafe Atmosphere/Unacceptable Limits

No Employee/Contractor Shall Enter Any Confined Space In Which A Hazardous Atmosphere Has Been Detected-whenever testing, (by a qualified person), of the atmosphere indicates that levels of oxygen, flammability, or toxicity are not within acceptable limits, entry shall be prohibited until appropriate controls are implemented or appropriate personal protective equipment, (PPE) and training has been provided.

If Hazardous Gas (Toxic/Flammable) or Oxygen Deficiency/Enrichment is Discovered

The space can be purged or force ventilated using "intrinsically safe" equipment, (explosion resistant), to eliminate or control atmospheric hazards. Then re-monitor the area:

Whenever possible, forced ventilation shall be directed to ventilate the immediate areas where an employee is or will be present within the space and shall continue until the employees have left the space.

If forced ventilation is necessary, and is to be used, the initial and subsequent atmospheric tests of the confined space shall be done with all ventilation equipment shut down for a significant period of time. (this is done to show hazardous and potentially hazardous conditions, should the ventilation system fail.)

After testing and documenting the results with the ventilation shut down, the ventilation system should then be turned back on. (the above is done to ensure that contaminants are not being drawn in to the confined space by the ventilation system, creating its own hazardous condition(s))

Exceptions:

Negative air (already permanently installed) can be used in lieu of forced ventilation (i.e., east Experiment to C.C. Parkway Garage) provided that it shall not draw in to the confined space, "Contaminated Air."

Fresh air intake plenums for buildings on campus.

Air supply for the forced air ventilation shall be from a clean source (i.e., not in close proximity to vehicle exhaust), and shall not increase the hazards within the confined space.

When Air quality (re-testing), shows that the atmosphere remains unsafe or unacceptable for entry, the entry permit shall be revoked and entry prohibited.

The permit can be revoked by: the attendant, supervisor, qualified personnel, Physical Plant Safety Officer or any "qualified person" within the department of Environmental Health and Safety.

If hazardous gases or oxygen deficiency/enrichment is not indicated after re-testing, the confined space may be entered. This provides that continuous atmospheric testing is conducted and that forced ventilation is continuous throughout the work period.

If, During Any Entry, A Hazardous Atmosphere Is Detected:

All Employees Shall Leave the Confined Space IMMEDIATELY.

Then notify the Physical Plant Safety Officer or Environmental Health and Safety.

The space shall then be evaluated by a "qualified person" to determine how the hazardous atmosphere developed. All necessary steps, including corrective action, continuous forced ventilation and atmospheric monitoring, shall be taken to protect employees prior to re-entry.*

If the source of the contaminant can not be determined, precautions shall be adequate to deal with the worst possible condition within the confined space.

If there is a possibility that the confined space could become unacceptable, while personnel are working, procedures and equipment including: Tripod, safety harness, telephone or portable radios shall be provided.

Permit Required Confined Space

The Permit required Confined Space Program shall:

• Implement measures necessary to prevent unauthorized entry.
• Identify and evaluate the hazards of PRCS before employees enter then:
• Develop and implement the means, procedures, and practices for safe entry into a PRCS, including but not limited to:
• Identification of acceptable entry conditions
• Isolating the PRCS
• Eliminating or controlling atmospheric hazards by purging, blanking, locking or tagging out, flushing inerting or ventilating
• Monitoring (periodically or continuously) of the PRCS as required by the "qualified person".
• Provide the required equipment (intrinsically safe, as necessary) needed for proper set up, entry and breakdown of the confined space, such as:
• Ventilation equipment
• Communication equipment
• Testing and monitoring equipment
• Personnel Protection Equipment
• Lighting
• Barriers
• Equipment
• Rescue and emergency equipment
• Evaluate PRCS prior to and during entry.
• Provide the necessary entrants/occupants, attendants and other additional support, as needed.

The above referenced personnel shall have the responsibilities listed in the following sections, IX, X, XI respectively. Permit Requirements:(

Prior to entry, the PRCS permit should be prepared and signed by the supervisor/project manager. In case of emergency, the permit can be signed by a "qualified person."

The completed permit shall be made available to all entrants, occupants and attendants by posting near the entry of the confined space.

The length of time to be spent in the confined space shall be noted on the permit,and shall be strictly adhered to.

The supervisor may need to terminate the permit if a condition arises, not covered for by the permit.

The University shall create and maintain a file for all canceled, expired or completed entry permits, indefinitely.

(All the requirements of the permit shall have been met, before entry is made.

Entry Permit

The entry permit shall identify:

Permit Space (by address and number) to be entered

Purpose of entry

Date and length of time for entry

The authorized entrants, attendants and supervisors

Actual or potential hazards

Measures used to isolate, eliminate or reduce the hazards of the PRCS.

Acceptable entry conditions- before and during each entry of the PRCS

Rescue equipment and the Confined Space Emergency Response Team, CSERT.

Communications equipment and procedures

Personal Protective Equipment

Other additional information

University PRCSs

Permit required confined spaces at the University of Massachusetts at Amherst shall include, but are not limited to:

Sewer(s)

Certain underground tunnels and pits, as identified

Elevator overheads and limited access pits

Previously identified exhaust systems/HVAC equipment accessed for maintenance

Sump pump pits

The 10 Pits in Lederle Grad Research Center (highrise and lowrise)

Campus Center Garage exhaust fans

Underground water stream from Visitor's Center to Lot 25, by Mullins

Polymer Penthouse HVAC and sump pump pits

Tanks that personnel can enter for cleaning and maintenance

Personnel Responsibilities:

Attendant Responsibility

Attendant(s) shall be stationed outside any Confined Space (permit/non-permit required)

The number of attendants that are required at any confined space shall be determined by a qualified person. It shall be the qualified person's responsibility to determine the manpower requirement(s) of the project:

For example: More than one attendant may be required if there is more than one entry to the confined space, and that the different entries are arranged in such a way that the distance between them may be greater than 20'.

Attendants and the occupants within the confined space, shall remain in constant two-way communication (i.e., Person to Person, radio, cellular phone).

Attendants shall also:

Assist the occupants entering the confined space, but shall not themselves, at any point, enter the confined space.

Direct occupants to exit the confined space when any irregularities are observed.

Initiate evacuation and emergency procedures:

Radio communications with Physical Plant and/or UMASS Police must be maintained at all times.

Begin (if not a PRCS) setting up tripod or initiating request for tripod.

Request any appropriate personnel:

Amherst Fire and Ambulance

Environmental Health and Safety ("F-1")

Confined Space Emergency Response Team

University of Mass Police

Monitor, using the necessary equipment for any changes or conditions that could adversely effect the entry. The attendant shall know how to interpret such information.

Remain at the entry point of the confined space, unless relieved by another attendant.

Unauthorized Persons-should unauthorized person(s) approach or enter a confined space while entry is underway the attendant shall:

Warn the unauthorized person(s) that they must stay out of the permit space.

Request unauthorized person(s) who have entered the permit space to exit immediately.

Inform authorized entrants and supervisors when any unauthorized persons have entered the Confined Space.

Occupant/Entrant(s) Responsibility

The occupant/entrant who will be entering the confined space shall make sure that the "qualified person" has evaluated/inspected the confined space, and that it was determined to be safe for entry.

The occupant shall make sure, before entry that all potential hazards have been identified and that serious hazards have been isolated.

Isolation includes: de-energizing and locking/tagging out exposed electrical equipment; locking/tagging out exposed mechanical equipment; blanking, blinding, misaligning or removing sections of pipes, ducts, or a double block and bleed system.

The occupant shall also make sure, before entry, that all appropriate Rescue Equipment has been made available, at the site. Whenever a worker is required to enter a Permit Required Confined Space (PRCS),

A full body harness may be required

An attached retrieval line, secured outside the confined space should be utilized, but may not be required to be attached to the occupant/entrant, if the attachment may cause additional harm or hazard to the occupant/entrant.

Retrieval lines must not be secured to any vehicle.

Mechanical hoisting equipment, i.e., tripod, retrieval line, and full body harness shall be set up to provide for emergency retrieval from (PRCS) such as a pit or manhole.

The occupant/attendant/qualified person shall make sure that the appropriate forced air ventilation equipment and tubing has been positioned properly to provide continuous, forced air to the work area, in any confined space.

The occupant/entrant shall make sure they have the necessary communication equipment for the type of work.

The occupant/entrant should be familiar with the use and warnings of all monitoring equipment.

Supervisor/Project Manager(s) Responsibilty:

The Supervisor/Project Manager for any confined space work shall ensure that the following criteria has been satisfied before work in the confined space is started:

The Supervisor/Project Manager shall make sure that all shops involved, or having responsibility for the confined space being worked on, have been notified at least 24 hours in advance.

This will allow the specific shop(s) to identify any possible hazards that they may be aware of, (i.e., asbestos, leaks etc.), before work is initiated.

The Supervisor/Project Manager shall ensure that the necessary equipment has been made available and placed on site before work has begun.

The Supervisor/Project Manager must ensure that each confined space to be entered shall have been properly assessed by a "qualified" person before entry is permitted.

If the "qualified" person finds the confined space unacceptable, the Supervisor/Project Manager shall make sure that no one enters the confined space until corrective measures have been made, and the qualified person has then permitted entry.

The Supervisor/Project Manager shall make sure that the attendants, occupants/entrants have monitoring equipment in the confined space at all times, when necessary and that the occupant/entrants know what to do in case of alarm(s).

The Supervisor/Project Manager shall also make sure that the appropriate two-way communication equipment has been made available to the occupant/entrants at all times. The Attendant shall be equipped with communication equipment, in case of emergency.

The University Physical Plant Work Control*/Dispatch Center shall be made aware of any confined space work, so that they are prepared to specifically listen for emergency requests.

The Supervisor/Project Manager shall ensure that the occupants/entrant/attendant shall have plenty of water and cups at the site, should heat and weather conditions warrant.

The Supervisor/Project Manager shall make sure that a proper ACGIH work/rest ratio has been implemented for working in a confined space. The ACGIH manual is available through EH&S.

This is done to avoid heat exhaustion or heat stroke, a life threatening illness.

The Supervisor/Project Monitor shall ensure that all persons who will be working in confined space, (PRCS) or (NPRCS), have been medically evaluated by their physician or physician at UHS to ensure adequate health and safety for confined space entry.

The Supervisor/Project Monitor shall enforce all appropriate provisions of this program with the assistance of the Physical Plant Safety Officer, EH&S Fire and Safety Staff and their respective department heads. Safety Officers from EH&S and Physical Plant will be monitoring worksites for compliance.

Special Considerations/Hazards

Asbestos:

Any potential asbestos problems (friable, mastic, transite etc.) shall be reported immediately to the Physical Plant Asbestos Shop. Precautions must be taken to reduce the risk of exposure to the occupant/entrant(s) and the University community.

Contact: Asbestos Shop at 545-6426.

Biological/Radiological Hazards:

Any Biological Hazards (i.e., holding tanks etc. for blood and body fluids), and/or Radiological Hazards shall be evaluated by the Department of Environmental Health and Safety as well as by the "qualified" person, before entry.

Contact: Biological or Radiological Safety Officer at 545-2682

Chemical Hazards:

Any chemical hazards not previously taken into consideration (i.e., you need not call about cleaning solutions), shall be evaluated by the Department of Environmental Health and Safety, as well as the "qualified person", before entry.

Contact: Chemical Safety Officer at EH&S at 545-2682

Electrical/Energy Hazards

All energy sources, (i.e., electric, hydraulic, mechanical and/or pneumatic), which are or could be hazardous to those entering a confined space, shall be secured/disconnected, etc., before personnel enter a confined space.

The Physical Plant/Housing/Building Services Electrical Shop (depending on area of work), must be contacted for assistance prior to starting work.

LOCK OUT/TAG OUT procedures, when necessary must be incorporated at all times to ensure the health and safety of all personnel, University and outside contractors.

In accordance with the different "isolation" procedures, a means of reducing hazards for health and safety reasons must be followed. See "isolation" in the definition section of this policy.

If complete isolation is not possible, provisions shall be made to reduce any hazard, before work in a confined space is initiated.

After locking or tagging out energy sources, the supervisor/project manager or entrant, (whoever locks or tags out an energy source), shall make sure that all potential stored energy has been relieved and that if necessary, blocked or otherwise secured for additional safety.

This shall be done for the protection of workers in and around confined space areas as well as for those who might otherwise be using the now de-energized equipment.

Fire

Open flames, welding, cutting, soldering, brazing, general purpose electrical equipment, light sources, smoking material, or other spark or flame producing agents or devices other than explosive-resistant equipment, shall not be used in any confined space, until it has been demonstrated by approved test that a flammable vapor does not exist.

Appropriate and sufficient portable fire extinguishers shall be readily available, and in good working order at the site.

When Hot Works (i.e., welding, cutting, soldering or brazing etc.) are required in a confined space, adequate fresh air ventilation of at least 2,000 cubic feet per minute per welder shall be provided.

A HOT WORKS PERMIT must be acquired from Environmental Health and Safety, before work in a confined space has begun.

Environmental Health and Safety shall be contacted if the 2,000 cfm rate per welder can not be obtained or maintained. Local exhaust, airline respirator, or self-contained breathing apparatus (SCBA) may be necessary.

Respirators and Self Contained Breathing Apparatus (SCBA's) require special training and other requirements. For assistance and information,

Contact: Environmental Health and Safety at 545-2682.

Gas Cylinders and work involving associated Hot Works (i.e., cutting/welding etc.), require a "HOT WORKS" Permit, before work in the confined space is started. Outside contractors must obtain the necessary permit from Environmental Health and Safety. University employees doing Hot Works can follow the university confined space program for notification.

Contact: EH&S for "HOT WORKS" Permit at 545-2682

In accordance with the Massachusetts State Fire Prevention Codes, 527CMR 39:

All equipment used shall be approved by a recognized testing agency.

The individual using such "HOT WORKS" equipment shall be properly trained for the intended work, and shall perform the work in a professional manner.

A FIREWATCH shall be provided as required by the permit, for the safety of the entrants and the University.

The person, (i.e., second occupant in the confined space), may be utilized for this purpose, provided their full attention is on the fire and safety issues.

"HOT WORKS" can only be performed in a confined space, after permission has been given by the "qualified" person.

Any "HOT WORKS" performed in close proximity to other openings or unrelocatable combustible material shall be properly covered with a non-combustible cover, or some other similar, protective means.

A portable Fire Extinguisher (Dry Chemical), with a rating of not less than a 4-A:60-BC shall be kept at the Hot Works location, and the occupant/entrants and attendants shall be familiar with its use.

Torch valves shall be closed and fuel-gas and oxygen supply to the torch positively shut-off at a point outside the confined space whenever the torch is not being used for a substantial period of time.

General Safety

Ground Fault Circuit Interrupters (GFCI):

All portable electrical devices including: power tools, lightning, generators, etc. shall be properly grounded and protected by approved GFCI's.

Guarding of Confined Spaces:

When covers of manholes, vaults or other confined space accesses are opened, the opening shall be guarded by either/or:

A standard railing

A hole cover of standard strength and construction

The temporary hole cover shall completely cap the opening and be able to withstand any weight that may be applied to it.

The guarding must also protect the occupants/entrants working in the manhole or other confined space from falling objects that may enter the hole/opening.

Appropriate cones with scotch lite and other warning devices must also be placed near the work area to worn of the work being done and/or the type of hazard involved.

Signs, barriers or other necessary measures shall be taken to prevent unauthorized access to the confined space work area.

Lighting

Adequate lighting shall be used to safely accomplish the work.

The following is required:

Grounding of all electrical appliances/equipment.

Ground Fault Circuit Interrupters

Explosion-Resistant Equipment shall be used when necessary

Personnel Protective Equipment (P.P.E.)

All necessary P.P.E., including but not limited to hard-hats, hand/foot protection and safety eyewear (including appropriate welder's glasses for all personnel in pits) shall be used. The "qualified person" or safety officer(s) shall identify the appropriate P.P.E. needed for the intended work.

The Supervisor/Project Manager shall be responsible for compliance.

Protection from Vehicular Traffic:

In addition and in conjunction with the "guarding" section, listed above; when work is required within roadways or when employees and/or outside contractors are exposed to vehicular traffic, the University Police Department (UMPD) shall be notified.

Proper measures must be taken to divert traffic away from the work area/opening. High visibility and reflectorized warning vests and garments shall also be used.

Downgrading Permit Required Confined Spaces

If after proper testing, (inspection and evaluation), by a "qualified person", the confined space is found to have no potential for atmospheric hazards, or if the only potential hazard in a (PRCS) is atmospheric, (no other hazards exist), and if it initially tests clear, the area may be downgraded to a Non-Permit Required Confined Space, (NPRCS).

In this case, it may be possible to omit ventilation, and/or rescue equipment with the approval of the "qualified person".

If the only potential hazard in a confined space is atmospheric, and the space tests as having a hazardous atmosphere, but ventilation alone is sufficient to maintain the area safe, the space may be entered, provided there is continuous ventilation and monitoring.

This shall be done only under the direction of the "qualified" person, the Physical Plant Safety Officer and/or "qualified"Environmental Health and Safety Staff.

Even though the downgraded type of confined space does not require rescue equipment, the following steps must be taken:

All other hazards within the space must be eliminated. This may include:

Lock Out/Tag Out

Blanking

Misaligning

Removing Pipes or,

Double Block and Bleed

Ventilation must keep the atmosphere at or below 5% of the Lower Explosive Limit, (LEL), determined by the "qualified" person.

The work to be done in the downgraded (NPRCS) shall not introduce any hazards such as:

Welding

Cutting

Chemical vapors or

Oxygen deprivation/enrichment

Air monitoring must be done prior to entry, and periodically, for the duration of the job. Monitoring must be continuous when ventilation alone is keeping an atmosphere safe. The data must be recorded on the permit form and maintained on the job site. A print outs from the monitoring equipment is deemed acceptable.

This will serve as written certification that the space is safe for entry.

PRCS require constant air monitoring for the duration of the project.

If a "qualified person" must enter the confined space to inspect or initially test the atmosphere or inspect for other hazards, entry is only permitted when all provisions of a "Permit Required Confined Space", (PRCS), is adhered to; (monitoring, attendant, rescue equipment etc.)

All proper procedures shall be taken for safe cover removal, guarding, air testing and ventilation as indicated in Section XI.

If at any time during an entry, a hazardous atmosphere is detected, the space shall be vacated immediately. The "qualified" person, the Physical Plant Safety Officer and/or Environmental Health and Safety shall be contacted to determine the cause of the change in atmosphere. Prior to re-entry, all necessary steps shall be taken to render the space safe. Re-evaluation shall be documented to certify safe re-entry.

Emergency Response

The Confined Space Emergency Response Team (CSERT) shall be made up of the following organizations for fast and effective rescue.

The Amherst Fire and Ambulance Service

Environmental Health and Safety

Physical Plant

The University Police Department

Should the (CSERT) team be necessary for a confined space rescue, the following procedures shall be followed:

The attendant, at the confined space shall notify the Physical Plant Work Control Desk* by portable radio or cellular phone, identifying the site as accurately as possible.

Physical Plant Work Control shall then notify Amherst Fire Department, the University Police and the Physical Plant PM staff, initiating the necessary response.

The University Police shall notify "F-1" of the incident, asking for Environmental Health and Safety to respond.

"F-1" shall respond with the necessary confined space rescue equipment to properly augment the Amherst Fire and Ambulance Service, and any on site personnel, (University/outside contractor).

"F-1" shall assist the Amherst Fire Department in any way possible.

"F-1" and the Physical Plant PM staff shall make all rescue equipment immediately available, for fast and effective removal of the victim(s).

All members of the CSERT Unit shall be trained in accordance with this policy.

EH&S, through "F-1" will make sure that Harnesses, tripods and other mechanical lifting devices for vertical entries have been supplied. Breathing apparatus and medical equipment will also be necessary.

In addition, lighting, communication, and other miscellaneous rescue equipment will be needed.

If entering a confined space to rescue victims, all personnel must use SCBA or combination, (Type C), Airline/SCBA breathing equipment.

If a hazardous atmosphere is not the cause of emergency, and the victim in the confined space is verbally communicating with the rescuers, rescue breathing equipment may not be necessary.

All Rescue Equipment must be inspected/evaluated periodically by "qualified" personnel prior to the start of work, to ensure proper working order.

Training

Any employee who is required to enter or supervise those entering or serve as an attendant for any entry into a confined space shall receive appropriate training. This training will assure that understanding, knowledge and skills necessary for safe performance of duties are acquired.

Initial training will be given to all affected employees and will be followed up with refresher training. Training will be conducted as necessary on any new procedures, before there is a change in assigned duties. When there is a change in confined space hazards, or when deficiencies become evident.

Training will be made available through

• Videos
• Handouts
• Field exercises
• Other applicable training

The above training aids will include, but is not limited to:

• Review of this policy and all confined space entry procedures.
• Familiarization with all hazards associated with confined space, (i.e., toxic atmospheres, oxygen deficiency, flammable vapors).
• Field training on the use of monitoring, testing, ventilation, safety and rescue equipment. This training will also include: hazard recognition, communication, emergency procedures, harness and hoisting equipment.
• Other associated concerns, such as electrical safety, guarding and Personal Protective Equipment.

The Office of Environmental Health and Safety shall maintain certification records of all employees trained and tested in confined space entry and operations.

The list will include the subjects, signature(s) of the trainer(s), attendees and dates of training.

Training for occupant/entrants, attendants, and supervisors shall meet the requirements specified in Sections VIII, IX, X and XI, respectively.

Union Contract

Appendix A