Confined Space Program

All UW departments/units/organizations that work in (or have control of) permit-required confined spaces must follow the UW Confined Space Program Manual.

• Identify all permit-required confined spaces the department/unit/organization owns or is responsible for.
• Appoint a Competent Person to evaluate confined spaces and determine if they are permit-required confined spaces.
• Maintain an inventory of the permit-required confined spaces that are managed by the department/unit/organization.
• Assign a Confined Space Owner(s) to ensure that confined spaces are evaluated, labeled, and secured.
• Determine the confined space entry supervisors, entrants and attendants within the department and ensure they are trained in the UW PRCS training.
• Ensure that a UW PRCS Entry Form is complete and approved prior to every PRCS entry.
• Ensure that proper procedures are followed and appropriate personal protective equipment (PPE) is worn whenever employees enter a confined space.
• Ensure that proper confined space entry equipment and PPE are purchased, maintained and available.
• Conduct an annual self-audit of the department/unit/organization confined space program.
• Work with EH&S to resolve issues related to the Confined Space Program.
• Ensure all injuries and near-misses, caused by work related to confined spaces, are reported using the Online Accident Reporting System.
• Ensure hiring managers working with contractors entering confined spaces follow procedures in the UW Confined Space Program Manual.

• Ensure Entrant(s) and Attendant(s) have completed UW PRCS entry training.
• Ensure that a UW PRCS Entry Form is completed before approving entry into a PRCS.
• Recognize any potential hazards during entry, including signs and symptoms of exposure.
• Verifies hazard controls or elimination methods are in place before entry.
• Verify air testing conducted properly by a qualified person.

• Complete required initial and periodic refresher training for PRCS entry.
• Be aware of and understand the hazards that may be encountered during entry.
• Follow UW PRCS entry practices and procedures.
• Wear appropriate PPE when entering a confined space.
• Alert Entry Supervisor and/or Attendants of potential hazards, warning alarms or prohibited conditions.
• Evacuate the space if a hazard is recognized, if ordered to evacuate, or if an alarm is activated.

• Complete required initial and refresher training for PRCS entry.
• Be aware of and understand the hazards that may be encountered during entry.
• Follow PRCS safety practices and procedures.
• Communicate regularly with Entrant(s).
• Conduct air monitoring in the space.
• Monitor work area for hazardous conditions.
• Communicate with entrants and monitor their status.
• Perform non-entry rescue.
• Summon rescue and emergency services as needed.
• Call for evacuation of the space as needed if a hazardous condition arises inside or outside the space.

• Establish and maintain the overall UW Confined Space Program.
• Produce and maintain program documentation, including confined space entry and evaluation forms.
• Work with departments to fully implement the program for the confined spaces they manage.
• Develop, evaluate, and/or recommend employee training.
• Audit departments for compliance with the program.
• Monitor changes in regulations, policies, and best practices.

• Hiring Managers of contractors with employees entering UW owned confined spaces must inform contractors of the following:
  • Presence of a PRCS that requires completion of a PRCS Entry Form before entry
  • Hazards of the space
  • Department/unit/organization experience with the space
  • Precautions and procedures implemented for protecting employees in or around the space
• Hiring Managers must ensure that contractors entering any UW PRCS:
  • Adhere to all applicable regulations regarding confined spaces; inform their sub-contractors, or other entities needing entry, of any hazards, ensure they are trained to enter, and they monitor the entry.
  • Provide the Hiring Manager with the company’s confined space program for review.
• Hiring Managers must coordinate with the contractor when employees and employers from different companies are working in or near any UW PRCS.

Confined spaces may contain hazards that can injure workers or quickly lead to death. Untrained and ill-equipped rescuers can easily become victims themselves. University units and departments, supported by Environmental Health & Safety (EH&S), must follow the requirements of the Confined Space Program to ensure personnel working in or near confined spaces are protected from harm.

EH&S provides the following confined space safety classes:

• Permit-Required Confined Space Entry - Classroom
• Confined Spaces Awareness - Online
• Permit-Required Confined Space Entry Refresher - Classroom

Washington Administrative Code WAC 296-809 Confined Spaces - Washington Department of Occupational Safety and Health (DOSH) publishes rules pertaining to confined space safety.

Entry is when a person passes through an opening into a permit-required confined space. Entry includes doing work activities in the space and occurs when any part of the body (arms, hands, head, torso) breaks the plane of the opening into the space.

If a space has limited or restricted means of entry or exit, an entrant's ability to escape in an emergency would be hindered. The dimensions of a door and its location are factors in determining whether an entrant can easily escape. However, the simple presence of a door may not mean that the space is not a confined space. For example, a space such as a bag house or crawl space that has a door leading into it, but also has pipes, conduits, ducts, equipment or materials that an employee would have to crawl over, under or squeeze around to escape, has limited or restricted means of exit. A piece of equipment with an access door, such as a conveyor feed, a drying oven or a paint spray enclosure, may also have restricted means of entry or exit if an employee has to crawl to gain access to their work location. Similarly, an access door or portal that is too small for an employee to walk through upright and unimpeded may restrict an employee's ability to escape.

Designed for Human Occupancy means the space is designed for a person to occupy the area under normal operating conditions and is intended as a place of work.

When all physical hazards have been eliminated in a PRCS and all atmospheric hazards have been either eliminated or controlled by continuous ventilation the space may be entered using Alternative Methods and documenting the entry with PCRS Entry Form Part A. If any hazard is present it is a “Permit” entry and PCRS Entry Form Part A & B must be used to enter the space which requires an Attendant and a rescue plan.

Engulfment means the surrounding and effective capture of a person by a liquid or finely divided (flowable) solid substance that can be breathed in and cause death by filling or plugging the respiratory system, or that can exert enough force on the body to cause death by strangulation, constriction or crushing. Engulfment hazards include any “flowable” materials, such as water, product or chemical.

Flowable material (e.g., gas, liquids, fine solids) hazards must be isolated by physical disconnect, blinding or blanking of interconnected piping; or a risk assessment must be completed that provides equal protection. Isolation with a single valve is not acceptable as valves can fail.

An alternative process for entering a permit space under very specific conditions; these methods include documentation showing the elimination of any physical hazards and elimination or control of any actual or potential atmospheric hazards

An individual stationed outside the permit space who monitors the authorized entrants and who performs all attendants’ duties assigned in the permit space program

The 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

A space that meets the following criteria:

Is large enough and so configured that an employee can bodily enter and perform assigned work

Has limited or restricted means for entry or exit

Is not designed for continuous human occupancy

The unit, department or individual who owns, controls access, and/or has administrative control over a confined space and understands the chemical and physical hazards associated with it.

The surrounding capture of a person by a liquid or finely divided (flowable) solid substance that can be inhaled to cause death by filling or plugging the respiratory system or that can exert enough force on the body to cause death by strangulation, constriction or crushing

Person who is authorized to enter a permit space

Action by which a person passes through an opening into a permit-required confined space and includes work activities in that space; entry occurs as soon as any part of the entrant’s body breaks the plane of the opening into the space.

The written or printed document provided by the University allowing and controlling entry into a permit space

The person (such as the supervisor, foreman or crew chief) responsible for:

• Determining if acceptable entry conditions are present at a permit space where entry is planned
• Authorizing entry and overseeing entry operations
• Terminating entry as required by this section

An atmosphere that may expose employees to the risk of death, incapacitation, impairment of ability to self-rescue, injury, or acute illness from one or more of the following:

• Flammable gas, vapor, or mist in excess of 10 percent of its lower explosive limit (LEL)
• Airborne combustible dust at a concentration that meets or exceeds its LEL
• Atmospheric oxygen concentration below 19.5 percent or above 23.5 percent
• Atmospheric concentration of any substance for which may exceed a permissible exposure limit
• Any other atmospheric condition that is immediately dangerous to life or health

Any condition that poses an immediately or delayed threat to life or what would cause irreversible adverse health effects or that would interfere with an individual’s ability to escape unaided from a permit space

The process by which a permit space is removed from service and completely protected against the release of energy and material into the space by such means as: blanking or blinding; misaligning or removing sections of lines, pipes or ducts; a double block and bleed system; lockout or tagout of all sources of energy, including hydraulic or electric; or blocking or disconnecting all mechanical linkages

Equipment used for non-entry rescue of persons from a permit space, such as a retrieval line, full-body harness, wristlets, and a lifting device or anchor