ACC staff and employees shall be provided with the knowledge of and protection from health hazards posed by confined space entry. The minimum standard that will be followed is OSHA's "permit-required confined spaces", 29CFR1910.146. (View here).
Access shall be denied until the space has been cleared for entry in accordance with this policy.
All confined spaces located at the Austin Community College District shall be inventoried, investigated and classified by EHS&I. ACC has compiled a Confined Space Database that identifies and classifies potential confined spaces on all ACC Campuses. The spaces are classified as:
||Designation in the online
Confined Space Database
Not a Confined Space
No Permit Required Confined Space
Permit Required Confined Space
Temporary Non Permit Required Confined Space
Note: ACC Faculty and Staff shall not be entering any Permit Required Spaces.
This program outlines responsibilities and provides procedures necessary to safely manage confined spaces and entry. It is intended to ensure that ACC personnel who enter confined spaces have:
- received appropriate training,
- appropriate personal protective equipment (PPE),
- appropriate document approval from EHS&I where needed
- any information necessary to ensure their safety while entering confined spaces
Note: Contractors who perform Confined Space Entry are required to have EHS approval
This program defines the confined space entry procedures that all ACC Faculty, Staff, and contractors shall follow.
This program is applicable to all ACC owned or leased facilities.
"Acceptable entry conditions" means the conditions that must exist in a permit space to allow entry and to ensure that employees involved with a permit-required confined space entry can safely enter into and work within the space.
"Authorized Attendant" means an individual (authorized by their employer) stationed outside one or more permit spaces who monitors the authorized entrants and who performs all attendant's duties assigned in the employer's permit space program.
"Authorized Entrant" means an employee who is authorized by the employer to enter a permit space.
"Authorized Entry Supervisor" means the person (authorized by their employer such as the employer, foreman, or crew chief) responsible for determining if acceptable entry conditions are present at a permit space where entry is planned, for authorizing entry and overseeing entry operations, and for terminating entry as required by this guideline.
NOTE: An entry supervisor also may serve as an attendant or as an authorized entrant, as long as that person is trained and equipped as required by this program for each role he or she fills. Also, the duties of entry supervisor may be passed from one authorized individual to another authorized individual during the course of an entry operation.
"Blanking or blinding" means the absolute closure of a pipe, line, or duct by the fastening of a solid plate (such as a spectacle blind or a skillet blind) that completely covers the bore and that is capable of withstanding the maximum pressure of the pipe, line, or duct with no leakage beyond the plate.
"Confined space" means a space that:
- Is large enough and so configured that an employee can bodily enter and perform assigned work; and
- Has limited or restricted means for entry or exit (for example, tanks, vessels, silos, storage bins, hoppers, vaults, and pits are spaces that may have limited means of entry.); and
- Is not designed for continuous employee occupancy.
"Double block and bleed" means the closure of a line, duct, or pipe by closing and locking or tagging two in-line valves and by opening and locking or tagging a drain or vent valve in the line between the two closed valves.
"Emergency" means any occurrence (including any failure of hazard control or monitoring equipment) or event internal or external to the permit space that could endanger entrants.
"Engulfment" means the surrounding and effective capture of a person by a liquid or finely divided (flowable) solid substance that can be aspirated to cause death by filling or plugging the respiratory system or that can exert enough force on the body to cause death by strangulation, constriction, or crushing.
"Entry" means the action by which a person passes through an opening into a permit-required confined space. 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.
"Entry permit (permit)" means the written or printed document that is provided by the employer to allow and control entry into a permit space.
"Hazardous atmosphere" means an atmosphere that may expose employees to the risk of death, incapacitation, impairment of ability to self-rescue (that is, escape unaided from a permit space), injury, or acute illness from one or more of the following causes:
- Flammable gas, vapor, or mist in excess of 10 percent of its lower flammable limit (LFL);
- Airborne combustible dust at a concentration that meets or exceeds its LFL; NOTE: This concentration may be approximated as a condition in which the dust obscures vision at a distance of 5 feet (1.52 m) or less.
- Atmospheric oxygen concentration below 19.5 percent or above 23.5 percent;
- Atmospheric concentration of any substance for which a dose or a permissible exposure limit is published in Subpart G, Occupational Health and Environmental Control, or in Subpart Z, Toxic and Hazardous Substances, of this Part and which could result in employee exposure in excess of its dose or permissible exposure limit; NOTE: An atmospheric concentration of any substance that is not capable of causing death, incapacitation, impairment of ability to self-rescue, injury, or acute illness due to its health effects is not covered by this provision.
- Any other atmospheric condition that is immediately dangerous to life or health. NOTE: For air contaminants for which OSHA has not determined a dose or permissible exposure limit, other sources of information, such as Material Safety Data Sheets that comply with the Hazard Communication Standard,1910.1200, published information, and internal documents can provide guidance in establishing acceptable atmospheric conditions.
"Hot work permit" means the employer's written authorization to perform operations (for example, riveting, welding, cutting, burning, and heating) capable of providing a source of ignition.
"Immediately dangerous to life or health (IDLH)" means 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 space.
NOTE: Some materials -- hydrogen fluoride gas and cadmium vapor, for example -- may produce immediate transient effects that, even if severe, may pass without medical attention, but are followed by sudden, possibly fatal collapse 12-72 hours after exposure. The victim "feels normal" from recovery from transient effects until collapse. Such materials in hazardous quantities are considered to be "immediately" dangerous to life or health.
"Inerting" means the displacement of the atmosphere in a permit space by a noncombustible gas (such as nitrogen) to such an extent that the resulting atmosphere is noncombustible.
NOTE: This procedure produces an IDLH oxygen-deficient atmosphere.
"Isolation" means the process by which a permit space is removed from service and completely protected against the release of energy and material into the space by such means as: blanking or blinding; misaligning or removing sections of lines, pipes, or ducts; a double block and bleed system; lockout or tagout of all sources of energy; or blocking or disconnecting all mechanical linkages.
"Line breaking" means the intentional opening of a pipe, line, or duct that is or has been carrying flammable, corrosive, or toxic material, an inert gas, or any fluid at a volume, pressure, or temperature capable of causing injury.
"Non-permit confined space" means a confined space that does not contain or, with respect to atmospheric hazards, have the potential to contain any hazard capable of causing death or serious physical harm.
"Oxygen deficient atmosphere" means an atmosphere containing less than 19.5 percent oxygen by volume.
"Oxygen enriched atmosphere" means an atmosphere containing more than 23.5 percent oxygen by volume.
"Permit-required confined space (permit space)" means a confined space that has one or more of the following characteristics:
- Contains or has a potential to contain a hazardous atmosphere;
- Contains a material that has the potential for engulfing an entrant;
- 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
- Contains any other recognized serious safety or health hazard.
"Permit-required confined space program (permit space program)" means the employer's overall program for controlling, and, where appropriate, for protecting employees from, permit space hazards and for regulating employee entry into permit spaces.
"Permit system" means the employer's written procedure for preparing and issuing permits for entry and for returning the permit space to service following termination of entry.
"Prohibited condition" means any condition in a permit space that is not allowed by the permit during the period when entry is authorized.
"Rescue service" means the personnel designated to rescue employees from permit required confined spaces.
"Retrieval system" means the equipment (including a retrieval line, chest or full-body harness, wristlets, if appropriate, and a lifting device or anchor) used for non-entry rescue of persons from permit required confined spaces.
"Temporary Non-permit confined space" (PRCS-T) means a confined space that poses no actual or potential atmospheric hazards and all hazards within the space are eliminated without entry into the space. (e.g. lockout)
NOTE: Control of atmospheric hazards through forced air ventilation does not constitute elimination of the hazards.
"Testing" means the process by which the hazards that may confront entrants of a permit space are identified and evaluated. Testing includes specifying the tests that are to be performed in the permit space.
NOTE: Testing enables employers both to devise and implement adequate control measures for the protection of authorized entrants and to determine if acceptable entry conditions are present immediately prior to, and during, entry.
The ACC President is responsible for ensuring adequate staff and funds are budgeted each year to support this program, including funds for engineering and/or administrative controls and training.
Vice-Presidents, Deans, Department Chairs, Directors, Managers, and Supervisors
- Ensure Faculty and Staff in their charge complies with the ACC Confined Space Program.
- Implement the ACC Confined Space Program within their area.
- Ensure that affected employees, Faculty and Staff participate in training programs as prescribed by this guideline/procedure.
Faculty and Staff Using Outside Contractors
- Ensure their contractors comply with ACC's Contractor Safety Guidelines and Procedures and the ACC Confined Space program.
- Review all contractor job assignments requiring confined space entry with ACC EHS&I before work starts.
- Obtain a copy of the contractors confined space program and training records prior to any confined space entry for review by EHS&I.
Contractors Working for ACC
- Comply with ACC's Contractor Safety Guidelines and Procedures and all applicable local, state, and federal requirements for confined space.
- Prior to any confined space entry, provide copies of their confined space program and training records to ACC EHS&I for review.
- Utilize any available information from the Austin Community College District regarding the permit-required confined space hazards and entry operations prior to entry.
Oversee and manage the confined space procedures and guidelines including:
- Assess the need for confined space entry at ACC.
- Identify and classify confined spaces. Maintain a searchable database of confined spaces
- Assist with assessments to identify all engineering and administrative controls available to eliminate or reduce the need for confined space entry.
- Determine if a permit-required confined space can be reclassified as a non-permit confined space.
- Implement the measures necessary to prevent unauthorized entry into a permit-required confined space by posting warning signs or other equally effective means.
- Lend assistance to Vice-Presidents, Deans, Department Chairs, Directors, and Supervisors in determining the tasks, activities, locations, etc., where confined space entry is necessary.
- Conduct periodic assessments of the guidelines and procedures, including training, to assure its effectiveness. Develop corrective action plans as needed to close gaps highlighted in the periodic assessments.
- Review contractors confined space program and training records prior to any confined space entry and notify them in writing of any known hazards in the confined space.
- Initially review and approve all departmental procedures for specific temporary non-permit-required confined spaces prior to implementation.
- Provid a means of training employees involved with entry into a confined space that has temporarily been reclassified as a non-permit confined space via lockout tagout, etc.
- Coordinate with the contractor's competent person to ensure proper procedures are in place, including communicating the potential hazards present, prior to entry.
- Periodically auditing contractor confined space entry.
Note: ACC's due diligence activities does not substitute for the contractor's responsibility for ensuring the safety of their employees.
Frequently Asked Questions
Who is responsible for identifying confined spaces?:
How do I determine if a space is a confined space?:
Consult the Confined Space database on the ACC EHS&I website or contact EHS&I.
How are confined spaces identified?:
Permit-required confined spaces on Austin Community College property shall inform employees of the existence of such a space by posting a warning sign.
When posting of warning signs is not feasible (e.g., sewers, pits), as determined by EHS& I Office, confined spaces shall be identified by other equally effective means (e.g., training).
Who is permitted to enter a confined space?:
Only those employees and contractors who have proper training and are authorized by ESH&I.
Note: ACC Staff and employees will not enter a permit required confined space.
What are the procedures for Non-Permit Required Confined Space Entry (CS)?:
A non-permit required confined space poses no hazard to an employee more serious than its restricted means of entry and exit. Therefore, provided that the work to be performed lacks any potential to create a prohibited or unacceptable condition, entry to a non-permit-required confined space may proceed as described below:
- Develop a work plan (e.g. Job Safety Analysis (JSA)) to determine what precautions are needed to work safely including requirements for:
- An entrant to wear a personal four gas meter for continuous air monitoring of the atmosphere
- Personal protective equipment.
- At least 2 people shall be present for any NPCS entry. One shall act as an attendant while the other(s) enter the space.
- Two way communications with Campus Police’s Dispatch office will be maintained in case of emergency
- Review the work plan with EHS&I.
Note: Entry shall only be allowed after receiving verbal approval from a member of ACC’s EHS & Insurance staff prior to each entry.
- Lockout of any forms of hazardous energy
- Establish traffic control barriers at the entry point, if applicable.
- Eliminate any condition making it unsafe to remove the confined space entry cover.
- Once the entry cover is removed, promptly guard the entry point with a temporary barrier to prevent an accidental fall through the opening and protect employees working in the space from foreign objects entering the space.
- Ensure a safe means of communication is available.
- Ensure appropriate lighting and/or equipment (e.g., ladders) for safe entry and exit by entrants is available.
Note: Activities such as chemical usage, welding etc. can result in a change in the atmosphere of a confined space. If these activities are to be performed within a confined space designated as a non-permit confined space it will be reclassified as a permit required confined space.
How can a Permit-Required Confined Space be reclassified to Non-Permit Required Confined Spaces (PRCS-T)?:
Under certain conditions, EHS&I may temporarily reclassify a permit-required confined space to non-permit-required. This action can facilitate entry into the space by reducing the entry requirements. The specific conditions necessary to allow this temporary reclassification are as follows:
- All hazards within the permit space are eliminated prior to entry through isolation techniques (e.g., lockout/tagout, line blocking, purging) which must be accomplished without having to enter the space.
- The space poses no atmospheric hazard (actual or potential) during entry. Any atmospheric hazard eliminated shall remain eliminated throughout the duration of the entry operation.
- Note: The use of continuous forced air ventilation to control an atmospheric hazard does not “eliminate” the hazard and thus does not constitute compliance with this condition.
- EHS&I shall document this reclassification and that all hazards in the space have been eliminated. This documentation is then made available to all employees entering the space by posting it at the entry point to the space.
- The procedure for Confined Space Entry shall be followed.
Note: The reclassification remains valid only for as long as the hazards remain eliminated. If a hazard is detected during entry, all employees will immediately evacuate the space and the entry supervisor will evaluate the space to determine how the prohibited conditions developed and implement measures to eliminate the prohibited conditions and prevent its recurrences before any subsequent re-entry.
Can we use alternate procedures for Permit-Required Confined Spaces?:
- Yes however alternate procedures can only be used when EHS approves it in writing and
- Documented monitoring and inspection data supports that:
- The only hazard present in a confined space is an actual or potential atmospheric hazard
- It can be controlled through continuous forced air ventilation alone.
- The documents are made available to anyone who enters the space.
What is the process for using alternate procedures?
- Contact EHS&I to develop and document an alternate procedure.
- The alternate procedure shall include:
- Any conditions making it unsafe to remove an entrance cover shall be eliminated before the cover is removed.
- When entrance covers are removed, the opening shall be promptly guarded by a railing, temporary cover, or other temporary barrier that will prevent an accidental fall through the opening and that will protect each employee working in the space from foreign objects entering the space.
- Before anyone enters the space, the internal atmosphere shall be tested, with a calibrated direct-reading instrument, for oxygen content, for flammable gases and vapors, and for potential toxic air contaminants, in that order.
- Anyone who enters the space shall be provided an opportunity to observe the pre-entry testing.
- There may be no hazardous atmosphere within the space whenever any employee is inside the space.
- Continuous forced air ventilation shall be used, as follows:
- An employee may not enter the space until the forced air ventilation has eliminated any hazardous atmosphere.
- The forced air ventilation shall be so directed as to ventilate the immediate areas where an employee is or will be present within the space and shall continue until all employees have left the space.
- The air supply for the forced air ventilation shall be from a clean source and may not increase the hazards in the space.
- An entrant will wear a personal four gas meter for continuous air monitoring of the atmosphere
- If a hazardous atmosphere is detected during entry:
- Each employee shall leave the space immediately.
- The space shall be evaluated to determine how the hazardous atmosphere developed.
- Measures shall be implemented to protect employees from the hazardous atmosphere before any subsequent entry takes place.
- EHS&I shall verify that the space is safe for entry and that the required pre-entry measures have been taken, through a written certification that contains:
- The date
- The location of the space
- The signature of the person providing the certification.
- The certification shall be made before entry and shall be made available to anyone entering the space
Who is authorized to do Permit-Required Confined Space Entry?
Trained contractors are the only persons authorized to enter a permit-required confined space.
What is the process for Permit Required Confined Space Entry?
- Only approved contractors (by EHS&I) shall perform permit required confined space entry using their confined space procedures (which shall comply with all college, local, state and federal regulations)
- EHS&I shall be contacted at least a week prior to the anticipated entry into a permit-required confined space to review and approve the contractors confined space entry program and personnel.
EXCEPTION: EHS&I Office shall be notified immediately during an emergency situation involving the anticipated entry into a permit-required confined space to perform the appropriate evaluations.
What are the conditions to be met prior to entry into a permit-required confined (PRCS) space?
The following conditions shall be met prior to entry into a permit-required confined space:
- The entry supervisor shall:
- perform a visual inspection of the permit-required confined space and document the general purpose of entry and nature of hazards on the entry permit;
- conduct pre-entry monitoring to determine if the space contains a hazardous atmosphere and document all results on their confined Space Permit
- If the permit-required confined space is determined as safe for entry, then a permit will be issued. If a permit is denied, the contractor’s competent person will identify the measures to be taken in order for a permit to be awarded and entry into the PRCS shall be prohibited until the space is deemed safe for entry.
- If an entry permit is awarded, the entry supervisor shall complete and post the entry permit at the entry portal of the permit-required confined space.
- The authorized entrant(s) shall wear a personal four gas meter for continuous air monitoring of the atmosphere in the permit-required confined space.
- The entry supervisor shall supervise the entry team's implementation of the means, procedures and practices necessary for safe entry operations which include, but are not limited to, the following:
- Isolating the permit space by blanking or blinding; misaligning or removing sections of lines, pipes, or ducts; using a double block and bleed system; using lockout or tagout procedures; or blocking or disconnecting all mechanical linkages.
- Purging, flushing, or ventilating the permit-required confined space as necessary to eliminate or control atmospheric hazards.
- Providing pedestrian, vehicle, or other barriers (e.g., barricades, tape) to protect entrants from external hazards whenever a permit-required space is entered.
- Only the assigned tasks or activities identified on the permit shall be conducted within the permit-required space and the duration of the permit may not exceed the time required to complete those assigned tasks or activities.
Note: If the assigned work goes beyond the planned time period or work tasks/activities other than those identified on the permit become necessary, the entrant shall leave the space and inform the supervisor of the expiration of the permit or of the newly proposed work tasks or activities.
- The entry supervisor shall immediately re-evaluate the space in regard to the proposed work task or activity.
What are the responsibilities of an authorized entrant?
- Know the hazards that may be faced during entry, including information on the mode, signs or symptoms, and consequences of the exposure.
- Properly use the required equipment.
- Communicate with the attendant as necessary to enable the attendant to monitor entrant status and to enable the attendant to alert entrants of the need to evacuate the space as needed.
- Alert the attendant whenever:
- The entrant recognizes any warning sign or symptom of exposure to a dangerous situation, or
- The entrant detects a prohibited condition.
- Exit from the permit space as quickly as possible whenever
- an order to evacuate is given by the attendant or the entry supervisor,
- or the entrant recognizes any warning sign or symptom of exposure to a dangerous situation,
- The entrant detects a prohibited condition, or
- An evacuation alarm is activated.
What are the responsibilities of an authorized attendant?
- Knows the hazards that may be faced during entry, including information on the mode, signs or symptoms, and consequences of the exposure.
- Is aware of possible behavioral effects of hazard exposure in authorized entrants.
- Continuously maintains an accurate count of authorized entrants in the permit space and ensures that the means used to identify authorized entrants accurately identifies who is in the permit space.
- Remains outside the permit space during entry operations until relieved by another authorized attendant.
- Communicates with authorized entrants as necessary to monitor entrant status and to alert entrants of the need to evacuate the space.
- Monitors activities inside and outside the space to determine if it is safe for entrants to remain in the space and orders the authorized entrants to evacuate the permit space immediately under any of the following conditions:
- If the attendant detects a prohibited condition.
- If the attendant detects the behavioral effects of hazard exposure in an authorized entrant.
- If the attendant detects a situation outside the space that could endanger the authorized entrants.
- If the attendant cannot effectively and safely perform all their required duties.
- Summons rescue and other emergency services as soon as the attendant determines that authorized entrants may need assistance to escape from permit space hazards.
- Takes the following actions when unauthorized persons approach or enter a permit space while entry is underway:
- Warn the unauthorized persons that they must stay away from the permit space.
- Advise the unauthorized persons that they must exit immediately if they have entered the permit space.
- Inform the authorized entrants and the entry supervisor if unauthorized persons have entered the permit space.
- Performs non-entry rescues as specified by the employer's rescue procedure.
- Performs no duties that might interfere with the attendant's primary duty to monitor and protect the authorized entrants.
What are the responsibilities of an entry supervisor?
- Knows the hazards that may be faced during entry, including information on the mode, signs or symptoms, and consequences of the exposure.
- Verifies, by checking that the appropriate entries have been made on the permit, that all tests specified by the permit have been conducted and that all procedures and equipment specified by the permit are in place before endorsing the permit and allowing entry to begin.
- Terminates the entry and cancels the permit as required.
- Verifies that rescue services are available and that the means for summoning them are operable.
- Removes unauthorized individuals who enter or who attempt to enter the permit space during entry operations.
- Determines, whenever responsibility for a permit space entry operation is transferred and at intervals dictated by the hazards and operations performed within the space that entry operations remain consistent with terms of the entry permit and that acceptable entry conditions are maintained.
What is required to terminate work in a confined space?
- PRCS - The entry supervisor shall terminate entry and cancel the permit when the work covered by the entry permit has been completed and/or a condition that is not allowed under the entry permit arises in or near the space.
- PRCS – T or CS – Any person identified on the work plan shall terminate entry and cancel the work when the work covered by the entry permit has been completed and/or a condition that is not allowed arises in or near the space.
How are outside contractors included in our plan?
If an outside contractor is hired to perform work within a permit-required confined space the responsible ACC individual (department supervisor or project manager etc.) shall contact EHS&I one week prior to beginning the work to review and authorize their program and personnel.
This responsible ACC individual shall be responsible for the following:
- Informing the contractor that the area in question is a permit-required confined space.
- Informing the contractor of any precautions or procedures that have been implemented for the protection of employees in the permit-required confined space where contractor personnel will be working.
- Debriefing the contractor at the end of the work to identify hazards discovered or created in the permit-required confined space during operations.
Note: This responsible ACC person shall coordinate entry operations with the entry supervisor of the outside contractor when ACC employees will be working near permit-required confined space(s).
- EHS&I shall be responsible for informing the contractor of the hazards identified within the space and any past experience with the space.
Who provides Rescue and Emergency Services?
- Contractors shall provide Rescue and Emergency Services in accordance with 29 CFR 1910.146 (k) (1).
Note: It is not acceptable for the Austin or other Fire Departments to perform permit-required confined space rescue.
- In addition to enacting their own rescue and emergency services, contractors shall contact Campus Police Dispatch by dialing 222 from a campus phone or 223-7999 from an off campus or cell phone.
- Attendants shall never enter the space to attempt a rescue and always remain outside the permit-required confined space during entry operations until relieved by another attendant.
Who provides training at ACC?
EHS&I shall be responsible for providing appropriate training for ACC Faculty and Staff.
Who needs to take training?
Training is provided to any faculty or staff who participates in confined space activities.
When is training required?
Training shall be provided as follows:
- Before any faculty or staff is assigned to a duty involving entry into a confined space.
- Before there is a change in assigned duties (e.g., attendant becomes an entrant).
- Whenever there is a change in confined space operations that presents a hazard that an employee has not been previously trained on.
- Whenever there are deviations from the entry procedures or inadequacies in the employee's knowledge or use of entry procedures as identified by EHS& I.
Who maintains the training program and records?
Training programs and records shall be maintained by EHS&I for three years subsequent to the initial training period.