The purpose of this program is to inform our employees that Fort Lewis College is complying with the OSHA Confined Space Standard, Title 29 Code of Federal Regulations 1910.146. We have determined that our campus needs written procedures for the evaluation of confined spaces, and where permit-required spaces are identified, we have developed and implemented a permit-required confined space entry program. This program applies to all work operations at Fort Lewis College where employees must enter a permit-required confined space as part of their job duties.
The Director of Environmental Health & Safety (EH&S) has overall responsibility for coordinating safety and health programs at Fort Lewis College. Members of the campus Health & Safety Group (H&SG) will review and update the program, as necessary. Copies of the written program may be obtained from EH&S, Physical Plant Services or Information Technology.
Under our program, we identify permit-required spaces in Fort Lewis College, and provide training for our employees according to their responsibilities in the permit space. These employees receive instructions for safe entry into our specific type of confined spaces, including testing and monitoring, appropriate personal protective equipment, rescue procedures, and attendant responsibilities.
This program is designed to ensure that safe work practices are utilized during all activities regarding the permit space to prevent personal injuries and illnesses that could occur. If, after reading this program, you find that improvements can be made, please contact Terry Richardson, Matthew McGlamery or Ted Gross. We encourage all suggestions because we are committed to sustaining a safe work environment for all our employees. A safe and effective permit-required confined space entry program is an important component of our overall safety plan.
Hazard Evaluation for Permit Spaces
To determine if there are permit-required confined spaces in Fort Lewis College, Physical Plant Services and Information Technology have conducted hazard evaluations on campus. These evaluations have provided us with the information necessary to identify the existence and location of permit-required confined spaces on campus that must be covered by the Permit-Required Confined Space Entry Program. This written hazard evaluation is kept in the EH&S office.
Preventing Unauthorized Entry
To provide a safe work environment and to prevent exposed employees from accidentally entering a permit space, we have implemented the following procedures to inform all employees of the existence, location, and danger posed by permit spaces in Fort Lewis College. To inform employees of the existence of a permit space, we use signage identifying the space. To ensure that unauthorized employees do not enter and work in permit spaces, we communicate the limitations via safety meetings and postings.
Safe Permit Space Entry Procedures
Ted Gross and Matthew McGlamery are the Entry Supervisors responsible for authorizing entry and issuing entry permits for work in our permit spaces. The file of permits and related documents are kept in the PPS and IT Departments. The procedures we follow for preparing, issuing, and canceling entry permits are discussed in the following sections. PPS and IT maintain current lists of employees authorized to work in or near the permit spaces. The list includes activities each person is qualified to perform, including supervisory, attendant and entry responsibilities.
To ensure the safety and health of our employees, before allowing authorized workers to enter a permit space, the conditions in that space are evaluated to determine if a safe entry is possible. Any employee who enters the space has the option of requesting a reevaluation of the space if they feel that the evaluation was not adequate. Our procedure includes testing the internal atmosphere with a calibrated direct-reading instrument for oxygen content, flammable gases and vapors, and potential toxic air contaminants. We also periodically test the atmosphere of the space to ensure that the continuous ventilation is preventing the accumulation of a hazardous atmosphere.
The Entry Supervisor verifies that the space is safe for entry and that the pre-entry measures have been taken and that all hazards have been eliminated by completing the Confined Space Work Permit. The pre-entry documentation is made before the entry is made, and is available for review by each employees participating in the entry.
To ensure the safety and health of our employees, Fort Lewis College provides appropriate equipment to all employees who work in or near our permit space. Each authorized entrant will use a full body harness with a retrieval line.
We maintain all equipment in proper working condition, train the entrants in the correct usage of this equipment, and ensure that all equipment, including that used for personal protection, is used properly
Duties: Authorized Entrants
Those persons who have completed the training and are authorized to enter our permit spaces are assigned specific duties and responsibilities that they must perform when they work in the permit space. The elements covered in the training program for authorized entrants include:
- Atmospheric testing and monitoring equipment operation
- Physiological reaction of oxygen deficiency, carbon monoxide exposure and toxic gases
- Potential hazard within the confined space – size, shape and any other physical limitation
- Psychological aspects of working in a confined space
- Emergency escape procedures
- Communication with attendant
- Ventilation options and special hazards associated with hot work
- Lockout-tagout and potential hazardous energy release
- Unexpected hazards and how to react to them
Those persons who have completed the training and have been designated as permit space attendants are assigned specific duties and responsibilities that they must perform in permit space job duties. These duties and responsibilities include:
- Remains outside the entry space to control the entry process and maintain communication with the entrants.
- Understand the potential hazards for the space and signs of overexposure to the hazards
- Keep a current head count of entrants
- Ensure only authorized employees enter the space
- Order the workers out of the space as needed
- Call for backup
- Never enter the space unless part of a rescue team
Duties: Entry Supervisors
Those persons who have completed the training and have been designated as permit space entry supervisors are assigned specific duties and responsibilities that they must perform in permit space job duties. Their duties and responsibilities include:
- Verifies the pre-entry permit is properly filled out and signs off on the permit
- Verifies with the attendant that conditions are safe for the entrants
- Cancels the permit if conditions warrant
- Assists in preventing unauthorized employees from entering the space
- After the work is completed, cancels the permit and concludes the process.
Every employee at Fort Lewis College who faces the risk of confined space entry is provided with training so that each designated employee acquires the understanding, knowledge and skills necessary for the safe performance of the duties assigned to them. Training can be conducted by designated employees in EH&S, PPS or IT. All training related materials, documents, and signed certificates are kept in EH&S.
Employees whose job duties may involve entry into a confined space will receive permit-required confined space training before participating in an entry. When we conduct the training, we use our written program, a Power Point presentation and handouts are available. New employees are always trained before their initial assignment of duties. We follow these procedures when training these employees - classroom presentation, open discussion, examination and hands-on training).
When changes occur in permit-required confined space areas on campus we halt the entry process, have all entrants leave the confined space, and retest before work is resumed. If we have reason to believe that an employee has deviated from a previously trained upon procedure or that their knowledge seems inadequate, we halt the job, correct the behavior, and have the employee explain their actions. If necessary, the employee will be instructed to participate in another confined space entry class.
Upon successful completion of Fort Lewis College permit-required confined space training program, each participant affirms that they will follow all Fort Lewis College policies and procedures regarding permit space entry.
Rescue and Emergency Services
Fort Lewis College utilizes its own employees to perform rescue services in the event of a permit space emergency. This group of employees has been trained, at a minimum, to:
- Perform the assigned rescue duties
- Correctly use personal protective equipment (PPE) required for the job;
- Establish proficiency as an authorized entrant
- Perform basic first-aid and cardiopulmonary resuscitation (CPR)
- Perform basic automatic external defibrillation (AED).
Fort Lewis College also requires affected employees practice making permit space rescues at least once every 12 months, by means of simulated rescue operations in which they remove dummies, manikins, or actual persons from the actual permit spaces or from representative permit spaces. Representative permit spaces will, with respect to opening size, configuration, and accessibility, simulate the types of permit spaces from which rescue is to be performed.
Multiple Employer Entry Procedures
When outside employers/contractors enter our facility to perform work in permit spaces, we coordinate entry and work operations following these procedures:
- Project manager coordinates with either Ted Gross or Matthew McGlamery
- Contractor’s program is review and ours is shared with them
- The entry is conducted per our written procedure.
- Both groups sign the closeout section of the permit following completion of the job.
To ensure that all employees participating in entry operations are protected from permit space hazards, Fort Lewis College reviews the Permit-Required Confined Space Entry Program on a regular basis. We use the retained canceled permits from the past 12 months within one year after each entry and revise the program as necessary. Fort Lewis College performs a single annual review covering all entries performed during a 12-month period. If no entry is performed during a 12-month period, no review will be performed.
Constant awareness of and respect for permit-required confined space entry hazards, and compliance with all safety rules are considered conditions of employment. Supervisors and individuals in the Safety and Personnel Department reserve the right to issue disciplinary warnings to employees, up to and including termination, for failure to follow the guidelines of this permit entry program.