Confined Space Entry Policy - Northern Michigan University

Scope And Application:

At Northern Michigan University, a permit-required confined space is defined as a space which is large enough and so configured that an employee can bodily enter and perform assigned work, has limited or restricted means for entry or exit, and is not designed for continuous employee occupancy, and has one or more of the following characteristics:  It contains, or has a known potential to contain a hazardous atmosphere, contains a material with the potential for engulfing an entrant, has an internal configuration such than an entrant could be trapped or asphyxiated by inwardly converging wall, or a floor which slopes downward and tapers to a smaller cross-section, or contains any other recognized serious safety or health hazard.  Northern Michigan University has taken the position that University employees are prohibited from entering or performing work in any permit-required space.

Administrative Measures: 

Northern Michigan University has evaluated the campus to determine the location of any permit-required confined spaces.  A complete list of Permit-Required Confined Spaces is contained in Appendix I of this document.  Detailed information and Hazard Assessment of these Permit-Required Confined Spaces can be obtained from Public Safety, Plant Operations or on the web.

Each Permit-Required Confined Space has been posted with a sign warning of the restricted entry.  The sign reads “DANGER, PERMIT REQUIRED CONFINED SPACE.  Special Precautions Required See Authorized Personnel Before Entry.”  A sample of this sign is Appendix 2 of this document.

Whenever there are changes in the use or configuration of a non-permit confined space that might increase the hazards to entrants, the Director, Public Safety, or designated representative, and the Director, Plant Operation, or designated representative, shall reevaluate that space and, if necessary, reclassify it as a Permit-Required Confined Space.  If a change is necessary, the new space will be added to the listing of Permit-Required Confined Space and the data base up-dated. 

Alternate Entry Confined Spaces: 

Northern Michigan University has evaluated all confined space on campus and has determined that several areas qualify for alternate entry procedures.  The locations of these Alternate Entry Confined Spaces are contained in Appendix 3 of this document. Detailed information and Hazard Assessment of these Alternate Entry Confined Spaces can be obtained from Public Safety, Plant Operations or on the web.

In determining that University employees will be allowed to perform work in the identified areas, the following conditions are mandatory:

The only hazard posed by the space is actual or potential hazardous atmosphere.

Continuous forced air ventilation alone is sufficient to maintain the space safety for entry

Monitoring and inspection data supports the two requirements above

If initial entry of the space is necessary to obtain the data identified above, the space is considered a Permit-Required Confined Space and University employees are prohibited from entering the space.

That information concerning hazard assessment and supporting data will be documented and made available to each employee who enters the space

That entry into the space will be governed by the following work practices:

1.  Any condition making it unsafe to remove an entrance cover shall be eliminated before the cover is removed.

2.  When entrance covers are removed, the opening shall be promptly guarded by a railing, temporary cover, or other 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.

3.  Before any employee enters the space, the internal atmosphere shall be tested, with a calibrated directing-reading instrument, for the following conditions in the order given:

a. Oxygen content

b. Flammable gasses and vapors, and

c. Potential toxic air contaminants.

4.  There may be no hazardous atmosphere within the space whenever an employee is present.

5.  Continuous forced air ventilation must be used as follows:

          a.       Employees may not enter the space until any hazardous atmosphere has been eliminated.

          b.       Forced air ventilation shall be directed to ventilate the immediate work area and shall continue until the
                    employee has left the work area.         
          c.       The air supply must be from a clean source and may not increase the hazards in the space.

6.  The atmosphere in the work space shall be periodically tested to ensure that forced air ventilation is preventing the accumulation of a hazardous atmosphere.

7.  If a hazardous atmosphere is detected during entry:

          a.       Each employee will leave the area immediately.

          b.       The space shall be evaluated to determine how the hazard developed.

          c.       Measures shall be taken to abate the hazardous atmosphere until further entry is allowed.

8.  A Confined Space Written Entry Procedure and Alternate Entry Certificate must be completed by the supervisor before any employee is allowed to enter the space.  These documents will be made available to every employee entering the space.  The documents will be turned in to Public Safety when the project is terminated.  Samples of the Confined Space Written Entry Procedure and Alternate Entry Certificate are Appendix 4 and Appendix 5 of this document.

9.  A flow chart has been developed by the University to aid employees in Confined Space decision making.  The flow chart is Appendix 6 of this document.

Confined Space Re-classification:

A space classified as a Permit-Required Confined Space may be reclassified as a non-permit space as follows:

1.  The space poses no actual or potential atmospheric hazards and if all hazards within the space are eliminated with out entry into the space.  (If entry into the space is required to eliminate hazards, it will remain a Permit-Required Confined Space, and University employees will be prohibited from entering.)  The Director, Public Safety, or designated representative, and the Director, Plant Operation, or designated representative, will make the evaluation.

2.  The University will document the basis for determining that the hazards have been eliminated on the Confined Space Hazard Assessment form.  This form shall be made available to every employee who enters the space.  The Confined Space Hazard Assessment shall be on file at Public Safety and Plant Operations. 

All Confined Space Hazard Assessment Forms are also available on the web. Sample of the Confined Space Hazard Assessment is Appendix 7 of this document.

3.  If hazards arise within a declassified space, each employee shall evacuate the space immediately.  The space will be re-evaluated as outlined in paragraph to determine if the space must be re-classified.

Employee Training:

Northern Michigan University shall provide training to all employees who will be performing work in confined spaces, prior to work assignments, if there is a change in an employees assigned duty, if there is a change that presents a hazard about which an employee has not been previously trained or whenever the University has reason to believe there has been a deviation from this policy or reason to believe there are inadequacies in an employees knowledge or use of these procedures.

The training will establish employee proficiency in the policies and procedures required under this policy and will introduce new or revised procedures, as necessary, for compliance with the Confined Space Entry Standards.

Arrangements for training, records of training and required certification shall be maintained at the Public Safety Institute in accordance with the Employee Safety Training Policy.   A copy of this policy is available at Public Safety or on the web.  A list of currently trained employees and supervisors is contained in Appendix 8 of this document.

Outside Contractors:

Because employees of Northern Michigan University are prohibited from performing work in Permit-Required Confined Spaces, outside contractors will be contracted to perform these responsibilities.  The University has implemented the following procedures for contractors:

University Responsibilities:

1.  The contractor will be informed that the workplace contains permit spaces and that permit space entry is allow only through compliance with a permit space program meeting the requirements of Act 154 of the Public Acts of 1974, as amended, Part 90.  A copy of the Contractors Written Program will be provided to Public Safety prior to starting work.

2.  The contractor will be informed of the hazards identified with the space and the Confined Space Hazard Assessment performed by the University.

3.  The contractor will be informed of any precautions or procedures that the University has implemented for the protection of employees near permit spaces where contractor personnel will be working.

4.  The University will coordinate entry operations with the contractor, whenever University personnel will be working near the permit space.

5.  The University will debrief the contractor at the conclusion of the entry regarding the permit space program followed and any hazards created or confronted.  Copies of the contractors’ evaluation and entry permit will be filed with Public Safety.

Contractor Responsibilities:

1.  Obtain available information regarding the permit space hazards from the University.

2.  Coordinate entry operations with the University when University employees will be working near the permit space.

3.  Inform the University of the permit space program they will follow and of any hazards confronted or created, either through a debriefing or during the entry operation.

4.  Provide Public Safety with a copy of the Confined Space Entry Program and copies of evaluations/assessments and permits used on the project.

Program Evaluation:

The Confined Space Entry Policy and procedures will be evaluated by the Director, Public Safety or designated representative, whenever there has been an unauthorized entry of a permit space, the detection of a hazard not covered by the permit, the detection of a condition not covered by the permit, the occurrences of any injury or near-miss during entry, a change in the use or configuration of a permit space or based on employee complaints about the effectiveness of the program.

Each year, the Director, Public Safety, or designated representative, and the Director, Plant Operations, or designated representative will review the canceled entry permits to evaluate the program and make revisions as necessary.

Questions:

Questions about Northern Michigan University’s Confined Space program should be directed to the Director, Public Safety.