Confined Spaces

CONFINED SPACES POLICYOSHA (29 CFR 1910.146)

 I. BACKGROUND

The purpose of this policy is to inform interested persons, including employees that the University of Saint Francis is complying with the Occupational Safety & Health Administration Confined Space Standard, Title 29 Code of Federal Regulations 1910.146 to protect employees from the hazards of entering permit-required confined spaces.

In summary, the university will evaluate the workplace to determine if any spaces are permit-required confined spaces and create an awareness of the existence and location of such spaces. University personnel will not be permitted to enter such spaces.

II. DEFINITIONS
A Confined Space is a space that meets all the following criteria:
1. Is large enough and so configured that an employee can bodily enter and perform assigned tasks.
2. Has limited or restricted means for entry or exit.
3. Is not designed for continuous employee occupancy.

Non-Permit Confined Space
A non-permit confined space means a confined space that does not contain, or with respect to atmospheric hazards, have the potential to contain, any hazard capable of causing death or serious physical harm.

Permit-Required Confined Space is a confined space that has one or more of the following characteristics:
1. Contains or has the 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.
4. Contains any other recognized serious safety or health hazard.

A space classified by the employer as a permit-required space may be reclassified as a non-permit confined space if the permit space poses no actual or potential atmospheric hazards and if all hazards within the space are eliminated without entry into the space, the space may be reclassified as a non-permit confined space for as long as the non-atmospheric hazards remain eliminated. Or, a permit-required confined space may be temporarily reclassified as a non-permit confined space, following OSHA 1910.146(c)(i).

III. PROCEDURE
The Director of Safety and Security will evaluate the workplace as facilities are acquired, constructed, modified or is otherwise altered to determine the presence of confined spaces. Confined spaces that are reconfigured or changed in their use will be re-evaluated to determine if there is a change in hazard. The re-classification of the space will be assigned accordingly. The written hazard evaluation is found in attachment A of this policy. Records of evaluations are kept by the Risk and Safety Management Committee, which holds overall responsibility for this policy. The locations of confined spaces are documented in this policy.

Non-Permit Confined Spaces:
• Performing Arts Center – Lobby foyer ceiling
• Achatz Hall – Planetarium dome
• Sewage pump pit -Trinity Hall, Room 23
• Crawl spaces -Trinity Hall, Bonzel Hall
• Utility tunnels -Trinity Hall, 18A, 18B, 18C
• First floor ceiling – Trinity Hall
• Chamber Building (KBSOBEL) – Attic space
• Chamber Building (KBSOBEL) – Mezzanine crawl space
• Chamber Building (KBSOBEL) – Basement pipe and wire chase tunnels

Permit-Required Spaces:
• Transformer vault -Trinity Hall – This space is controlled by Indiana and Michigan Electric Power.
• City sanitary sewers – These are on the north-east corner of the property and are maintained by the city of Fort Wayne.
• Sanitary sewers -There are 14 access points to the sanitary sewer system on the campus grounds. The only hazard posed by these spaces is potentially an atmospheric one. The presence of a hazard has not yet been established, nor, if present, that forced air ventilation will be sufficient to maintain safe entry. Until the atmosphere can be tested it is advised that no one enter these spaces.

The university has determined that employees shall not enter a permit-required confined space and reserves the right to issue disciplinary warnings to employees, up to and including termination, for failure to follow the guidelines of this confined space policy. Measures taken to prevent accidental entry include awareness training and/or posting signage. Outside agencies will be contracted to perform work in confined spaces.

IV. TRAINING
The university will provide confined space awareness information to maintenance and security personnel. The university forbids entrance of permit-required confined spaces by university employees; therefore, permit-required confined space entry training is not required. A contracted vendor entering such space will be required to submit proof of training per 29 CFR 1910.146(g).

V. OVERSIGHT OF THIRD PARTY SERVICE PROVIDERS
In accordance with 29 CFR 1910.146(c)(8), the university will be responsible for informing the contractor of the presence and location of permit-required confined spaces and apprising the contractor of identified hazards, university procedures and precautions. The university will ensure the contractor, arranged by the university, has a written confined space program including a pre-entry evaluation, appropriate monitoring equipment, assigned entrants, attendants, supervisor and rescue personnel that have been trained, and that work completed in the confined space is in accordance with OSHA policy. The university will ensure the permit has been issued before entry into the space and that the permit is cancelled at the conclusion of the work. The university will work with the contractor to coordinate entry operations and debrief the contractor prior to and at the conclusion of the work. Utility companies are solely responsible for confined space procedures when working in confined spaces controlled by that utility.
Approved 6-6-12

Updated 17 September 2015

Risk and Safety Management Committee