Confined space entry responsibilities/procedures

The contractors SSAHPs at Sites B, F, and K had general confined space provisions but lacked site-specific confined space procedures. For example, SSAHPs for the Site K contractor and subcontractor had written confined space entry programs, but the programs did not establish site-specific rescue procedures or identify the confined space hazards present on the site. The job hazard analyses for both programs failed to address site maintenance tasks that could involve confined space entry and hot work hazards. The programs also failed to identify the specific person or position responsible for supervising confined space entry procedures and the location of permit-required confined spaces on site. Interviews with both contractors indicated confusion about rescue procedures. 

Procedural or operating procedures, for example, operator response to alarms, emergency response procedures, safety rules and standard procedures, training. An example is a confined space entry procedure. 

Station at least one attendant outside during entry and coordinate actions with contractors used to conduct rescue procedures. Establish a written permit system and review the effectiveness of the system annually. OSHA also requires training to ensure that employees involved in confined space work can perform their job functions safely. This training covers specific items for the authorized entrant, the attendant, and the entry supervisor. Training will cover the following authorized entrant responsibilities (1) hazards involved in confined space entry, (2) use of appropriate PPE for confined space entry, (3) communication policies with the attendant, (4) requirement to leave... 

Work outside the normal routine needs special management control. This requires formal procedures, carefully followed, for such things as confined space entry, hot work, and line breaking and equipment opening. The procedures should cover the activities of operators, plant maintenance workers, contractors, and any others who may become involved. Written documents should spell out responsibilities, approval mechanisms, tagout procedures, and methods for verification of proper completion. 

Figure 14.1 Confined space entry requires clear procedures, training, permit-to-work and emergency response (photo courtesy of Joe Maglizza and MARCSTA, Australia)...

The role of the confined space attendant should not be taken lightly, as their responsibilities can literally save lives. Unfortunately, the person assigned to the role of attendant is often an entry-level employee who has not been properly trained in confined space entry safety. In other cases, a local off-duty fireman or friend of a worker is brought in to serve as the confined space attendant. Even local fireman can pose a risk if not trained in OSHA protocol and confined space procedures. 

The next step is for the company to develop and implement a written safety program for all permit-required confined spaces that complies with OSHA 1910.146. The company is also responsible for employee training on confined space entry and providing proper personal protective or fall protection equipment. Even if the confined space is not regulated by OSHA, appropriate fall protection equipment and rescue procedures should be used in any confined space that presents a fall hazard. 

Typical work requiring a permit to work includes hot work, entry into confined spaces, excavations, high voltage electrical work, work involving toxic and hazardous chemicals etc. For a permit to work to be effective it is essential that all those involved understand the system, the procedure and the importance of following the laid down procedure. Before the work starts all those concerned should be trained in the system and their individual responsibilities emphasised. 

Under this program, we identify permit-required spaces in our facihty and provide training for our employees according to their responsibilities in the permit space. These employees receive instructions for safe entry into our specific type of confined spaces, including testing and monitoring, appropriate personal protective equipment, rescue procedures, and attendant responsibilities. 

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