Many workplaces contain areas that are considered “confined spaces” because while they are not necessarily designed for people, they are large enough for workers to enter and perform certain jobs. A confined space also has limited or restricted means for entry and is not designed for continuous occupancy. Confined spaces include, but are not limited to, tanks, vessels, storage bins, vaults, pits, manholes, tunnels, equipment housings, etc.
The Confined Space Program has been developed to protect all University employees and contractors from the serious hazards associated with entering and working within a confined space. As required by the Occupational Safety and Health Administration (OSHA) Standard 29 CFR 1910.146, Permit-Required Confined Spaces, this program establishes procedures to regulate entry into confined spaces, and to ensure the safety of the employees who enter or work in a confined space.
No confined space shall be entered until adequate precautions have been taken to ensure the safety of the employees entering the space and their surrounding work environment.
All spaces owned or operated by Western Carolina University (WCU) that meet the definition of a confined space shall be identified and appropriately marked, and access to such spaces shall be controlled.
Employees are prohibited from entering any space meeting the definition of permit required confined space, unless the flowing conditions are met:
The appropriate WCU department determines that employees must enter permit confined spaces to perform the mission of the department and/or duties of the employee.
The employees are trained in the entry duties under this program which they are to perform.
The space is rendered safe for entry by any of the following: Issuance and compliance with the conditions of the entry permit; The space is classified as a non-permit space; The space is a permit space reclassified as a non-permitted space prior to entry.
Confined Space Definitions
Confined space: A space that meets all three of the following conditions:
Large enough for a person to bodily enter and perform work.
Has only means of entry/egress that requires a person to enter by a means other than normal walking, such as crawling, squatting, climbing, bending, or use of devices.
Is not designed for people to continually occupy the space.
Non-Permit Space: A confined space that does not contain any actual or potential hazards capable of causing death or serious physical harm.
Permit Required Confined Space; Permit Space: A confined space which has one or more of the following characteristics:
Contains or has the potential to contain a hazardous atmosphere;
Contains a material that has the potential to engulf an entrant;
Has an internal configuration that could trap or asphyxiate an entrant, such as inwardly converging walls or a floor that slopes downward and tapers to a smaller cross-section; and/or
Contains any other recognized serious safety and/or health hazard.
Attendant: The trained individual stationed outside the permit space who monitors the authorized entrants and who performs all attendant duties.
Entrant: The trained individual who enters the permit space.
Entry Supervisor: The trained individual with the responsibility to:
Assure that acceptable entry conditions are present within the permit space under his/her jurisdiction.
Issue a permit authorizing entry.
Oversee entry operations.
Terminate the entry and permit.
Engulfment: The surrounding and effective capture of a person by a liquid or finely divided (flow-able) solid substance that can be aspirated to cause death by filling or plugging the respiratory system, or that can exert force on the body to cause death by strangulation, constriction, or crushing.
Hazardous atmosphere: an atmosphere that may expose employees to the risk of death, incapacitation, impairment of the ability to escape unaided from a permit space, injury, or acute illness. Hazardous atmospheres may be created by conditions such as, but not limited to:
Flammable gas, vapors, or mists in excess of ten percent of the lower flammable limit (LFL).
Airborne combustible dust at a concentration that:
Meets or exceeds its LFL.
Obscures vision at a distance of five feet or less
Atmosphere oxygen concentration below 19.5 percent or above 23.5 percent.
Atmospheric concentrations at or above the Permissible Limit (PEL) of substances identified in Subpart Z of 29 CFR 1910.
Any other atmospheric conditions which are immediately dangerous to life and health.
Immediately dangerous to life or health (IDLH): means any condition that poses an immediate or delayed threat to life or that would cause irreversible adverse health effects or that would interfere with an individual's ability to escape unaided from a permit space.
Hazard Control Definitions
Conditions of Entry: The conditions that must exist in a permit space to allow employees to safely enter and perform duties within the space.
Blanking, Binding: Absolute closure of a pipe, line, or duct by fastening a solid plate that completely covers the bore and that is capable of withstanding the maximum pressure of the pipe, line, or duct with no leakage beyond the plate.
Double Block and Bleed: The closure of a line, duct, or pipe by closing and locking/tagging out two in-line valves, and opening and locking/tagging out a drain or vent in the line between the two closed valves.
Inerting: The displacement of the atmosphere in a permit space by a noncombustible gas to such an extent that the resulting atmosphere is noncombustible, producing an IDLH oxygen-deficient atmosphere.
Isolation: The complete removal of a permit space from service and the complete protection of that space from the release of energy or material.
Line Breaking: The intentional opening of a pipe, line, or duct that is or has been carrying flammable, corrosive, or toxic material, an inert gas, or any fluid at a volume, pressure, or temperature capable of causing injury.
Alternate Entry Procedures: The use of continuous forced air ventilation and atmosphere monitoring in lieu of a permit to enter a permit required confined space that:
Has an actual or potential hazardous atmosphere that can be demonstrably controlled by continuous forced air ventilation alone.
Has no other hazards of any kind.
Emergency: Any occurrence (including the failure of hazard control or monitoring equipment) or event, internal or external to the permit space, which could endanger entrants.
Entry: The action of breaking the plane of an opening of a permit space with any part of the body.
Permit: The written or printed document authorizing entry into a permit space and designating the requirements for entry.
Prohibited Condition: Any condition in a permit space that is not allowed by the permit during the period when entry is authorized.
Testing: The process by which the hazards that may confront entrants are identified and evaluated. This term includes the specification of tests that are to be performed in the permit space.
Safety and Risk Management
Safety and Risk Management has the primary responsibility for the implementation and enforcement of the CSEP and is responsible for the following:
Develop the University’s written Confined Space Entry Program and update when necessary.
Provide guidance in the selection of air monitoring equipment, maintenance, field calibration, and training of its use.
Assist in the evaluation and identification of confined spaces.
Perform air monitoring or testing of confined space work.
Develop and assist with conducting confined space training.
Entry Supervisors are responsible for providing the necessary direction and support to ensure the effective implementation of the CSEP for their work areas. Entry supervisors are responsible for the overall permit space entry and must coordinate all entry procedures, tests, permits, and other required duties. Entry Supervisors are also responsible for the following:
Assure that all employees involved in the work are trained in accordance with 29 CFR 1910.146 Confined Spaces and other requirements.
Determine if acceptable entry conditions are present at a permit space where the entry is planned.
Inform Authorized Entrants and Attendants of the potential hazards associated with entering each space.
Sign-off on entry permit to allow employees to enter the confined space. Verify appropriate entries have been made on the permit, all tests specified by the permit have been conducted and that all procedures and equipment specified by the permit are in place before signing the permit.
Terminate the entry and cancel the permit when appropriate.
Coordinate confined space entry operations with contractor should work involve spaces owned or operated by WCU.
Verify rescue services are available and communication systems are functioning.
Remove unauthorized persons from work area who enter or attempt to enter the permitted space.
At least one attendant is required outside the permit space for the duration of the authorized entry operation. All attendants are required to have completed confined space training before they are allowed to serve as attendants. Attendants are responsible for the following:
Know the hazards that may be faced during entry of the confined space.
Perform no other duties beyond stated for Attendants.
Station themselves outside permit space at the opening to the space, and remain in place throughout the duration of the entry or until relieved by another authorized Attendant.
Continuously maintain an accurate count of entrants in the permit space and ensure a means to accurately identify authorized entrants.
Communicate with entrants frequently by voice or communication equipment to ensure all is well or when they need to evacuate.
Order an immediate evacuation of the space:
Upon becoming aware of the development of a sign or symptom of an exposure to a dangerous situation.
Upon becoming aware of the development of a condition that could endanger the entrants.
If the attendant cannot effectively and safety perform all the attendant responsibilities.
To summon rescue and other emergency services as soon as the attendant determines entrants need assistance to escape the permit confined space.
Warn unauthorized persons to stay away from the permit confined space. Do not allow unauthorized persons to enter the permit space. Inform the authorized entrants and the entry supervisor if unauthorized persons have entered the permitted space. Entry supervisor shall remove unauthorized persons from the permitted space.
Do not perform non-entry rescues as specified by the rescue procedures and the entry supervisor.
All entrants must be authorized by the entry supervisor to enter permit spaces, have received the required training, use the proper equipment, and observe the entry procedures and permit. Entrants are responsible for the following:
Know the hazards that may be encountered during entry.
Enter the space and perform the assigned work as expediently as possible.
Communicate with the attendant frequently or upon request to confirm all is well.
Immediately evacuate the space and alert the attendant or entry supervisor whenever any of the following occurs:
The development of a condition that causes a dangerous situation.
The development of a sign or symptom of exposure to a dangerous situation.
Failure of any required equipment to enter the permitted space.
Exit the permit space as quickly as possible whenever:
Attendant or entry supervisor gives an order to evacuate the permit space.
Entrant recognizes any warning sign or symptoms of a dangerous situation.
Entrant detects a prohibit condition not in compliance with the permit.
Failure of any required equipment to enter the permitted space.
Outside contractors may need to enter a permit space to perform work for the university. The Safety and Risk Management Office shall be informed when a contractor will be entering a WCU permitted confined space.
Contractors shall be informed that the space is a permit-required confined space and known hazards within the space.
Contractors must follow WCU Confined Space Entry Program per OSHA Standard 29 CFR 1910.146 and use an authorized permit for entry.
Require the contractor to eliminate any temporary hazards created by the work, or notify the supervisor
Contractors are responsible for the following:
Obtain and use the available information provided.
The entry supervisor shall notify any employees near or affected by entry.
If employees shall enter the space with contractor employees, the entry supervisor shall ensure that entry operations are coordinated with the contractor or designee to assure that:
All entrants of both employees can be accounted for during the entry.
The work of one employer does not endanger the employees of the second employer.
There is an attendant in place whenever employees of either employer have entered the space.
Debrief the contractor at the conclusion of the entry regarding the permit space program followed and any hazards confronted or created in the space during work.
The University has identified known permit required confined spaces. Please note that WCU does not allow the use of alternate procedures during permit space entry. Entry Supervisors are required to complete an entry permit for every permit required confined space and have the permit onsite for the duration of the entry. The following are examples of permit required confined spaces on campus:
Confined Space Reclassification
If a permit space poses no actual or potential atmospheric hazards and if all hazards within the space are eliminated without entry into the space, the permit space may be reclassified as non-permit confined space as long as the non-atmospheric conditions remain eliminated.
If it is necessary to enter the permit space to eliminate hazards, such entry shall be performed according to confined space entry procedures. If testing and inspection during that entry demonstrate that the hazards within the permit space have been eliminated, the permit space may be reclassified as a non-permit confined space as long as the hazards remain eliminated.
A certification is documented showing the hazards were eliminated. If the hazards arise within a permit space that has been declassified to a non-permit space, each employee must exit the space and the space is reevaluated to determine if it must be reclassified as a permit space.
Note: Control of the atmospheric hazards through forced air ventilation does not constitute elimination of the hazards.
Non-permit required confined spaces do not contain additional hazards such as the potential of a hazardous atmosphere or the potential for workers to become engulfed or trapped by materials. Entry into confined spaces that do not require a permit should be made with caution. The following are examples of non-permit confined spaces on campus:
Potentially Non-permit required:
Note: The locations of permit-required and non- permit required confined spaces are continuously under review.
When there are changes in the use and configuration of a non-permit confined space that might increase the hazards to entrants, the space is reevaluated and, if necessary, reclassified as a permit-required confined space. Any changes to a confined space should be communicated to the Safety and Risk Management Office.
The Safety and Risk Management Office and department supervisors shall perform a workplace risk assessment to identify confined spaces, the hazards in or around the spaces, and the potential for hazards to develop in or around the spaces. The assessment shall identify all known permit required confined spaces (PRCSs), along with all energy sources, moving equipment, and pipe inlets which must be controlled before entering the space.
Confined Space Hazards
Each supervisor shall evaluate the hazards of a confined space before allowing employees to enter. Supervisors shall identify the following, but not limited to, if present:
Atmospheric Hazards: oxygen depleted, toxic gases, or explosive
Physical Hazards: slip trip or fall, falling objects, moving parts of equipment or machinery, electrical shock, temperature extremes, crushing, pinching, or excessive noise.
Precautions must be taken to prevent creating hazardous, toxic, or explosive atmospheres while employees are within a confined space. The types of materials used while working in a confined space must be thoroughly evaluated. Testing the atmosphere inside the confined space is necessary before entering and during the time when work is being performed. The use of toxic or flammable chemicals or materials can change the atmospheric condition of a confined space after initial testing. When an atmosphere is changed, it can create a dangerous environment.
Examples of work which can create a potentially dangerous atmosphere:
Using chemical products (painting, cleaning with solvents, applying adhesives, etc.)
Mixing of incompatible chemicals
Identify Confined Spaces
Each confined space listed shall be designated as a non-permit or permit required space. The hazards of each permit required space shall be catalogued on the list. WCU supervisors are encouraged to contact the Safety and Risk Management Office for assistance with classifying confined spaces. Confined spaces shall be considered hazardous until an evaluation is completed.
Departments shall notify Safety and Risk Management if additional confined spaces are identified or if new ones are installed or created. For each newly identified space, a “Confined Space Hazard Evaluation Form” must be completed and sent to the Safety Office.
Safety and Risk Management will maintain a campus-wide list of known permit required confined spaces. The list shall be available to all supervisors and employees.
Elevator mechanical Spaces
Elevator mechanical spaces at WCU are generally considered confined spaces, but are not generally considered permit required confined spaces.
If a hazardous or potentially hazardous atmosphere exists (e.g. a chemical leak, spill, or welding) within or in close proximity to an elevator pit, the pit will be reclassified as a permit-required confined space for the duration of the event. Employees who enter the pit under these circumstances must perform operations in accordance with WCU Confined Space Entry Program
Acceptable Entry Conditions
Before a permit space that may have a hazardous atmosphere can be entered, the atmosphere must be tested using the steps identified on the permit (developed during evaluation testing). Verification testing is done to make sure that the chemical hazards that may be present are below the levels necessary for safe entry, and that they meet the conditions identified on the permit. Test the atmosphere in the following order: (1) for oxygen, (2) for combustible gases, and then (3) for toxic gases and vapors. The testing results, the actual test concentrations, must be recorded on the permit near the levels identified for safe entry.
The atmosphere will be considered unacceptable if the following conditions are present:
oxygen level is below 19.5%
oxygen level above 23.5%
flammable gas levels exceed 10% of the Lower Flammable Limit (LEL)
carbon monoxide levels above 25 ppm
hydrogen sulfide (H2s) above 10 ppm
Sulfur Dioxide (SO2) above 2 ppm
Before an employee enters the space, the internal atmosphere shall be tested, with a calibrated direct-reading instrument. Any employee who enters the space shall be provided an opportunity to observe the pre-entry testing. The atmosphere within the space shall be periodically tested as necessary to ensure the space is maintained within the limits of the acceptable entry conditions per OSHA standards.
Isolating the Permit Space
All hazardous energy sources associated with permit spaces which may expose entrants to potential injury are isolated, locked out and/or tagged out prior to entry:
Purging, Inerting, Flushing, or Ventilating Permit Spaces: All permit entry spaces are thoroughly purged, inerted, flushed, and ventilated as necessary to ensure the elimination and/or control of all hazards which may cause entrant injury and/or illness.
External Hazards: Pedestrian, vehicle, or other barriers are provided as necessary to protect entrants from external hazards.
Verifying Acceptable Conditions: Conditions in permit spaces are tested and monitored throughout entry as necessary to ensure that they are acceptable for the duration of the authorized entry.
Atmospheric testing is necessary to evaluate airborne hazards present in the permit space, and to verify that acceptable entry conditions are present.
Initial evaluation of the atmosphere of a confined space should be analyzed with a Safety Office approved instrument that is sensitive enough and designed to evaluate any hazardous atmospheres that may exist or arise. The results of the atmospheric testing will have a direct impact on the:
The Safety office should be called for assistance with the evaluation and interpretation of the data, and the development of the entry procedure.
Prior to entry, a PRCS which may contain a hazardous atmosphere shall be tested for residues of all contaminants identified by the evaluation testing using an instrument specified in the entry permit. Results of testing shall be recorded on the entry permit and compared to the acceptable entry conditions. If testing reveals oxygen deficiency or the presence of toxic gases or vapors, the space must be ventilated or purged and retested before entry. The atmosphere shall be tested continuously during entry operations.
The measurement of each atmospheric parameter shall be made for at least the minimum response time of the test instrument specified by the manufacturer.
The density of gases and vapors will cause them to be:
When monitoring for entries involving a descent into atmospheres that may be stratified, the space should be tested every four feet (4 ft.) in the direction of travel and to each side. The entrant’s rate of progress should be slowed to allow for sampling and detector response.
The following equipment should be included, but not limited to:
Additional equipment required for PRCS entries:
Note: All equipment shall be maintained and supervisors shall ensure that employees use the equipment properly.
Non-permit Confined Spaces
Persons desiring to enter a non-permit confined space shall:
Permit Required Spaces
Note: Permits issued under the procedures in this program shall be limited in duration to no longer than eight hours.
Under no circumstances shall unauthorized personnel enter a confined space to attempt a rescue. At the present time there are no university employees authorized to perform a confined space rescue.
Offsite Emergency Services
The Cullowhee Voluntary Fire Department will be dispatched to provide assistance on confined space rescue. Jackson County Emergency Medical Services (EMS) is responsible for providing emergency medical treatment.
In case of an emergency, contact WCU Emergency Services by one of the following methods:
To facilitate non-entry rescue, retrieval systems or methods shall be used whenever an authorized entrant enters a permit space, unless the retrieval equipment would increase the overall risk of entry or would not contribute to the rescue of the entrant.
All entry supervisors, attendants, entrants are properly trained initially and refresher training is provided when duties and space hazards change or whenever an evaluation determines inadequacies in the employee’s knowledge.
The supervisor shall provide training so that all employees whose work is regulated by this program with the necessary understanding, knowledge, and skills to safely enter, work in, and exit from permitted spaces.
Specific training shall be provided to each affected employee:
The training shall establish employee proficiency in the required duties and shall establish new or revised procedures, as necessary, for compliance with this program.
The supervisor shall certify that the training required has been accomplished. The certification shall contain each employee’s name, signatures or initials of the trainers, and training dates. The training certification is available for inspection by employees and their authorized representatives.