Confined Space Entry Plan
© 2018 Resource Training & Solutions
Written Program - St. Cloud Public Schools Confined Space Management Plan
Regulation - OSHA Regulation - 29 C F R 1910.146
Confined Space Inventory - Inventory of Permit Required and Non-Permit Required Spaces
Contractor Relations - Form to be completed anytime an outside Contractor's work requires entry into a Confined Space
Confined Space Entry Permit - To be completed anytime entry into a Permit Required Space is necessary
Annual Checklist - To be completed annually when the program is reviewed
Confined Space Assessment Form
Permit-Required Confined Space Decision Flow Chart
When completing any of the forms in the plan, make a copy of the original to use and file all completed forms in the binder under the corresponding tab.
Confined spaces in the workplace are considered dangerous places for employees to enter. Often times these areas are so dangerous that they may cause injuries or even multiple deaths due to asphyxiation or other hazards that are invisible to the naked eye. Often times these deaths and injuries could have been prevented by following the proper safety procedures before entering confined spaces.
The purpose of this written program is to prevent hazardous situations from occurring and to protect the health and safety of employees who may enter confined spaces and/or are assigned to serve as attendants or rescue personnel for entry into confined spaces.
Confined spaces meet all of the following conditions: the space is large enough to bodily enter and perform work, the space has limited means of entry and egress, and the space is not designed for continuous worker occupancy. A confined space may require a permit if the space contains or has the potential to contain a hazardous atmosphere, contains a material that has the potential to engulf an entrant, has a hazardous internal configuration, or contains any other recognized serious safety or health hazard.
Plan Review and Updated Report
Confined Space Entry Management Plan Update Report
Program review and changes are documented below. Documented reviews indicate that the plan continues to meet the needs of the District, or has been modified to do so more effectively.
Date Updates/Notes Reviewer 4-1-16 Wayne Warzecha 5/11/16 Removed Roosevelt confined old space assessments 5/12/16 Added confined space assessment form
Added permit required confined space decision flow chart
4/23/21 Updated contact information Wayne Warzecha 4/23/21 Updated Emergency Service Confined Space Rescue Wayne Warzecha 4/23/21 Updated Confined Space Inventory Documents Wayne Warzecha 10/05/22 Removed contact person and old Tech inventory Wayne Warzecha 1/31/23 Removed Boiler Permits under Record Keeping Wayne Warzecha
Authority and Reference
Occupational Safety and Health Administration (OSHA) Confined Spaces, 29 CFR 1910.146.
Confined Space Entry Supervisors
Each building Head Engineer has been selected and trained as a Confined Space Entry Supervisors. The responsibilities of these individuals are as follows:
- Know the hazards that may be encountered during entry and informing the entrants about the hazards, including information on the mode, signs, or symptoms and consequences of exposure.
- Verify that the proper atmospheric tests have been conducted and that all procedures and equipment are in place before signing the confined space entry permit.
- Verify that the confined space entry permit is completed prior to each entry.
- Terminate the entry and cancel the permit when needed. Inform the Health and Safety Supervisor of the cancellation and reasons for cancellation.
- Verify that the means for summoning emergency personnel are available and operable in the event that an emergency occurs.
- Remove unauthorized individuals who have entered or who attempted to enter the confined space.
- Provide employees an opportunity to observe the atmospheric testing of a confined space.
Confined Space Authorized Entrants
Head Engineers, Assistant Engineers, and Maintenance Personnel have been designated and trained as Authorized Entrants for confined spaces in the St. Cloud School District. The responsibilities of these individuals are as follows:
- Know and recognize the hazards that may be faced during entry, including modes, signs or symptoms, and consequences of exposure.
- Use and maintain proper PPE and other equipment needed as outlined by the confined space management plan.
- Communicate with the attendant as necessary.
- Alert the attendant when hazardous conditions are detected, identified, or suspected.
- Exit the confined space immediately when:Ordered to do so by other attendants, the confined space entry supervisor, or the identified contact person.
- Warning signs or symptoms are identified while in the area.
- Prohibited conditions exist or are identified by the entrant during work done in the area.
- An evacuation alarm on the four-gas meter is activated.
- As other conditions dictate.
- Comply with all other aspects of the Confined Space Entry Program.
Confined Space Attendants
Head Engineers, Assistant Engineers and Maintenance Personnel have been selected and trained by the St. Cloud School District to be attendants for confined space entry. All authorized attendants will be responsible for the following:
- Know the hazards that may be faced during entry, including modes, signs, or symptoms, and consequences of the exposure.
- Know behavioral effects of potential hazard exposures.
- Maintain an accurate count of authorized entrants.
- Remain outside the confined space during entry operations until relieved by another attendant.
- Communicate with authorized entrants as necessary to monitor entrant status and to alert entrants of the need to evacuate confined spaces in emergency situations.
- Monitor activities inside and outside the confined space to determine if it is safe for authorized entrants to remain in the space and order the authorized entrants to evacuate the space immediately under any of the following condition:
- If the attendant detects a prohibited condition.
- If the attendant detects an effect of a hazard exposure in an authorized entrant.
- If the attendant detects a situation outside the confined space that could endanger the authorized entrants; or
- If the attendant cannot effectively and safely perform all duties required.
- Summon rescue and emergency personnel as soon as the attendant determines that entrants need assistance to escape from confined space hazards.
- Take the following actions when an unauthorized person(s) approach or enter a confined space while entry is underway:
- Warn the unauthorized person(s) that they must stay away from the confined space.
- Advise the unauthorized person(s) that they must exit immediately if they have entered the confined space.
- Inform the authorized entrants and the entry supervisor if an unauthorized person(s) has entered the confined spaces.
- Postpone duties that might interfere with the attendant's primary duty to monitor and protect the authorized entrants.
All employees mentioned above who are required to enter a confined space or serve as an attendant are trained and properly equipped to recognize, understand, and control hazards that may be encountered during confined space entry. All training is documented and available for inspection by employees or other personnel.
- All employees who are required to enter a confined space or serve as attendants receive training in the following areas:
- Associated safety and health hazards of Confined Space Entry.
- Duties of entrants and attendants.
- Air monitoring.
- Respiratory protection.
- Emergency rescue procedures.
- Lockout isolation procedures.
- Training is provided to each affected employee:
- Before the employee is first assigned to Confined Space Entry duties.
- Before there is a change in assigned duties.
- Whenever there is change in confined space operations that presents a hazard about which the employee has been previously trained.
- All employees who are required to enter a confined space and/or serve as attendants will receive training on the proper use of any PPE needed to perform the job safely. This includes protective clothing and suits, gloves, respiratory protection, confined space rescue equipment, body harnesses, hearing protection, and eye/face, hand, foot, and head protection.
Identification of Confined Space
The St. Cloud School District has identified all confined spaces by sign, placard, or symbols. These means of warning for the identification of confined spaces are printed in English, reading one of (but not necessarily limited to) the following:
CAUTION: NON-PERMIT REQUIRED CONFINED SPACE
CAUTION: PERMIT REQUIRED CONFINED SPACE - DO NOT ENTER UNLESS AUTHORIZED
The following statements will be added in large letters to the warning sign when a specific work practice must be performed or when specific safety equipment is necessary:
- Respirator Required For Entry
- Lifeline Required for Entry
- Hot Work Permit-Required
- No Hot Work Permitted
Workplace Confined Space Evaluations and Reclassification
The District Health and Safety Supervisor is responsible for coordinating/conducting an evaluation of the school district to determine if confined spaces are present. A detailed assessment of these findings, including the location of each space, a brief description of the space, actual or potential health and safety hazards, and classification of the space (permit required or non-permit required) is located in the Confined Space Inventory tab of this management plan.
When there are changes in the use of a Non-Permit Confined Space that may introduce new hazards, the space shall be re-evaluated and classified as a permit-required confined space where necessary.
Reclassification would be required for application of solvents, paint chemicals, or other material that could potentially create a hazardous atmosphere in a confined space, and while performing welding, cutting, brazing, or soldering in those confined spaces with limited or no ventilation. Reclassification is documented and maintained with the Confined Space Management Plan.
Entry Procedures for Permit Required Confined Spaces
The following is a detailed outline of the procedures to be taken prior to any entry of a permit-required confined space. All steps must be followed to ensure proper entry into such areas.
- Health and Safety Supervisor is notified prior to the entry of a permit required confined space.
- Only properly trained and authorized individuals are allowed to enter a permit-required confined space. All entrants maintain contact with an attendant through the use of two-way communication.
- The Confined Space Entry Permit is properly completed and signed by The Confined Space Entry Supervisor prior to entry. The permit contains the following information:
- The names of the individuals entering the permit-required confined space.
- The date and time of entry.
- The expiration date of the permit.
- The results of atmospheric testing.
- Date and signature of confined space entry supervisor
- Prior to entry, the confined space is tested for oxygen content, flammable gases and potential toxic air contaminants by a properly trained individual. High, middle and low points of the area are tested to properly determine if the area is safe for entry. Sampling procedures are listed below:
- The oxygen level is between 19.5% and 23.5%.
- The level of carbon monoxide (CO) is less than 35 ppm.
- The level of airborne hydrogen sulfide (H2S) is below 10 parts per million (ppm).
- The concentrations of flammable gas, vapors, or mists, are below 10% of their lower flammability limits (LFL).
- The concentration of airborne combustible dust does not exceed 10% of the lower flammability limit (LFL). Note: An indication of this condition is if the dust obscures vision at a distance of 5 feet.
- Toxic air contaminants are less than the OSHA Permissible Exposure Limit (PEL) Note: If the substance does not have a PEL, the Threshold Limit Value (TLV) established by the American Conference of Governmental Industrial Hygienists (ACGIH) shall be used.
- Atmospheric concentrations of all toxic substances known to be present in the confined space are below what is considered as Immediately Dangerous to Life and Health (IDLH).
- The sampling device used is a four-gas meter that can simultaneously test for oxygen, hydrogen sulfide, carbon monoxide, and combustible gas without manually switching.
- Calibration of all sampling equipment is relative to the oxygen content of the ambient air at the time of sampling. Calibration of the sampling device relative to the oxygen content shall be performed where the 20.9% natural content of oxygen in the air is most likely to occur. Note: Calibration of this equipment should not be performed near a confined space opening.
- When sampling, the following levels must be obtained:
- Results of this test shall be posted outside the confined space on the Confined Space Entry Permit. If any of these atmospheric conditions are not met, entry into the confined space is not allowed.
- In order to allow entry and maintain a safe atmosphere, one or more of the following actions need to be taken to render the space safe for human occupancy:
- Isolation —Precautions taken to prevent release of material and/or energy into the space. This can be achieved through blinding, blanking, disconnecting, lockout/tagout, or removal of incoming pipes or related energy sources.
- Ventilation—Purging, flushing, or otherwise ventilating the space with fresh air. The replacement air will displace the contaminated air allowing for safe entry. This can be accomplished by removing ports and openings or by mechanically ventilating the vessel.
- Separation—Where there is a possibility of external hazards, the space may require barricades to protect the entrants from falling objects or from unauthorized entry.
- Personal protective equipment, including respirators, is provided to entrants as necessary for safe entry into the confined space and shall be used properly.
- The District's Health and Safety Supervisor must approve all PPE.
- Respirators shall be used in accordance with the Respiratory Protection Standard, 29 CFR 1910.134.
- Employees of St. Cloud School District are prohibited from entering confined spaces with unknown atmospheres. A Rescue Team or Emergency Personnel with self-contained breathing apparatus (SCBA) must be present on-site and immediately available if entry is into an atmosphere that is actually or potentially immediately dangerous to life or health.
- Electrical equipment used in confined spaces shall be appropriate for the hazard and meet the requirements of the National Electric Code if a hazardous atmosphere is present.
- Any condition making removal of an entrance cover unsafe (i.e. pressure differential or physical obstacles) shall be eliminated before the cover is removed. When the cover has been removed, the opening(s) shall be promptly guarded to prevent an accidental fall into the opening and prevent objects from falling into the opening.
- Where applicable, appropriate vehicle and pedestrian barriers are used to protect workers.
- Metal ladders are not to be used under any circumstances in permit-required confined spaces.
- Any use of chemicals or welding, soldering, or cutting operations must be pre-approved by the confined space entry supervisor prior to entry.
- Contractors who send their employees into confined spaces will inform all entrants of the potential hazards, safety rules, and emergency procedures in effect with the school district. In cases where contractors decide to use their own confined space program, a copy of the program shall be made available to the school district upon request for approval. A copy of the school district's Confined Space Program will also be made available to contractors or any outside person(s) upon his/her request. All contractors and employees of the school district are expected to fully comply with the safety and health procedures listed in 29 C F R 1910.146.
If a hazardous atmosphere is detected during entry into a permit-required confined space, each employee shall leave the space immediately, the space shall be evaluated to determine how the hazardous atmosphere developed, and measures shall be implemented to protect employees from the hazardous atmosphere before any subsequent entry takes place.
Safety Rules and Work Practices for Permit-Required Confined Spaces
In order to protect the safety and health of all employees associated with permit-required confined space entry, employees (and supervisors) will comply with the following safety rules and work practices:
- All employees entering a confined space shall follow the outlined entry procedures for all permit required confined spaces. No employee shall enter or work in a permit required confined space without following the guidelines outlined above.
- Employees must obtain permission to enter the confined space from the confined space entry supervisor.
- Employees must conduct continuous air monitoring of the atmosphere within the confined space in the entrant's immediate work area.
- Employees obtain and use the proper PPE, tools and emergency rescue equipment.
- Employees never enter a confined space without at least one attendant present with the same level of PPE and respiratory protection.
- The employee immediately exits the confined space in the event that the attendant must leave his/her post.
- All employees within the confined space and those employees assigned to serve as attendants shall be in constant two-way communication.
- All employees required to wear respiratory protection must properly use and maintain the respirator in accordance with 29 CFR 1910.134 and the specific instructions provided to them by their supervisor during training.
- Smoking is not permitted within the confined space or within a 10-foot radius of the entrance of the confined space.
- All employees shall comply with the requirements and limitations on the confined space entry permit, including the maximum number of employees permitted to work in the confined space.
Safety Rules and Work Practices for Non-Permit-Required Confined Spaces
In order to protect the safety and health of all employees associated with non-permit-required confined space entry, employees (and supervisors) will obtain and use the proper PPE, tools and other equipment necessary to perform the job. Atmospheric testing of a non-permit-required confined space is not required by OSHA's Confined Space Entry Standard. However, testing the atmosphere for toxic gases and oxygen deficiency prior to entering the confined space is recommended if a properly calibrated four-gas meter is available. The OSHA standard does not require an attendant for entry into a non-permit required confined space; however, St. Cloud School District employees will inform other personnel when entering and exiting a non-permit required confined space and will utilize two-way radios as appropriate. Other OSHA standards (i.e. Personal Protective and Respiratory Protection) still apply to entry into all confined spaces.
Safety Rules and Work Practices for Boilers and Other Vessels
Before any employee may enter a boiler or any other type of vessel classified as a confined space, the following safety precautions will be implemented:
- Ensure that the interior temperature of the confined space closely equals the ambient temperature outside that space before an entry is made into any confined space subjected to extreme hot or cold temperatures.
- Ensure that all hazardous materials (solids and liquids) inside the work area are removed from the vessel before entry is allowed.
- Ensure that all lines leading into and away from the vessel are blanked, blinded, and/or double blocked and bled before entry is allowed.
- Treat all boilers and other vessel-type confined space in a manner consistent with that of other confined spaces.
Ventilation of Confined Spaces
If a confined space is found to contain a hazardous atmosphere, forced air ventilation may be provided for a period of time in order to bring the air quality within acceptable limits. Once the determined ventilation period expires, employees shall monitor the confined space. If sampling shows that a hazard still exists, additional ventilation, and sampling may be required.
If the hazard still exists after repeated ventilation steps, the confined space shall then be considered a permit-required confined space and employees will not be allowed to enter. Note: Forced air ventilation may not be used in lieu of monitoring. Consideration must also be given to the possibility of static discharge that could be a source of ignition.
Whenever ventilation is used, employees shall:
- Keep the blower controls at least ten feet from the confined space, and out of the wind or downwind from the entrance of the confined space.
- Use a ventilation blower that is designed to be intrinsically safe if the possibility of an explosive atmosphere could exist.
- Verify that the exhaust systems are designed and placed so that they protect employees in the surrounding area from being contaminated.
- Verify that the ventilation system is fully operational.
- Take measures to prevent contaminated air from being that contaminated air is not re-circulated into the confined space.
- Purge the ventilation hose outlet for at least one-minute (at street level if possible) before inserting the hose into the confined space.
- Maintain continuous local ventilation when toxic atmospheres are being produced as part of a work procedure (i.e. welding, painting or cleaning operations).
Equipment and Confined Spaces
When a confined space entry requires the use of equipment and tools inside the space, this equipment shall be inspected and must meet the following requirements:
- All hand tools must be in good repair and kept clean.
- Portable electric tools, equipment, and lighting shall be listed Class I, Division I, and Group D. All grounds are to be checked and in good working condition prior to the use of electrical equipment in a confined space. Note: Ground fault protectors will be used whenever possible to protect employees from electrical shock when working in damp or wet locations.
- All electrical cords, tools, and equipment must be constructed of a heavy-duty, double insulated cord and equipped with a three-prong plug. No two prong plugs will be acceptable unless under special circumstances and approved by the Health and Safety Supervisor.
- All electrical cords, tools, and equipment must be visually inspected for defects before entering a confined space. Defects include cut or frayed cords, missing ground plugs, and taped cords. If equipment is found defective, it shall be removed, replaced and marked "Do Not Use - Out of Service" before any employee enters a confined space.
- It is prohibited to bring compressed gas cylinders into a confined space. The only exemption from this rule is the cylinders that are considered part of S C B A or resuscitation equipment.
- Ladders to be used in confined spaces will be constructed of plastic or fiberglass and must be adequately secured or of a permanent type which provides the same degree of safety. Permanent ladders used in confined spaces must be inspected for rust or corrosion and must be repaired or replaced if necessary.
- All equipment that may be used in a flammable atmosphere shall be approved as either explosion proof or intrinsically safe for the atmosphere and shall be approved by a recognized testing laboratory (i.e., U L , FM).
Assessment of Additional Hazards in Confined Spaces
Before entering a confined space, the Confined Space Entry Supervisor will conduct an assessment of any additional hazards that the entrant may encounter during a confined space entry. This assessment will include, but is not limited to, the following additional hazards:
Thermal Hazards—Hazards due to extremes in hot and cold temperatures.
Engulfment Hazards—Hazards from being overcome by material in a confined space (i.e. steam, gas, water, IDLH atmospheres).
Noise Hazards—Hazards that can affect hearing in emergency situations or two- way communications that may result directly to an injury suffered by an employee.
Slick/Wet Surfaces—Hazards that can increase the risks of slips, trips, or falls. These surfaces may also increase the risks and effects of shocks from electric tools, machinery, and/or circuitry.
Falling Objects—Hazards that exist from loose gravel, cement, tools, etc... that have the potential to cause harm on a worker in a confined space.
Mechanical Equipment—Hazards that may exist due to required machinery operating during an entry. Electrical Hazards—Hazards that may exist from exposed wiring, power lines, or other faulty equipment.
Fall Hazards—Hazards that may be caused due to loose gravel, exposed wiring, or equipment left in an open area.
Biological Hazards—Hazards that exist from any personal injury that may occur in a confined space.
Emergency Service Confined Space Rescue
In the event of a confined space rescue by using emergency services, the St. Cloud School District has complied with the following procedures:
- Evaluated prospective rescuer's ability to respond to a rescue summons in a timely manner, considering the hazard(s) identified.
- Evaluated prospective rescue service's ability, in terms of proficiency with rescue related tasks and equipment, to function appropriately while rescuing entrants from the particular permit space or types of permit space identified.
- Selected rescue teams or services that have the capacity to reach the victim(s) within a time frame that is appropriate for the permit space hazard(s) identified, and are equipped for and proficient in performing the needed rescue services.
- Informed rescue teams or services of the hazards they may confront when called on to perform rescue at the site.
- Provided rescue teams or services access to all permit spaces from which rescue may be necessary so that the rescue service can develop and implement appropriate rescue plans and practice rescue operations. Note: Appendix F of the OSHA 29 CFR 1910.146 Standard contains examples of criteria which employers can use in evaluating prospective rescuers. The area Fire Departments have agreed to work as rescue teams in the event of a confined space emergency. The fire departments and which schools they cover are as follows:
St. Cloud Fire Department
- Apollo High School
- District Service Building
- Lincoln Elementary
- Madison Elementary
- North Junior High
- Oak Hill Elementary
- Roosevelt Early Childhood
- South Junior High
- Talahi Elementary
- Technical High School
- Westwood Elementary
Waite Park Fire Department
- Discovery Elementary
- McKinley Center
Clear Lake Fire Department
- Clearview Elementary
In the event of an emergency, the school will dial 911. The call will be directed to the appropriate fire department. Each department has been trained on confined space procedures and retains a copy of the District confined space inventory. The fire departments rely on mutual aid in the event of an emergency that cannot be handled by one or more of the fire departments.
The following records will be maintained in relation to this program:
- Employee Training Records—this will include dates and names of attendees. These records will be held at least three years. Confined Space
- Entry Equipment Inspections—this should include dates, results, and corrective actions taken if necessary. These records shall be held for the lifetime use of the equipment.
- Monitoring Equipment Calibration/Service Reports—this will indicate the calibration dates and any service conducted by the manufacturer. These records should be maintained for the lifetime of the equipment.
- Confined Space Permits—this should include the names of the individuals entering the confined space, dates and time of entry, expiration date of the permit, results of the atmospheric testing, and the signature of the Confined Space Entry Supervisor. These records should be maintained for a period of one year.
Regulation: 29 CFR 1910.146
- 1910.146 App A - Permit-required Confined Space Decision Flow Chart
- 1910.146 App B - Procedures for Atmospheric Testing
- 1910.146 App C - Examples of Permit-required Confined Space Programs
- 1910.146 App D - Confined Space Pre-Entry Check List
- 1910.146 App E - Sewer System Entry
- 1910.146 App F - Non-Mandatory Appendix F -- Rescue Team or Rescue Service Evaluation Criteria
Confined Space Inventory
Click the name of a building to view/download the Confined Space Inventory
Roosevelt Early Childhood