Confined-Space Entry Program

Lawrence Berkeley National Laboratory

CONTENTS

1\. Policy 2

2\. Scope 2

3\. Classification 2

4\. Confined-Space Entry Work Permit System 3

5\. Documentation and Record Keeping 8

6\. Labels 8

7\. Non-permit Confined Spaces 8

8\. Training 9

9\. Responsible Parties 9

10\. Glossary 11

11\. References and Standards 13

12\. Appendix A: Confined Space Entry Work Permit 14

Confined-Space Entry Program

1\. POLICY

Any permit-required space at Berkeley Laboratory may be entered only
after a written Confined Space Entry Work Permit has been approved. All
entries into confined spaces must be conducted in a safe manner
consistent with applicable regulations and recognized good work
practices.

2\. SCOPE

1.  GENERAL

This policy sets forth the requirements necessary for working in
confined spaces at Lawrence Berkeley National Laboratory to prevent
exposure of personnel to dangerous air contamination, oxygen deficiency,
and physical hazards associated with confined spaces. Confined spaces
include, but are not limited to, tanks, ducts, pipelines, sumps, sewers,
trenches, vaults, and similar spaces not intended for continuous human
occupancy and meeting the criteria described in 29 CFR 1910.146.

2.  LABORATORY EMPLOYEES

This policy applies to all Laboratory employees and any worker under the
technical supervision of a Laboratory employee.

3.  SUB-CONTRACTORS

Sub-contractors may elect in their Safety Plan to comply with PUB 3000;
in which case, this policy, except for paragraph 3.2 below, is
applicable. If the sub-contractor chooses to use their own Safety Plan
for confined space procedures, it must be reviewed by the LBNL's
Environmental Health and Safety (EHS) Division and approved by the
Facilities Project Manager, before work may commence. The safety plan
must contain procedures which meet Federal and/or CAL OSHA requirements
for entering permit-required confined spaces and include the completion
of a permit form acceptable to the Laboratory.

3\. CLASSIFICATION

1.  PERMIT-REQUIRED CONFINED SPACES (PRCS)

Permit-required confined spaces are confined spaces where actual hazards
have been identified, or where the probability of a hazard is
significant. Evaluation using the Confined Space Entry Permit (Appendix
A) is required. Both the on-site supervisor (or designee) and a
Laboratory industrial hygienist must sign the permit. Some cases may
require signature approval by EHS Radiation Protection if radiological
hazards are present and by the Electrical Shop Supervisor if 12KV lines
are present.

2.  PROCEDURAL CONFINED SPACE (This option is not available to
    subcontractors)

For confined spaces where a permit is required, but hazards have been
evaluated as low risk, the on-site supervisor may approve a procedural
confined space permit. The following conditions must be met:

-   The work is performed by Laboratory employees or contract employees
    who have completed EHS 275 Confined Space Entry Hazards Training.

-   The entry permit must be completed and signed by a Laboratory
    employee who has completed EHS 277, Permit Writer Training and has
    current EHS 275 Training.

-   All conditions for a permit-required confined space are met.

    1.  NON-PERMIT REQUIRED CONFINED SPACES (NPRCS)

Confined spaces that do not contain hazards, nor have a potential to
contain hazards, do not require an approved Confined Space Entry Permit.
However, a permit must be completed by the on-site supervisor, and, if
hazards are found not to exist, clearly marked as a "Non-permit Space"
and posted at the work site. "Non-permit Space" must be approved by the
Industrial Hygienist.

4\. Confined-Space Entry Work Permit System

A Confined Space Entry Work Permit (see Appendix A) **must** be
completed for all confined-spaces before entry. This permit documents in
writing the location(s) and type of work to be done, certifies that all
existing hazards have been evaluated by the responsible qualified
person(s), and ensures that necessary protective measures have been
taken to protect the safety of each involved LBNL employee. Non-permit
confined spaces must be identified as such by documenting that chemical
and physical hazards (e.g., oxygen levels, etc.) do not exist and by
writing "Non-Permit Space" in bold print across the work permit.

Permits will expire when the entrance is closed or at the end of the
8-hour work shift, whichever is sooner. In certain instances (e.g., if
the confined space will remain isolated and the type of work will not
change), the permit may be extended by EH&S.

(Sections 4.1 through 4.5 describe sections of the Confined Space Entry
Work Permit found on page 14; Appendix A).

4.1 Confined-Space Team

List the person(s) entering the space (entrant) and the designated
standby (attendant) person(s). If applicable, the rotation by the
designated attendant(s) with personnel working in the confined space
must be specified.

4.2 Requirements Completed Prior to Entry

This section of the permit is a checklist of items to be considered
prior to entry. The checklist is designed to determine the hazard level
of the permit-required confined space \[i.e., procedural (low-hazard) or
permit-required (high hazard)\]. For example, if a requirement indicated
by a footnote is marked "yes," then the confined space is
permit-required (even if it was previously classified as a procedural
confined space), and **both** the supervisor and an industrial hygienist
must sign off on the permit prior to entry.

If the answer to any of the asterisked (\*) requirements is "yes,"
site-specific details are required in the "Additional Information"
section.

Figure 4-1 is a flow chart to help determine if a confined-space permit
needs to be signed by the supervisor or the supervisor and EHS.

> **n**
>
> **Figure 4-1.** Confined-space decision flow chart.

The key points in this section are described below.

> **•** If **12-kv electrical** lines are present in the confined space,
> the Electrical Shop Supervisor (or designee) must also approve the
> entry permit.

**• Lockout and tagout/blockout** must be done in accordance with LBNL's
lockout and tagout procedures. This may require the completion of
Berkeley Lab's Lock and Tag Out course, EHS 256.

**•** Lines, pipes, etc., must be **blanked/capped** to the extent
feasible before the confined space is entered.

**•** If mechanical **ventilation** is required, site-specific details,
such as the direction of airflow and the placement of the air intake,
must be documented in the "Additional Information" section. The air
supply must be from a clean source: exhaust from vehicles, cranes, earth
compactors, and other potential sources of contaminants must be
considered when locating the blower.

• The confined space must be emptied and purged of all **hazardous
materials** to the extent possible prior to entry. If **hazardous
materials** have been identified or will be used in the confined space,
an industrial hygienist must be present to determine their
concentrations and approve the permit. If these materials exceed, or
have the possibility to exceed, occupational health limits (e.g., PEL or
TLV; see the glossary section for details), rescue equipment (e.g.,
**hoist**, **lifelines, and harness**) is required, and the **standby**
must be CPR trained (LBNL Fire Department could serve as standby).

• Periodic or continuous **air monitoring** may be required if the
confined space cannot be isolated from potential contaminants. For
example, flowing sewers often cannot be blanked off, and continuous air
monitoring is recommended.

**•** When entrance covers are removed, openings must be guarded by
**temporary barriers** that will protect the entrants from external
hazards, such as vehicles, and protect pedestrians from falling into the
opening.

**•** A **fire extinguisher** must be present if "hot work" is being
performed.

**•** If **ionizing radiation** may be present, radiation levels must be
monitored by personnel trained in radiation hazard assessment before
entry.

**•** When **protective clothing** is specified, site-specific
information (e.g., type of coveralls, gloves, etc.) must be specified in
the "Additional Information" section.

**•** At least one **standby** person must be present at all times while
the PRCS is occupied. The primary responsibility of the standby
personnel is the safety of the occupants in the confined space. Standby
personnel must be in constant **visual/radio** contact with the
occupants and must immediately notify the LBNL Fire Department if there
are any problems. The standby person should always summon emergency
rescue workers, and may never enter a confined space to attempt a
rescue. However, the standby can initiate a non-entry rescue, such as by
operating a hoist or lift.

**•** If **respiratory protection** is required, site-specific details,
such as the type of respirator and cartridges, must be specified in the
"Additional Information" section.

**•** If "**hot work**" will be performed, a Fire Safety Permit,
available from the Fire Department, must be completed and posted at the
entrance to the space prior to the start of work. **All** confined
spaces become permit-required confined spaces when hot work is performed
in them. In addition, welding gas cylinders may never be brought into a
confined space.

**•** Personnel entering the space must receive **confined-space
training** (EHS 275) prior to entering a permit-required or procedural
confined space. Attendants must also receive EHS275 prior to fulfilling
the role as an attendant. In addition to this training in the hazards
and classification of confined spaces, personnel must review the
Confined Space Entry Work Permit, as well as any special procedures
written for the space(s) prior to entry. In certain instances, employees
may receive site-specific confined-space training from a EHS industrial
hygienist until they can be scheduled for the confined space training
class.

**•** Additional **lighting** equipment may be needed to enable
employees to see well enough to work safely and to exit the space
quickly in an emergency. In certain instances, explosion-proof lighting
may be required.

**•** The **gas monitor** must be calibrated monthly and function
checked prior to each daily use.

4.3 Monitoring Results

Atmospheric monitoring is required for **all** permit-required confined
spaces (i.e., procedural and permit-required). This monitoring must be
performed by personnel who have been trained in the use of gas-detecting
instruments (Permit Writer Training, EHS 277). When testing for
atmospheric hazards, test first for oxygen, then for flammable gases and
vapors, and finally for toxic gases and vapors \[29 CFR 1910.146 (d) 5
(iii)\]. Many modern direct-reading instruments provide simultaneous
reading of oxygen, flammable gases, and select toxic gases. All levels
of a confined space must be tested: since gases and vapors can be
lighter or heavier than air, they may tend to accumulate at one level.
Atmospheric monitoring is required before mechanical ventilation is put
into operation.

Safe levels for confined-space work are 19.5--23.5% oxygen, flammable
vapors less than (\<) 10%, and other toxins less than (\<) the PEL, TLV,
STEL, ceiling, or manufacturer's recommendations. Any deviation from
"normal" atmospheric readings (20.9% oxygen, 0% LEL or any detectable
amount of toxin) must be investigated further to determine the cause of
contamination and to ensure that the confined space is truly isolated.
For example, a 4% flammability reading in a telephone or electrical
vault may indicate seepage from a leaking underground natural gas line
that is not even located within the vault.

4.4 Additional Information

Include site-specific details required by the checklist here.

4.5 Approvals

Approval signatures go in this section.

• For procedural confined spaces, either the LBNL supervisor or designee
(EHS 277 required) or the LBNL EHS industrial hygienist may sign.

• For permit-required confined spaces, **both** the supervisor and the
LBNL EHS industrial hygienist must sign.

The permit must be completed and approved before the confined space can
be entered.

An Electrical Shop supervisor's (or designee) signature is required for
**all** entries into confined spaces with 12-kv lines.

[5.]{.smallcaps} Documentation and Record Keeping

The original copy of the completed Confined Space Entry Work Permit must
be posted at the job site for the duration of the work. The yellow copy
of the signed permit must be kept on file by the EHS Industrial Hygiene
Group for at least one year.

The EHS Industrial Hygiene Group must maintain the Confined Space Survey
file that inventories and evaluates all procedural and permit-required
confined spaces at Berkeley Lab.

All training will be documented in the LBNL training database by the EHS
Division.

6\. Labels

Confined spaces must be surveyed and posted with one of the signs listed
below. An exception to this labeling requirement is spaces whose
entrances are in roadways, sidewalks, etc., and subject to vehicular and
foot traffic.

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7\. Non-permit confined spaces

Work requirements for non-permit confined spaces are as follows:

• Non-permit confined spaces must be identified as such by documenting
that chemical and physical hazards (e.g., oxygen, etc.) do not exist and
by writing "Non-Permit Space" in bold print across the work permit.

• Barricades and isolation (if appropriate).

• Ground fault circuit interrupters (GFCI) on power hand tools and other
electrical equipment.

> • Proposed activities must not introduce hazards to the area, thereby
> converting it into a high-hazard confined space.

-   Prior approval by the Industrial Hygienist is required.

8\. TRAINING

Supervisors who authorize entry into confined spaces and employees who
enter confined spaces or serve as attendants must have completed the
Confined Space Training class, EHS 275. This training provides
information on the hazards and classification of confined spaces,
recommended safe work practices, and the correct use of a Confined Space
Entry Work Permit. Retraining will be performed every three years (EHS
274).

LBNL employees who perform atmospheric monitoring for procedural
confined spaces are required to have completed the Permit Writer
Training class, EHS 277. This training provides information concerning
instrument calibration, field checks and responsibilities of the Entry
Supervisor. Retraining will be performed every three years (repeat EHS
277).

Depending on responsibilities and the type of confined-space entry,
additional training may be required, such as:

• First aid and CPR certification (EHS 116, 123)

• Respirator training (EHS 310)

**•** Lockout/tagout (EHS 256)

9\. Responsible Parties

9.1 Attendant (Standby)

• Read the Confined Space Entry Work Permit before starting work, and
abide by its conditions.

• Stop work and request that workers exit the confined space if
conditions under which the permit was written change, or if any danger
is perceived.

• Remain outside the confined space until relieved by another attendant.

• Summon the Fire Department if it is determined that employees in the
confined space may need assistance in escaping.

• Be knowledgeable of the hazards that may be encountered during the
entry, including the signs, symptoms, and consequences of exposure to
these hazards.

• Perform non-entry rescues, if possible.

• Maintain contact with the workers in the confined space.

9.2 EHS Industrial Hygiene Group

• Authorize entry for procedural (low-hazard) confined spaces, and
jointly approve entry with the supervisor (or designee) for
permit-required confined spaces.

• Approve site-specific written entry procedures for procedural confined
spaces.

• Provide technical guidance.

• Assist in monitoring and evaluating of confined-space hazards (e.g.,
oxygen deficiency, toxins).

• Conduct the Confined Space Entry Hazards class (EHS 275) and Refresher
(EHS274).

• Conduct the Permit Writer training class (EHS 277).

• Administer the Confined Space Entry Program.

• Maintain copies of all Confined Space Entry Work Permits for at least
one year.

• Maintain the inventory of permit-required confined spaces for Berkeley
Lab.

• Perform the initial and periodic evaluation of the hazards associated
with each confined space.

-   Review Confined Space Programs submitted by subcontractors.

9.3 EH&S Fire Department Personnel

• Assist in the development and implementation of rescue/recovery
procedures for confined-space entry.

• Designate the rescue team.

• Conduct confined-space rescue drills at least once per year.

9.4 Personnel Entering Confined Spaces

• Read the Confined Space Entry Work Permit before starting work, and
abide by its conditions.

• Stop work and exit the confined space if conditions under which the
permit was written change or if any danger is perceived. Report this to
the attendant and supervisor.

• Ensure that the Confined Space Entry Work Permit is posted at the
worksite, and that other safety precautions, such as isolation of the
space, lockout/tagout, barricades, etc., are performed, if required.

• Confer with the space/equipment owners and the person completing the
permit to ensure that all hazards have been considered.

• Be knowledgeable of the hazards that may be encountered during the
entry, including the signs, symptoms, and consequences of exposure to
these hazards.

• Remove permits/barriers after the work has been completed.

• Maintain contact with the attendant.

-   Ensure that a copy of the Confined Space Permit is forwarded to EH&S
    Confined Space Program Manager.

9.5 Purchasing

• Ensure that prospective subcontractors bidding on LBNL projects are
informed when work in confined spaces will be required.

9.6 Supervisors

• Ensure that employees who may work or authorize entry into confined
spaces have completed the Confined Space Entry Hazards (EH&S 275) and
any additional safety classes that may be required.

• Ensure that employees who may perform atmospheric monitoring in
confined spaces have completed the Permit Writer (EH&S 277) training.

• Authorize entry for procedural (low-hazard) confined spaces, and
jointly approve entry with an industrial hygienist for permit-required
confined spaces.

• Ensure equipment used for confined-space entries is kept in good
operational condition and is calibrated according to manufacturers'
recommendations.

> • If necessary, write a site-specific procedure for entry into a
> procedural confined space, and obtain pre-approval from an EH&S
> industrial hygienist.

**Note**: This type of procedure is generally most applicable to
temporary, unique, research equipment.

• Ensure that operations comply with the terms and conditions on the
permit.

10\. Glossary

**Attendant (standby).** An individual stationed outside one or more
confined spaces to monitor authorized entrants, and who performs all
attendants' duties assigned in the confined-space program.

**Confined space.** A space that (1) is large enough and so configured
that an employee can enter bodily, (2) has limited or restricted means
for entry or exit (e.g., tanks, vessels, vaults, pits), and (3) is not
designed for continuous occupancy.

**Entry.** The action by which a person passes through an opening into a
permit-required confined space. Entry is considered to have occurred as
soon as any body part of the entrant's body breaks the plane of an
opening into the space.

**Entry permit.** The written permit that must be completed and posted
at the worksite before a confined space is entered (see Appendix A).

**Hazardous atmosphere.** An atmosphere that may expose employees to the
risk of death, injury, or illness from one of the following:

> • Flammable gas, vapor, or mist exceeding 10% of its lower explosive
> limit (LEL)
>
> • Airborne combustible dust at a concentration that meets or exceed
> its LEL
>
> **Note:** This concentration may be approximated as a condition in
> which dust\
> obscures vision at a distance of 5 ft or less.
>
> • Atmospheric oxygen concentration below 19.5% or above 23.5%
>
> • Atmospheric concentration that exceeds the PEL, TLV, STEL, ceiling,
> or the\
> manufacturer's recommendations on the Material Safety Data Sheet
> (MSDS)

**Non-permit confined space.** A 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. Examples
of these types of spaces are false ceiling plenums, trailer sub-floor
areas, and shored trenches greater than 5 feet in depth.

**[Note:]{.underline}** These spaces become permit-required confined
spaces if hazards are brought in or exposed by the work. Examples
include gasoline-powered earth compactors (carbon monoxide);
solvent-based coatings, epoxies, and paints; open sewer lines in the
bottom of trenches; contaminated soil; welding; etc.

**Permissible Exposure Limit (PEL) and Threshold Limit Value (TLV).**
Employee airborne-exposure limits established for particular chemicals
by the Federal Occupational Safety and Health Administration (Fed/OSHA)
and the American Conference of Governmental Industrial Hygienists
(ACGIH), respectively. DOE requires that employee exposures must not
exceed PELs or TLVs. Time-weighted average (TWA), short-term exposure
limit (STEL), and ceiling (C) standards are summarized as follows:

**[Organizations and Standards Work Exposure Duration]{.underline}**

Fed/OSHA PEL-TWA and ACGIH TLV-TWA 8-hour shift and 40-hour week

Fed/OSHA PEL-STEL and ACGIH TLV-STEL 15 minutes

Fed/OSHA PEL-C and ACGIH TLV-C Any point in time

**Permit-required confined spaces (PRCS).** Confined spaces where actual
hazards have been identified or the probability for a serious accident
or hazard being present is high. Written authorization on the permit by
both the supervisor and an EH&S industrial hygienist is required. Types
of hazards may include

> • Hazardous atmosphere
>
> • Physical hazards, such as radiation, acids, combustible dusts,
> engulfment, crushing, falling etc.

• Oxygen deficiency

Examples of these types of confined spaces include sewers, degreasers,
waste treatment tanks, and sumps.

**Note**: A space classified as a permit-required confined space may be
reclassified as a non-permit confined space if the permit space poses no
actual or potential atmospheric hazards and if all hazards within the
space are eliminated without entry into the space \[29 CFR 1910.146 c
(7) i\].

**Procedural confined spaces.** A type of permit-required confined space
that meets the definition of a confined space but in which hazards are
unlikely to be present. Written authorization on the permit may be by
the supervisor (who has completed EH&S 275 & 277) **or** an EH&S
industrial hygienist. Examples of these types of spaces include
electrical vaults, communication (phone) vaults, water valve vaults,
etc.

**Note:** A procedural confined space becomes a permit-required confined
space if hazards are brought in by the work. Examples include welding,
epoxies, paints, solvent cleaning, etc.

11\. REFERENCES AND Standards

29 CFR 1910.146, *Permit Required Confined Spaces* (Department of Labor)

Title 8, Article 108, *Confined Spaces* (California Code of Regulations)

ANSI Z117.1-1989, *Safety Requirements for Confined Spaces*

12\. Appendix A. Confined Space Entry Work Permit

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