Confined Space Entry

Purpose

A confined space, by legal definition, is a space that meets all of the following conditions: is large enough for a person to fully enter and perform work, has a limited means of entry or exit and is not designed or equipped for continuous occupancy.

A permit required confined space is one that has one or more of the following hazards or characteristics:

Contains or has a potential for a hazardous atmosphere
Contains a material that could drown or cover an entrant
Has an internal configuration that could trap or asphyxiate an entrant by inwardly converging walls of a floor that slopes downward to a smaller cross section
Contains any physical hazard, including engulfment, electrical shock, or moving parts
Contains any other recognized serious safety or health hazard

Confined spaces with these hazards can cause serious injuries or death for the entrant and people who may try to rescue the entrant. Rescuers who are not trained to recognize potential confined space hazards commonly succumb to the same hazard upon entry, such as a deadly atmosphere.

The Confined Space program is designed to provide specific directions to our employees while ensuring a safe workplace free from recognized hazards. This program identifies management and employee responsibilities to reduce risk of exposure to hazards associated with Confined Space Entry that may result in severe injury and/or loss of life.

Applicability

The Confined Space Entry Program applies to all District employees working under the scope and application of WAC 296-45 and WAC 296-809 performing any confined space entry with the exception of URD (Underground Residential Distribution) enclosed space entry procedures apply. It is mandatory that employees enter a confined space only after they have been trained, the space has been evaluated, a confined space entry permit or alternate method documentation has been completed, and all other safety and health considerations have been met.

Responsibility and Communication

Each department that has employees who enter confined spaces must develop a written document, identifying all of the confined spaces. They must determine if the confined spaces have hazards that make them permit spaces. Required entry procedures must be specified and followed. Entry into undocumented confined spaces must follow the permit-required confined space procedure in this section.

Management Responsibilities

Implement this program within their scope of responsibility.
Conduct workplace safety assessments to identify and categorize all confined spaces under their control.
Ensure that employees are trained on confined space entry.
Ensure that employees actively participate in confined space rescue training on an annual basis.
Retain confined space entry permits for a minimum of 2 years.
Ensure “confined space entry permit” or “alternate method documentation form” is complete.
Document locations in GIS that have been flagged as hazardous. For example, spaces that have been identified as containing elevated levels of hydrogen sulfide (H2S) should be marked.
Managers must maintain the log of confined spaces within their department.
Certify employee proficiency by making sure the certification contains each employee’s name, the trainer’s written or electronic signature or initials, and the dates of training. It must be available for inspection by employees and their authorized representatives.

Worker Responsibilities

Identify, document, and discuss roles and responsibilities for attendants, entrants, and rescue personnel.
Utilize stop work authority if conditions change that create a hazard.
Ensure that rescue provisions are discussed and established prior to entry.
Notify safety and management when deficiencies in entry procedures are identified.
Stay up to date on required training.

Safety Department Responsibilities

Program administration to include audit, permits, log of spaces, inspection, program development and management implementation.
Assist the affected departments with the selection of gas monitors, rescue equipment and additional PPE, as necessary.
Review and revise the program on an annual basis.
Assist departments in evaluating spaces
Monitor and communicate compliance updates

Engineering Department Responsibilities

Ensure confined space requirements are identified and addressed when designing equipment or facilities to ensure that adequate access and rescue provisions are in place.
Assist departments in incorporating rescue anchorages at existing confined spaces.

Identification and Determination of Permit Required Confined Spaces

Initial evaluation and designation of permit spaces and work procedures shall be performed by the department manager and assisted by the Safety Department, as needed. Prior to working in a confined space, a confined space evaluation and hazard analysis form must be completed.

Where feasible, permit spaces must have a label or sign affixed at a conspicuous location near all access points. The wording, “DANGER – PERMIT REQUIRED CONFINED SPACE, DO NOT ENTER”, or similar wording will satisfy this requirement. If signage is not feasible, effective training must be given to employees who may potentially enter these spaces.

Confined Space Entry Procedure

Prior to entering a confined space:

Complete the linked confined space entry permit and post on site.
Review the following responsibilities and permit entry procedures for entry the supervisor, entrant(s), and attendant(s) prior to entering the permit entry confined space.
Conduct and document tailboard.

Entry Supervisor has the overall responsibility for safe entry into the confined space.

Ensure the entry permit contains the necessary information before authorizing entry.
Verify that only persons trained in confined space work enter the space.
Verify attendants have current first-aid cards.
Ensure where applicable, harnesses, lifelines, and a retrieval system are used.
Ensure use of air monitoring equipment, communications, and outside attendants.
Ensure air is monitored for oxygen content, flammable or combustible gases or vapors, and toxic gases or vapors.
Ensure entrants and their representative(s) have an opportunity to review air monitoring and hazard controls.
Ensure approved fall-protection equipment is used if a fall hazard of four (4) feet or more exists.
Ensure special protective clothing (i.e., boots, gloves, pants, eye/face protection) is used where spaces contain hazardous chemicals or substances due to spills and/or leaks.
Ensure the necessary procedures, practices, and equipment for safe entry are in effect before allowing entry.
Ensure all energy sources are properly isolated before entry (view the Lockout/Tagout (LOTO) section of this APM for more information.)
Ensure all entrances to a confined space are posted and entry is controlled by an attendant.
Ensure the space is returned to operational status when the work is complete.
Identify fire hazards.
Authorize hot work.
Ensure fire protection for hot work.
Ensure continuous ventilation during hot work.
Ensure entry and hot work permits are saved for two years.

Entry Attendant is the designated individual stationed outside the permit confined space who is trained as required and who monitors the authorized entrants inside the permit confined space. They control access into the space, continuously monitor atmospheric conditions, hazards, and entrants. They have the authority to order all entrants out of the confined space if hazards are suspected. The Attendant may also be the Entry Supervisor.

The Attendant must:

Monitor only one confined space, (may do other tasks as long as they can monitor space and communicate with entrants).
Control access into the space
Set up and maintain signs and/ or barriers around the opening as needed.
Log and monitor entrants.
Continuously monitor atmospheric conditions and keep an hourly log.
Monitor ventilating equipment.
Monitor for hazards that may develop inside the confined space.
Watch for hazards outside the confined space that may endanger entrants.
Maintain direct communication with entrants.
Maintain rescue equipment.
Summon emergency responders when necessary.
Assist in entrant rescue without entering the confined space.

Confined Space Entrants must:

Understand the entry requirements being worked in and voice any concerns prior to entry.
Be able to recognize the presence of specific hazards that may be encountered in the confined space.
Understand the use and application of the rescue equipment, procedures and be capable of executing the rescue plan.

Hot Work Permits must be initiated, completed, and signed by the entry supervisor and will be issued when the following conditions are met:

Link to Hot Work Permit.
Continuous ventilation and/or appropriate respiratory equipment is provided where the nature of the hot work creates a potential for toxic or oxygen-deficient atmosphere.
Work may create a fire hazard inside the confined space must be protected by appropriate fire extinguishing equipment. Consideration must be given to hazards that fire extinguishers may create inside a confined space such as oxygen deficiency from CO2 and toxicity from dry chemical.

Alternative Methods

A permit-required confined space may be entered without a permit using alternative methods when monitoring and inspection data supports the following:

All hazards have been eliminated: or

All physical hazards have been eliminated, and continuous forced air ventilation controls the actual or potential hazardous atmospheres.

Alternative method procedures may only be authorized for a maximum of one work shift. A new authorization must be made for each work shift. An alternate entry form must be completed.

If activities occurring in the confined space introduce atmospheric hazards, they must be carefully assessed to ensure no hazard will occur. Some examples of these activities are painting, sand blasting, welding, or the use of solvents. Work must stop until the space is reauthorized for entry.

Air Monitoring

Air monitoring must be performed by trained and competent personnel prior to and during entry to any confined space.

The permit-required confined space or alternate entry forms in this document shall be used to record initial and subsequent supplemental air monitoring results. A longer atmospheric check log can be found here.

Atmospheric testing shall be performed in the following order:

Oxygen (02-19.5% to 23.5%)
Flammability (<410% LEL)
Carbon monoxide (CO <35ppm)
Hydrogen sulfide (H2S < 10ppm)

Readings shall be allowed to stabilized long enough to account for response time of instrument and length of sample tube.

Pre-entry testing must be performed before removal of the lid, if possible, before any ventilation to assess if a hazardous atmosphere exists. Stratification or inaccessible areas must be taken into consideration. If entry is required to assess atmosphere, a full permit-confined space entry is required with extreme caution.

Testing records must be retained for at least two years and audited during the annual program review.

Site calibration and visual inspection of the air monitoring equipment shall be according to the manufacturer’s direction on the same day just prior to use. Additional daily calibration or bump tests with calibration gas may be needed or appropriate.

Training

All employees who access or supervise employees who enter confined spaces must be trained and certified to a level of proficiency to ensure that they can execute the provisions of the confined space entry program and comply with additional requirements in WAC 296-809. Certification must include the employee’s name, the trainer’s written or electronic signature or initials, and the dates of training entered into Employee Central.

Training shall be provided:

Before an employee is assigned to duties under this policy
When new or revised procedures are introduced
When there is a change in confined space operation that presents a hazard for which the employee has not been trained
When deviations from procedures or inadequacies in the program have been identified
Before there is a change in an employee’s assigned duties

Retrain employees if there are either:

Deviations from your procedures for permit-required confined space entry; or
Employee knowledge or use of your procedures is inadequate

Training must include the following:

Roles and responsibilities
Hazards of a confined space
Procedures to protect employees from stored energy.
Use and care of test equipment such as 4-gas meters, including the logging procedure for entrants.
Hands-on use and care of rescue equipment, including demonstration of proficiency.
Dangers of unauthorized entry and rescue.
Department and/or location specific emergency response protocol

Definitions:

Enclosed Space: This section applies to routine entry into enclosed spaces in lieu of the permit-space entry requirements contained in chapter 296-809 WAC. If, after the employer takes the precautions given in WAC 296-45-205, 296-45-215, and 296-45-225, the hazards remaining in the enclosed space endanger the life of an entrant or could interfere with an entrant’s escape from the space, then entry into the enclosed space must meet the permit-space entry requirements of chapter WAC 296-809.

Attendant: An employee with first-aid training that is immediately available outside the enclosed space to monitor activity and available to provide assistance.

Entry: The action where any part of a person’s body breaks the plane (passes through an opening) into a confined space. Entry occurs as soon as any part of the entrant’s body breaks the plane of the opening into the space whether or not such action is intentional, or any work activities are actually performed in the space.

Hazardous atmosphere: An atmosphere that may expose employees to the risk of death, incapacitation, impair their ability to self-rescue (escape unaided from a permit-required confined space), injury, or acute illness caused by one or more of the following:

Flammable gas, vapor, or mist in excess of ten percent of its lower flammable limit (LFL) or lower explosive limit (LEL).
Airborne combustible dust at a concentration that meets or exceeds its LFL. The concentration may be approximated as a condition in which the dust obscures vision at a distance of five feet or less.
Atmospheric oxygen concentration below 19.5 percent or above 23.5 percent
Atmospheric concentration of any substance which may exceed a permissible exposure limit. (PEL)
Any other atmospheric condition that is immediately dangerous to life or health.

Emergencies

You must make sure you have adequate rescue and emergency services available during your permit-required confined space entry operations in accordance to WAC 296-809-50014.

Use nonentry rescue systems or methods whenever possible.

You must use nonentry retrieval systems or methods to rescue entrants in a permit-required confined space unless this would increase the overall risk of the injury to the entrants or it would not contribute to the rescue of the entrant.

You must make sure each entrant uses a chest or full-body harness, with a retrieval line attached to the harness at one of the following locations:

At the center of the employee’s back, near shoulder level
Above the employee's head
At another point which presents a profile small enough for the successful removal of the employee

You must attach the retrieval line to a mechanical device or fixed point outside the space, so rescue can begin as soon as necessary.

You must make sure a mechanical device is available to retrieve entrants from vertical spaces more than five feet deep.

Contractors

This section outlines how the District coordinates confined space entries involving contractors, in compliance with WAC 296-809

Pre-Entry Coordination Meeting:

Before any contractor or subcontractor enters a permit-required confined space on site, Our Project Manager or site Manager must hold a pre-entry coordination meeting with the contractor’s competent person or entry supervisor. This meeting will cover:

Review of specific confined space hazards and our experience with the space.
Discussion of the work to be performed and potential new hazards.
Definition of roles and responsibilities (Entry Supervisor, Attendant, Authorized Entrants).
Agreement on the entry permit to be used, typically a single comprehensive permit.
Rescue and emergency plan, including rescue service availability and communication.
Entry-specific procedures including atmospheric testing, PPE, and isolation steps.

Communication During Entry

Effective communication must be maintained at all times. Entrants and attendants will use a common communication system (e.g., radios, hand signals). The entry permit will list communication procedures. Communication checks will be conducted before and during entry.

Contractor Training & Documentation Requirements

Contractors must provide proof of training for all employees involved in confined space entry. Documentation must include:

Names of trained employees
Dates of training
Trainer’s name and signature
Confirmation of proficiency in confined space duties

Training must meet WAC 296-809 and be in a language and vocabulary the worker understands.

Permit, Hazard Exchange, and Responsibilities

Entry Permit Completion: A single permit will be completed and signed before entry, listing all entrants and roles.
Hazard Information Exchange: We will provide all known hazards and precautions. Contractors must share any new hazards introduced.
District Responsibilities: Authorize and supervise entry, coordinate operations, provide site-specific safety requirements, ensure rescue arrangements, and conduct post-entry debrief.
Contractor Responsibilities: Follow a permit space program, obtain hazard info, coordinate with others, provide trained personnel and equipment, and inform the host of procedures and hazards.
Multi-Employer Permit Signing: A qualified Entry Supervisor will sign and manage the permit. Canceled permits will be retained for at least one year.

Post-Entry Debriefing and Program Review

After entry, a debrief will be conducted to review the entry process, hazards encountered, and any lessons learned. Both host and contractor will use this information to improve their confined space programs.

Links

Confined Space Evaluation Form

Confined Space Entry Permit

Alternate Entry Form

Atmospheric Check Log

Hot Work Entry Permit