Confined Space Safety

manhole cover

Confined spaces may contain hazards that can injure or quickly lead to death. Untrained and ill-equipped rescuers can easily become victims themselves. UW Departments, supported by EH&S, must follow the UW Confined Space Safety Program, or equivalent, to prevent unqualified personnel from becoming injured by confined space hazards and to minimize those hazards for personnel who must work in and around confined spaces. The elements of the Confined Space Program are described below.

Confined Space (CS) Definition

Consistent with regulation, a CS means a space that:

  1. Is large enough and so configured that an employee can bodily enter and perform assigned work; and
  2. Has limited or restricted means for entry or exit; and
  3. Is not designed for continuous occupancy.

Examples of CSs at UW may include, but aren't limited to: utility vaults, sewers, lift stations, pits, plenums, boilers and tanks. For a complete list see the UW CS Inventory List (Excel). This inventory is maintained by EH&S as a service to UW departments and it contains all known permit required confined spaces, any evaluated CSs, and any spaces that were evaluated and determined not to be CSs.

Permit Required Confined Space (PRCS) Definition

A CS that has one or more of the following characteristics is a permit required confined space (PRCS). Special plans, procedures, and permits need to be followed before, during, and after entry into a PRCS:

  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
A hazardous atmosphere means an atmosphere that may expose employees to the risk of death, incapacitation, and impairment of ability to self-rescue (that is, escape unaided from a permit space), injury, or acute illness from one or more of the following causes:
  1. Flammable gas, vapor, dust or mist in excess of 10 percent of its lower flammable limit (LFL)
  2. Airborne combustible dust at a concentration that meets or exceeds its LFL
  3. Atmospheric oxygen concentration below 19.5 percent or above 23.5 percent
  4. Atmospheric concentration of any substance which could result in employee exposure in excess of its dose or permissible exposure limit in the WA-DOSH rules
  5. Any other atmospheric condition that is immediately dangerous to life or health
If you suspect a space meets the definition of a PRCS, please do not enter. Complete the CS Evaluation form and submit it to EH&S for evaluation.

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Confined Space Labeling

All PRCSs identified at UW and some non-permitted spaces will have signs or labeling to alert personnel. Many non-permitted spaces are impractical to label or sign.

PRCSs will have one of two signs (note that signs may be painted on walls and doors):

danger cf space 1 danger cf space 2

If signed, non-permitted CSs will have the following sign or label:

danger cf space 3

If no labeling is present and it is unclear if a space is a CS, the space must be treated as a CS until it is evaluated and classified by EH&S.

Under no circumstances should a confirmed or potential CS be entered for evaluation without training, proper procedures and appropriate equipment.

Procedures

All UW departments who work in or have control of permit-required CSs should develop, implement, and enforce a CS entry program. Such programs should follow the UW CS Program and address the department's specific needs. Use this fillable template plan for Department-specific CS entry procedures.

The written program must address the following:

  • Written permit entry procedures and permit form
  • Written alternate entry procedures, if applicable
  • Provision to identify all CS and submit form to EH&S to perform initial evaluation. Until evaluated, all CS are presumed permit-required.
  • Designation of roles and duties of personnel such as entrants, attendants, entry supervisors, and those who test or monitor atmospheres in a PRCS
  • Training requirements for each role
  • How your department identifies and evaluates hazards
  • Proper use and care of equipment
  • How to prevent unauthorized entry
  • How to coordinate entry with another entity or department
  • Rescue plans

Procedures for Departments without a Confined Space Safety Program

UW departments that do not reasonably anticipate conducting CS entry are not required to maintain a written program. If a department or their contractor require entry to a confined space, they can contact the controlling department, or EH&S, for more information about the space.

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Procedures for Outside Contractors

WAC 296-809-30004 requires outside employers and contractors who will access your department’s CSs to:

  • Obtain any available information about PRCS hazards and entry operations from the host employer
  • Coordinate entry operations with any other employers or departments whose employees will be working in or near the PRCS
  • Inform the host employer or department, either through debriefing or during entry operations, about: 1) the entry program that will be followed; and 2) any hazards confronted or created in the space during entry operations.

Accident/Incident Reporting

All injuries and near-misses, including those potentially caused by work in CSs, must be reported using the Online Accident Reporting System (OARS).

Confined Space Rescue

As part of the written CS entry program, it is important to understand that available personnel experience and equipment may not be adequate for safe rescue. A rescue plan must address how to extract entrants when a space presents challenges to an effective retrieval before entry occurs. Some conditions that may warrant having an on-site rescue resource during entry include:

  • Entries into spaces where traditional retrieval equipment is not practical
  • Entries into spaces where the atmosphere cannot be made safe without the use of supplied air respiratory equipment
  • Spaces with openings not large enough to allow entry by personnel with typical rescue gear (SCBA, etc.)
  • Entries into spaces fully or partially submerged in water requiring special equipment for access

It is also important to realize that not all local fire and emergency resources where UW facilities exist can provide effective 911 responses to CS emergencies. UW departments must plan their entry and communicate with the local fire department well in advance to determine what rescue resources are available and seek alternatives when local resources are insufficient.

EH&S Responsibilities and Services

EH&S has the following responsibilities and provides services to assist departments with developing, maintaining, and improving their CS safety programs:

  • Maintains the UW CS inventory
  • Posts signs at PRCSs
  • Evaluates spaces and determines if a space meets the definition and must be managed as a PRCS
  • Provides consultation and advice on safe access to CSs
  • Assists departments with the development of a CS safety program
  • Monitors changes in regulations, policies and best practices
  • Provides CS safety training and resources (see below)

Confined Space Training

Training is a required element of any CS safety program. EH&S provides CS safety training. Information for CS safety classes and registration instructions can be found on the UW EH&S Training Web page.

Forms and Resources

CS Evaluation Form (PDF) - Used to evaluate a space to determine if it needs special permitting procedures for entry
CS Entry Permit Templates - Permit examples available on the Washington L&I Helpful Tools Web site that can be tailored to meet the specific needs of UW departments
CS Entry Permit (PDF) - A permit adapted from the Washington L&I examples that can be modified by UW departments
CS Entry Plan Template (Word) - For use in customizing department specific procedures to meet the Confined Space Entry Program requirements.
CS Entry Program (Word) - The document that defines the campus-wide Confined Space Entry Program for the University of Washington
UW CS Inventory (Excel) - Listing of all known CSs and PRCSs at UW
Guidance: Temporarily Reclassifying Permit Required Confined Spaces (PDF)
Temporary Reclassification of PRCS (Word) - Certificate of Confined Space Hazard Elimination
OSHA Quick Card: Permit-Required CSs in General Industry - Assists with quickly remembering the most important CS safety issues

References

WAC 296-809 Confined Spaces (PDF) - Washington’s Department of Occupational Safety and Health (DOSH) publishes rules pertaining to CS safety.

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