Requirements for Work in Confined Spaces

1.0 Purpose

1.1 This document establishes safety requirements for all work conducted within confined spaces on the University of Delaware campus.

1.2 The compliance with this procedure does not preclude or preempt the applicability of any other governmental or industry standard, procedure or policy.

2.0 Definition of Confined Space

2.1 A confined space refers to a space that:

  1. Is large enough and so configured that an employee can bodily enter and perform assigned work
  2. 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.)
  3. Is not designed for continuous occupancy

2.2 A confined space includes, but is not limited to, any of the following if the criteria set forth in Paragraph 2.1 are met:

  1. Storage tanks, tank cars, process vessels, bins, tank trailers, and other tank-like compartments usually with one or more manholes for entry.
  2. Open-topped spaces of more than 4 feet in depth, such as bins, silos, pits, vats, tubs, vaults, vessels, floating roof storage tanks, or trenches.
  3. Ventilation or exhaust ducts, manholes, sewers, tunnels, pipelines, and similar structures;
  4. Ovens, furnaces, kilns, and similar structures.

2.3 Permit Required Confined Space

Permit-required confined space (permit space) means a confined space that has one or more of the following characteristics:

  1. Contains or has a potential to contain a hazardous atmosphere;
  2. Contains a material that has the potential for engulfing an entrant;
  3. Has an internal configuration such that an entrant could be trapped or asphyxiated by inwardly converging walls or by a floor which slopes downward and tapers to a smaller cross-section; or
  4. Contains any other recognized serious safety or health hazard.
  5. Any other space so designated by the University of Delaware

2.4 Non-Permit Required Confined Space

A non-permit confined space means 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.

In some instances, activities to be conducted in the space determine whether the confined space is permit or non-permit required.

3.0 Confined Space Entry: All Operations (Farm Operations Have Additional Requirements)

3.1 Entry into a confined space shall not be made unless the following procedures have been completed.

  1. Except for fire suppressants and extinguishing systems, insure that all lines containing harmful agents, such as supply, discharge, overflow, vent, drain, or similar connections entering the space are physically separated or blocked by means of blinds or other devices, capable of ensuring complete closure. Steam lines running into and through confined spaces shall be double valved off from non-confined space locations and allowed to cool before entry is made into such spaces. Any exception to this procedure must be approved by the Director of Facilities Management and the Director of the Department of Environmental Health & Safety.
  2. Fixed mechanical devices or equipment, the operation of which might endanger the employee or cause additional hazards, shall be rendered inoperable by physically disconnecting power sources.
  3. Lock out/tag out all mechanical, pneumatic, electrical equipment, and steam lines within the confined space. Check operation to verify lock-out.
  4. The atmosphere within the confined space shall be tested to verify the oxygen concentration is adequate. Entry into the confined space is not allowed if the oxygen concentration is less than 19.5% or greater than 22%. The atmosphere in the confined space shall also be tested to verify that combustible gas concentration is less than10% of the lower explosive limit and, when there is reason to suspect their presence, that there are no air contaminants in excess of maximum exposure levels specified in CFR 1910 Subpart Z or the American Conference of Governmental Industrial Hygienist (ACGIH) TLV booklet (latest edition).

3.2 Ventilation

  1. If the tests made in accordance with Paragraph 3.1.4 indicate that the atmosphere is unsafe, the space shall be ventilated until concentrations are returned to a safe level before any personnel are permitted to enter the confined space. Ventilation shall be continued for the duration of the entry.
  2. As an alternative to ventilation, or if ventilation does not adequately reduce or remove the hazardous substance, personnel may enter a confined space only if wearing an appropriate respirator in accordance with the requirements of the University Respiratory Protection Program. If the employee uses an air supplied respirator (self-contained breathing apparatus or a type C airline respirator), sufficient primary air capacity shall be available as well as reserve capacity to perform the task inside the confined space. The wearer of the respirator may not be permitted to remain in the confined space when the primary air system is depleted or is being replaced. The reserve air supply shall be used only in the event of an emergency.

3.3 Mechanical ventilation is required for all confined spaces regardless of test results from Paragraph 3.1(4). The only exception is when the presence of asbestos containing materials is suspected.

3.4 The employees working inside and outside the confined space shall be adequately trained in confined space entry. An employee shall not enter a confined space subject to a hazardous atmosphere or other recognized safety or health hazards unless:

  1. Provision has been made for constant communication with an attendant in the immediate vicinity who is not in the confined space;
  2. Provision has been made for communication equipment for summoning emergency or rescue services;
  3. Provision has been made for adequate rescue procedure including rescue equipment specifically designed for rescue from the confined space in which work is being performed; and
  4. The employees working inside and outside the confined space have been adequately trained in confined space entry.

3.5 Ladders or other safe means shall be used to enter and exit manholes, trenches, etc. exceeding 4 feet in depth.

3.6 When open flames are used in a confined space, the following precautions shall be taken to protect against the accumulation of combustible gas:

  1. A test for combustible gas shall be made immediately before using the open-flame device and at least once per hour while using the device; and
  2. A fuel tank (for example, acetylene) may not be in the confined space.

3.7 Lighting and electrical equipment

  1. Temporary lights shall be equipped with guards to prevent accidental contact with the bulb, except that guards are not required when the construction of the reflector is such that the bulb is deeply recessed.
  2. Temporary lights shall be equipped with heavy-duty electric cords with connections and insulation maintained in safe condition. Temporary lights may not be suspended by their electric cords unless cords and lights are designed for this means of suspension. Splices shall have insulation equal to that of a cable.
  3. Working spaces, walkways, and similar locations shall be kept clear of cords so as not to create a hazard to employees.
  4. Portable electric lighting (125 volts) shall be protected by a ground fault circuit interrupter (GFCI). Portable electric lighting used in moist or other hazardous locations (for example, drums, tanks, and vessels) shall be operated at a maximum of 12 volts.
  5. All electrical equipment shall be protected by a ground fault circuit interrupter (GFCI).

4.0 Confined Space Entry: Farm Operations

4.1 Personnel shall not enter into a confined space for farm operations unless:

  1. Fixed mechanical devices or equipment and electrical service equipment which might endanger the employee or cause additional hazards shall be rendered inoperable by disconnecting and following lock out/tag out procedures.
  2. Lighting and electrical equipment
    1. Temporary lights shall be equipped with guards to prevent accidental contact with the bulb, except that guards are not required when the construction of the reflector is such that the bulb is deeply recessed.
    2. Temporary lights shall be equipped with heavy-duty electric cords with connections and insulation maintained in safe condition. Temporary lights may not be suspended by their electric cords unless cords and lights are designed for this means of suspension. Splices shall have insulation equal to that of a cable.
    3. Temporary lights and electrical services shall be protected by a ground fault circuit interrupter (GFCI).
    4. Working spaces, walkways, and similar locations shall be kept clear of cords so as not to create a hazard to employees.
    5. All electrical equipment shall be protected by a GFCI.

4.2 Requirements for Entering Confined Spaces Containing Fermenting Animal Feeds

  1. Personnel shall not enter a confined space containing fermenting animal feed during filling or 10 days thereafter. Exceptions to this rule must be approved by the Department of Environmental Health & Safety.

4.3 Requirements for Entering Confined Spaces for Grain Storage

  1. Personnel shall not enter a confined space used for grain storage without wearing an appropriate respirator in accordance with the requirements of the University Respiratory Protection Program.

4.4 Requirements for Entering Manure Pits, Tanks and Other Animal Waste Handling Systems

  1. Personnel shall not enter a confined space used for animal waste handling without approval of the Department of Environmental Health & Safety.

4.5 All items listed under Section 3 apply to farm confined spaces.

5.0 Entry Permit

5.1 An entry permit shall be required for entry into all confined spaces on campus.

5.2 The entry permit shall authorize entry only by authorized entrants into a specific confined space, for a specific purpose, with entry by a specific shift or work crew permitted for a period not to exceed 8 hours.

5.3 The entry permit shall include items 1 through 11 below.

  1. Specify the minimum acceptable environmental conditions for entry and work in the confined space;
  2. Make provision for assuring and certifying that the specified pre-entry requirements are met;
  3. Name the attendant, unless the permit directs that the attendant function rotates;
  4. Make provision for assuring that the means specified by the department to summon the designated outside assistance is available.
  5. Describe the hazards known or reasonably expected to be present in the confined space;
  6. Specify all means of isolation, cleaning, purging or inerting to be done prior to entry to remove or control those hazards, or certify that these procedures have been done;
  7. Describe any additional hazards that may be reasonably expected to be generated by entrants' activities in the space and specify all special work practices or procedures to be followed;
  8. Specify the personal protective equipment, including respiratory protection, clothing, etc., that is necessary for entry or rescue;
  9. Specify the atmospheric testing to be done immediately prior to and during the entry period
  10. Where hot work is necessary, authorize such hot work, either as part of the entry permit itself or by a separate hot work permit which is attached to the entry permit, with its issuance noted on the entry permit; and
  11. Specify the type(s) of equipment necessary for rescue purposes that must be readily available. In the case of entry into an actually or potentially IDLH atmosphere, NIOSH approved positive pressure atmosphere supplying breathing apparatus or a positive pressure airline respirator equipped with 5 minute (or greater) emergency escape bottle, and any other equipment necessary for rescue purposes shall be available at the point of entry.

5.4 The permit must be conspicuously posted at the entrance to the confined space before entry is made and remain posted until the permit expires or the work has been completed.

6.0 Training Requirements

6.1 General. Departments shall assure that all employees who may enter a confined space in the course of their employment are aware of the appropriate procedures and controls for entry and, also, are aware that unauthorized entry into such spaces is forbidden. Employees shall be made aware that the consequences of unauthorized entry can be fatal, and that their senses are unable to detect and evaluate the severity of atmospheric hazards.

6.2 Training for authorized entrants. Departments shall assure that all authorized entrants know the emergency action plan and have received training covering the following subjects prior to entering any confined space:

  1. Hazard recognition. Departments shall assure that every employee, before entering a confined space containing a potentially hazardous environment, understands the nature of the hazard, and the need to perform appropriate testing to determine if it is safe to enter.
  2. Use of personal protective equipment. Employees shall be taught the proper use of all personal protective equipment, including respirators and clothing required for entry or rescue.
  3. Self-rescue
    • Employees must be trained to exit from the confined space as rapidly as they can without help (self-rescue) whenever an order to evacuate is given by the attendant, whenever an automatic evacuation alarm is activated, or whenever employees recognize the warning signs of exposure to substances whose presence in the confined space is known or expected.
    • Employees shall be made aware of the toxic effects and symptoms of exposure to anticipated hazardous materials that may be absorbed through the skin, inhaled, or ingested, or which may be carried through their skin by solvents they are using. They shall also be trained to relay an alarm to their attendant and to attempt self-rescue immediately on becoming aware of these effects.
  4. Special work practices or procedures. The employer shall train employees in any modifications of normal work practices that are necessary for confined space work.

6.3 Training for person authorizing or in charge of entry. In addition to the requirements of paragraph 6.1, the person authorizing or in charge of entry shall be trained to:

  1. Recognize the effects of exposure to hazards reasonably expected to be present;
  2. Carry out those duties that the entry permit (if applicable) assigns to the person authorizing or in charge of entry.

6.4 Training for attendant. The attendant shall be trained in the department's emergency action plan, the duties of the attendant, and in:

  1. Proper use of the communications equipment furnished by the department for communicating with authorized entrants or summoning emergency or rescue services;
  2. Authorized procedures for summoning rescue or other emergency services;
  3. Recognition of the early signs of intoxication caused by contaminants whose presence are anticipated to be in the space;
  4. The requirements of paragraph 6.2 if the permit (if applicable) specifies that the attendant function will alternate among the authorized entrants; and
  5. In accordance with section 9.0 if the attendant will have rescue duties that could require entry.

7.0 Duties of the Attendant.

The attendant shall remain outside the confined space and shall:

  1. Maintain continuous communication with all authorized entrants within the permit entry confined space by voice, radio, telephone, visual observation, or other equally effective means. If it is not possible for one attendant to maintain communication with each entrant because of the entrant's work station in the space, other arrangements shall be made to assure that the attendant is continuously aware of the location and condition of any entrant who is out of direct communication range;
  2. Have the authority to order entrants to exit the space at the first indication of an unpermitted condition, an unexpected hazard, indication of a toxic reaction, i.e., unusual conduct by the entrants, or if a situation occurs outside the space that could pose a hazard to the entrants;
  3. Know the procedure and have the means to summon immediate emergency assistance if needed; and
  4. Remain at his or her post and not leave for any reason except for health and medical reasons or by being replaced by an equally qualified individual while entry continues. The attendant shall order the entrants to exit the space if the attendant must leave and there is no replacement.
  5. Warn unauthorized persons not to enter or to exit immediately if they have entered and to advise the authorized entrants as well as others required by the University.

8.0 Duties of the Person Authorizing or in Charge of Entry.

The person authorizing or in charge of entry shall:

  1. Assure that the pre-entry portions of the permit are completed before any employee enters a permit entry confined space.
  2. Verify that the necessary pre-entry conditions exist (does not need to personally conduct tests).
  3. Verify that the means for summoning the rescue team or other emergency assistance are operable.
  4. Terminate the entry upon becoming aware of an unpermitted condition.

9.0 Equipment

9.1 Departments with employees who may enter a confined space shall purchase or otherwise make available all equipment and supplies necessary for compliance with this procedure.

9.2 Departments shall maintain equipment in accordance with the manufacturer's specifications.

10.0 Entry into Non-Permit Required Confined Spaces

All confined spaces are permit-required confined spaces unless reclassified by the Department of Environmental Health & Safety. Entry into non-permit required confined spaces does not require an attendant.

  1. Elevator Pits
    1. Elevator pits five feet or less in depth may be considered for reclassification to a non-permit required confined space. All elevator pits greater than five feet in depth are permit required spaces.
    2. Elevator pit entry procedures for routine inspection and maintenance (i.e., no car movement and no hazardous work) are listed below.
      1. Notify Operations Center at x1141
      2. De-energize electricity in cars
      3. Erect barricade across opening to pit
      4. Remotely test atmosphere and document readings
      5. Make entry wearing test meter and two way radio
      6. 6. Notify Operations Center when work is completed
    3. Entry into pits greater than five feet deep or entry into any pit with car movement, hot work, or work reasonably anticipated to create additional safety hazards are considered permit required spaces.
    4. All training requirements apply to entrants into both categories of confined spaces.

11.0 Contractors

11.1 University Requirements

When the University arranges to have employees of another company (contractor) perform work that involves permit required confined space entry, the assigned University employee shall:

  1. Inform the contractor that the workplace contains confined spaces and that entry is allowed only through compliance with the University's Confined Space Program.
  2. Provide copies of these procedures and a University of Delaware Confined Space Permit.
  3. Apprise the contractor of the elements that make the space in question a permit required confined space, including potential hazards and the University's experience with the space.
  4. Apprise the contractor of any precautions or procedures that the University has implemented for the protection of employees in or near permit required confined spaces where contractor personnel will be working.
  5. Coordinate entry operations with the contractor, when both University and contractor personnel will be working in or near permit required confined spaces to protect both groups of employees.
  6. Debrief the contractor at the conclusion of the entry operations regarding the Confined Space Program followed and regarding any hazards confronted or created in these spaces during entry operations.

11.2 Contractor Requirements

In addition to complying with the confined space requirements that apply to all employees, each contractor who is retained to perform confined space entry operations shall:

  1. Prior to entry into a confined space, demonstrate to the University that the Contractor has an active Confined Space Permit Entry program that meets minimum OSHA requirements.
  2. Obtain any available information regarding confined space hazards and entry operations from the host employer.
  3. Inform host employer of any hazards confronted or created in confined spaces through a debriefing or during the entry operation. Provide a copy of the contractor company’s Confined Space Procedures to the University prior to commencement of work.
  4. Notify the Department of Environmental Health and Safety when employees enter a confined space and when all employees have exited the confined space for the day.

12.0 Placarding

All identified confined spaces shall be placarded with a sign reading:

"Danger-Confined Space, DO NOT ENTER"
Contact Operations Center at 831-1141 or
Environmental Health & Safety at 831-8475

Questions regarding confined space entry procedures should be addressed to EHS (x8475)