HAzEN AND SAWYER

CONSTRUCTION CAPITAL PROJECT WP-103 WARDS ISLAND WPCP PHONE (212) 831-7550 MANAGEMENT SERVICES 7 WARDS ISLAND NEW YORK, NY 10035 FAX (212) 831-7599

MEMORANDUM
To: Distribution

Memo No.: M79-1112

From: Subject:

Jamil F. Mi~da, p.E/y . Resident Engineer

..71;p4---' ()"FT'fIIV

Date:

December 19,2011

Contracts WI-79G, E, H and P

Revised Environmental Health and Safety Procedures Confined Space Entry Program, Revision 2
Attached is the revised NYCDEP Confined Space Entry Program. Please make sure your Safety Professionals and Site Safety Representatives are also provided with a copy for their review. This revised procedure will take effect on December 1, 2011. If you have any questions please contact Tom Davey at 212-831-7550 ext. 128 or email him at tdavey@bidwellenvironmental.com

Distribution:

79G-Silverite Construction 79E-Schlesinger Electric 79P-James McCullagh Co 79H-RA.M.S. Mechanical

JFMlTD Attachment cc: Chen /Wellette/MclIugh (Letter) BelovinILicopoli (Letter) Morrow (Letter) Miranda/LonglDavey /Carey/Metzger (Letter) File: 79G-2d 79E-2d 79P-2d 79H-2d

Environmental
Protection

To:

Carter H. Strickland, Jr.
cstrlckland@dep.nyc.gov
Commissioner

Persis D. Luke Assistant Commissioner Office of Environmental
Health & Safety lukep@dep.nyc.gov

59-17 Junction Boulevard Flushing, NY 11373 T: (718) 595-6565 F: (718) 595--3525

Carter Strickland Steven Lawitts Kathryn Garcia MaryPazan Matthew Mahoney Joseph Singleton Joseph Murin Kathryn Mallon, P.E. Robin Levine Kevin McBride Paul Rush. P.E. James Roberts. P .E. Vincent Sapienza, P.E. Zoe Ann Campbell Jin Chang Martha Osenni Elissa Stein Cushman Persis D. Luke ~ Assistant Commissioner, ERS September 29, 2011 Revised Environmental Health and Safety Procedure Confined Space Entry Program

From:

Date: Re:

Attached, please find revision 2 of the Confined Space Entry Program. This replaces revision 1. dated September 28, 2005. While DEP is taking steps to streamline and simplify EHS policies, the Permit Required Confined Space program (PRCS) retains a significant level of detail because it serves as the regulatory required confined space program for DEP bureaus. The key changes to this revision are:

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Section 5: Removed the "Local Program Administrator" (LPA) as a confined space program title. The previous LPA responsibilities have been incorporated into the Responsible Individual's duties. Section 6.1: Changed language regarding who is allowed to evaluate confined spaces; removed guidance for posting non-permit confined spaces; clarified procedure for reclassifying confined spaces. Section 6.2: Significantly revised procedure for entry into non-permit confined spaces; clarified the alternate entry procedure; broke permit required entry procedure into three major categories; developed entry procedures for shared spaces (contractor and DEP) and contractor only spaces.

~ Section 6.3: Revised direction regarding the need to make a space as safe as possible for entry regardless of classification through the use of hazard elimination and controls. ~ Section 6.4: Added sections on evacuation and non-entry rescue. ~ Section 7: Split training requirements into five groupings: entrant/attendant, entry supervisor, rescue team member, refresher, and awareness. ~ Attachment A: Reverted back to one confined space inventory form instead of two and simplified directions for use. -+ Attachment B: Revised confined space evaluation and classification into specific sections and added box to specify if the space is being reevaluated. ~ Attachment C: Reduced the confined space permit down to two pages. ~ Attachment F: Revised annual confined space review content to provide more guidance in performing annual review of permits and local programs. Also. please note that the distribution of this program will be supported by training sessions which are commensurate with the employees' involvement in confined. space entries. Each Bureau (ERS) will identify training needs. OEHS will supply training modules to be used or adapted. Hard copies are delivered directly to your EHS DirectorsILiaisons and they will proceed with distributing this policy for inclusion in EHS binders and will also make provisions to communicate the content of this program. As always, this procedure is also available on DEP Pipeline. Please contact me if you have any questions.

Attachment c: C. Graff W. Yulinsky K. Marino H. Belovin P. Theodorellys S. Wickham A. Evangelista K.O·Connor D. Johann D. Nadler G.McCoy V. Nyarko M. Sherer

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Environmental Protection

Confined Space Entry Program
Environmental Health & Safety Policies, Procedures and Guidelines

Applies to: EBS Policy Volume: Revision Number: Document Type: Effective Date: Reviewed By: Approved By:

All DEP Bureaus and Offices
OJ 011 ·Ii?JDI ON

2
Ii?JPolicy OProcedure December 1, 2011 DEBS DEBS

o Guideline

OSOP

Objective To protect DEP employees from the hazards of entering and working in confined spaces and to maintain compliance with the OSHA PermitRequired Confined Spaces Standard (29 CFR 1910.146). Purpose The purpose of this Confmed Space Entry program is to: • Inform DEP employees about hazards, requirements and responsibilities of DEP personnel • Provide details for confined space entries ,iJ Describe the training requirements, metrics and auditing protocol, and reporting and recordkeeping requirements.

Revision I Action Revision O. have found it to be acceptable and authorize its use for all DEP operations. a duly authorized representative of the DEP Agency Compliance Office.DEP Office of Environmental. Health and Safety Compliance Authorization I. Authorization Revision 2. Authorization SiK!!ature On file Date: Date: Date: Date: Date: Date: Date: Date: 02/14/03 10/11105 :~ • 09129/11 Pagei . have reviewed this document. Authorization Revision 1.

......2 REsPONSmLE INDIVIDUAL (RI) BUREAU ENVlRONMENTAL HEALTH & SAFETY PERSONNEL (BEBS) ENTRY SUPERVISOR ATTENDANT ENTRAN"T DEP CONTRACT SUPERVISOR AND PROTOCOLS IDENTlFICA1'ION~ EVALUATION~ LABELING AND RECLASSIFICATION ENTRY PROCEDURES 1 1 1 1 3 3 3 4 4 "' ..................3 6......5 s 5....4 PROCEDURES 6 6 6 100 155 18 HAzARD CONTROL AND PROTECTIVE EQUWMENT EMERGENCY PROCEDURES 7 8' 9 10 TRAININ"G METRICS AND AUDITlNG RECORDKEEPING AITACBMENTS ATTACHMENT A ATTACHMENT B ATTACHMENT C ATTACHMENT D ATTACHMENT E ATTACHMENT F " ..........6 6 6...1 6.1 5.. 222 233 233 233 CONFINED SPACE INVENTORY CONFINED SPACE 23 FORM 25 26 28 29 30 HAzARD IDENTIFICATIONIEVALUAIION CONFINED SPACE ENTRY PERMIT CONFINED SPACE RECLASSIFICATION FORM NON-PERMIT ENTRY DOCUMENTATION FORM ANNUAL REVIEW DOCUMENTATION Page ii ...4 5......3 5........Table of Contents 1 2 3 4 5 PURPOSE SCOPE REFERENCES DEFINITIONS RESPONSmILITIES 5........ 5..........2 6.....••••• ..

146). 3 REFERENCES NYCDEP Contractor Selection and Management Policy NYCDEP Control of Hazardous Energy Lock-Out / Tag-Out Policy NYCDEP Hazard Markings and Color-Coding Policy NYCDEP Hot Work Policy NYCDEP Personal Protective Equipment Policy NYCDEP Respiratory Protection Policy 29 CFR 1910. to enter a permit-required confined space. it may be necessary for certain Bureaus/Offices to develop supplemental procedures or to modify the program attachments. Authorized Entrant . references to the use of Attachments A . Attendant .An individual stationed outside a permit-required confined space who monitors the activities of the authorized entrants and who performs all attendant's duties assigned in this program. Health & Safety Revision: 2 912912011 12/112011 Confined Space Entry Program Issuance Date: Effective Date. Throughout this document. and maintain compliance with the OSHA Permit-Required Confined Spaces Standard (29 CFR 1910.Conditions that must exist in a permit-required confined space to allow entry and to ensure that employees involved in a permit-required confined space entry can safely enter into and work within the space. The DEP Confined Space Entry Program applies to all Bureaus and Offices within DEP. no entry shall be permitted.An individual who is authorized. Page 1 .NEW YORK CITY DEPARTMENT OF ENVIRONMENTAL PROTECTION Policies and Procedures Manual Volume III Environmental.146 Permit Required Confined Spaces 4 DEFINITIONS Acceptable Entry Conditions . 1 PuRPOSE The purpose of this Confined Space Entry Program is to protect DEP employees from the hazards of entering and working in confined spaces. If a confined space entry cannot be made safely and according to procedures.3. in accordance with this program.2. however. depending on individual needs. 2 SCOPE DEP's Confmed Space Entry Program applies to all DEP employees who enter DEP confined spaces and to contractors as described in Section 6.F are specifically meant to allow the use of an equivalent form as approved by the Bureau EHS Director. Any supplemental procedures developed or modification of program attachments shall be consistent with the approach used in this program.

aqueducts.The person responsible.Established to protect workers against the health effects of exposure to hazardous substances. for determining whether acceptable entry conditions are present at a permit-required confined space where entry is planned. or ). vaults. Lower Explosive Limit (LEL) . Entry Supervisor .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 impairment of ability to self-rescue (that is. Entry . Lockout/fagout . or ). tanks. incapacitation.. Permissible Exposure Limits (PEL) .An atmosphere that may expose employees to the risk of death.> Contains a material that has the potential for engulfing an entrant. below which ignition will not occur. in accordance with this procedure. and 3.The action by which an authorized entrant passes any part of hislher body through an opening into a confined space.Any space that meets all three of the following conditions: 1. PELs are regulatory limits on the amount or concentration of a substance in the air.Also known as Lower Flammable Limit (LFL). and sewer lines). Hazardous Atmosphere . Entry includes ensuing work activities in that space and is considered to have occurred as soon as any part of the entrant's body breaks the plane of an opening into the space. Immediately dangerous to life or health (IDLH) .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-required confined space. Permit-Required Confined Space (PRCS) . and 2. Is large enough and so configured that an employee can bodily enter and perform assigned work.NEW YORK CITY DEPARTMENT OF ENVIRONMENTAL PROTECTION Policies and Procedures Manual Volume III Environmental. Health & Safety Revision: 2 9fl9l20 11 1211aQl1 ~--------~--------------------------------~~~~==~~. Has limited or restricted means for entry or exit (for example. injury. escape unaided from a permit-required confined space). Is not designed for continuous employee occupancy. for authorizing entry and overseeing entry operations. OSHA PELs are based on an 8-hour time weighted average (TWA) exposure. Confined Space .l- Confined Space Entry Program Issuance Date: Effective Date: Contains or has the potential to contain a hazardous atmosphere. or Page 2 . acute illness..A confined space which has one or more of the following characteristics: ). is the lowest concentration of flammable gases or vapors in air. and for terminating the entry operation as required by the regulations.Established procedure to control hazardous energy by placement of a lockout or tagout device to prevent equipment or process from becoming energized.

1 Responsible Individual (RI) The Responsible Individual. as appropriate.e.Ensuring that employees are trained. evaluation. via training.Ensuring that required equipment is available. The RI may delegate tasks. evaluation and classification of confined spaces with Bureau EHS. 5 RESPONSIBILITIES 5. Health and Safety (OEHS) of programmatic changes.Contains any other recognized or potentially serious safety or health hazard. and ). Coordinating identification.2 Bureau Environmental Health & Safety Personnel (BEBS) It is the responsibility of BEHS to facilitate and foster adherence to this program. and » Annually reviewing the Confined Space Program cancelled entry permits with Bureau EHS Personnel and correcting any deficiencies in hazard control measures. toolbox talks or other suitable forums). Annually reviewing the effectiveness of the Confined Space Entry Program with the RI and making recommendations to the Office of Environmental. :> Ensuring that all other requirements of this program are met. and classification of confined spaces.NEW YORK CITY DEPARTMENT OF ENVIRONMENTAL PROTECTION Policies and Procedures Manual Volume ill Environmental. » Coordinating with any DEP staff managing contractor activities involving PRCS entry at the Rl's facilities. ). inspection and maintenance of gas monitoring/detection devices used for confined space entry. Coordinating training for affected employees. :> Maintaining the written program including the confined space inventory and associated evaluations. Reviewing entry operations whenever there is reason to believe that hazard control measures may not protect entrants and revising measures for subsequent entries.. » » 5. the highest ranking manager or supervisor. :> Ensuring the regular calibration. Health & Safety Confined Space Entry Program Revision: Issuance Date: Effective Date: 2 91'2912011 121112011 ). is responsible for: ). Page 3 . Responsibilities include: » :> Working with the RI to ensure consistent and accurate identification. for each BureaU/Office at locations where confined space entries are made. and » Ensuring that identified issues and deficiencies noted during annual reviews are communicated to all affected staff (i. and.

Ensuring that air monitoring results are recorded on the entry permit.Ensuring that entry operations remain consistent with terms of the entry permit and that acceptable entry conditions are maintained.Verifying that acceptable entry conditions exist prior to a PReS entry. including information on the modes. >. and consequences of the exposure. Monitoring activities inside and outside the space to determine whether it is safe for entrants to remain in the PReS and ordering Entrants to evacuate the space immediately under any of the following conditions: Page 4 .Verifying that 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 and allowing entry to begin. including information on the modes. symptoms. symptoms...4 Attendant Responsibilities of the Attendant include: >- » Knowing the hazards that may be faced during entry. 5. as long as he or she is trained and equipped as required by this procedure for each role that the person fills. and consequences of exposure.Being familiar with emergency procedures and non-entry rescue equipment.Removing unauthorized individuals who enter or who attempt to enter the PRes during entry operations. A lso. signs. >.Verifying that rescue services are available and that the means for summoning them are operable.Knowing the hazards that may be faced during entry.Being aware of and observing entrants for possible behavioral effects of hazard exposure in authorized entrants. ). ). » Remaining outside the PReS during entry operations until relieved by another Attendant and performing no additional duties that might interfere with monitoring and protecting the authorized entrants.Terminating the entry and canceling the permit when required..NEW YORK CITY DEPARTMENT OF ENVIRONMENTAL PROTECTION Policies and Procedures Manual Volume III Environmental. >.3 Entry Supervisor Responsibilities of the Entry Supervisor include: ). and ~ Ensuring that the entry permit is properly completed and filed after entry is complete. signs. ). ). the duties of Entry Supervisor may be passed from one Entry Supervisor to another during the course of an entry operation.. >. ). .Being in continuous communication and maintaining an accurate count of authorized entrants in the PReS and ensuring accurate identification of who is in thePRCS. Health & Safety Confined Space Entry Program Revision: Issuance Date: EffeCtive Date: 2 9/2912011 12{112011 5. Note: An Entry Supervisor may serve as an Attendant or as an Authorized Entrant.

Health & Safety Confined Space Entry Program Revision: Issuance Date: Effective Date: 2 912912011 121112011 • A prohibited condition is detected. ~ Being m continuous conununication with the Attendant to enable the Attendant to monitor Entrant status and. ). and ~ Exiting from the PRCS as quickly as possible whenever: • • An evacuation alarm is activated or an order to evacuate is given by another Entrant. and Informing the Entrants and the Entry Supervisor if unauthorized persons do not cooperate or have entered the PRCS.NEW YORK CITY DEPARTMENT OF ENVIRONMENTAL PROTECTION Policies and Procedures Manual Volume ill Environmental. including information on the modes. using available equipment such as a tripod retrieval system (Note: Attendant entry is prohibited).5 Entrant Responsibilities of the Entrants include: ~ Knowing the hazards that may be faced during entry.~ A prohibited condition is detected. and consequences of the exposure. • Communication is compromised. • There is a situation outside the space that could endanger the Entrant. or • A prohibited condition is detected. PageS . if needed. ~ Taking the following actions when unauthorized persons approach or enter a PRCS while entry is underway: ~ Warning the unauthorized persons that they must stay away from the PRCS. signs. the Attendant or the Entry Supervisor. or . to alert entrants of the need to evacuate the space.Performing non-entry rescues. ~ Alerting the Attendant whenever: ~ Any warning sign or symptom of exposure to a dangerous situation is recognized. or • The Attendant cannot effectively and safely perform all of his duties. ~ Summoning rescue and other emergency services as soon as it is determined that Entrants may need assistance to escape from PRCS hazards. when necessary. 5. ~ Properly using equipment per manufacturer's specifications and training. • • Advising the unauthorized persons that they must exit immediately if they have entered the PRCS. Any warning sign or symptom of exposure to a dangerous situation is recognized. symptoms. ·eo Behavioral effects of hazard exposure are detected in an Entrant.

All spaces evaluated must be included on the inventory. which is a two-step process: 1.1) by BEHS or other authorized employee who is qualified and trained in the DEP Confined Space Entry Program. 6 PROCEDURES AND PROTOCOLS 6. A determination must be made as to whether the identified space meets the criteria for a confined space. sewers).g. Labeling and Reclassification 6. If the identified space meets the criteria for a confined space then the space must be evaluated to determine whether it meets the criteria-for a PRCS. Page 6 . process or facility modification or installation that may change the classification of a space or create a new confined space and coordinate the evaluation and revision of the inventory and facilitate any other actions required by a new classification (e. and + Precautions and procedures in place that DEP uses to protect its employees when they are in or near a PRCS. 2. Evaluation. Responsibilities of the Contract Supervisor include: » Coordinating with facility RI on all contractor activities involving confined space entry to ensure that the contractor is made aware of: . posting of signs. they may be listed by category. Health & Safety Revision: __ .1 Identification The RI will work with facility staff and BEHS to identify and inventory (..1. 6.)..NEW YORK CITY DEPARTMENT OF ENVIRONMENTAL PROTECfION Policies and Procedures Manual Volume III Environmental..=. training.1 Identification.1..2 9/29/2011 1211/2011 _ Confined Space Entry Program Issuance Date: Effective Date: 5.6 DEP Contract Supervisor The Contract Supervisor is the person responsible for managing and overseeing the Contract.. etc.tttachment A) all spaces that potentially meet the definition of a confined space (see Section 4 and Figure 1). and » Coordinating confined space entries with RI when both DEP and contractor employees are to work near or in a PRCS to ensure that both the contractor and DEP employees are safe. The RI must be cognizant of any' equipment.g.1. Existence of PRCSs that must be entered in accordance with applicable regulations. + Hazards within the PRCSs based on DEP experience. The confined space identification and classification flowchart (Figure 1) can be used as a guide during the evaluation.2 Evaluation and Classification A Confined Space Evaluation Form (Attachment B) must be completed for each potential confmed space identified on the inventory (see Section 6. Where there are numerous spaces with similar characteristics (e.

has the potential to contain.Atmospheric Hazard Only. Health & Safety Confined Space Entry Program Revision: IssuanceDate: EffectiveDate: 2 90. Page 7 . 2. Entry into the space must meet the minimum requirements set forth in this program for non-permit confined spaces. Mechanical The evaluation should be of the identified space and not of work that may be performed in the space during future entries (e. however. Based on the results of the evaluation. These are PReS spaces where the only hazard posed is an actual or potential hazardous atmosphere and these are the only spaces that may potentially be entered utilizing the "alternate procedures" detailed in this program. but not limited to. The space does not meet the definition of a confined space. hazards capable of causing death or serious physical harm. Permit-Required Confined Space . 3. The space meets the defmition of a confined space but does not meet the defmition of a PRCS.. Any additional hazards or changes in existing hazards will be identified and evaluated by the Entry Supervisor when the entry permit is completed prior to entry. Permit-Required Confined Space.. spaces will be classified into one of the following four categories: 1. with respect to atmospheric hazards. Not a confined space. Non-Permit-Reguired Confined Space.. 4.9120 II 12/lI2011 When determining whether a confmed space meets the criteria of a PRCS. Entry into the space is not regulated by this program. it is necessary to identify and evaluate all potential hazards inside and outside the space under normal operations expected during entry including. spring tension) .g. The space meets the definition of a PRCS.NEW YORK CITY DEPARTMENT OF ENVIRONMENTAL PROTECTION Policies and Procedures Manual Volume III Environmental. Entry into the space must be performed in accordance with this program.g. welding or cutting). any entry must be made safely per applicable regulations and/or applicable DEP policy. the space contains or. the following: • • IiII • Atmospheric Engulfment Electrical Chemical • • • • Pneumatic Steam Heat Noise !II !II Potential Energy (Gravity) Stored Energy (e.

tG YES '. Confined Space Evaluation NOTA CONFINED SPACE .Confined Space Identification & Classification Potenbal Confined Space 1----. Health & Safety Confined Space Entry Program Revision: Issuance Date: Effective Date: 2 912912011 121112011 Figure 1 . + YES to an 3 CONFINED SPACE Alternate Entl y Procedure PReS YES f -~ ~> o_j NO NON·PERMIT REQUIRED CONFINED SPACE • Page 8 .NEW YORK CITY DEPARTMENT OF ENVIRONMENTAL PROTECTION Environmental.... ..

4 Reclassification of Confined Spaces Confined spaces may be permanently or temporarily reclassified based on the introduction or elimination of hazards in or around the space.1. if appropriate. Health & Safety Revision: Confined Space Entry Program Labeling Confined Spaces Confined Spaces 2 912912011 121112011 Issuance Date: Effective Date: 6. If a hazard is permanently introduced into a non. then Attachment D should be completed to document the hazard elimination procedure for use during future entries. If the only hazard posed in a PRCS is actual or potential hazardous atmospheres. If routine use of alternate procedures is deemed appropriate. The re-evaluation should be documented using Attachment B. Once Attachment D is approved. the HI must coordinate updating the inventory and labeling that space to reflect the new classification as a non-permit-required confined space. as needed. 6. BEHS working with the HI and facility staff can make a determination that routine entry utilizing alternate procedures is appropriate (use of alternate procedures is NOT required). The sign must conform to the DEP Hazard Marking and Color Coding Procedure.3 Permit-Required The RI must ensure that all identified PRCSs are posted with a sign alerting employees to the hazard. If all hazards in a PRCS can be temporarily eliminated and the PRCS will be routinely reclassified to a non-permit-required confined space. the information should also be included in new employee training and/or posted at the facility.1. the space must be reclassified by completion of a new Attachment B. Details regarding how all hazards were permanently eliminated must be documented either in the space provided on Attachment B or by completing Attachment D. all reservoir building forebays are to be considered PRCSs). Reclassifications should be clearly Page 9 . Once the reclassification is complete. Attachment D should be reviewed and approved by BEHS (or other authorized personnel). inventory and labeling for that space to reflect the new hazard(s) and classification.DEPARTMENT NEW YORK CITY OF ENVIRONMENTAL PROTECTIOS Policies and Procedures Manual Volume III Environmental. Attachment D must be completed to document the procedure to control the hazardous atmosphere and the attachment must be reviewed and certified by BEHS. When utilizing an alternate means to notify employees of a PRCS. the HI must coordinate a reevaluation of the space and update the confined space evaluation. If all hazards in a PRCS are permanently eliminated. the HI must coordinate updating the confined space inventory for that space to reflect that a written standard procedure has been developed for temporarily reclassifying the PRCS to a temporary non-permitrequired confmed space for routine entries.permit-required confined space or an additional hazard is permanently introduced into a PRCS. the HI may inform exposed employees by any other equally effective means such as po stings or memorandum identifying the PRCSs (ex. The following or similar language may be used for the posted sign: DANGER PERMIT-REQUIRED CONFINED SPACE DO NOT ENTER Alternatively.

welding may generate fumes that might change the atmosphere)..e. During entry into a non-perm it-required confined space.e.g.DEPARTMENT NEW YORK CITY OF ENVIRONMENTAL PROTECTION Policies and Procedures Manual Volume III Environmental. 3. secure the space to prevent others from entering.2. The entrance to the space should he appropriately barricaded and/or attended to prevent creation of a fall hazard for others. the Entry Supervisor may temporarily reclassify the PRCS as a non-permit required confined space by following the procedure detailed in section 6. notify their supervisor and request that the space he re-evaluated. All necessary steps must be taken before entry to minimize hazards. whenever possible. 6.3 to reclassify and Page 10 . air monitoring is required for all unventilated spaces to confirm acceptable entry conditions. Health & Safety Confined Space Entry Program Revision: Issuance Date: Effective Date: 2 9/29120 II 121112011 communicated to all potentially affected staff.1 Temporary Reclassification to Non-Permit Confined Space If the PRCS poses NO actual or potential atmospheric hazards and if ALL other hazards within the space can he eliminated for the length of the entry.. Bureaus may establish procedures equivalent to or more stringent than these minimum requirements..2.2 Entry Procedures This section provides the minimum entry procedures that must be complied with for all spaces determined to be confmed spaces as set forth in the section above. To determine the number of personnel needed to ensure a safe entry.1 Non-Permit-Required Confined Space Entry This procedure applies to spaces that have been classified as non-permit-required confined spaces. 1. 6. Prior to entering a non-permit-required confined space. oxygen and LEL within limits and air contaminants below PELs) by forced air ventilation. Entries into non-perm it-required confined spaces do not require a permit. consideration should be given to the location of the space (i. 4. 5.2.2 Permit-Required Confined Space Entry The following procedures apply to spaces that have been classified as PReSs. 6.2.2. entrants should verify that planned work activities in or around the space will not create any hazards necessitating the reclassification of the non-permit-required confined space to a PRes (e. Attachment E may he used to document air monitoring results. 6. including. remoteness.) as well as the inherent hazards of the confined space. etc. reclassifying the space to a temporary non-permit-required confined space or requiring an alternate entry procedure. The RI must coordinate updating the confined space inventory for that space to reflect that a written alternate procedure has been established and must keep ALL original PRes entry permits and/or data forms used to demonstrate that the atmospheric hazards are adequately controlled (i. 2. In the event that a hazardous situation is encountered during the entry.2. high vehicle traffic. Entrants shall immediately exit the space.

If a PReS will be routinely reclassified to a non-permit-required confined space.3.2. Health & Safety Revision: 2 Confined Space Entry Program Issuance Date: Effective Date' 912912011 121112011 authorize entry as a temporary non-permit required confined space.Hazardous Atmosphere Only When the ONL Y hazard within the space is atmospheric and it can be controlled by continuous forced air ventilation. In order to initially re-identify a PRCS to an alternate procedure space. Attachment D should be completed to document the hazard elimination procedure for use during future entries. alternate entries require following section 6. therefore. At a minimum. The controlling of atmospheric hazards with forced air ventilation is a control measure and does not eliminate the hazard. The attachments shall be made available to the employees entering the space upon request. atmospheric monitoring. If a PReS will be routinely entered by an alternate entry procedure. The confined space has been classified as a PReS Alternate Entry Procedure space and/or the Entry Supervisor has determined that the only hazard in the space is an actually or potentially hazardous atmosphere.2. AND through AND the use of continuous 3. the space shall be evacuated immediately and the space shall be evaluated to determine how the hazardous atmosphere developed. an entry permit (Attachment C). continuous air monitoring must be conducted within the space to verify that conditions are acceptable for and during entry. Alternate entry procedures can only be used when: alternate 6. forced ventilation as needed to eliminate or hazards. Entrant. which may require an entry as a PReS. and provision in advance for rescue (see Section 6. corrective measures must then be implemented prior to any re-entry. If a hazardous atmosphere is detected during entry. Attachment D should be completed to document the specific procedure for the control of the hazardous atmosphere in that PReS for use during future entries. 6. monitoring.1. Entry Supervisor. and forced air ventilation.2. Entry Supervisor. atmospheric .2. Page 11 Entrant.2. Once the PRCS has been reclassified the space may be entered in accordance with section 6.2.2 1. Attendant. a PRes may be entered by following entry procedures. The effectiveness of the continuous forced air ventilation is sufficient to maintain the space safe for entry as demonstrated by air monitoring results. 2.3 to reclassify the space. the Confined Space Entry Permit. control atmospheric Confined Space Entry Procedures entry requires an entry permit.4).2.2) are adequately controlled by forced air ventilation. to demonstrate that all atmospheric hazards (including those indicated in Table 1 in section 6. The atmospheric hazard can be controlled forced air ventilation. data must be collected. All determinations for reclassifying a space to non-permit status shall be documented and certified using Attachment C.3 Permit-Required At a minimum. Attendant. Entry by Alternate Procedure .NEW YORK CITY DEPARTMENT OF ENVIRONMENTAL PROTECfION Policies and Procedures Manual Volume ill Environmental.

Perform and document air monitoring to Page 12 . Attendant and Entrants) has received requisite training in its assigned duties. hatches or covers. ENTRY PLANNING: Confined Space Entry Program Issuance Date: Effective Date: The Entry Supervisor will: 1.3. Assess the need and/or purpose for entering the space. Review the Confined Space Hazard IdentificationlEvaluation Form to determine whether current conditions within the space are consistent with those identified.4). 6. 7. If required.3.4.2) before entry and. requirements and controls. Implement any additional controls as identified on the permit that required opening of space. Carefully assess any comments or difficulties noted and proceed accordingly. NO ENTRY -WILL BE MADE. If acceptable readings are not achieved. 3. 4. Make all necessary pre-notifications of rescue services whether within the Bureau or to an outside agency (see Emergency Procedures Section 6. When the entrance covers are removed. Perform and document initial air monitoring in accordance with air monitoring requirements (Section 6. establish forced air ventilation in accordance with Section 6. Open the space. Prepare to open the space by eliminating any condition that could make it unsafe to remove manholes. Confirm that the entry team (Entry Supervisor. Review previous entry records (completed permits). 7.NEW YORK CITY DEPARTMENf OF ENVIRONMENTAL PROTECTION Policies and Procedures Manual Volume ill Environmental. 6. including all pre-entry checks. before initiating forced air ventilation. 4. Review/complete entry permit.3 to meet the entry penn it requirements. if required. 8. ensure that the entrance is appropriately barricaded (traffic cones and/or barricades) to create safe working conditions and prevent unauthorized entry into the space or inadvertent fall hazards. Implement controls that are capable of being accomplished prior to opening of the space. doors. Prepare for and be equipped to follow the appropriate Emergency Procedure identified in Section 6. Health & Safety Revision: 2 912912011 121112011 ~--------~--------------------------------~~==~~==~. 5. Notify other workers and supervisors in the area that an entry will take place. 5. 2. Review and evaluate all aspects of the work to be performed to determine whether a new hazard could be created or an existing hazard magnified and to identify appropriate hazard control measures. 3. 2. PRE-ENTRY PROCEDURE: The entry team will: 1.

the Entry Supervisor may authorize entry under the appropriate classification: alternate entry procedure. 8. entry may be made under a single permit.. If acceptable readings are not achieved. ENTRY PROCEDURE: 1.g. 5. If non-entry rescue equipment is utilized. alarming of air monitoring devices. If a space is evacuated. 3. temporarily reclassified non-perm it-required spaces. If permit conditions change for re-entry.2 for the duration of the entry and record periodically (e. or PRCS. 10.4 and carefully enter. Any safety and health issues encountered during the entry must be noted on the permit. the completed permit must be returned to the RI. no re-entry will be made until air monitoring readings are determined to be within acceptable range and/or any other unanticipated hazardous condition. signs or symptoms of exposure or any other condition that may impact the health or safety of entrant{s). Each entry must' be documented on the permit (Attachment C) including air monitoring and entrant accounting at each location. Ensure that the entry permit properly reflects the information identified during the pre-entry process. Health & Safety Revision: Issuance Date: EffectiveDate: 2 912912011 Confined Space Entry Program IVlI2011 verify conditions are acceptable. Implement any additional controls identified on the permit that required entry into the space. After the PRCS work is complete. 2. is corrected. After evaluating pre-entry readings and instituted hazard controls. Station the Attendant outside of the space and ensure that a system is in place for communication with Entrants. Immediately evacuate the space if hazards arise inside or outside the space that may endanger entrants such as unusual odors or unexpected hazardous conditions.NEW YORK CITY DEPARTMENT OF ENVIRONMENTAL PROTECTION Policies and Procedures Manual Volume III Environmental. Commence continuous air monitoring in accordance with Section 6. The entry permit will be cancelled on-site by the Entry Supervisor when work is complete or any previously unidentified hazardous conditions develop. as confirmed by the entry supervisor. using the same precautions and procedures described above at each location. Post the signed entry permit near the confined space entrance. 7. the Entrant will connect to the nonentry rescue retrieval system in accordance with Section 6. 4. NO ENTRY WILL BE MADE. Page 13 . SEQUENTIAL SEWER ENTRIES UNDER ONE PERMIT: When entries are made at multiple points in a sewer system over the course of the same day.3. a new permit must be completed. 6. every 15 minutes) on the permit. 9.

3 Tunnels When the work to be performed consists of solely construction-type activities located in an underground tunnel. or passageway. for inspection andlor observation purposes. At the conclusion of any entry operations. the Contractor shall use the DEP permit or Operating Bureau approved equivalent. the contractors shall fully comply with all aspects of this policy (training shall be in compliance with OSHA requirements).2. the contractor shall utilize the DEP confined space classifications. the contractor may utilize a confined space entry program or develop a program in compliance Page 14 .2 When contractors are working in an area with no active DEP operations which has been cleared by the DEP facility RI and released to the Contractor.3. When DEP personnel are required. Shared Spaces 6. Contractor's rescue service/system shall be adequate for all personnel (Contractor and DEP) entering the confined space.2.2.3.3 Contractor Entry Procedures The DEP Contract Supervisor shall ensure that the Operating Bureau communicates and coordinates with the Contractor in regards to identified hazards within and around confmed spaces that may be entered as well as any precautions and procedures that have been implemented for the protection of employees.3. the DEP Contract Supervisor will debrief contractors regarding the PRCS program followed and regarding any hazards confronted or created in PRess during the entry operations. The DEP Contract Supervisor will provide any pertinent information from the debriefing to the facility Rl for inclusion in the confined space program as necessary. When a joint entry is to be made into a PRCS. the contractor may enter PRCSs utilizing its own confmed space program which must comply with all OSHA requirements. The Contracting Bureau EHS shall be responsible for reviewing and accepting the Contractor's Confined Space Program for compliance with this Policy. shaft. 6. A plan detailing how hazard communication and coordination will occur shall be incorporated into the work plan or other written document and approved/accepted by both Contractor and Operating Bureau. Health & Safety Revision: 2 912912011 121112011 Confined Space Entry Program Issuance Date: Effective Date: 6. to enter a contractor PRCS in a work area wholly relinquished to a contractor.2.NEW YORK CITY DEPARTMENT OF ENVIRONMENTAL PROTECTlOl'i" Policies and Procedures Manual Volume III Environmental. unless or until a re-evaluation and re-classification by the Contractor is completed and the Contract Supervisor consents to the reclassification. Contractor Spaces 6.1 Where contractors share a space with an operating (or other) bureau. such entry may be done under the Contractor's permit and work procedures. and DEP personnel will enter under the Contractor's approved rescue plan. Space classifications shall be as classified by the Operating Bureau or may be reclassified as agreed upon by both Contractor and Operating Bureau. At a minimum. chamber.

1 Hazard Elimination and Control The elimination of all hazards in a PRCS is required prior to entry. and during entry. Monitoring for atmospheric Page 15 . The DEP Control of Hazardous Energy Lock-OutlTag-Out policy. including removal of potential sources of hazardous atmospheres. opening of piping. whenever feasible. Non-serious hazards may remain after the space has been prepared for entry. Welding. or ducts.800). Health & Safety 2 912912011 121112011 Confined Space Entry Program Revision: Issuance Date: Effective Date: with the OSHA Underground Construction standard (29 CFR 1926.2 Air Monitoring Air monitoring is required to determine whether acceptable entry conditions are present immediately prior to. controls must be implemented for the protection of entrants.3. a confined space must be protected against the release of energy and material into the space by such means as: blanking or blinding. and for use in devising and implementing adequate control measures for the protection of authorized entrants. those hazards must be addressed as required by other DEP policies and procedures and/or regulations. the Entry Supervisor must also consider any hazards that may be created by the work to be conducted in the space. The Entry Supervisor must verify that hazard elimination and/or control is conducted and documented on the entry permit or other required forms. 6. prior to entry. or blocking or disconnection of all mechanical linkages. 6.3 Hazard Control and Protective Equipment 6.3. Preparation Confined space preparation involves the removal of conditions that may present a serious hazard or impair self-rescue. and any other established precautions. In evaluating the entry hazards and specifying controls. When hazards cannot be eliminated. as appropriate. application of coatings. personal protective equipment. and other work may introduce into the space additional hazards that must be controlled. however. ventilation. Blanking or lockout of gates and valves is usually sufficient for the control of most liquids if the minor leakage that may occur from a single valve does not create a serious hazard or interfere with escape. Bureau-specific procedures and equipment-specific energy control procedures for lockout of processes and equipment must be followed when isolating energy and equipment hazards. The introduction of hazards may also necessitate the re-evaluation of air monitoring. lock-out andlor tag-out of all sources of energy. pipes. Isolation Whenever possible.NEW YORK CITY DEPARTMENT OF ENVIRONMENTAL PROTECTION Policies and Procedures Manual Volume III Environmental. a double block and bleed system. misaligning or removing sections of lines. Double block and bleed or misaligning/removing sections of lines is used for high hazard liquids and gases where even small leakage may present a hazard to entrants.

Air monitoring results shall be recorded on the entry permit and should be posted outside the space so Entrants can confirm that the atmosphere is safe before any entry or re-entry. calibration must be performed. acute illness or impairment of ability to self-rescue.). Continuous monitoring and periodic recording of results is required whenever a space is occupied. A bump test is conducted by exposing the instrument to a test gas to verify meter response.5% less than 10% of the LEL less than 10 ppm less than 35 ppm Bump Tests and Calibration All air monitoring equipment must be regularly calibrated. Air Monitoring Locations Air monitoring locations shall be selected based on the size and configuration of the space. Calibration is required when an instrument fails a bump test. after it has been serviced. and the characteristics of potential contaminants including gas/vapor density. mercury. the hazards.NEW YORK CITY DEPARTMENT OF ENVIRONMENTAL PROTECTION Policies and Procedures Manual Volume III Environmental. Meters must be located so that audible and/visible alarms are readily apparent to Entrant(s) or Attendant(s) at all times when the space is occupied. If an instrument is not calibrated or fails calibration it shall not be used. but not exceeding 30 days. Minimum air monitoring requirements and acceptable limits are: Parameter Oxygen LEL Hydrogen Sulfide Carbon Monoxide Table 1 Confined Space Exposure Limit (Acceptable Range) 19. If the bump test results are not acceptable. methane. More than one meter may be required depending on the size and configuration of the space. monitoring locations must include the breathing zone of the entrants. Page 16 . injury. Calibration is the adjustment of the instrument's reading to coincide with a known concentration oftest gas. Exposure limits for chronic or other health effects may be different and must be addressed separately. and the number and location of Entrants. a bump test of the air monitoring equipment must be made. etc. Health & Safety Confined Space Entry Program Revision: Issuance Date: Effective Date: 2 912912011 121112011 hazards including the parameters specified in Table 1 must be conducted by individuals trained in the use of the monitoring equipment and under the supervision of the Entry Supervisor. incapacitation. Contact BEHS for assistance in establishing limits for additional atmospheric hazards (chlorine. Exposure Limits Exposure limits for confined space entry are based on atmospheric concentrations of various parameters capable of causing death. location of potential contaminant sources. inspected and maintained per manufacturers' instructions. A bump test that activates alarms is preferred. These are limits requiring immediate evacuation if exceeded in a confined space.5% to 23. and as specified by the manufacturer. Prior to each day's use. Entrants may observe air monitoring as it occurs. During entry.

The respiratory protection requirements must be documented on the entry permit.2 are satisfied. for the continuous control of atmospheric hazards. continued forced air ventilation is not required.3. Page 17 .2.2. air monitoring must be conducted prior to entry with the ventilation off over a set period of time based on the characteristics of the hazard. or for human comfort during entry. Respiratory protection selection and use. alternate entry procedures may be followed if all requirements of Section 6. including the use of escape packs. The air supply utilized for ventilation must be from a clean source and may not increase the hazards in the space. Forced air ventilation may be used to eliminate a non-recurring atmospheric hazard. shall be in accordance with the DEP Respiratory Protection Policy. additional time is required for the atmospheric sample to be pumped through the hose.1 are satisfied. the ventilation must be directed so as to ventilate the immediate areas where entrants are or will be within the space.4 Personal Protective Equipment Personal protective equipment (PPE) shall be selected in accordance with the DEP Personal Protective Equipment policy. When monitoring confirms that the atmosphere in the space is acceptable and that a hazardous atmosphere will not recur. Health & Safety Revision: 2 912912011 12{112011 Confined Space Entry Program Issuance Date: Effective Date: Meter Response Time Sampling at each location shall be of sufficient duration to allow for meters to respond.3. 6.NEW YORK CITY DEPARTMENT OF ENVIRONMENTAL PROTECTION Policies and Procedures Manual Volume III Envirorunental. Air exhausted from the confined space must be so directed that it does not impact the Attendant or support staff. The Entry Supervisor must identify hazards requmng respiratory protection and consult with the Respiratory Protection Program Administrator to select the proper respiratory protection. Forced air ventilation may be used to remove a non-recurring hazardous atmosphere that cannot be removed through natural ventilation. specify the PPE and document it on the entry permit. For spaces where the ONLY hazard is atmospheric and continuous forced air ventilation can control the atmospheric hazards. If hoses are attached to meters.2. BEHS may be contacted for assistance in hazard assessment and PPE selection.3 Ventilation Natural ventilation should be maximized to the extent feasible by opening covers. When continuous forced air ventilation is used during entry. Consult the operating manual for response times and pump flow rates. it must operate until all entrants have left the space. allowing for reclassification if the requirements of Section 6. To verify that ventilation is not required. hatches or other barriers that restrict the natural flow of air through the space. The Entry Supervisor must identify hazards requiring PPE. 6.2.

and communication between the Attendant and emergency responders. The Entry Supervisor must verify that communication is adequate and communication equipment is operable. If the emergency procedure for an entry cannot be properly implemented. Health & Safety Revision: 2 912912011 121112011 Confined Space Entry Program Issuance Date: Effective Date: For protection of entrants during entry into any IDLH or potentially IDLH atmosphere. and other precautions must be in accordance with a BEHS approved procedure or BEHS must be consulted prior to entry.5 Communication Two types of communication are required during entry: communication between the Attendant and Entrants. and staffing vary from place to place. Entry Supervisor. hand signals. Non-entry rescues can be performed by the Attendant. 6. locations. The Entry Supervisor is responsible for ensuring that non-entry rescue equipment is adequate to carry the weight of those authorized to enter the PReS. Typically. non-entry rescue equipment is rated for 310 lbs.DEPARTMENT NEW YORK CITY OF ENVIRONMENTAL PROTECTION Policies and Procedures Manual VoJumeill Environmental. Entrant-Attendant Communication The minimum level of communication required at all times is the ability to provide notification of an emergency. respiratory protection. non-entry rescues are the preferred method of rescue whenever possible. This may be accomplished through verbal communication. including PPE. and/or other personnel with documented training in non-entry rescue. The Entry Supervisor must verify that the Entrant(s) and Attendant(s) have coordinated signals so there is no confusion that could cause a delay in egress from the space or other emergency action. however. Rescues requiring entry into a PReS shall only be performed by PReS entry rescue-trained DEP personnel and/or available PRes entry rescue services. selection ofPPE.. and document same on the entry permit. the entry shall be postponed and permit cancelled until all issues have been addressed. Attendant-Rescue Communication The Entry Supervisor shall verify that communication between the Attendant and rescue services is adequate and timely based on the specific rescue provisions established for the entry.4 Emergency Procedures The Entry Supervisor is responsible for ensuring that location-specific emergency procedures have been established and communicated to all Entrants and Attendants prior to anyone's entering a PReS since conditions. or other methods. Page 18 . All PReS entries require that plans be established for summoning rescue and emergency services in case a rescue requiring entry is needed. warning horns or signals. equipment ratings vary so each unit should be checked. 6.3. In the event of an emergency requiring rescue. The Attendant shall not have to leave an occupied space unattended in order to make emergency communications.

Health & Safety Confined Space Entry Program Revision: Issuance Date: Effective Date: 2 912912011 121112011 6.1 Evacuation Confined space Entrants are required to immediately evacuate a confined space whenever: » » » )))- » )- An order to evacuate is given by the Attendant. A non-entry rescue allows for the removal of an entrant from a space while minimizing the risk to personnel performing the removal since they do not enter the space. When initiating a non-entry rescue the following should occur: ). Entry Supervisor or other Entrants. An Entrant experiences behavioral effects of hazard exposure. » Confirm that the Entrant's body harness is attached to the retrieval system and that the Entrant is positioned so that he or she will not become entangled with or strike against pipes. 6.4.3 New York City (In-City) . ). The estimated response times are less than 5 minutes which is acceptable to DEP. An unusual or prohibited condition is detected.Pre-Notification of Confined Space Entry PRCS entries which are considered and documented to be routine for in-City Bureaus will be covered under the current DEP-FDNY agreement which does not require pre-notification to FDNY.4.Perform non-entry rescue. Locations and/or types of routine PRCS entries have been reviewed and agreed upon by FDNY and DEP.3. Entry Supervisor.1 Phase I . or Any other situation arises that may compromise the safety of the Entrant. machinery or equipment.4. the condition is abated.If the Entrant has sustained an injury that may be aggravated by non-entry removal and conditions are not immediately dangerous to life and health.2 Non-Entry Rescue Non-Entry rescue is the preferred method of rescue for all PRCS entries and can be performed by the Attendant.Entry Rescue 6.Summon rescue. 6. other emergency services and additional on-site assistance.NEW YORK CITY DEPARTMENT OF ENVIRONMENTAL PROTECTION Policies and Procedures Manual Volume III Envirorunental.4. A situation is detected outside the space that could endanger the Entrant. Confined space Entrants will not re-enter a confined space until the source of the problem is identified. and re-entry is authorized by the Entry Supervisor. The Attendant cannot effectively and safely perform all of his or her duties. wait for professional rescue services to arrive and package the Entrant for removal. ). Communications are compromised. and/or other personnel with documented training in non-entry rescue. Page 19 . An air monitor alarm or evacuation alarm sounds.

Examples ofBWT (non-routine PRCS entries requiring pre-notification to FDNY) • • \i) • Digester Cleaning (less than annually) Chemical Tanks Tide Gates Sewer line entry In situations where use of a body harness might increase the overall risk during entry. All pre-notifications shall be documented on the permit. Health & Safety Confined Space Entry Program Revision: Issuance Date: Effective Date: 2 912912011 121112011 Examples ofBWSO (non-routine PRCS entries requiring pre-notification to FDNY) • • • • Sewer manhole dives to target a connection Visual inspection of a sewer line Plugging a sewer main Sewer Flushing which requires entry of DEP personnel. Queens: Staten Island: 212-999-2222 718-999-3333 718-999-4444 718-999-5555 718-999-6666 Page 20 .NEW YORK CITY DEPARTMENT OF ENVIRONMENTAL PROTECTION Policies and Procedures Manual Volume ill Environmental. Each affected Bureau should periodically communicate with Fire and Police rescue groups to offer coordination.2 Phase II . These designations will be reviewed and updated by Bureaus during their annual program review. or employees need to unhook from the lifeline. Other unanticipated situations may arise that are and may require pre-notification to FDNY to evaluate or plan for more rapid response times. pre-planning and exercise opportunities.3.4. #: (212) 755 . In-City designations of non-routine and routine PRCSs may be found on Pipeline under the Confmed Space Policy. Pre-entry notifications should be made to the Fire Department utilizing the contact information below: Fire Department Chief of Rescue Operations or Officer on Duty Special Operations Command Tel.8684 or 212-755-8597 Fax #: (212) 755 .8470 Police Department Emergency Services Unit Tel. emergency service units shall be provided with advance notification of the entry to be performed. would not facilitate an external rescue. familiarization.Emergency Numbers on Entry Permit The Emergency Phone Number space on each Confined Space Entry Permit must include 911 and one of the following telephone numbers for the Fire Communications Center for the borough where entry is made: Manhattan: Bronx: Brooklyn: . #: (718)-677-8300 Fax #: (718)-677-8330 6.

. address and exact location. The procedure to summon additional emergency services such as medical services (i. ambulance) is to call either 911 or. type of incident if known.4. or when employees will need to unhook from the lifeline. A call (or patch Communications Rescue Unit may time to respond is through by 911 operator) is made to the appropriate Fire Center directly. the DEP Entry Supervisor and/or the Attendant shall ensure the following occurs: 1. the Entry Supervisor must determine how contact will be made with rescue services Page 21 .4.4.2 Prior to allowing any work to be done in an alternate procedure confmed space.4.1 Penn it Required Confmed Spaces In general. 3. the emergency phone number entered in the appropriate space on the entry permit.e. Entry Supervisor or Entrants when needed. In the event of an emergency.NEW YORK CITY DEPARTMENT OF ENVIRONMENTAL PROTECTION Policies and Procedures Manual Volume ill Environmental.Entry Rescue 6. if other than 911. Bureau specific emergency notification protocols are implemented. Alternate Procedure Spaces 6. The confined space rescue team may be a DEP rescue team or a vetted and approved external confined space entry rescue team. Note: a Police Department Emergency be dispatched if FDNY commitments so require. rescue services will be summoned by the Attendant. 6. The caller to 911 must state that this is a "CONFINED SPACE INCIDENT.4. number of people involved. There are a limited number of locations where it may be possible to utilize an offsite rescue team. Average less than five minutes. Health & Safety Revision: 2 9/29/2011 121112011 Confined Space Entry Program Issuance Date: Effective Date: When use of a body harness might increase the overall risk during entry.4 Upstate .. etc.3. All PPE and rescue equipment necessary for making the rescue will be assembled and brought to the site prior to entry into the PRCS being allowed. This notification should be documented on the permit.4.Emergency Situations 6.3 If an emergency situation arises. an on-site rescue team should be assigned and standing by prior to any entries being made into a PReS.). the use of an off-site rescue team must be approved in advance by BEHS and Bureau Senior Management. would not facilitate an external rescue.e." 2. however. The Entry Supervisor will work with the rescue team to ensure that it is afforded access to the PReS and provided with information regarding the planned work activities and associated hazards for rescue pre-planning purposes. emergency service units shall be provided with advance notification of the entry to be performed. 911 is called and the operator is provided with all pertinent information (i. Phase III .

g. Health & Safety Revision: 2 9/291201) 12{112011 ~--------~--------------------------------~~~~==~~. Participants will also be trained in emergency planning and non-entry rescue procedures. to entry supervisor).Be familiar with the emergency services for providing necessary medical services if other than 911. Prerequisite to this training is Entrant/Attendant training.Participants will be trained in the duties of the Entry Supervisor including how to properly assess hazards. whenever there is reason to believe that there are deviations from the accepted program or Page 22 . 4. should the need arise.Trained in the proper use of PPE and rescue equipment. verification of permit conditions and termination and permit close-out procedures. hazard recognition and control.NEW YORK CITY DEPARTMENT OF ENVIRONMENTAL PROTECTION" Policies and Procedures Manual Volume ill Environmental. DEP Confined Space program and other pertinent DEP policies and programs.Each rescue team member will be trained and/or current in the following requirements: ). Entrant! Attendant . PPE. and to plan and supervise entry into confined spaces including completion of entry permit. the assigned rescue duties and in the characteristics of the space. Confined Space Rescue . ). and ). OSHA requires only that a minimum of one member of the rescue team holds a current certification in first aid and CPR. ). The training is designed to ensure that employees acquire the skills.Practiced in making a PRCS rescue at least once every 12 months. proper use of confined space equipment such as air monitoring equipment. Training will emphasize understanding and application of regulations. Entry Supervisor and Hazard Analysis . Training can be provided as broken out below or may be combined depending on the needs of the employee. The applicable phone numbers must be on the entry permit form as well as posted at the communication source that might be used.Training is required before a change in assigned duties (e. 3. 7 TRAINING Confined Space Entry Program Issuance Dare: Effective Date: All employees required to enter a confined space must be trained in DEP entry policies and procedures and the proper use of specified equipment prior to their being assigned confmed space entry duties.Trained to perform confined space entry. Refresher or additional training .. 2. Note: While all members of the recue team must be trained in first-aid and CPR. ). whenever there' is a change in PRCS operations that presents a hazard about which an employee has not previously been trained.Trained in basic first-aid and CPR. understanding and knowledge necessary for the safe performance of duties under this program. Entrant/Attendant training will include an entry into an actual or simulated confined space. 1. Topics to be covered include: hazards that may be faced during confined space entry.Participants will be trained in the duties of the authorized Entrant and the confined space Attendant. ventilation apparatus. and non-entry rescue equipment and standard entry procedures and emergency procedures including performance of non-entry rescue.

If the reviewers believe this DEP Confined Space Entry program should be revised to facilitate hazard control. Right-to-Know). 8 METRICS A~D AUDITING This program must be reviewed annual1y and entry procedures revised. Such employees must be able to recognize the existence of a confined space and be instructed to avoid this hazard. The annual review will include a review of the following: ). The review must be documented using Attachment F. 10 ATTACHMENTS Attachment Attachment Attachment Attachment Attachment Attachment A B C D E F Confined Space Inventory Confined Space Hazard Identification/Evaluation Confined Space Entry Permit Confined Space Reclassification Form Non-Permit Entry Documentation Form Annual Review Documentation Form Page 23 . 2 Confined Space Entry Program Issuance Date: Effective Date: 9/29/2011 1211aOll inadequacies in the employee's knowledge. as needed.> Review Review Review Review Review of all entry permits generated since the last annual evaluation. of permits for proper completion and certification of hazard elimination. Training records will be kept and maintained by BEHS. documentation and recordkeeping. of permits for effectiveness in controlling and communicating hazards.DEP encourages awareness level training and communications for all employees working in locations where they may come into contact with confined spaces but are not expected to enter them. Awareness level training . or whenever there is a significant change in policy.g. Such procedures must be modified for use in subsequent entries as necessary to protect employees. of routine and non-routine PRCS designations. This training can be integrated into other training (e.NEW YORK CITY DEPARTMENT OF ENVIRONMENTAL PROTECfION Policies and Procedures Manual Volume III Environmental. Regulations also allow a rolling evaluation within 1 year after each entry (although this may be more difficult to administer) and do not require a review if no entry was performed during a prior 12-month period. they shall so advise OEHS. by the RI and BEHS.. and of permits for proper close-out. 5. The review will identify entry procedures that did not protect from PReS hazards. employees participating in entry operations. Health & Safety Revision. 9 RECORDKEEPING The RI will retain all canceled entry permits for at least one year to facilitate the annual review of the program.>)0> )0> )0> j.

atmospheric hazards with written standard procedure for alternate entry. ~ Date:. Name I Location of Space PRCS PRCSAtmosphe r ic Only NonPe rmit Con tined Space Not a Confined Space Alternate Entry Proeedure" Non-Pe .ATTACHMENT A CONnNED SPACE INVENTORY Bureau: -------------------- Division: ------------------------------------------------------~ Classification (check box aftercompJetion of Evaluation) Location/OperationIWorkgroup: ___ PRCS Re-Classifieation Status (insert date procedure developed) m No. (Signature) _ _ Person conducting initial inventory: (print name). PRCS with written standard procedure for temporary reclassification to a Non-Permit Confined Space.. Signature of person conducting initial inventory: 24 .mit Entry Procedure" :It * ** PRCS with J!!!!I.

Complete form in Section 3.the space is a confined space. Ifno to afO!question .the space is a Permit-Required Confined Space If all answers are "no" .CONFINED SPACE DETERMINATION lA 1B IC Yes Is space large enough to bodily enter and perform work? D [] Does space have limited or restricted means for entrY and exit? [] Is the space "not desi2ned" for continuous occupancy? If yes to all three .5%) 0 Flammable(>10%LEL) D Toxic/Corrosive(Specify) Other (Specify) Contains a material with the potential for ene:uIfment? If yes.Chemical. Specify: If the answer to any question above is "yes" .CLASSIFICATION 0 Not a Confined Space Non-Permit Required Confined Space Permit-Required Confined Sp_ace With Atmospheric Hazard Only I [] Notes or Comments: Survey Conducted By (Print Name): Signature: Date: 0 0 0 25 . Specify: Oxygen « 19.5%or> 23. Heat. Specify: Contains converging walls or other internal configuration hazard which could cause entrapment? If yes.the space is not a confined space. SECTION 2 .the SJ1!lfeis a Non-Permit Required Confined Space SECTION 3 . Proceed to hazard assessment in Section 2.Noise) No [1 0 0 No 2A 0 0 0 0 0 2B 0 0 2C 2D If yes.ATIACHMENT B CONFINED SPACE EVALUATION AND CLASSIFICATION Bureau: Facility/Location: Description of Space: Space ID#: o Check if this is a reevaluation or reclassificationand explain in Section 3 or attach documentation. SECTION 1. Electrical. Specify: Contains any other serious safety or health hazard? (Mechanical Energy.EVALUATION Yes Contains or has the potential to contain a hazardous atmosphere? If Yes.

ENTRY AUTHORIZATION Type of Entry Requirements All hazards confirmed temporarily eliminated.5 to 23. Entry to be made under permit conditions. Bottom SECTION 2 .PRE-ENTRY I Permit#: I Entry Expiration Yes No nla Date & Time: YeS No nla Draining Cleaning Secure work area Other (specify): Lock-OutlDe-Energizel Isolation Purging/Flushing/V enting Forced Air Ventilation Other (specify): Additional Hazards including those created by work in the space: Hazard: Hazard: Hazard: Entry Equipment Traffic work zone equipment Fall barriers/warning signs Fall protection/non-entry rescue Access ladder Lighting (explosive proof7) Escape Pack Air Monitorine Meter Calibrations Current Bump. ft. Air monitoring results confirm effectiveness of ventilation.5%) LEL «10%) H2S «10 ppm) CO (<35 ppm) Other (specify): Other (specify): Hazard completely controlled/eliminated? Yes No Yes Yes Yes No No No nla Yes Top ft.TestlFresh Air Checks Can acceptable readings be maintained without continuous forced air ventilation? Control: Control: Control: Yes No nla Ventilation (type): Communication (type): PPE (specify): PPE (specify): Other (specify): Other (specify): No nla Pre-Entry Readioes: Oxygen (19.ATTACHMENT C CONFINED SPACE ENTRY PERMIT Date: Location: Space Description: Purpose of Entry: Entry Date & Time: Pre-Entry Preparations I Space ID#: SECTION 1 . Temporary Non-permit Space The only hazard is atmospheric that is controlled by Alternate Procedure Entry continuous forced air ventilation. Entry Supervisor Name: Signature: 26 Select Type 0 0 0 . Sections 3 Permit Required Confined Space and 4 must be complete before signing authorization.

.'.RESCUE PLAN NoD Non Routine Entry? Yes D No D Rescue Team if not 911: Radio Cell Phone Other (specify): Non-Entry Entry rescue: Off-Site Team: On-Site Team: D D [] Other required notification numbers: On-Site Rescue Equipment Retrieval System Harness SCBA Other: Other: 0 D D D Rescue Plan Details: 0 Metet#: Time Area 02 SECTION s .i t..: ':1' IF" .... Authorized Entrants In Out In Out In Out In Out In Out Attendant(s): "'Time m and out must be logged for each entrant.. Rescue Prenotification? Emergency Phone Numbers Emergency Communications Rescue Methods YesD ATTACHMENTC CONFINED SPACE ENTRY PERMIT SECTION 3 . H2S CO Other: I:.:._..... ..ENTRY AND AIR MONITORING LOGS Conducted b DCheck if additional pages used.. '.ADDITIONAL PRCS ENTRY REQUIREMENTS For PRCS entry specify hazard(s) not completely controlled or eliminated and additional precaution(s) to be followed: SECTION 4 .ENTRY CLOSE-OUT FOR PERMIT ENTRIES Reason: DProhibited Condition DOther: Comments and/or problems encountered: o Entry Completed Date: Entry Supervisor Name: Time: Signature: POST PERMIT AT THE CONFINED SPACE DURING ENTRY 27 . SECTION 6 .--'... Time 02 LEL H2S CO Other: LEL Area .

Close and lockout Sludge Outlet valve. This space is now permanently reclassified as a non-permit space unless new hazards appear or are introduced. Elimination Method (List or Attach) 1.Temporary Reclassification: The procedures above (or attached) have been found to reliably eliminate all hazards within this space on a temporary basis. are permanent and all hazards within this space have been permanently eliminated. Note: control of atmospheric hazards throughforced air ventilation does not constitute elimination of the hazards.Permanent Reclassification: Hazard elimination procedures (above or attached) have been implemented. Close and lockout inlet Valves 1 and 2 3. Space . until the work is complete and the controls are removed. D Alternate D Non-Permit o Non-Permit Space . Potential Example: Inundation Hazard Description Potential for water to fin from the main water supply pipes to fill the clarifier with water.: The following actions form the basis for determiningthat all hazards identifiedon Confined SpaceEvaluationsurvey have been eliminatedor controlled. Printed Name Signature of Reviewer Date 28 . Close and lockout chemical feed pump and chemical feed shutoff valve. This space can be temporarily reclassified as a non-permit space using these procedures unless new hazards appear or are introduced. Pump out clarifier to Sludge Tank 4. Entry Procedure Space: I certify that the only hazard(s) are atmospheric hazards within this space and the atmospheric hazard(s) can be controlled by forced air ventilation alone as demonstrated by the attached data (if a PRCS entry was necessary attach permit). These actions must be verified completeprior to reclassificationof this confined space to Non-Permit space or Alternate Entry Procedure space.A'ITACHMENT D Confined Space Reclassification Space Name: Space Location: Date: Space ID No. 2.

' --c- -- -~-~ _- ~- ---- ~---' -- ---- -- --- ----- -_ -- --- -- --_ -- -_ --- -_--'- -- Note problems or issues encountered during entry operations (use back of page ifneeded): -- --- -_ ------ -- 29 .-- --- -~--- ---.e. LEL. H2S Additional required air monitoring based on location (i. ---- --- -- ----- ---. --. Hydrogen Sulfide < 10 ppm. Initial Air monitoring must be performed prior to every entry. CO.. Monitor all items listed in order listed & record time of readings.ATIACHMENT E NON~PERMIT Required Confined Space Entry Air Monitoring Log Date: Location: Description: Nature of work (i.5% to 23. ete. maintenance): Entrant(s): Confined Space # / / Required Air Monitoring ~O2. Ch.e.): Acceptable Air Levels Oxygen 19.5%. Use "other" column for any additional parameters. repair. -- _--. inspection. Other: Carbon Monoxide <35 ppm. Hg. Other: LEL<10%. Oxygen LEL CO Time Location H2S Initials Other opening halfway bottom -- --~ .

. Also. or routine/non-routine designations? Are labels. attendants.. Envfronmental Pl'Qtectlon ATTACHMENT F ANNUAL CONFINED SPACE PROGRAM REVIEW Bureau/Di visionIF acility: Individual Responsible for Local Program: Annual Review Participants: Review Date: Yes No nla Identification. Use back of form if additional space is needed. Evaluation and Labeling of Confined Spaces Have inventories and evaluations been updated to reflect changes to facilities. including temporary reclassifications & alternate procedure entries. list corrective actions and name of individual responsible for follow-up. Local Program including permits and entry procedures: Program issues to be sent to OEHS: Reviewer Name: SignaturelDate: Individual Responsible for Local Program: Signature/Date: 30 ... Was training current for entrants. program... supervisors and rescue personal at the time of the enjry? Corrective Actions and Comments Based on the information above as well as feedback from review participants. Were there any injuries or near misses attributable to failure of the program or failure to follow the program? Were there any conditions encountered that were not captured on the evaluation or identified on the entry permit? Were entry procedures adequate to protect employees from PRes hazards? D D D D D 0 D "0 Training 0 For a representative sample of permits obtain training records for the entry team.. _ I. note the specific sections below and obtain feedback from the entry supervisor to identify corrective actions to the pennit entry procedures or written program. signs or other methods used to inform employees of permit-required confined spaces? 0 D D D D D D 0 00 0 D D 0 0 D 0 Permit Review Review permits from last 12 months..n. equipment andlor hazards. provide any comments or concerns to be forwarded to OEHS regarding the Agenc. D Are entry preparations and precautions appropriately noted on the permits? For a representative sample of permits obtain the confined space evaluations. Are the entry preparations and precautions consistent with the hazards listed in the evaluation? Are permits consistently correct and complete? If not.

and 2. who is this and what are their responsibilities? 10) What about tunnels and shafts. This FAQ is not intended to rep/ace the need jor BEDC and contractor employees to be familiar and comply with the DEP Policy requirements. required with This FAQ should serve as a "quick-guide" to the OEP's and BEDC'sConfined Space Requirements and the expectations for all BEOCemployees that All persons exposed to or entering confined spaces are to have training prior to the exposure/entry. some mechanical spaces. Examples of typical non-permit required confined spaces at BEOCsites include: new tank that has not been filled nor is connected to be filled. a BEDCemployee was identified as entering a confined space without appropriate training. and 3. Recently. are they confined spaces? 6 What is a confined space? Any space that: 1. PAGE 1 2 2 3 4 4 5 5 6 QUESTIONSINCLUDED 1) 2) 3) 4) 6) 7) 8) 9) What is a confined space? How is a permit required confined space different from a non-permit required confined space? When I'm in the field how willi know a space is a confined space? What should I know about confined spaces? How do all these requirements work when the operating bureau is present with BEOC? How do all these requirements work when there is no operating bureau present? Do I need training to enter a confined space? I'm on the design side. Is not designed for continuous employee occupancy.Envfronmental Protection BEDCEHS CONFINED SPACE FREQUENTLY ASKED QUESTIONS (FAQ) BEDCroutinely receives questions about confined spaces and their associated entry procedures. coordination. may be exposed to or enter a confined space. HVAC plenums wj restricted access. open pits without engulfment hazard. Is large enough and so configured that an employee can bodily enter and perform assigned work. . Confined spaces are classified as either a "permlt required confined space" (PRCS)or "non-permit required confined space" (non-PRCS). does this affect me also? 5) The DEP Policy talks about a Contract Supervisor. Has limited or restricted means for entry or exit. ductwork. or compliance with DEPjOSHA requirements.

October 11. You must ensure that whenever you are at a site with which you are unfamiliar. 2011 BEDC EHS Confined Space FAQ Page 2 of6 . or 3. Operating bureaus may also use alternative means of identifying confined spaces such as placing signage at entries to buildings or floors. CONFINED SPACE ENTER BY PERMIT ONLY When JIm in the field how willI know a space is a confined space? Confined spaces are routinely indicated by the posting of standardized red. or 2. that you receive an orientation which also includes the method(s) utilized by the site to label confined spaces. or may use an inventory system along with training to communicate the confined space locations. or 4. sump pits. digesters. white and black signage. A PRCSis a confined space that has one or more of the following characteristics: 1. Contains any other recognized or potentially serious safety or health hazard. screening channels. Contains a material that has the potential for engulfing an entrant. Contains or has the potential to contain a hazardous atmosphere. Examples of typical PReSat BEOCsites include: tanks. Has an inward 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.How is a permit required confined space different from a non-permit required confined space? A permit required confined space (PRCS)is a special subcategory of confined space.

4. implement remaining controls. (These options are more fully covered in the DEP Policy and are discussed in detail within the Entry Supervisor training course. implement required controls. This planning includes reviewing the space assessment and confirming the space conditions are consistent. i. all Entrants must be connected to a non-entry rescue/retrieval system. notify rescue services.) 4. If hazardous situation is identified during entry the Entrant{s) must exit and secure the space and notify the supervisor to allow the space to be re-evaluated.What should I know about confined spaces? Because of the hazards inherent in confined spaces OSHA and the DEP have put procedures in place to ensure the safety of personnel. These include review entry permit and perform pre-entry checks. Both non-PRCS and PRCShave specific entry procedures that must be complied with in order to enter. The air monitoring readings must be recorded on the permit at least every 15 minutes. Continuous air monitoring of the space must occur during entry. The entry team is responsible for complying with the pre-entry procedure requirements. Air monitoring is required if the non-PRCS is unventilated (and air monitoring is documented). The Entry Supervisor may also temporarily reclassify the space or may establish an alternate entry procedure. review prior entry permits. As needed space entrance should be guarded/attended to prevent a fall hazard. 3. and BEDCEHS. and install forced ventilation if needed and conduct and document additional air monitoring. 2011 BEDC EHS Confined Space FAQ Page 30fG . For PRCSthese entry procedures include: 1. For non-PRCS. review the work to be performed. perform and document initial air monitoring. There will be some limited entries where procedures are put in place to allow disconnection from the retrieval system. These requirements include that all confined spaces require training in order to access (see below for a more detailed description). a. The Entry Supervisor is responsible for entry planning. These procedures need to be well developed and implemented and should be reviewed and coordinated between the Contractor. Upon completion of the above steps the Entry Supervisor may authorize entry in accordance with the classification and permit work procedures. Verify work activities in or around space will not create hazards that could affect space classification. operating bureaus may develop equivalent or more stringent requirements which must be complied with at their sites. October 11. Generally. 2. 3. open space and install necessary protections. If authorized by the Entry Supervisor then entry may be made by the Entrant(s). confirm the entry team is properly trained. b. 2. Additionally. 5. CM.these entry procedures include: 1. and notify other workers and supervisors in the area that a PRCSis to take place. Adequate personnel must be present and this number is dependent upon the space characteristics and location.

For BEDCwe hold the Accountable Manager responsible as the Contract Supervisor (though the AM may rely upon their field support staff to perform these roles and responsibilities. e. Coordinate with the facility Responsible Individual all contractor activities involving confined spaces to ensure that contractor is made aware of: a. Precautions or procedures DEP utilizes to protect personnel in or near the PRCS 2. unusual odors. etc. All safety and health issues observed during the entry must be noted on the permit. b. Known or suspected hazards present within PRCSbased upon DEP's experience. October 11. The Contract Supervisor is responsible to: 1. After the entry is complete the completed permit must be submitted to the Responsible Individual.) arise either inside or outside the space. all contractors are required to comply with the DEP confined space policy. The DEP Policy talks about a Contract Supervisor. 2011 BEOC EHS Confined Space FAQ Page40f6 . i. If any hazards that may endanger entrants [l. air monitoring alarms. Presence of PRCSthat will need to be entered. d.. Re-entry may not be made until all air monitoring results are within the acceptable range and/or any other hazardous condition is corrected. and c. The contractor(s) must incorporate the DEP requirements into their Confined Space Program and BEDCEHSis responsible for reviewing that program for compliance. All confined spaces shall be classified by the Operating Bureau and may only be re-classified where agreed upon by both the Operating Bureau and Contractor{s). who is this and what are their responsibilities? The DEP Policy defines the Contract Supervisor as the person responsible for managing and overseeing the Contract. Implement any permit controls that required entry into the space. the space must be immediately evacuated. i.e. ii.c. Coordinating the confined space entries with facility Responsible Individual when both DEP and contractor personnel witl be in or near the PRCS. Copies of permits for all entries made on BEDCprojects must be maintained on site by the Construction Manager. the AM holds the ultimate responsibility). The Entry Supervisor will close-out and cancel the permit when work is complete or an unexpected hazardous condition is identified that prevents the entry to proceed as planned. How do all these requirements work when the operating bureau is present with BEDC? Whenever a space is shared by both DEP personnel and contractors.

unless or until a re-evaluation and re-classification by the contractor is completed (and the BEDCContractor Supervisor agrees to the re-classification). the contractor must utilize the DEP confined space classifications. when the policies or procedures change. or when there is reason to believe that an employee's training needs refreshing. affiliation. an employee's duties are increased beyond their current level of training. that rescue service will be utilized for all personnel entering under that permit. When DEP personnel are required. have successfully taken a DEP Confined Space Entrant/Attendant serving as the entry supervisor or performing confined space hazard analysis must have additionally taken the DEP Confined Space Entry Supervisor level training course. the entry should be made under the Contractor's permit and entry procedures. However. Additional training is required when hazards are present for which the employee has not been trained. 2011 BEOC EHS Confined Space FAQ Page 5 of 6 . whether for inspection or observation purposes to enter a PRCS wholly relinquished to the contractor. at a minimum.the contractor(s) may utilize their own Confined Space Program if that program meets/exceeds all OSHA requirements. at a minimum. Where the Contractor provides a rescue service. Personnel required to enter confined spaces must.For CSentries made jointly with both DEP and Contractor personnel. Personnel October 11. regardless of their company How do all these requirements work when there is no operating bureau present? When an area has no active DEPoperations and has been cleared and released to BEDC. the Contractor will utilize the DEP PRCSpermit or Operating Bureau equivalent. level training course. 00 I need training to enter a confined space? YESI All employees required to enter a confined space must be trained in DEPentry policies and procedures.

they will typically consider the space to be a confined space (and enter using those requirements) in order to allow them to establish all the controls necessary for compliance with the underground construction standard. However. this should be identified in their Health & Safety Plan/Safe Work plan. of whether they are either a This FAQ is not intended to replace the DEPConfined Space Entry Program. This FRTKtraining. like this FAQ. are they confined spaces? Yes. 2011 BEDC EHS Confined Space FAQ Page 60f6 . (For example. for construction work OSHA provides a specific underground construction standard that may be followed instead of these confined space requirements. designer. tunnels and shafts are generally considered to be confined spaces. BEDCpersonnel that are required to enter confined spaces or work at sites where confined spaces are present must ensure that they are familiar with the full requirements of the DEPConfined Space Entry Program. regardless of whether your role is a planner. Moving that same gauge to the other side of the wall so that it is outside the confined space will reduce the burden placed on the operating bureau personneL) What about tunnels and shafts. or just a visitor at a site. Designers should note the presence of confined spaces as part of their design review and should consider these when placing equipment/gauges that require routine review/service since placement will affect the user's ability to operate the equipment or read the gauge. I'm on the design side.All BEDCfield employees receive the Facility Right to Know (FRTK)training which includes awareness level training on confined spaces. Upon establishment of those controls the space can then be treated in accordance with the underground construction standard. Where a contractor desires to utilize the OSHA Underground Construction Standard. Where a contractor desires to follow the underground construction standard. these rules affect everyone that may ever visit and be exposed to a confined space. is intended to allow personnel to recognize the existence of confined spaces and to avoid entry without proper training. October 11. does this affect me also? Yes. construction manager. if a gauge that requires an operator to record a reading each shift is placed inside the door of a confined space the operating bureau personnel will need to make three confined entries per day in order to record. like other spaces (and as described above) these must be classified prior to entry for determination non-PRCS or PRCSand the same rules discussed above will apply.

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