Confined Space Entry Policy - NMU Policies and Requirements

MIOSHA defines a Confined Space as:

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.

Administrative Measures:

Northern Michigan University has evaluated its campus to determine the classification of all confined spaces. Detailed information and Hazard Assessment of these Confined Spaces can be obtained from the NMU Safety Department or Plant Operations.

Each Confined Space has been posted with a sign warning of the restricted entry.  The sign reads “DANGER; CONFINED SPACE AUTHORIZED PERSONNEL ONLY”

If changes occur that impact a confined space the Director of Safety or designated representative and the Director of Facilities or designated representative shall reevaluate the space and classify it appropriately. 

DEFINITIONS/CLASSIFICATIONS:

Permit Required Confined Space: As defined by MIOSHA: "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.

Only trained and approved NMU employees will be authorized to enter permit required confined spaces. Note that MIOSHA's alternate entry procedures for confined spaces as outlined in 29 CFR 1910.146(c)(5), allow for entry without a permit if the only hazard is an actual or potential hazardous atmosphere that can be controlled by continuous forced air ventilation. This means that physical hazards must be eliminated or controlled, and the atmosphere must be continuously monitored. 

Non-Permit Confined Space: For a confined space to be classified as non-permit, it must not have any hazards present, or have the potential to contain any hazard capable of causing death or serious physical harm. This includes atmospheric hazards, engulfment hazards, and internal configuration hazards. All NMU employees must have NMU Confined Space training and the appropriate training for all safety equipment being used.

PROCEDURES FOR ENTRY: 

Confined Space Entry:  

1. Determine which type of space will be entered: Permit Required, Alternate Entry or Non-Permit. (refer to flow chart appendix A).
2. Procure necessary equipment: Multi-gas meter, blower, permit, certificate, tripod, harness, hand-held lights, radio, and any other safety equipment necessary to complete the job.
3. All employees must have training on all safety equipment being used.
4. Contractors shall follow all state and local regulations to enter a confined space on the NMU Campus.
5. NMU employees entering a Permit Required Confined Space requires a Supervisors approval as well as approval from the NMU Safety Department prior to entry.
6. Alternate Entry requires a Supervisors approval and notification to the Safety Department prior to entry. 
7. Hot Work is prohibited within a confined space by NMU employees without special permission from either a supervisor or the Safety Department.  Should hot work be conducted within a confined space, the required hot work permit must be accompanied with the confined space permit or certificate.  The following must be strictly adhered to should hot work be conducted within a confined space:
   • All Permits/Certificates completely filled out and signed by supervisor,
   • Remove or protect any hazardous or combustible materials,
   • Lockout/Tagout any system not required during hot work, if applicable
8. Assess the confined space looking for all hazards; any other safety hazards that exist within a confined space must be controlled during the entire entry.  Contact the appropriate departments to coordinate isolation of other safety hazards or contact the Safety Department for further assistance.
9. Conduct air monitoring with the multi-gas meter prior to entry and during entry.
10. Fill out appropriate permits or certificates and record all items below.
    • Pre-job safety meeting
    • Conduct forced air ventilation (from a clean air source) at least 30 minutes prior to entering the space, natural ventilation is recommended as well if applicable. Note, ventilation should not be conducted if it will create additional hazards such as asbestos disturbance or dust disturbance.  Contact the Safety Department for further assistance at x2151.
    • Conduct air monitoring with the multi-gas meter prior to entry and during entry
    • Why confined space will be entered
    • Names of entrants and attendants
    • Name and location of the confined space
    • Any items Locked out and tagged out and by which department
    • Signature of Entry Supervisor prior to entry and following closure of permit
    • Any other information required on the permit
11. Set-up tripod if applicable.
12. Use harnesses in conjunction with tripod if applicable
13. Attendant must be present at all times outside the confined space during entry.
    • Attendant shall be trained in confined space, hazards, and all equipment used.
14. Entrant must immediately exit the confined space if an alarm exists on the multi-gas meter and may not reenter the space until the Entry Supervisor or Safety Department determines the confined space is safe to reenter.
15. Entrant and attendant must be in voice or radio contact at all times
16. Upon completion of entry, the space must be returned to original safe closure.
17. Any safety hazards discovered during entry must be immediately report to the Safety Department.
18. Entry into a confined space should not be attempted if all applicable items above cannot be met.
19. Rescue services will be conducted by the Marquette City Fire Department.  Dial 911. State your emergency and specific location and that your emergency is located within a confined space on the Campus of NMU.

Alternate Entry Procedure 

A confined space alternate entry certificate must be completed by the supervisor before any employee is allowed to enter the space.  This document can be found in Appendix B.

The employee must do the following to use alternate entry procedures:

1. The employee must eliminate all hazards prior to entry.  This would include but is not limited to hazards involving high noise levels, lockout-tagout, drowning, high heat or cold, slips, trips or falls, or any other hazard.   The only hazard that could be present is an atmospheric hazard.
2. The employee must provide continuous forced air ventilation throughout entry from a clean air source.
3. The employee must monitor space before and during entry with a 4-gas meter.
4. The employee must complete an alternate entry certificate prior to entry.
5. Alternate entry certificates must be given to the employee's supervisor to be filed upon completion of work.
6. The employee must ensure the entry spaces are secure so outside hazards can not affect the employee during entry.
7. The employee must know if any additional access points exist prior to entry as a means of emergency exit.
8. The employee must have a radio for communication with them at all times.
9. If the conditions can not be met, the space will be a permit required space.
10. All employees must have the appropriate training for all safety equipment being used.

Steam Vault Alternate Entry Confined Space: All steam vaults on the NMU Campus are Alternate Entry Confined Spaces. 
Pre-Entry Procedures for Steam Vault Alternate Entry Confined Spaces

1. Set up a flag line with a 6’ radius from the vault. 
2. Naturally ventilate each vault (if feasible) prior to entry.
3. Secure forced air ventilation unit outside of space. Ventilate space with fan for 30 minutes prior to entry from a clean air source.
4. Test each vault with a 4-gas meter prior to entry by lowering the meter to the bottom of the vault the rope line that is available when you check out the meter.
   • Should an alarm exist within the vault, determine which type of alarm is sounding and remediate the problem prior to entry.
   • If the problem can not be remediated, you may NOT enter the vault.
5. Ensure communication methods are operational
6. Fill out certificate verifying space is safe to enter.
7. Set up Tripod to be used during entire entry.
8. Ensure harness and all PPE is in good working condition.
9. Space must be isolated from outside sources (i.e. live steam lines, gas, etc.)
10. All Employees must have training on all safety equipment being used.
11. Attendant shall be present at all times.

Entry Procedures for Steam Vault Alternate Entry Confined Spaces

1. Complete Pre-Entry Procedures for Steam Vault Alternate Entry Confined Spaces
2. Provide forced air ventilation from a clean air source during the entire entry.
3. Entrant must have 4-Gas meter on their person and operating during the entire entry.
4. Each entrant must be attached to the tripod system while climbing up and down.
5. An attendant must remain outside the space during the entire entry and maintain communication with the entrant.
6. If an alarm occurs, all entrants must evacuate the space immediately and may not re-enter until the problem has been resolved and documented.
7. Attendant shall summon rescue services if necessary by calling 911.

Post Entry Procedures for Steam Vault Alternate Entry Confined Spaces

1. Ensure the space is secured
2. Complete the Certificate paperwork
3. Report and problems to Supervisor or Safety Department

Non-Permit Confined Space Entry Procedure

1. All employees must have the appropriate training for all safety equipment being used.
2. Ensure necessary equipment is in proper working order. Necessary equipment includes a flash light, 4-gas meter, bump cap and a radio at a minimum.
3. Check that you have all the appropriate PPE 
4. Ensure non-permit space is secured open
5. Have radio contact with a designated person while performing entry in space.  Call designated person upon entry and relay entry is in progress
6. During entry if any unsafe conditions exist or an alarm on the 4-gas meter sounds, immediately exit the space in a safe manner and contact your supervisor with any problems
7. Upon completion of entry, call designated person to relay entry is complete
8. Upon completion of entry, close and secure confined space and report to supervisor any problems during entry.