Managing the program and capstone: writing an entry plan

The earlier lessons covered each part of confined space safety separately. In practice they must work together as a program: a set of written procedures, trained people, equipment and checks that make every entry safe, every time, whoever is doing it. This final lesson explains how a confined space program is managed, how contractors are coordinated, what training each role needs and how the program is reviewed. It finishes with a capstone in which you put everything together to draft an entry plan for a real-world type of space.

The written program

1910.146(d) requires employers whose workers enter permit spaces to have a written permit space program, available to employees and their representatives. The program must be reviewed when there is reason to believe it does not protect employees, and the employer must review it at least annually, using the canceled permits kept over the previous year, and revise it as needed.

A typical program document covers:

• scope and responsibilities, from senior management to entrants;
• how confined spaces are identified, inventoried, signed and secured;
• how hazards are assessed and entry plans written;
• isolation, cleaning, ventilation and atmospheric testing requirements, including acceptable values and instrument care;
• the permit system, including who may issue permits and for how long they are valid;
• duties of entrants, attendants, entry supervisors, testers and rescuers;
• rescue arrangements and drills;
• contractor coordination;
• training and competency requirements;
• records, audits and program review.

Training and competency

Every role in confined space work needs training matched to its duties, and that training must be refreshed and updated when the spaces, hazards, equipment or procedures change.

1910.146(g) requires training before an employee is first assigned confined space duties, before any change in assigned duties, whenever there is a change in permit space operations that presents a new hazard, and whenever the employer has reason to believe there are deviations from the procedures or gaps in the employee's knowledge. The employer must certify that the training has been done, with each employee's name, the trainers' signatures or initials and the dates.

This awareness course is only the first step. Before taking any of the roles above, you need training from your employer on the actual spaces, procedures and equipment, and practical skills such as using a detector, a retrieval system or breathing apparatus must be demonstrated, not just studied.

Contractors and multi-employer work

Much confined space work is done by contractors: tank cleaners, coating crews, inspectors, welders, sewer specialists. Incidents often happen when the host employer and the contractor each assume the other is handling a hazard. Coordination should cover:

• the host telling the contractor about the space, its hazards and any known precautions, and about its own confined space program;
• the contractor telling the host about the hazards its work will create, such as solvents or welding;
• agreeing who isolates the space, who tests, who issues the permit, who attends and who provides rescue;
• coordinating when more than one employer's workers are in or near the same space;
• debriefing at the end to share any hazards found or problems encountered.

1910.146(c)(8) and (c)(9) set out the duties of host employers and contractors: the host must inform the contractor of the permit spaces and their hazards, the precautions taken and its own program, coordinate entry operations and debrief the contractor; the contractor must obtain that information, coordinate entries and tell the host about its program and any hazards it confronted or created. In construction, Subpart AA assigns coordination duties to the controlling contractor.

Auditing and reviewing the program

A program on paper is only as good as its use in the field. Regular checks help keep it alive:

• field audits of entries in progress, checking that the permit matches what is actually happening at the space;
• review of completed permits for missing tests, signatures or information, and for trends such as rising gas readings;
• review of detector bump test and calibration records;
• rescue drill results and the lessons learned from them;
• investigation of incidents, near misses and alarms;
• updates to the inventory and entry plans when spaces or processes change;
• feedback from entrants, attendants and the health and safety committee.

Capstone: writing an entry plan

In this capstone you draft an entry plan for a common type of space, using everything in the course. Read the scenario, then compare your plan with the model answer that follows.

The scenario. A municipal lift station has a wet well 16 ft deep and 10 ft in diameter, entered through a 30-inch square hatch with a fixed ladder. Two submersible pumps at the bottom need their float switch replaced. Sewage enters through an inlet pipe that can be closed with an upstream gate; the pumps discharge through a separate line. The well contains a layer of sludge. Previous tests in similar wells have found hydrogen sulfide up to 50 ppm when sludge was disturbed, and occasional low oxygen. The nearest fire department with confined space rescue capability is about 20 minutes away. Two maintenance workers and a supervisor are available, and another crew can be called in.

Before reading on, write down: the classification of the space; the hazards; how you would avoid or reduce entry; isolation; cleaning and ventilation; testing; the permit and roles; equipment; communication; and rescue.

Model answer

Classification. The wet well is a permit-required confined space: it has a hazardous atmosphere (hydrogen sulfide, low oxygen, possibly methane), a potential for engulfment or drowning from incoming sewage, moving parts in the pumps, electrical hazards and a fall risk on the ladder. It requires a permit under 1910.146, and reclassification is not possible because the atmospheric hazard can only be controlled, not eliminated.

Avoiding or reducing entry. Can the float switch be replaced from the surface? Many lift stations have guide rails that let pumps and switches be raised without entry. If so, no entry is needed. If entry is unavoidable, pump the well down as far as possible first and plan the work to minimize time inside.

Isolation. Close and lock the upstream inlet gate and, where possible, divert or store incoming flow; lock out both pumps and the control panel at their disconnects and verify zero energy (HSE-210); isolate the discharge line with its check and isolation valves, locked; and confirm that no other lines can introduce sewage or gas.

Cleaning and ventilation. Pump down and, if practical, vacuum out sludge from the surface. Set up a supply blower with a clean intake upwind and away from vehicles, and run the duct to the bottom of the well. Estimate purge time and keep the blower running throughout the entry.

Testing. After ventilation, test from the surface with a pumped multi-gas detector (oxygen, percent LEL, hydrogen sulfide and carbon monoxide), at the top, middle and bottom and near the sludge, allowing transport time for the tubing. Record the results. Entry may start only if all readings are within the acceptable values on the permit. The entrant wears a personal detector, and continuous monitoring continues throughout.

Permit and roles. The supervisor acts as entry supervisor, completes the permit at the space and verifies each control before signing. One worker is the entrant. The second is the attendant, who stays at the hatch for the whole entry with no other duties. Because standby rescue is needed and the attendant must not enter, a second crew trained and equipped for entry rescue is called in to stand by at the station.

Equipment. Multi-gas detectors (bump tested), the blower and ducting, a tripod and winch over the hatch with the entrant in a full-body harness attached to the retrieval line, which also provides fall protection on the ladder; supplied-air respirators for the rescue team; low-voltage or battery lighting rated for possible flammable gas; radios checked for coverage at the bottom; gloves, boots, protective clothing and washing facilities for biological hazards; barriers around the hatch.

Communication. Radio contact with check-ins at least every few minutes plus visual contact down the hatch; rope signals as backup; the attendant's radio or phone tested for calling the rescue team and emergency services.

Rescue. Self-rescue on alarm or symptoms; non-entry retrieval by the attendant using the winch; entry rescue by the standby team with supplied air if retrieval fails; the fire department notified before the entry and called immediately in an emergency; first aid and CPR available; safety data sheets and permit information ready to send with a casualty.

Closing. When the work is done, confirm the entrant is out and counted, tools are removed, the hatch is closed, isolation is removed in the right order, the pumps are tested from the panel, and the permit is signed off with any issues noted.