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Chapter 34 – Confined Spaces

Published on by Heather Madison.

DRAFT

Contents

Approved by Michael-Ray Boyden
Revised 1/24

34.1 Policy
34.2 Scope and Applicability
34.3 Roles and Responsibilities
34.4 Definitions
34.5 Required Work Processes

34.6 Source Requirements
34.7 Other References
34.8 Appendices

Note:
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34.1 Policy

Confined spaces are work locations that meet regulatory definitions and require rigorous evaluation, planning and work authorization in addition to the usual safe work practices and procedures required by Integrated Safety Management Systems.

This program applies to:

  1. All spaces at LBNL, including those classified or not classified as:
    1. A Non-Permit Confined Space (NPCS)
    2. A Permit-Required Confined Space (PRCS)
  2. All employees, visitors, affiliates, and subcontractors who perform work at the main LBNL campus.
  3. Subcontractors performing work directly for LBNL at off-site DOE leased or other off-site locations are covered by the health and safety components of this program. However, LBNL does not evaluate or maintain an inventory of off-site confined spaces. Each separate facility or respective property management firm manages their own confined space inventory. Subcontractors are responsible for obtaining information regarding confined spaces and the associated hazards and precautions from the respective property management firms.

34.2 Scope and Applicability

Management of LBNL’s confined spaces, including Permit-Required Confined Spaces (PRCS), is in accordance with the requirements of both Federal and California state Occupational Safety and Health Administration (OSHA) standards.

Regulations applicable to General Industry work, such as maintenance and repair operations:

  • Cal/OSHA Title 8 CCR 5156 and 5157 Group 16, Article 108, Permit-Required Confined Spaces and/or
  • Code of Federal Regulations (CFR), Title 29, Part 1910.146, Permit-Required Confined Spaces

Regulations which are acceptable for contractor submittals, such as written programs and training, on construction-related projects:

  • Cal/OSHA Title 8 CCR Subchapter 4, Construction Safety Orders, Article 37 1950-1962 Confined Space in Construction and the additional requirements in this chapter and/or
  • Code of Federal Regulations (CFR), Title 29, Part 1926.1200–1213, Subpart AA, Confined Spaces in the Construction Industry.

Exceptions: Pits, excavations, trenches, and confined spaces entered by subcontractors for Maintenance, Repair, and Operations (MRO) purposes under the subcontractor’s approved PRCS Program are managed by LBNL’s Construction Safety Program under the requirements of Chapter 10, Section 38 of the Construction Safety Manual, where confined space work is described.

Construction-related confined space entry is specifically covered under Title 8 CCR Subchapter 4, Construction Safety Orders, Article 37 1950-1962, Confined Space in Construction. Contractors may use the option of OSHA 29 CFR Part 1926.1200–1213, Subpart AA, Confined Spaces in the Construction Industry as an equivalent alternative. Where a standard applies and a provision addresses a confined space hazard in another applicable OSHA standard, the employer must comply with both that requirement and the applicable provisions of this standard.

All employees, visitors, affiliates, and subcontractorswho perform work at LBNL (excluding subcontractors operating under their own approved PRCS Program) may not enter any PRCS unless:

  • The entrant has PRCS training and is authorized by their supervisor.
  • The hazards within have been properly eliminated or controlled and the PRCS has been reclassified per applicable permitting processes and the procedures herein.
  • If the only hazard in the PRCS is an actual or potential hazardous atmosphere; and that condition is controlled through continuous ventilation and monitoring; and the entry is performed under an Alternate Entry Procedure per applicable permitting processes.
  • The entry does not require specialized personal protective equipment, procedures or methods that are outside of the normal scope of work for in-house staff. For example, the sanitary sewer flume clean-out and underground fuel storage tank work are specialized operations and only authorized subcontractors may conduct them. Other examples are entries that require a self-contained breathing apparatus (SCBA) or supplied air respirators for safe entry.
  • The entry does not involve entrance into hazardous materials storage vessels, gas storage vessels, or any tank.
  • The entry does not involve spray-applying any chemical such as epoxy coatings or other hazardous materials work.
  • The entry does not involve entering any space that is known to have hazardous materials contamination, or has the potential to have contamination (i.e., radiological, chemical, biological, toxins, metals, solvents, acids, or flammable liquids).
  1. Facilities In-House Staff Confined Space Entry Facilities PRCS entry is allowed only for the following situations:
    1. For Maintenance and Repair Operation (MRO) purposes
    2. When the entry is required to keep a critical utility system running for lab operations (“operationally critical”)
  2. Subcontractor Submittals Prior to PRCS Entry 
    1. Prior to any subcontractor entering a PRCS, the subcontractor’s written PRCS Program and the Entry Team worker’s confined space training must be reviewed and approved by LBNL. This program along with worker training documents will be included in the Site Specific Safety Plan (SSSP).
    2. Further information can be found in EHS Manual Document PUB-3000 Chapter 10 Appendix A – LBNL Construction Safety Manual.
    3. For non-construction, general industry work the program and training will be under the Subcontractor Job Hazard Assessment (SJHA) and address Cal/OSHA Title 8 CCR 5156 and 5157 Group 16, Article 108, Permit-Required Confined Spaces.
    4. Subcontractors are required to be used for PRCS entry when the following situations or conditions are present unless task specific Work Planning and Control Activities are developed and reviewed by the Confined Space SME:
      1. For specialized, high-risk, high-hazard entries where conditions described in 34.2, work performance section, cannot be met.
      2. When specialized equipment and training are needed.
      3. When specialized PPE, such as a SCBA or supplied air lines are required.
      4. When a specialized task must be performed. Specialized tasks may be those, which require specific training or experience to perform.
      5. For all entries where an atmospheric hazard, other than that associated with a sanitary sewer, is present and cannot be eliminated or controlled.
      6. When applying chemicals or coatings such as epoxy coating.
      7. When there is an anticipated risk of exceeding an OSHA Permissible Exposure Limit (PEL) / Threshold Limit Value (TLV) and/or when there is no data to prove exposures will remain below the PEL/TLV for a specific operation.
      8. For all entries into hazardous materials storage vessels, gas storage vessels, or any tank.
    5. Subcontractors who perform construction-related PRCS entry or have confined spaces on their controlled job site are required to submit and maintain:
      1. Their company’s written PRCS Program, which describes Cal/OSHA Title 8 CCR Sections 1950-1962, Confined Spaces in Construction, or Code of Federal Regulations (CFR), Title 29, Part 1926.1200–1213, Subpart AA, Confined Spaces in the Construction Industry may be used as an equivalent.
      2. A full Entry Team, including an attendant. Each team member must have applicable confined space training for their role and responsibility.
      3. The Entry Supervisor (Permit Writer) must be a Qualified Person per the OSHA definition of such and have training specific to atmospheric monitoring concepts and evaluating hazards and controls for confined space entry.
      4. An emergency rescue plan and qualified designated rescue provider. Alameda County Fire Department is the LBNL designated rescue provider and may be used in this function for subcontracted work following Work Process D
      5. Supply their own equipment necessary to conduct the entry.
      6. The Controlling Contractor will identify existing confined spaces and the associated hazards on their controlled job sites. Upon request, LBNL will appraise and consult with the Controlling Contractor of existing confined spaces and their hazards.
      7. The Controlling Contractor will inform LBNL of any spaces which are newly constructed or demolished so that the Host Employer can keep the inventory updated.

34.3 Roles and Responsibilities

The following table describes the roles and responsibilities of confined space personnel:

Role Responsibilities

Division Directors

Ensure that entries into PRCSs under their divisions’ control are made only in accordance with this program

Environment/Health/Safety (EHS) Division
  • Administers the LBNL Confined Space Program
  • Provides training (Work Process H) to LBNL staff and affiliates involved in entry into confined spaces. Training is not provided to subcontractors.
  • Designates the Confined Space Program Manager, who shall either personally or via delegation:
    • Classify spaces as an NPCS or a PRCS.
    • Determine which spaces are not confined spaces.
    • Be provided access to the Confined Space Database inventory.
    • Designate Entry Supervisors (permit writers).
    • Provide confined space training and field support.
    • Develop, in consultation with space owners and entrants, Safe Work Procedures for work in spaces. This is often conducted on a case-by-case basis.
    • Review PRCS Reclassification Certifications, PRCS Alternate Entry Procedure Certifications, and Subcontractor PRCS Permits on an annual basis.
    • Review Subcontractor PRCS programs and provide the Activity Lead with his or her comments.
    • Conduct ongoing program effectiveness review and assurance (Work Process J). 

Activity Leads

Activity Leads include researchers, Facilities/PIMD Construction Managers, Facilities/PIMD Project Managers, Superintendents, Shop Supervisors, and others who manage or direct activities, including subcontracted work, that include entry into inventoried spaces. Activity Leads may or may not be the “requester” as described in Chapter 31, Subcontractor Job Hazards Analysis (SJHA) and may or may not be a “Line Manager” as described in Chapter 1 General ES&H Requirements. Activity Leads also may or may not be the Activity Lead as the term is described in Work Planning and Control.

Activity Leads will:

  • Define the activity that requires entry into a confined space.
  • Are ultimately responsible for successful planning, coordination and completion of the activity, including preplanning and coordination of rescue services whether this is provided through Alameda County Fire Department (ACFD) following Work Process D or other third party service provider.
  • May direct the day-to-day tasks that make up the activity.
  • Review the work area and determine whether spaces that must be entered are included in the Confined Space Database. Activity leads may also consult with the Confined Space Program Manager as to the type of confined space present.
  • If any space that must be entered is included in the Confined Space Database, review the inventory and determine whether a Safe Work Procedure exists for work in that space.
  • For activities involving LBNL employee or affiliate entry into inventoried spaces, assign a properly trained and qualified Entry Supervisor for any entry into a PRCS and assure that entry proceeds only in accordance with Work Process F, Planning an Entry into Inventoried Spaces by LBNL Employees or Affiliates (Does Not Include Subcontractors). A list of Entry Supervisors is provided on the Confined Space web page. https://ehs.lbl.gov/service/industrial-hygiene/confined-space-evaluations/
  • For activities involving subcontractor entry into inventoried spaces:
    • After review and concurrence by the Confined Space Program Manager, approve Subcontractor PRCS programs and procedures.
    • Co-approve (with the Construction Safety Entry Supervisor) documentation prepared by subcontractors for entry into PRCSs. Documentation includes, but is not limited to, Reclassification or Alternate Entry Procedure Certification, an entry permit, coordination procedures, and authorizations.
    • Ensure that entry proceeds only in accordance with Work Process G, Subcontractor Entry into Confined Spaces.
    • Document specialized procedures and controls used for a specific confined space entry event on the permit.
  • Immediately report to the Confined Space Program Manager:
    • Any unauthorized entry into a PRCS;
    • Detection of any hazard in a PRCS that is not covered in the permit;
    • Detection of a condition prohibited by the permit;
    • Occurrence of an injury or near-miss during entry including a rescue event;
    • Change in use or configuration of the Permit Space; or
    • Employee complaints about the effectiveness of the permit process.
  • Activity Leads are NOT Entry Supervisors unless they have been separately so designated by the Confined Space Program Manager.

Entry Supervisors (Permit Writers)

General Industry definition:

An Entry Supervisor or “Permit Writer” is the person responsible for determining whether there are acceptable entry conditions at a Permit-Required Confined Space where entry is planned; for authorizing entry and overseeing entry operations; and for terminating entry as required by this document and applicable regulations. Entry Supervisors must be designated by the Confined Space Program Manager, and are required to complete Confined Space Entry Supervisor course (EHS 0277). In-house LBNL Entry Supervisors must also complete a refresher course (EHS 0387) every two years.

Construction Industry definition:

For construction-related work, the Entry Supervisor is the Qualified Person (such as the employer, foreman, or crew chief) responsible for determining if acceptable entry conditions are present at a permit space where entry is planned, for authorizing entry and overseeing entry operations, and for suspending or terminating entry if required. Construction-related Entry Supervisors are required to complete and submit training that covers the principles of atmospheric testing, gas detection equipment, calibration, ventilation, hazard identification, hazard control, and elimination.   

Entry supervisors or permit writers will:

  • Operate only on PRCSs within their specific area of technical expertise. Consult an Activity Lead, Subject Matter Expert (SME) or researcher if there are technical questions regarding potential safety hazards, such as falls, electrical, mechanical, radioactive, or chemical hazards.
  • Ensure that PRCSs are entered only as provided in this document and applicable regulations. See Work Process F, Planning an Entry into Inventoried Spaces by LBNL Employees or Affiliates (Does Not Include Subcontractors).
  • Reclassify PRCSs with a permit to NPCSs and authorize entry or authorize entry into PRCSs via an Alternate Entry Procedure, as outlined by this program.
  • Forward completed entry permits to the Confined Space Program Manager after expiration of the certification. A drop box is currently available at Building 78 for completed permits.
  • Immediately report to the Confined Space Program Manager:
    • Any unauthorized entry of a PRCS;
    • Any unexpected or new hazards discovered;
    • Detection of any hazard in a PRCS that is not covered in the permit;
    • Detection of a condition prohibited by the permit;
    • Occurrence of an injury or near-miss during entry including a rescue event;
    • Change in use or configuration of the Permit Space; or
    • Employee complaints about the effectiveness of the entry permit system.

Construction Safety Entry Supervisors

A Construction Safety Entry Supervisor is a member of LBNL’s EHS Division Construction Safety staff who has also been designated as an Entry Supervisor and has completed the EHS 0277 course.

Construction Safety Entry Supervisors will:

  • Review, concur on adequacy, and co-approve (with the Activity Lead) documentation prepared by the subcontractor for entry into PRCSs. Documentation includes but is not limited to Reclassification or Alternate Entry Procedure Certification, an entry permit, coordination procedures, and authorizations.
  • Uses the SBN safety reporting system to document entries

Attendant

 

A trained and competent individual stationed outside one or more Permit Spaces who monitors and supports the authorized entrants and who performs all the attendant’s duties assigned in the employer’s Permit Space Program. Attendants must remain at the point of entry full time and are not to leave the work site when the entrant is present inside a confined space.

Subcontractors

Subcontractors will:

  • Conform to the requirements of applicable regulations, this program and the LBNL Site Specific Safety Plan (SSSP) or Subcontractor Job Hazards Analysis (SJHA).
  • If the subcontractor plans to work on a construction-related confined space entry, then the subcontractor will comply with Title 8 CCR Subchapter 4, Construction Safety Orders, Article 37 1950-1962 Confined Space in Construction or, alternatively, 29 CFR OSHA Part 1926.1200-1213 Subpart AA, Confined Spaces in Construction Industry regulation.
  • Construction-related confined spaces may include equipment brought on site such as water tanks, cement mixing trucks, and cooling units; and any confined space built during the construction or removed during demolition. Construction-related spaces include pre-existing confined spaces that fall within a construction site temporarily controlled by the Controlling Contractor. Trenches and excavations were verified by EHS through direct communication with OSHA, to be exempt from the 29 CFR OSHA Part 1926.1200-1213 Subpart AA, Confined Spaces in Construction Industry regulation.
  • EXCEPTIONS: Cal/OSHA Title 8 CCR Subchapter 4, Construction Safety Orders, Article 37 1950-1962 Confined Space in Construction does not apply to: (1) Construction work regulated by Construction Safety Orders, Article 6, Excavations. 29 CFR Part 1926.1200 does not apply to: (1) construction work regulated by 1926 Subpart P, Excavations. Trenches and excavations fall under the Cal/OSHA Title 8, Article 6 Sections 1539-1547.
  • Subcontractor workers must provide EHS with valid proof of confined space training in Title 8 CCR Subchapter 4, Construction Safety Orders, Article 37 1950-1962 Confined Space in Construction. Contractors may use the option of OSHA 29 CFR Part 1926.1200–1213, Subpart AA, Confined Spaces in the Construction Industry as an equivalent training alternative.
  • If a subcontractor is engaging solely in non-construction work as related to facility maintenance and repair operations, then their confined space safety will be covered under the LBNL Subcontractor Job Hazard Analysis (SJHA) System.

Controlling contractor (for construction-related Work)

The Controlling Contractor is the employer (generally the prime contractor) that has overall responsibility for construction at the work site. The following section is a summary of the requirements that the Controlling contractor must comply with:

  • The controlling contractor must ensure that a competent person identifies all confined spaces in which one or more of the Controlling Contractor’s employees may work, either pre-existing, newly constructed, or being demolished and identifies each space that is a Permit Space, through consideration and evaluation of the elements of that space, including testing as necessary.
  • The controlling contractor must post danger signs or any other equally effective means of communication to inform exposed employees of the existence and location of, and dangers posed by, each Permit Space.
  • The controlling contractor must inform its employees’ authorized representatives of the existence and location of, and the danger posed by, each Permit Space in a timely manner and in a manner other than posting a danger sign.
  • Each employer who identifies, or receives notice of, a Permit Space and has not authorized its employees to work in that space must take effective measures to prevent those employees from entering that Permit Space in addition to complying with all other applicable requirements of this standard.
  • If any employer decides that its employees will enter a PRCS, that employer must have a written PRCS Program that complies with §1926.1204 and is implemented at the construction site. The written PRCS Program must be made available for inspection prior to and during entry operations by employees and their authorized representatives.
  • The employer must provide and maintain training and ensure that employees who are authorized to perform confined space entry rescues possess the understanding, knowledge, and skills necessary for the safe performance of the duties assigned. This training must result in an understanding of the hazards in the Permit Space as well as an understanding of the methods used to isolate, control, or in other ways protect employees from these hazards. Entry Team members are required to have training on how to use rescue equipment including: tripod, winch, life line, harnesses, and rescue pole. The employee (i.e., the controlling contractor) must also provide and maintain training to ensure employees who are not authorized to perform confined space entry rescues are aware of the dangers of attempting such rescues.
  • The controlling contractor must designate each person who is to have an active role (for example, authorized entrants, attendants, entry supervisors, or persons who test or monitor the atmosphere in a Permit Space) in entry operations, and identify the duties of each employee.
  • The controlling contractor must provide testing and monitoring equipment, ventilating equipment, communication equipment, personal protective equipment, lighting equipment, barriers, guards and shields, ladders, etc.
  • The controlling contractor must ensure a safe method of entering and exiting the space.
  • The controlling contractor must eliminate or isolate the hazards without entering the space.
  • The controlling contractor must perform pre-entry atmospheric testing.
  • The controlling contractor must continuously monitor entry conditions in the areas where authorized entrants are working.
  • The controlling contractor must continuously monitor atmospheric hazards unless they can demonstrate that the equipment for continuously monitoring a hazard is not commercially available or that periodic monitoring is of sufficient frequency to ensure that the atmospheric hazard is being controlled at safe levels.
  • The controlling contractor must provide an early-warning system that continuously monitors for non-isolated engulfment hazards. The system must alert authorized entrants and attendants in sufficient time for the authorized entrants to safely exit the space.
  • The controlling contractor must provide at least one attendant outside the Permit Space(s) into which entry is authorized for the duration of entry operations.
  • The controlling contractor must document the basis for determining that all hazards in a Permit Space have been eliminated or isolated, through a certification that contains the date, the location of the space, and the signature of the person making the determination.
  • The controlling contractor will obtain the host employer’s information about existing Confined Space Permit Space locations and hazards and previous entry operations, if any.
  • The controlling contractor must provide each entity entering a Permit Space and any other entity at the work site whose activities could foreseeably result in a hazard in the Permit Space with the following information:
    • The controlling contractor and entry employer (employers who decide an employee will enter a confined space) must coordinate entry operations when more than one entity performs Permit Space entry at the same time; or when Permit Space entry is performed at the same time and place as another activity that could result in a hazard.
    • The controlling contractor must apprise the host employer (LBNL) of the information exchanged with the entry entities.
  • The controlling contractor must develop and implement procedures for summoning rescue and emergency services (including procedures for summoning emergency assistance in the event of a failed non-entry rescue); procedures for rescuing entrants from Permit Spaces; procedures for providing necessary emergency services to rescued employees; and procedures for preventing unauthorized personnel from attempting a rescue.
  • The contractor’s Entry Team may perform either entry or non-entry rescues at their own risk. However, if the space has IDLH conditions then the Entry Team will summon the LBNL Fire Department (ACFD) for rescue provider services.

Fall Protection SME

The Fall Protection SME is responsible for developing, implementing, maintaining, and evaluating the Fall Protection Program. The SME also provides guidance to all others involved with the program, establishes a procedure to identify fall hazards, develops fall protection and rescue procedures, ensures training is completed, and participates in incident investigations.

Fire Department (Alameda County Fire Department – ACFD)

The Alameda County Fire Department (ACFD) crew, located at Building 48, provides high angle and low angle emergency rescue from confined spaces. However, self-rescue (either by entry or non-entry) can be conducted by the Entry Team based upon professional judgment and with regard to response time, hazardous conditions in the space, and the nature of the emergency. IDLH and/or hazardous atmosphere emergencies require the specialized response action of the rescue service provider, the Alameda County Fire Department (ACFD).

Host employer (LBNL)

The employer that owns or manages the property where the confined space work is taking place. The Owner of the property on which the confined space activity occurs who has contracted with an entity for the general management of that property, and has transferred to that entity hazard and other information, they are considered the Host Employer for as long as that entity manages the property. In no case will there be more than one host employer. LBNL is the host employer for existing confined spaces at the LBNL main facility property.

34.4 Definitions

TermDefinition
Acceptable entry conditions  The conditions that must exist in a Permit Space to allow entry and to ensure that employees involved with a Permit-Required Confined Space entry can safely enter into and work within the space.
Alternate Entry (for General Industry)An alternate entry procedure specified in paragraph 1910.146 (c)(5)(ii) or Cal/OSHA equivalent. This is an entry permit that is sometimes simply referred to as “C-5”. It is used if the employer can demonstrate that the only hazard posed by the permit space is an actual or potential hazardous atmosphere; The employer can demonstrate that continuous forced air ventilation alone is sufficient to maintain that permit space safe for entry. Continuous atmospheric testing is also required for this type of permit.
Atmospheric testingThe process of testing the atmosphere within a confined space to determine whether the atmosphere is both initially safe for entry as well as ensuring that it will remain safe for the duration of work.  A four-gas meter is used to test for at minimum; oxygen, carbon monoxide, hydrogen sulfide and lower explosive limit (LEL).  The testing must occur at all levels of the confined space since different gasses may settle or rise within the space.  Continuous atmospheric testing must be provided when operations are introduced into the space that are anticipated or known to create atmospheric hazards (i.e., hot work, exhausts, chemicals, fumes, welding)
Attendant  A trained and competent individual stationed outside one or more Permit Spaces who monitors and supports the authorized entrants and who performs all the attendant’s duties assigned in the employer’s Permit Space Program. Attendants must remain at the point of entry full time and are not to leave the work site when the entrant is present inside a confined space.
Authorized entrant  A competent employee who is trained and authorized by the employer to enter a Permit Space.
Blanking or blinding  The absolute closure of a pipe, line, or duct by the fastening of a solid plate (such as a spectacle blind or a skillet blind) that completely covers the bore and that is capable of withstanding the maximum pressure of the pipe, line, or duct with no leakage beyond the plate.
Competent personOne who is capable of identifying existing and predictable hazards in the surroundings or working conditions which are unsanitary, hazardous, or dangerous to employees, and who has the authorization to take prompt corrective measures to eliminate them. A competent person identifies all confined spaces in which one or more of the employees it directs may work, and identifies each space that is a permit space, through consideration and evaluation of the elements of that space, including testing as necessary. When there are changes in the use or configuration of a non-permit confined space that might increase the hazards to entrants, or some indication that the initial evaluation of the space may not have been adequate, a competent person reevaluate that space and, if necessary, reclassify it as a permit-required confined space.
Confined spaceA confined space is a space that: Is large enough and so configured that an employee can bodily enter and perform assigned work; and Has limited or restricted means for entry or exit (for example, tanks, vessels, silos, storage bins, hoppers, vaults, and pits are spaces that may have limited means of entry); and Is not designed for continuous employee occupancy; andIs an open top space, pit, utility vault, trench, vessel, etc., which is deeper than 4-feet and has solid side walls (OSHA 1926.21[b][6][ii]). LBNL has adopted this 4-foot rule for spaces on the site.
Controlling contractor  The employer that has overall responsibility for construction at the worksite. Note: If the controlling contractor owns or manages the property, then it is both a controlling employer and a host employer.
Double block and bleedThe closure of a line, duct, or pipe by closing and locking or tagging two in-line valves and by opening and locking or tagging a drain or vent valve in the line between the two closed valves.
Early-warning systemThe method used to alert authorized entrants and attendants that an engulfment hazard may be developing. Examples of early-warning systems include but are not limited to: alarms activated by remote sensors, and lookouts with equipment for immediately communicating with authorized entrants and attendants.
EliminatedRemoved by a means that does not require active intervention to maintain. For example, lockout/tagout of rotating machinery or physical blocking of a hydraulic ram would be considered elimination. On the other hand, traffic control or continuous forced air ventilation would not be considered elimination but a reduction of a hazard.
EmergencyAny occurrence (including any failure of hazard control or monitoring equipment) or event that is internal or external to the Permit Space that could endanger entrants.
EngulfmentThe surrounding and effective capture of a person by a liquid or finely divided (flowable) solid substance that can be aspirated to cause death by filling or plugging the respiratory system or that can exert enough force on the body to cause death by strangulation, constriction, or crushing.
EntryThe action by which a person passes through an opening into a Permit-Required Confined Space. Entry includes ensuing work activities in that space and is considered to have occurred as soon as any part of the entrant’s body breaks the plane of an opening into the space.
Entry employerAny employer who decides that an employee it directs will enter a Permit Space. Note: An employer cannot avoid the duties of the standard merely by refusing to decide whether its employees will enter a Permit Space, and OSHA will consider the failure to so decide to be an implicit decision to allow employees to enter those spaces if they are working in the proximity of the space.
Entry permit (permit)The written or printed document that is provided by the employer to allow and control entry into a permit-required confined space. There are three types of permits for General Industry; Alternate Entry, Reclassification, and Regular Permit-Required Confined Space.  Note that a reclassification is still considered a type of permit. 
Entry supervisorThe person (such as the employer, foreman, or crew chief) responsible for determining if acceptable entry conditions are present at a Permit Space where entry is planned, for authorizing entry and overseeing entry operations, and for terminating entry as required by this section.
Note: An entry supervisor may also serve as an attendant or as an authorized entrant, as long as that person is trained and equipped as required by Chapter 10 Section 38 of the Construction Safety Manual for each role he or she fills. Also, the duties of entry supervisor may be passed from one individual to another during the course of an entry operation.
Hazardous atmosphereAn atmosphere with toxic, oxygen deficient/enriched, or combustible gases that may expose employees to the risk of death, incapacitation, impairment of ability to self-rescue (that is, escape unaided from a Permit Space), injury, or acute illness from one or more of the following causes: Flammable gas, vapor, or mist in excess of 10 percent of its lower explosive limit (LEL), sometimes referred to as LFL. Atmospheric oxygen concentration below 19.5 percent (deficient) or above 23.5 percent (enriched) Carbon monoxide greater than 25 ppm concentration Hydrogen sulfide greater than 1 ppm concentration Atmospheric concentration of any substance for which a dose or a permissible exposure limit is published in Subpart G, Occupational Health and Environmental Control, or in Subpart Z, Toxic and Hazardous Substances, of this Part and which could result in employee exposure in excess of its dose or permissible exposure limit. (Note: An atmospheric concentration of any substance that is not capable of causing death, incapacitation, impairment of ability to self-rescue, injury, or acute illness due to its health effects is not covered by this provision.) 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.) 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 exposure limit, other sources of information, such as Safety Data Sheets that comply with the Hazard Communication Standard, 29 CFR 1910.1200 published information, and internal documents can provide guidance in establishing acceptable atmospheric conditions.)
Hot workOperations capable of providing a source of ignition (e.g. grinding, brazing, welding, cutting, burning, and heating).
Hot work permitThe employer’s written authorization to perform operations capable of providing a source of ignition (for example, riveting, welding, cutting, burning, and heating).
Immediately dangerous to life or health (IDLH)Any condition that poses an immediate or delayed threat to life or that would cause irreversible adverse health effects or that would interfere with an individual’s ability to escape unaided from a Permit Space. (Note: Some materials — hydrogen fluoride gas and cadmium vapor, for example — may produce immediate transient effects that, even if severe, may pass without medical attention, but are followed by sudden, possibly fatal collapse 12–72 hours after exposure. For example, the victim “feels normal” from recovery from transient effects until collapse. Such materials in hazardous quantities are considered to be “immediately” dangerous to life or health.)
InertingThe displacement of the atmosphere in a Permit Space by a noncombustible gas (such as nitrogen) to such an extent that the resulting atmosphere is noncombustible.
Note: This procedure produces an IDLH oxygen-deficient atmosphere.
IsolationThe process by which a Permit Space is removed from service and completely 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 block and bleed system; lockout or tagout of all sources of energy; or blocking or disconnecting all mechanical linkages.
Limited or restricted means for entry or exitA condition that has a potential to impede an employee’s movement into or out of a confined space. Such conditions include, but are not limited to, trip hazards, poor illumination, slippery floors, inclining surfaces and ladders.
Line breakingThe intentional opening of a pipe, line, or duct that is or has been carrying flammable, corrosive, or toxic material, an inert gas, or any fluid at a volume, pressure, or temperature capable of causing injury.
Non-Permit Confined SpaceA confined space that does not contain or, with respect to atmospheric hazards, have the potential to contain any hazard capable of causing death or serious physical harm. No other hazards may be present or introduced to maintain the NPCS status.
Oxygen-deficient atmosphereAn atmosphere containing less than 19.5 percent oxygen by volume
Oxygen-enriched atmosphereAn atmosphere containing more than 23.5 percent oxygen by volume
Permit-Required Confined Space (Permit Space)A confined space that has one or more of the following characteristics: Contains or has a potential to contain a hazardous atmosphere; Contains a material that has the potential for engulfing an entrant; 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; or Contains any other recognized serious safety or health hazard.
Permit-Required Confined Space Program (Permit Space Program)The employer’s overall program for controlling and, where appropriate, protecting employees from Permit Space hazards; and for regulating employee entry into Permit Spaces.
Permit systemThe employer’s written procedure for preparing and issuing permits for entry and for returning the Permit Space to service following termination of entry.
Prohibited conditionAny condition in a Permit Space that is not allowed by the permit during the period when entry is authorized. For example, a hazardous atmosphere is a prohibited condition unless the employer can demonstrate that personal protective equipment (PPE) will provide effective protection for each employee in the Permit Space and provide the appropriate PPE to each employee.
Qualified personOne who, by possession of a recognized degree, certificate, or professional standing, or who by extensive knowledge, training, and experience, has successfully demonstrated his or her ability to solve or resolve problems relating to the subject matter, the work, or the project. 
Reclassification Entry Permit (For General Industry only)A reclassification permit is commonly referred to as “C-7” and can be used if the hazards posed by the PRCS are not related to an actual or potential hazardous atmosphere, and the hazards can be eliminated from outside the space prior to entry (e.g. LOTO used to shut of moving mechanical components or energized components). The Entry Supervisor may temporarily declassify (for the duration of the work shift) the PRCS to an NPCS per OSHA 29 CFR 1910.146(c)(7) or Cal/OSHA equivalent by completing the PRCS Reclassification Certification prior to the entry. Note that even though the space is temporarily “reclassified”, it still requires this permit.
Representative Permit Space  A mock-up of a confined space that has entrance openings that are similar to, and is of similar size, configuration, and accessibility to, the Permit Space that authorized entrants enter.
RescueRetrieving and providing medical assistance to one or more employees who are in a Permit Space. Rescues can be either entry or non-entry types.
Designated Rescue Service/ProviderPersonnel designated to rescue employees from Permit Spaces. The Alameda County Fire Department at LBNL is the designated rescue service. LBNL maintains a contract with ACFD for emergency rescue. Rescue services shall be arranged in advance following Work Process D. In the event of any emergency contact ACFD at x7911.
Retrieval systemThe equipment (including a retrieval line [life line], full-body harness, and a lifting device or anchor) used for non-entry rescue of persons from Permit Spaces. (Note: Chest harnesses are no longer rated by ANSI for OSHA approval and are prohibited.
Serious physical damageAn impairment or illness in which a body part is made functionally useless or is substantially reduced in efficiency. Such impairment or illness may be permanent or temporary and includes, but is not limited to, loss of consciousness, disorientation, or other immediate and substantial reduction in mental efficiency. Injuries involving such impairment would usually require treatment by a physician or other licensed health-care professional.
Tagout (LOTO)Tagout or lock out tag out, is the (1) placement of a tagout device on a circuit or equipment that has been de-energized, in accordance with an established procedure, to indicate that the circuit or equipment being controlled may not be operated until the tagout device is removed; and (2) the employer ensures that (a) a tagout provides equivalent protection to a lockout, or (b) that a lockout is infeasible and the employer has relieved, disconnected, restrained, and otherwise rendered safe stored (residual) energy.
TestingThe process by which the hazards that may confront entrants of a Permit Space are identified and evaluated. Testing includes specifying the tests that are to be performed in the Permit Space. Note: Testing enables employers both to devise and implement adequate control measures for the protection of authorized entrants and to determine if acceptable entry conditions are present immediately prior to, and during, entry.
Ventilate or ventilationControlling a hazardous atmosphere using continuous forced-air mechanical systems that meet the requirements of §1926.57—Ventilation.

34.5 Required Work Processes

Work Process A. Confined Space Entry Process
Work Process B. Evaluation and Classification of Spaces
Work Process C. Safe Work Procedures, Engineering Controls, Rescue Plans, PPE, and Precautions
Work Process D. Confined Space Emergency Rescue Services
Work Process E. Emergency Rescue Provider – Capabilities and Technical Rescue References- Alameda County Fire Department (ACFD)
Work Process F. Planning an Entry into Inventoried Spaces by LBNL Employees or Affiliates (Does Not Include Subcontractors)
Work Process G. Subcontractor Entry into Confined Spaces
Work Process H. Training
Work Process I. Fall Protection for Confined Space Work
Work Process J. Program Effectiveness Review and Assurance

Work Process A. Confined Space Entry Process

  1. The Confined Space Databases lists LBNL spaces that have been evaluated and classified as:
    1. A Non-Permit Confined Space (NPCS)
    2. A Permit-Required Confined Space (PRCS)

EHS maintains and administers a confined space inventory database. The inventory is the primary database used by EHS for tracking confined space information.

New confined spaces which are constructed or installed are required to be reported to the confined space program manager following completion of the construction installation. The report is required to include the type of space, purpose of space, the location description, a location drawing so that the space can be entered into the SBN database. Similarly, removed or demolished confined spaces are required to be reported to the confined space program manager with descriptions and location information.

The inventory system provides the following information:

  • Space identifications numbers, if available
  • Location of the space — this is associated with a map coordinate or an LBNL building or outside location
  • Type of space (e.g., tank, sanitary sewer, electrical vault, etc.)
  • Classification (i.e., Confined Space, PRCS)
  • Hazards present or noted
  • Precautions and Safe Work Procedures for the space (general and specific) as noted.  To access a spreadsheet listing hazards and precautions in Maximo®, click here. 
  • Associated documentation and other supplemental information
  1. Facilities uses Maximo for work order planning and control of all sitewide assets. Whenever the Maximo® Work Control System generates a work request, it checks to see if an inventoried space is associated with the location or asset referenced in the work request. If so, it extracts available inventory information and appends it to the work request. Facilities frequently also contacts EHS for additional information on a confined space asset for work planning.
    1. During work planning, Activity Leads must review the work area to evaluate its potential for containing inventoried spaces.
    2. The work request, if present, may list the space and supporting information (e.g., the Safe Work Procedure) as contained in the Confined Space Database.  To access a spreadsheet listing hazards and precautions in Maximo®, click here. 
    3. The absence of a listing does not mean that an NPCS or a PRCS is not present. It means that an evaluation may not have been performed or the space has not yet been entered into the database.  If there is not listing present, consult with the confined space SME with questions regarding classification.
    4. Spaces that are not confined spaces (i.e., spaces classified as Not a Confined Space) are no longer included in the inventory. For example, many of these spaces included HVAC ducts, which cannot be bodily entered.  To clarify, if a space cannot be bodily entered, it is not a confined space. Upon completion of EHS 0275 training employees will be able to identify whether a space is a confined space. Contact the Confined Space Program Manager for questions on whether a particular space is Not a Confined Space.
    5. Not all confined spaces are labeled with danger or caution signage due to outdoor weathering of labels. Generally, confined spaces are labeled if they are indoors or in a sheltered area. Manhole covers usually have the ID number bead welded or tagged with a circular brass badge. Some spaces such as vaults or storm drains may have painted stencil signage. However, many confined space covers do not currently have an ID number tag. As the Owner, Facilities is responsible for maintaining ID numbers on confined space assets. Site maps may be available from Facilities for storm water, sanitary sewage, electrical, and telecommunication lines. 
    6. The absence of an inventory listing for a space or an unclassified space does not mean that a hazard is not present. Hazards may exist (e.g., an exposed edge posing a fall hazard) that are unrelated to the confined space classifications.
    7. The Confined Space Program Manager must be consulted for a formal evaluation and classification of new spaces (see Work Process B below).

Work Process B. Evaluation and Classification of Spaces

  1. An individual must contact the Confined Space Program Manager to classify or review the classification of the space if the individual suspects that:
    1. A space not listed in the Confined Space Databases is a confined space; or
    2. A space is listed in the Confined Space Databases, but the classification is not correct; or
    3. The space cannot be found in the Confined Space Databases; or
    4. A new hazard is encountered that should be documented; or
    5. There is a change in the configuration or use of the space.
  2. The Confined Space Program Manager (SME) has sole (delegable) authority for classification of spaces.
  3. The Confined Space Program Manager classifies a space by:
    1. Evaluating the space using the Confined Space Evaluation Worksheet which is a checklist decision type form;
    2. Determining the space classification as Not a Confined Space, a Non-Permit Confined Space (NPCS), or a Permit-Required Confined Space (PRCS) using the Confined Space Evaluation Worksheet;
    3. Determining if any unique or sui generis Safe Work Procedures are necessary for entry into that space; and if so
    4. Developing the Safe Work Procedure in consultation with the entrants and the space owner
  4. Some spaces across LBNL are categorically classified as an NPCS or a PRCS. “Categorical classification” means that the category of the space has been classified based upon general homogeneous characteristics of the space, and that categorical classification applies unless the individual space has been specifically classified otherwise and listed in the Confined Space Database as such. For example, all manholes are classified as Permit-Required Confined Spaces. Generally, the categorical classification information is contained in the Confined Space Database under “General Safe Work Procedure.”

Categorical classification is based on determining criteria specified in OSHA 1910.146 or Cal/OSHA equivalent definitions and Section 34.4, Definitions, above.  If a space does not meet the regulatory definition of a Confined Space or PRCS, this does NOT necessarily imply that the space is without hazards. Hazards unrelated to the regulatory classification may exist. Other work control processes and/or permit requirements, including but not limited to this program’s Work Process C may govern work in the space.

If the space is categorically classified as a PRCS, then it may or may not be individually labeled. Communication of categorical classification is made via this program and via ongoing classroom training.

If at any time any person feels that a categorical classification of a space is incorrect, he or she must contact the Confined Space Program Manager to make a determination (see Work Process B.1 above).

Examples of categorically classified spaces are listed below:

  • Sanitary sewer manholes, lift stations, and wet sumps are PRCSs with hazardous atmosphere being the primary, defining hazard characteristic.
  • Components of the storm-water system may be categorized as: Not a Confined Space, an NPCS, or a PRCS.  See component items i through iv below for further explanation:
    • Storm-water pipes or curb grate openings with a diameter or dimensions too small to bodily enter are considered Not a Confined Space.
    • Underground storm-water pipes with a diameter large enough to bodily enter are PRCSs.
    • Confined spaces include, but are not limited to, storage tanks, process vessels, bins, boilers, ventilation or exhaust ducts, sewers, underground utility vaults, tunnels, pipelines, and open top spaces more than 4 feet in depth such as pits, tubs, vaults, and vessels.
    • Catch basins or sumps less than 4 feet deep are Not a Confined Space.
    • Catch basins greater than 4 feet deep are NPCSs with associated Safe Work Procedures.  The presence of decaying leaf litter can create an oxygen deficient hazardous atmosphere making catch basins PRCS.
  • Storm-water manholes are categorically PRCSs with falls, engulfment and hazardous atmospheres (oxygen deficiency) being the defining characteristics. Electrical and telecommunication manholes are PRCSs with a potential hazardous atmosphere (oxygen deficiency), standing water, and narrow configurations being the defining characteristics. (Note: Vaults are not categorically classified. They are individually classified, and the information is listed in the Confined Space Database.)
  • Electrical hazards may be present in confined spaces.  Electrical hazards are often caused by storm water flooding which submerges electrical outlets, submersible pumps, damaged components, and wiring. Standing water should always be tested to determine if it is energized before contacting.  Standing water also needs to be pumped out before work can occur at lower levels.  Some manholes have high voltage electrical cables (i.e. 12Kv) that will require a Qualified Electrical Worker III (QEW 3) to enter.  A QEW 2 may only enter high voltage confined spaces with direct supervision from a QEW 3.
  • Fuel storage tanks, whether above ground or underground, are PRCSs with hazardous atmosphere (flammable vapor) being the defining characteristic (exception: those that cannot be bodily entered are Not a Confined Space).
  • Cryogen (e.g., liquid nitrogen) storage tanks (fixed locations at buildings) are PRCSs with hazardous atmosphere (oxygen deficiency) being the defining characteristic (Exception: Those that cannot be entered are Not a Confined Space).
  • Elevator pits and shafts are PRCSs with the presence of a recognized safety and health hazard (e.g., crushing by the elevator car or falls) being the defining characteristic and LOTO being the control.
  • Air-handling units with exposed (unshrouded / unguarded) moving mechanical parts that are running or which may automatically start are PRCS due to the hazard of Entrants being caught up in the components. Air handling units that are under negative air pressure are also PRCS due to difficulty in entering and exiting the space if there is an emergency. 
  • Raised computer room floors, which can be bodily entered, are categorically classified as Non-Permit Confined Spaces and require safe work practices or building-specific safety procedures such as those at Building 59 CRT. 
  • Liquid nitrogen tanks with hatch openings that are too small for bodily entry are not considered confined spaces, Not a Confined Space.
  • Attics and storage closets with standard-size entry doors are generally not considered confined spaces. However, attics with hatch doors or small doors that require entrants to stoop, contort the body, or crawl to enter or exit, and/or that have any other type of limited access or exit, are considered confined spaces.
  • Cooling towers are considered PRCS.  Typical hazards associated with cooling tower entries are moving mechanical parts, unshrouded mechanical, internal configurations, exterior caged ladder access, falls, and standing water. 
  • Subcontractors commonly bring Permit Required Confined Spaces onto the LBNL site.  These may include water tanks, mobile coolings systems, cement trucks, storage tanks, etc.  The Controlling Contractor is responsible for the regulatory compliance and safety of its workers regarding those PRCS brought onto the site.  Due to the high risk of worker injury, it is prohibited to enter and clean out cement trucks on the LBNL site.

Work Process C. Safe Work Procedures, Engineering Controls, Rescue Plans, PPE, and Precautions

  1. Requirements for Authorized Confined Space Entry
    1. A Permit-Required Confined Space Entry Team, including an attendant, is required for Permit-Required Confined Space entry. In-house staff must have current EHS0276 Fall Protection training to be authorized to work as a member of a Permit-Required Confined Space Entry Team. This is to ensure the proper inspection, use and adjustment of a harness as well as other rescue systems such as the tripod, winch, davit arm, life line and rescue pole. Attendants must be competent in the use of the winch for lowering and hoisting personnel.
    2. All entries and Entry Team members must be authorized to perform the entry by the Activity Lead or LBNL Project/Construction Manager.
    3. Members of the Entry team are required to have CPR training and knowledge of how to set up and operate the tripod and winch system.  Use of such hoisting systems is taught in the EHS 0276 practical course. 
  2. Safe Work Procedures (SWPs) are steps and precautions developed by LBNL which apply to all PUB 3000 programs and hands on work.  The SWPs for confined space entry are described below.  SWPs for confined spaces are also now included in Work Planning and Control (WPC).
    1. Specific SWPs are established by the Confined Space Program Manager in cooperation with the owner of the space, Activity Managers and Facilities MRO staff.   Entrants who enter that space, regardless of the category or type, must adhere to the requirements of the SWP.  If the circumstances of a particular phase of work do not allow adherence to the SWP requirements, the SWP must be revised or supplemented as necessary and reviewed by the Confined Space Program Manager.
    2. SWPs may be either general or specific.
      1. General SWPs are associated with a type or type/subtype of space, and provide requirements for work within any space classified as such. For example, general SWPs for work in attics and crawl spaces (listed in the Confined Space Database as the type “Architectural Spaces” and subtype “Attic”) prescribe notification of entry procedures, radio contact requirements, do not introduce hazards, wear appropriate PPE, and use the “buddy system” (no work-alone policy).   Work within all attic and crawl spaces is subject to this general SWP.   See the general SWPs for Non-Permit Required confined spaces on the caution label below. 
      2. Specific SWPs are associated with a specific confined space. They supplement the general SWP for a particular space. If there is a contradiction between a General and a Specific SWP, the Specific SWP applies.
      3. SWPs are shown in the precautionary labels (shown below) and are affixed to many confined spaces at the point of entry.
      4. The “Caution” label is used only for Non-Permit Required Confined Spaces. Examples where this label is affixed are attics and crawlspaces. The “Danger” label may be affixed to Permit-Required Confined Spaces where the label will remain adhered.

  1. Engineering Controls and PPE
    1. Full-Body Harnesses
      1. Wearing a full-body harness in a confined space does not necessarily imply working from height.  The two main purposes for harnesses in this context are 1. for lowering or hoisting personnel from a confined space for hands-free work and 2, emergency rescue.
        1. In general, confined space entry does not require a fall matrix permit to be prepared since there is no working from height. If an engineered, fall protection system is required; a fall protection matrix permit may become necessary.
        2. If the Entrant will be wearing a harness and will remain continuously tied off to a tripod or other such lowering device, and is required to perform ‘hands free’ work within the space, then a fall protection matrix form is required to be completed prior to work.
        3. If the Entrant is using a manhole ladder to enter the space and can maintain ‘three points of contact’ then no fall protection matrix is required.
      2. Full-body harnesses are required for lowering or hoisting personnel from vertical confined spaces when using a tripod or davit arm. A rescue-type harness is preferred. 
      3. A boatswain’s chair may be used in conjunction with the harness for lowering and raising Entrants.
      4. Harnesses are required to be worn at all times by Entrants for work in vertical spaces greater than 6 feet in depth. 
      5. Full-body harnesses are required to be worn by any Entrant whether they are in-house staff, subcontractors or inspectors.
      6. Facilities or other in-house staff are responsible for acquiring their own harnesses.
      7. Entrants may choose to wear rescue-type harnesses.
    2. Retrieval Lines. In general, entrants must maintain a load rated retrieval line connected to their harness during vertical confined space entry (i.e., manholes and deep vertical spaces such as storm drains) to enable a means for body support during retrieval. The retrieval line should be immediately accessible by the attendant(s), but it does not necessarily need to be tied off full time above the confined space. If the retrieval line causes a demonstrated danger of entanglement or hazardous impediment such that a greater hazard is created, then the conditions will be evaluated on a case-by-case basis and only then exempted by the designated Entry Supervisor.
    3. Self-rescue equipment, including a tripod with winch, life line, and rescue pole must be immediately available at the location of entry during vertical space entry operations for either Facilities MRO work or construction-related work where the Alameda County Fire Department is not relied upon as a primary rescue provider.  For example, an Entry Team may choose to use a manhole ladder as the primary means for entry/exit; however; a tripod with winch, life line and rescue pole must still be available at the job site. Descriptions of self-rescue equipment appear at the end of this work process.
    4. Guarding Requirements. When entrance covers are removed, the opening shall be promptly guarded by a railing, temporary cover, or other temporary barrier that will prevent an accidental fall through the opening and that will protect each employee working in the space from foreign objects entering the space.
      1. Guarding must always be used for vertical confined spaces. Guarding requires the use of a collapsible, steel guard gate to warn and prevent pedestrians and workers from falling into an open confined space.
      2. Guarding of open manholes from tools and equipment falling into an open manhole may include the use of a circular manhole guard ring. Certain manhole configurations may not be suitable for using the manhole guard ring. These conditions may include improper sizing that is not within the diameter range of 28″, 30″, or 32″ of the ring.  Another condition may include a guard ring increasing the distance to an upper ladder rung so that the initial step-down distance becomes too great to allow safe entry. In these situations, the use of the guard ring may create a hazard and therefore may be exempted by the Entry Supervisor.  The use of a fixed manhole ladder, which extends at least 3 feet above the manhole guard ring will generally allow safe entry and exit. Another condition where a manhole guard ring may not be a feasible option is when a line of some type (for example, a supplied airline, hydraulic line, etc.) must be routed down into the manhole, and which would prevent the proper fit of the guard ring or crimp a line.
      3. Guarding is especially critical in areas with foot traffic such as walkways and corridors. Interior walkways with manholes, such as those at the ALS are recommended to have additional guarding such as cones and open manhole floor signage to further warn pedestrians of work.
    5. Lighting Requirements. Adequate illumination must be provided for work within confined spaces. Headlamps are a preferred supplement to ambient light since they provide hands-free operation. Intrinsically safe LED lights are recommended to provide ambient light.
    6. Safety Guidelines for Equipment. Intrinsically safe electronic devices and equipment are required when working in potentially hazardous atmosphere spaces such as sanitary sewer manholes or flammable materials. (Note: “Intrinsic safety” is a protection technique for the safe operation of electrical equipment in hazardous areas by limiting the electrical and thermal energy available for ignition, and to reduce sparking.)
    7. General Equipment. Facilities and contractors are expected to provide proper equipment for safe confined space entry.  LBNL does not loan out equipment to contractors.  The following equipment items are provided as a general guidance checklist for entering confined spaces.   Not all of these items will always apply since the types of confined spaces vary as well as the type of work operation. 
      • Manhole ladder (the ladder needs to be long enough to allow safe entry/exit).  Extension ladders are prohibited.   
      • Collapsible tripod with Self Retracting Device (SRD) (keep it at the site during entries in case rescue is needed).  A tripod can also be used for lowering and raising workers.
      • Rescue Poles are used to remotely attach a life line to an Entrant’s harness if needed.
      • Harnesses (worn full time for vertical confined space entry.)
      • Hand free work were the Entrant is lowered into a vertical confined space via a tripod will need a fall protection matrix
      • Collapsible guard rail (yellow, steel tubular guardrail).
      • Barricades and barriers to regulate the work area, traffic control, and keeping unauthorized people out
      • Signage to prevent pedestrians from falling into open holes (if in walkways or building interiors)
      • Forced air ventilation blower unit with flex duct. 
      • Protect the opened vault from equipment or debris falling inside when an Entrant is inside.  A guard ring can be used. 
      • Illumination
      • Means of communication (radios)
      • Atmospheric testing meter (calibrated monthly)
    8. Ladder Requirements. If a ladder is used for entry, manhole ladders are to be used.  Manhole ladders are narrow, light, have handle hoops and are specifically designed for entering and exiting manhole confined spaces.  Extension ladders are not suitable and should not be used unless there is a reason why manhole ladders are not safe to use.  Some internal ladders at LBNL are aging and the rungs or ladder assembly may be loose and/or unsafe.  Check the integrity of the rungs prior to relying on their ability to support weight.  Many of the internal sanitary sewer manhole ladders at LBNL have been removed, which will now require the use of a ladder or hoisting system for entry.
    9. Atmospheric Testing.  Before an employee enters the space, the internal atmosphere must be tested, with a calibrated direct-reading instrument, for oxygen content, for flammable gases and vapors, and for potential toxic air contaminants, in that order. Any employee who enters the space, or that employee’s authorized representative, must be provided an opportunity to observe the pre-entry testing readings. Following the initial atmospheric readings by the Entry Supervisor, the Entry Team team is required to test the atmosphere within a confined space to determine whether the atmosphere will remain safe for the duration of work.  A four-gas meter is required to test for at minimum; oxygen, carbon monoxide, hydrogen sulfide and lower explosive limit (LEL).  Four gas meters are available for check out by EHS 0277 trained staff at the Building 26 industrial hygiene lab, Room 032.  Meters are not loaned out to contractors. The Entry Supervisor will ensure that the meter to be used is within the monthly calibration period and will perform a ‘bump test’ or pre-work daily verification.  Contractors are required to use pumped type four-gas meters which are kept in calibration per the manufacturer’s instructions. Daily bump testing is required prior to use, to verify the meter’s sensors are responsive, alarms work and concentrations are in range. Entrants may wear passive type four-gas meter; however, all entry permits must be prepared using a pumped type meter.

      During the entry, if a meter alarms, the Attendant will direct the Entrant(s) to exit the space. An evaluation will then be made as to the source and cause of the alarm.  Engineering controls and elimination methods will need to be re-evaluated to prevent further atmospheric hazards from occurring.  The current lower alarms (audible and visible) for these four gases are set as follows: 

      Oxygen = 19.5%
      Carbon Monoxide = 25 ppm
      Hydrogen sulfide = 1 ppm
      Lower Explosive Limit (LEL) = 10% of LEL

      Testing must occur at all levels of the confined space (top, middle and bottom and/or every five feet) since different gasses may settle or rise within the space respectively.  Adequate time must be given for the pumped meter to pull up air from deep levels and analyze the gas.  Typically, the duration for gas to travel up the sample tubing is one second per foot of tubing.  Continuous atmospheric testing must be provided when operations are introduced into the space that are anticipated or known to create atmospheric hazards (i.e., hot work, exhausts, chemicals, fumes, welding).  All Alternate Entry permits require continuous atmospheric testing.  The atmosphere in and around the confined space should remain safe during entry operations.  Attendants must be aware of common sources of hazardous atmospheres such as adjacent idling vehicles and portable generators which create carbon monoxide that can enter the space.

    10. Pathogen hazards when working in sanitary sewers. Sanitary sewers are known to contain various human pathogens. These pathogens may include coronaviruses, Salmonella, Shigella, E. coli, Streptococcus, Pseudomonas aeroginosa, mycobacterium and Giardia Lamblia, etc. For general in-house operations and maintenance work in sanitary sewers where workers are not disturbing or coming into direct contact with raw sewage, the minimum PPE includes full Tyvek suits, goggles, boots, gloves and half mask elastomeric respirators with P100 filters. For work such as power wash cleaning the sanitary sewer flumes, contractors will be used. The contractor is required to wear a continuous-flow, supplied-air respirator, Tyvek suits, boots and gloves. Non-disposable PPE items and equipment must be properly decontaminated with bleach solution after use.
    11. Contractor Equipment Inspections and Maintenance. Contractors are responsible for maintaining and inspecting equipment used in confined space entry work. An example of critical equipment requiring inspections and maintenance includes sand blasting hoses, power tools, and other energized equipment. Contractors will follow the manufacturer’s instructions and recommendations for the maintenance, inspections and upkeep of equipment. Damaged equipment is required to be removed from service for repair or replacement. Equipment safety controls such as whip checks on hoses, kill switches, alarms, communications, and back up safety systems must be verified to be in place and operational prior to work. Contractors shall include inspections on the written the daily pre-task hazard analysis (PTHA).
    12. Permit-required Confined Space Pre-Entry Procedures. The Entry Team must verify that the space is safe for entry and that pre entry measures have been taken, through a written certification that contains the date, the location of the space, and the signature of the person providing the certification. The certification permit must be made before entry and must be made available to each employee entering the space and Entry Team.
    13. Hazards and Controls. Some confined spaces may have miscellaneous hazards which require identifying, eliminating and/or controlling prior to entry. Common examples are manholes which have collected storm water, deposits of organic leaf litter sludge, venomous spiders, electrical hazards, contamination, etc. Manholes with standing water or biological sludge accumulations can create hazards including anaerobic conditions which result in oxygen deficiency. These are required to be pumped out with the vacuum truck prior to entry. Other hazards are removed through various means prior to entry. Lock Out Tag Out (LOTO) is commonly used to turn off energized equipment or lines. COmmon examples requiring LOTO are energized electrical lines, moving mechanical components that are not guarded or shrouded, pressurized lines, and gas lines.
    14. Non-Permit Confined Space Entry Procedures. Non-Permit Required Confined Spaces, such as attics and crawlspaces, may be entered without a permit. However, the workers must have confined space training, use a minimum of two workers (buddy system), use safe work practices and do not introduce hazards. When there are changes in the use or configuration of a non-permit confined space that might increase the hazards to entrants, or hazards are introduced by the work, or some indication that the initial evaluation of the space may not have been adequate, each entry employer must have a competent person reevaluate that space and, if necessary, reclassify it as a permit-required confined space.
    15. High voltage 12kV Electrical Manholes. There are electrical manholes at LBNL which have 12 kilovolt (kV) cables. The primary hazard associated with working in high voltage electrical manholes is arc flash. Work in 12Kv electrical manholes may require wearing specialized PPE such as 40 cal suits and Qualified Electrical Worker (QEW) 3 training. Additionally, safety compliance in these confined spaces falls under OSHA 1926.965 Underground Electrical Installations. This regulation covers safety controls that include lower equipment, QEW training, identifying multiple cables being worked on, protecting cables from damage, inspecting cables for abnormalities and faults, de-energizing, shielding and other worker protections.
    16. Ventilation. An employee must not enter the space until the forced air ventilation has eliminated any hazardous atmosphere.Forced air ventilation must be so directed as to ventilate the immediate areas where an employee is or will be present within the space and must continue until all employees have left the space.Ventilation purge time calculators are commonly used. These calculators employ a sliding system that takes into account the space volume and the cubic feet per minute blower rating to determine purge time. Continuous forced air ventilation must be used when there is an atmospheric hazard present to eliminate any hazardous atmosphere or reduce it to an acceptable level. The air supply for the forced air ventilation must be from a clean source and must not increase the hazards in the space. Monitoring equipment must have a visible flashing alarm and an audible alarm that will notify all entrants if a specified atmospheric threshold is achieved.
    17. Ventilation Plans. Some projects require a written ventilation plan to design and calculate adequate ventilation for atmospheric hazards. An example would be sandblasting or epoxy spraying inside tanks. Subcontractors are responsible for providing a ventilation plan for work in spaces where complex, high volume ventilation is required. Calculations will be made to determine an adequate air exchange rate and the associated flow rates in cfm of ventilation blower units. Per AIHA and OSHA, A minimum of 20 air exchanges per hour or, every 3-minutes are required. Ventilation calculations will be based on the volume of the space and the specific chemicals or process to be used and the protection factor for the type of respirators proposed to be used. Variables such as ambient temperatures, flash points and the type of application (i.e. spray application or blasting) will be considered. SDS sheets will be referenced for permissible exposure limits. Providing adequate air exchanges may require creating a circuit of air flow in certain spaces whereby air is forced in at one point and exhausted out an exit using a seperate exhaust blower or fan unit. Welding in confined spaces requires the use of local exhaust ventilation (smog hogs) at the point of welding work. Contractors may choose to retain a 3rd party industrial hygiene consultant for preparing a ventilation plan.
    18. Unguarded and unshrouded moving mechanical components. There are confined spaces at LBNL which have unguarded/unshrouded moving mechanical components. Specific examples are HVAC air handling units (AHUs) at Building 2, 90X, 64, and 59. Additional air handling units without shrouds or guarding are also found at various locations throughout the Lab. Any confined space with unguarded/unshrouded moving mechanical components are categorically Permit Required Confined Spaces. To prevent workers from being caught up in moving component’s machinery, the mechanical components are required to be de-energized under LOTO prior to entry and work.
    19. Gas powered tools. Gas powered equipment and tool use is prohibited in confined spaces without controls. Gas powered tools, such as gas powered saws, generate carbon monoxide. Carbon monoxide is a poisonous gas that can quickly concentrate in confined spaces and rapidly result in IDLH atmospheric conditions. Caution must be used during manhole and vault entries to prevent idling vehicles from parking next to the confined space. Idling vehicle exhaust can introduce carbon monoxide into the confined space creating a hazardous atmosphere inside the confined space. Gas powered equipment and tools may be used in trenches and excavation with the proper controls such as continuous ventilation and atmospheric testing. Trenches and excavations fall under the Cal/OSHA Title 8, Article 6 Sections 1539-1547.
    20. Load rated equipment. Load rated equipment is required to be used for work in confined spaces. 5-gallon plastic buckets are prohibited from use to lower equipment into confined spaces. ANSI load rated drawstring canvas buckets (i.e., 100 pound rating) are an acceptable means for lowering equipment into confined spaces. Tripods, lanyards and other rescue equipment are also required to be ANSI load rated.
    21. Illumination. Adequate lighting to safely perform work inside confined spaces is required. OSHA requires a minimum of 5 foot candles of illumination in tunnels, shafts, and underground utilities 1926.56(a). Per OSHA: When natural lighting is not sufficient, additional lighting will be provided. It must not exceed 12 volts in damp conditions and will be equipped with a ground fault circuit interrupter. It is recommended that entrants wear LED headlamps for hands free work inside confined spaces.
            1. Rescue Plans and Associated Equipment
              1. A rescue plan at LBNL involves two rescue scenario types as described below:A self-rescue system can be used whereby the Entry Team provides their own rescue to the entrant(s) via their own trained personnel and with the use of their own equipment kept on site. Self-rescue is generally the preferred method due to the faster response time as compared to summoning a rescue provider. However, self-rescues should be limited to spaces where the only hazard was physical, such as an internal fall. Alameda County Fire Department shall still be notified prior to attempting self rescue in order to ensure prompt rescue in the event self rescue is unsuccessful.
              2. Suspected or known atmospheric hazards in the space or, IDLH conditions necessitate that the Alameda County Fire Department will need to conduct the rescue.  This is due to specialized training, PPE and respiratory protection (i.e., SCBA) would need to be worn. In addition, specialized equipment, such as high/low angle rescue and hoisting devices may need to be employed for an effective rescue. LBNL maintains a contract with ACFD to provide rescue. ACFD provides LBNL with their confined space and high/low angle rescue certificates. All ACFD Rescue services provided shall follow Work Process D
                1. The second type of system is where a rescue service provider, such as the Alameda County Fire Department, is named by the Entry Team as the emergency responder and relied upon for rescuing an entrant(s). Both types of rescue systems are acceptable depending upon the circumstances. Regardless of the plan used, wearing a full-body harness enables emergency rescue.  Keep in mind that 60% of all confined space fatalities are the would-be rescuers because they did not have the proper equipment or training to perform a safe rescue.  Therefore, a fallen entrant(s) trapped in a confined space with the presence of IDLH condition and/or hazardous atmospheres will require that the rescue be performed by the Alameda County Fire Department. Note that self-contained breathing apparatus (SCBA) are usually required to be worn for emergency rescues and that LBNL staff and contractors do not own or use SCBA.
              3. Although the preferred rescue device is a full-body, rescue-type harness, wristlets may be worn instead. Only in-house staff conducting short-term, non-hands-on inspection work may wear wristlets. Wristlets are not to be used by contractors or for the routine lowering or hoisting of personnel into a vertical confined space. Wristlets are designed for emergency rescue purposes only. Since wristlets are not allowable for lowering or hoisting personnel, it is implied that a ladder will be used to enter and exit the space. Chest harnesses are no longer load-rated by ANSI for OSHA and therefore may not be used.
              4. Short duration inspection-type operations, without a tripod provided directly at the work site, must have a rescue plan coordinated with the Alameda County Fire Department in order to ensure their availability to respond during the specific time of entry following Work Process D.
              5. Incident Reporting. If there is an incident such as a near miss, injury, emergency, illness from exposure, rescue, or other mishap, then it is required to be reported to the confined space program manager. The incident is to be reported as soon as possible to enable a timely investigation.
            Self-Rescue Equipment Descriptions
            EquipmentDescription and tasks used for
            Tripod with winch and cableA tripod can be used to lower and raise the entrant for access into a vertical confined space.  The Entrant is typically tied off continuously to the tripod cable which is attached to the winch.  However, a tripod can also be used for rescue purposes.  If a manhole ladder is used to access a vertical confined space, then a tripod must be kept immediately available at the entry location for rescue purposes. 
            Davit ArmA davit arm is a hoisting device that can also be used to raise and lower Entrants in vertical confined spaces.  The Entrant is typically kept continuously attached to the davit arm cable.  However, since davit arms are bulky, heavy, and require significant time to assemble the modular components, they are not kept at the entry site as a rescue device.  A davit arm is typically when more access is needed to the entry point of vertical confined spaces. 
            HarnessA full body harness is worn by the Entrant at all times when entering a vertical confined space.  However, the Entrant’s harness may not necessarily be connected full time to the tripod cable, or life line.  (For rescue a lifeline is connected to the dorsal D ring connector.) Rescue-type harness with a seat or bridle that connects with double D rings is preferred. 
            SRLA self-retracting lifeline (SRL) is not required unless the confined space is excessively deep where a worker could fall to lower levels.  An SRL is commonly attached to one of the tripod arms in addition to the winch.   
            LifelineLifelines are attached to the worker’s harness for lower/raising or rescue purposes.  A lifeline must be immediately available at the entry site for rescue purposes. 
            LanyardA flexible line of rope, wire rope, or strap which generally has a connector at each end for connecting the body belt or body harness to a deceleration device, lifeline, or anchorage.   Lanyards are typically 6 feet in length or less.  Lanyards may be used in some cases for rescues but are mostly used to restrain workers around unprotected edges of open vaults, pits and manholes. 
            Rescue poleA telescoping pole used to attach a lifeline to a fallen Entrant for rescue.  Rescue pole kits include a descender with carabiner, rope and safety hook, extension pole, mini-haul system anchorage strap.  The rescue pole is used to remotely hook up a lifeline to the Entrant’s harness for rescue purposes.  Rescue poles are often used for self-rescue when there are IDLH conditions present that would prevent an Attendant from performing an entry rescue. 
            WristletsWristlets may be worn for rescue purposes only.   Wristlets offer a slight advantage for extracting an Entrant out vertically by the arms thus, offering more clearance in small diameter configuration manholes.  Workers are not to be lowered or raised by the use of wristlets. 

            Work Process D. Confined Space Emergency Rescue Service

            The intent of this process is to formalize requirements involving Alameda County Fire Department (ACFD) providing confined space rescue services at Lawrence Berkeley National Laboratory (LBNL). All work performed at the LBNL that involves confined space entry must be authorized through an LBNL approved Work Planning and Control process.

            ACFD will provide emergency response and rescue capabilities as stated in the LBNL Workplace Needs Assessment, to include personnel and equipment trained to the requirements of the Confined Space Rescue Team and the minimum standards set forth in the CFR, CCR, and Office of the State Fire Training Curriculum.

            LBNL and ACFD must meet prior to high-risk/high-hazard confined space entry to formalize emergency response capabilities. 

            For high-risk/high-hazard work, the ACFD Chief Liaison Officer, Special Operations Division, ACFD Station 19 personnel will be notified and may be requested to meet with the contractors, project team and Environment, Health, and Safety (EHS) in the field, to assess the project-specific hazards to discuss rescue capabilities and access into the confined space.  The intent of this notification and meeting is to provide the ACFD with knowledge and awareness of unique hazards, rescue plan, hazard control measures, and accessibility to the projects in the case of an emergency. Contractors, LBNL work leads, and LBNL project managers will apprise the ACFD of the planned work tasks, hazards, and configurations of the space. Contractor written rescue plans are required for high-risk/high-hazard projects and will be provided to ACFD for review.

            Third Party Rescue Providers

            In cases where contractors / vendors designate their own Rescue Service Provider, a written Rescue Plan must be submitted to ACFD. A written rescue plan does not supersede or replace an ACFD Technical Rescue Response. The Rescue Plan must include at a minimum the following:

            1. Name and Contact information of the Designated Rescue Provider
            2. Confined Space Trained Rescue Competent Person and Qualified Person
            3. Rescue system components 
            4. Logistical Diagrams (as needed)
            5. List of trained rescue personnel onsite during the entry.
            6. Training documentation meeting the requirements of OSHA
            7. Proof of periodic assessments (at least annually) of the effectiveness of confined space rescue training
            8. Any other documentation necessary to properly characterize the rescue requirement



            Reference Documents

            • Federal Regulations are contained in Volume 58, No. 9 of the Federal Register, Chapter 29, Part 1910, Section 146 of the Code of Federal Regulations.  29 CFR Part 1910 covers general industry only.  Groups covered by other regulations, such as construction (Part 1926) and agriculture (Part 1928) are not covered under the Part 1910 but may related to working being performed at LBNL.
            • California state regulations are in the General Industry Safety Orders, Title 8 of the California Code of Regulation, Article 108, Sections 5156, 5157, and 5158.  California state regulation meet or exceed the federal standards.

            Additional guidelines and standards for confined spaces are provided by the following:

            • The National Institute for Occupational Safety and Health (NIOSH) – Publication No. 80-106
            • The American National Standards Institute (ANSI) Z117.1 – Safety Requirement for Confined Spaces
            • The National Fire Protection Association (NFPA) – International 1006 Standards for Rescue Technician Professional Qualifications
            • NFPA 1670 Standard on Operations and Training for Technical Search and Rescue Incidents

            Work Process E. Emergency Rescue Provider – Capabilities and Technical Rescue References- Alameda County Fire Department (ACFD)

            • Current Capabilities, Technical Rescue. LBNL has specialized projects involving confined spaces and elevated areas that require careful planning and coordination for emergency rescue. These spaces include tanks, pits, vaults, and storm water basins.
            • Training. The ACFD is required by OSHA to conduct annual training for technical rescue, including confined space and high-angle rescue..
            • When operations are planned that may require technical rescue assistance in an emergency, ACFD must be notified in advance. These notifications and coordination efforts are required a minimum of five working days prior to commencement of confined space or high-angle rescue operations and are incorporated into operational procedures.
            • When necessary, ACFD may provide and stage technical heavy equipment from the San Leandro Station 24. ACFD Station 12 also serves as a secondary Level 1 Hazardous Materials Response Station, providing backup to ACFD Station 19 on LBNL. ACFD maintains a Type 1 Heavy Rescue Team and a Type 1 Hazardous Materials Response team for these specific operations as noted at Station 24. These teams are certified by the California Office of Emergency Services (Cal-OES). The required emergency services response for technical rescue, including personnel, apparatus and other protocols is provided in Section 6 of the Base Needs Assessment (BNA).
            • Technical Rescue: ACFD members assigned to the on-site engine company are trained to the operations level rescue techniques with additional resources available via the ACFD Type I Urban Search and Rescue Team stationed in the San Leandro Station 24 or mutual aid resources. The ACFD staffs a minimum of 6 technical rescue specialists per day.
            • Technical Rescue Response Requirements. The LBNL primary work location contains unique buildings and structures used for a variety of experimental purposes. Areas such as confined spaces, tall buildings, specially constructed test chambers, and other one-of-a-kind structures can present unusual rescue problems after an accident. DOE Order 420.1C and DOE Standard 1066-2016 discuss the need for DOE contractors to have a timely and effective response to a spectrum of emergency conditions that they encounter, including specialized rescue.
            • Analysis – Technical Rescue. There are federal requirements for responses to confined space incidents (29CFR1910.146 and 29CFR1926.1200-1213) that form the basis for those responses. NFPA 1670, Standard on Operations and Training for Technical Search and Rescue Incidents and NFPA 1006 Standard for Technical Rescuer Professional Qualifications establish the operations and training requirements for confined space and other technical rescue incidents.
            • NFPA 1670 categorizes responses into three categories, Awareness, Operations, and Technician for the various types of technical rescue incidents (e.g., structural collapse, rope rescue, confined space search and rescue, vehicle and machinery search and rescue, wilderness search and rescue, and trench and excavation search and rescue). Staffing for a confined space search and rescue scenario is recommended in an Annex note as a minimum of six persons to be able to perform all the tasks required.
            • Heavy rescue incidents such as structural collapse, trench rescue, and certain types of machinery rescue situations will require specialized equipment and staffing that are beyond the scope of normal first alarm response capabilities and would need to be dispatched from the ACFD’s Technical Rescue Unit stationed in San Leandro. The Unit has a fully compliant, Type I Apparatus compliant with the State of California OES requirements. NFPA 1710 does not establish response time criteria for technical rescue, which the standard calls special operations. Since the level of urgency is parallel to that for a structural fire, the response time criteria for first arriving unit and first alarm for structural fires, without the credit for sprinkler protection is appropriate for initial awareness level responses. The first alarm technical rescue incident total response time is set at 13 minutes-6 seconds.
            • The Fire Department participates in pre-entry work planning and in some cases is requested to be on-site with a technical rescue team for “high-hazard entries.” ACFD partners with LBNL to be fully engaged in pre-entry/work planning and to ensure timely rescue response is available. The idea is to be pre-emptive and ensure that all preventive measures are implemented before and during the entry by ACFD to reduce the potential for a required entry to perform rescue or recovery operations.
            • Minimum Performance Measure – Technical Rescue Based on the requirements of OSHA 29CFR1910.120, 29CFR1910.146 and NFPA 1670, the minimum performance measure for a Technical Rescue incident is established as follows: Respond to reported technical rescue incidents to provide rescue and extrication of victims of minor structural collapse, minor construction accidents and confined space accidents on the LBNL primary work location within a total response time of 486 seconds for Operations Level incidents 90% of the time.
            • Respond to reported technical rescue incidents to provide rescue and extrication of victims of structural collapse, vehicle accidents, and construction accidents or confined space accidents on the LBNL primary work location within a total response time of 786 seconds 90% of the time.

                  Work Process F. Planning an Entry into Inventoried Spaces by LBNL Employees or Affiliates (Does Not Include Subcontractors)

                  1. Entry into Permit-required Confined Spaces (PRCS)

                  Prior to entry into any Permit-Required Space (PRCS), the Activity Lead must:

                  1. Review the work request (if available) for that activity;
                  2. Determine whether in fact the PRCS needs to be entered. There may be an SWP for that space allowing work from outside the space or if a substitution method can be implemented.  Keep in mind that if the plane of the entry to the confined space is broken (e.g. putting an arm into the space for example) then that is considered an “entry”.  
                  3. Consult the Confined Space Database to determine the classification and determine what hazard(s) are present in the confined space.
                  4. Inspect the work space to verify that conditions within the space are as described in the Confined Space Database, or to note changed conditions; and
                  5. Notify the Confined Space Program Manager of any changed conditions.
                  6. Select and coordinate an Entry Team.  Ensure the team members have current EHS 0275 training and the Entry Supervisor has EHS 0277 training. 
                  7. Reference Work Plan and Control (WPC) for hazards and precautions.    
                  8. Communicate hazards and determine the hazard controls to the Entry Team.
                  9. Arrange a scheduled time for an Entry Supervisor to write a permit as needed.

                  1. Entry into Non-Permit Confined Spaces (NPCSs) with Work that Introduces a Hazard

                  If the work introduces any hazard(s), then the space becomes a permit-required confined space (PRCS).  Prior to entry into a NPCS where the work will introduce a hazard, the Activity Lead must:

                  1. Determine whether an applicable Safe Work Procedure (SWP) exists for entry into that NPCS by consulting the Maximo® Confined Space Database or other type of known hazard. If so, follow that procedure. If there are any questions on a confined space procedure, contact the Confined Space Program Manager prior to executing the work. 
                  2. Determine whether in fact the PRCS needs to be entered. There may be an SWP for that space allowing work from outside the space or if a substitution method can be implemented.  Keep in mind that if the plane of the entry to the confined space is broken (e.g. putting an arm into the space for example) then that is considered an “entry”.  
                  3. Reference Work Plan and Control (WPC) for hazards and precautions.   
                  4. Determine what hazard(s) planned on being introduced into the NPCS space and determine an appropriate corresponding control. Examples of hazards that are commonly introduced include but are not limited to:
                    • Hazardous atmospheres (e.g., solvents, paints, or welding)
                    • Fire (e.g., hot work or grinding)
                    • Electrical (e.g., exposed live electrical energy)
                    • Energy (e.g., removing guards
                    • Chemicals or contamination (which may expose entrant)

                  If the work introduces any hazard(s), then the space becomes a permit-required confined space (PRCS) and unauthorized workers will be prohibited from entering that space (see Section 34.1, Policy, above).   A permitting process will be required for entry when a hazard is introduced and an Entry Supervisor will be needed to prepare the entry permit.  In conjunction with the Activity Lead, the Entry Supervisor determines what the hazards or potential hazards are within that PRCS.

                  1. Reclassification

                  If the hazards posed by the PRCS are not related to an actual or potential hazardous atmosphere, and the hazards can be eliminated from outside the space prior to entry (e.g. LOTO used to shut of moving mechanical components or energized components), the Entry Supervisor may temporarily declassify (for the duration of the work shift) the PRCS to an NPCS per OSHA 29 CFR 1910.146(c)(7) by completing the PRCS Reclassification Certification prior to the entry.  The entry permits must be fully completed with detailed descriptions as follows:

                  1. Describe in the detail the purpose of the work
                  2. Describe the pre-existing and/or introduced hazards in detail
                  3. Describe the hazard controls to be used in detail
                  4. Record the initial and periodic atmospheric testing results
                  5. Document the names of the entry team members
                  6. All spaces for information must be completed
                  7. Each hazards-analysis box must be completed, and a determination confirmed (checked off) that entry conditions are acceptable.
                  8. When all hazards have been evaluated, eliminated if necessary, and confirmed as acceptable, the Entry Supervisor completes the final signature block at the bottom of the permit, which temporarily declassifies the space as an NPCS.

                  1. Alternate Entry Procedure

                  If the only hazard posed by the PRCS is actual or potential hazardous atmosphere, and continuous forced air ventilation and continuous atmospheric testing is sufficient to maintain the PRCS safe for entry, then the Entry Supervisor may authorize entry via the Alternate Entry Procedure. This authorization is documented by completing the PRCS Alternate Entry Procedure Certification prior to the entry.

                  1. Describe in the detail the purpose of the work
                  2. Describe the pre-existing and/or introduced hazards in detail
                  3. Describe the hazard controls to be used in detail
                  4. Record the initial and continuous atmospheric testing results
                  5. Document the names of the entry team members
                  6. All spaces for information must be completed
                  7. Each hazards-analysis box on page 1 must be completed, and a determination confirmed (checked off) that no non-atmospheric hazards exist within that PRCS.
                  8. After air monitoring has been conducted (and recorded on page 1 continuing onto page 2) to document that the continuous forced air ventilation and continuous atmospheric testing is sufficient to maintain the PRCS as safe for entry, the Entry Supervisor completes the final signature block at the bottom of the page, which authorizes entry under the Alternate Entry Procedure.

                  If the hazards have been removed and the PRCS has been reclassified (Step 3.b.i above), or if the entry may be made under Alternate Entry Procedure (Step 3.b.ii above), the Entry Supervisor may authorize work to proceed per general safe work practices, including any specified for that work (e.g., an SWP). When entry proceeds, the Entry Supervisor may either stay at the work site or leave and pass over authority to the Attendant.  The Attendants must ensure the following:

                  1. Continually evaluate conditions to assure that the terms of the entry remain valid (for entry under the Alternate Entry Procedure, this includes periodic air-quality testing to support the determination that continuous forced air ventilation protects workers in the space)
                  2. Provide continual, full-time, support to the entrant(s), recognize any unusual health symptoms of the entrant(s) and ensure their general safety. 
                  3. Remove all workers from the space if at any time hazards arise within the space, and re-evaluate the space to determine whether it must be reclassified for permit entry.

                  If the PRCS cannot be temporarily reclassified as an NPCS or entered under an Alternate Entry Procedure, then the Entry Supervisor must prohibit workers from entering the space, and advise the confined space SME and Activity Lead. A qualified subcontractor may need to be retained to perform work where high hazard risks are involved and cannot be controlled or eliminated.

                  Work Process G. Subcontractor Entry into Confined Spaces

                  1. Non-Construction Related Subcontractor Confined Space Entry into Either PRCS or Non-PRCS

                  For non-construction related work, such as MRO, a subcontractor may enter a pre-existing confined space at LBNL.  This type of work is covered under the general industry regulation 1910.146 and this Program.  Prior to a subcontractor entering an inventoried confined space, the Activity Lead must:

                  1. Consult EHS and the Confined Space Program Manager (SME) for subcontractor approval and authorization status.  (Subcontractors must submit a program and training for review)
                  2. Reference the subcontractor Job Hazard Analysis (sJHA) database for information on hazards, precautions, and equipment required for entry. 
                  3. Inspect the space to verify that conditions within are as described in the Confined Space Database;
                  4. Notify the subcontractor of the hazards and precautions
                  5. Notify the Confined Space Program Manager (SME) of any changed conditions;
                  6. Arrange for an Entry Supervisor to write an entry permit for PRCS.  Entry permits are required to be completely filled out. This includes a detailed description of the space, the location of the space, the purpose of entry, the work performed, Entry team members, and the hazards and controls.
                  7. Submit the completed entry permit to the confined space SME at Building 78.

                  1. Construction-Related Subcontractor Entry in Confined Spaces

                    If a subcontractor must enter a PRCS, including entries into a PRCS after reclassification or under Alternate Entry Procedures, then the Host Employer’s Activity Lead and Confined Space SME will do the following:
                    1. Transmit the following information to the subcontractor:
                      1. Inform the subcontractor that the work area contains a PRCS, and that entry into the PRCS is allowed only through compliance with a PRCS program meeting the OSHA requirements.
                      2. Provide the subcontractor with Confined Space Database information about the PRCS in or near the area where the subcontractor will be working, including the locations, hazards identified and precautions or procedures that LBNL has implemented for the protection of employees.
                    2. Approve the subcontractor’s PRCS program after obtaining the Confined Space Program Manager’s input as follows:
                      1. Obtain a copy of the subcontractor’s written confined space program as part of the SSSP.
                      2. Provide the subcontractor’s written confined space program to the Confined Space Program Manager or disgnee for review. Allow at least ten workdays for review and resolution of comments.
                      3. For those subcontractors who wish to use their own Entry Supervisor to prepare entry permits the following items are required to be submitted to the Confined Space Program Manager for review and approval. 1. A certificate showing Confined Space Qualified Persons training in atmospheric testing principles for confined spaces 2. Documentation for the type of four-gas meter to be used; only pump-type meters will be approved. 3. Documentation of monthly and daily calibration. 4. Information on low and high meter alarm settings. 5. Submit blank copies of the entry permits to be used for review. 6. A sampling methods plan.
                      4. Direct the subcontractor during resolution of the comments. The Confined Space Program Manager does not direct the subcontractor.
                      5. Prohibit the subcontractor from entering the PRCS until any issues with the subcontractor’s written confined space program have been resolved to the satisfaction of the Confined Space Program Manager
                      6. Obtain confined space training certificates for all workers who will be on site. The worker training certificate must state if the course covered the Construction Industry and/or General Industry. Training must include a hands-on practical portion if the worker is to be a member of a PRCS entry team, and rescue training must also be included. Training certificates must have the name of the course instructor and the date completed. In-house training as provided directly to workers by the employer is not acceptable.
                      7. Obtain and submit records of monthly calibration documentation for the four-gas meters to be used on site.
                      8. Provide a self-rescue plan as needed. Coordinate with the ACFD rescue service provider on rescue plans.
                      9. Provide equipment inspection and maintenance processes to ensure that equipment does not malfunction.
                    3. If multiple subcontractors will simultaneously enter the PRCS, or if subcontractor and LBNL personnel will work in or near the PRCS, convene a meeting of affected parties to discuss the work that will be performed in and around the PRCS. Coordinate entry operations such that employees of one subcontractor do not endanger LBNL employees or the employees of any other subcontractor. No subcontractor shall enter a PRCS under any reclassification, Alternate Entry Procedure, or permit until coordination procedures and authorizations have been agreed upon.
                    4. Assure that prior to subcontractor entry into a PRCS, an LBNL Construction Safety Entry Supervisor has reviewed the documentation prepared by the subcontractor (e.g., the coordination procedures and authorizations) and concurs on the documentation’s adequacy.
                    5. Debrief the subcontractor at the conclusion of the PRCS entry operations regarding the confined space program followed, and regarding any hazards confronted or created, or changes in Permit Spaces during entry operations.
                    6. Annual reviews of the confined space entry permits are conducted by the Confined Space Program Manager. As part of this review, debriefing and notification of deficiencies are communicated.

                  Work Process H. Training

                  1. With the exception of subcontractors covered by their own approved Permit-Required Confined Space (PRCS) Program, any LBNL staff, affiliate, visitor, or other individual who performs work at LBNL and who will enter a space classified as a PRCS, whether on a Safe Work Procedure, reclassification, Alternate Entry Procedure, or another work plan, must have current training in EHS0275 Confined Space Hazards and EHS0274 Confined Space Hazards Retraining(if applicable). This training requirement is triggered by employee’s work activities in Work Planning & Control (WPC).
                  2. EHS0275 or an equivalent one hour, 1:1 course is required for those entering Non-Permit Confined Spaces.  The following criteria must be met and maintained: No hazards are to introduced into the space (i.e., hot work, chemicals, etc.); use the buddy system (i.e., workers do not work alone); Use Safe Work Procedures; and wear proper PPE (i.e., hard hats or helmets while working in spaces with head injury hazards).
                  3. With the exception of subcontractors covered by their own approved PRCS Program, any LBNL staff member or affiliate who performs work at LBNL and who functions as an Entry Supervisor shall be pre-selected based on qualifications and remain current in EHS0277 Confined Space Entry Supervisor training. 
                  4. EHS0276 Fall Protection training must be completed by in-house staff who will be an authorized member of a Confined Space Entry Team. The purpose of this training is to ensure proper use of harnesses, tripod and self-rescue.

                  Work Process I. Fall Protection for Confined Space Work

                  • Many confined spaces at LBNL have external and internal fall hazards. The requirements of the Fall Protection Program apply to working on any walking or working surface having an unprotected side or edge that is 6 feet or more above a lower level for construction and 4 feet or more above a lower level for Non-construction. This includes leading edges, roofs, tanks, manholes, unguarded machinery, aerial lifts, ladders, slopes steeper than 2:1 (horizontal to vertical) hillsides, roofs, and surfaces with open holes or skylights. For more information, see Chapter 30 Fall Protection or contact the LBNL Fall Protection SME.
                  • Work inside vertical spaces (greater than 6 feet in depth) requires the entrant(s) to wear a full-body harness whether or not the entrant is connected to a tripod or davit arm. This requirement is not a fall protection requirement but an OSHA emergency rescue requirement.
                  • Entries that require the Entrant be lowered into a vertical confined space and who are doing hands-free work requires a fall protection permit. 
                  • When the Entrant is wearing a harness, but is not connected directly to a life line, then a rescue pole must be immediately available at the work site in order to remotely connect a life line onto the Entrant’s harness.

                  Work Process J. Program Effectiveness Review and Assurance

                  1. The Confined Space Program Manager, Activity Lead, and Entry Supervisor must prohibit further entry into a Permit-Required Confined Space (PRCS) Program and review entry operations whenever there is reason to believe that measures taken under this program may not protect employees. In particular, the Activity Lead and Entry Supervisor must notify the Confined Space Program Manager of:
                    • Any unauthorized entry of a PRCS;
                    • Detection of any hazard in a PRCS that is not covered in the permit;
                    • Detection of a condition prohibited by the permit;
                    • Occurrence of an injury or near-miss during entry;
                    • Change in use or configuration of the Permit Space; or
                    • Employee complaints about the effectiveness of the program.
                  2. Additionally, the Confined Space Program Manager must review entry operations after:
                    • Any unauthorized entry of a PRCS;
                    • Detection of any hazard in a PRCS that is not covered in the permit;
                    • Detection of a condition prohibited by the permit;
                    • Occurrence of an injury or near-miss during entry;
                    • Change in use or configuration of the Permit Space; or
                    • Employee complaints about the effectiveness of the program.
                  3. The Confined Space Program Manager must conduct an ongoing effectiveness (Technical Assurance) review of the program by annually reviewing all PRCS entries.

                  34.6 Source Requirements

                  • 10 CFR 851.21(a)(5), Hazard Identification and Assessment

                  Regulations applicable to General Industry work, such as maintenance and repair operations:

                  • Cal/OSHA Title 8 CCR 5156 and 5157 Group 16, Article 108, Permit-Required Confined Spaces and/or
                  • Code of Federal Regulations (CFR), Title 29, Part 1910.146, Permit-Required Confined Spaces

                  Regulations which are acceptable for contractor submittals, such as written programs and training, on construction-related projects:

                  • Cal/OSHA Title 8 CCR Subchapter 4, Construction Safety Orders, Article 37 1950-1962 Confined Space in Construction and the additional requirements in this chapter and/or
                  • Code of Federal Regulations (CFR), Title 29, Part 1926.1200–1213, Subpart AA, Confined Spaces in the Construction Industry

                  34.7 Other References

                  • DOE Guide 440.1-8, Implementation Guide for use with 10 CFR Part 851, Worker Safety and Health Program, Section 3.3.2.1.5

                  34.8 Appendices

                  Appendix A. LBNL Implementation of Permit-required Confined Space Decision Flowchart
                  Appendix B. Confined Space Evaluation Worksheet
                  Appendix C. PRCS Reclassification Certification
                  Appendix D. PRCS Alternate Entry Procedure Certification
                  Appendix E. Permit-Required Confined Space Entry Debrief

                  _____________________

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