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Confined Space Policy

Introduction
Definition
Morningside Campus Responsibilities
Identification of Morningside Campus Confined Spaces
Designated Roles
Morningside Campus Permit-Required Confined Space Entry Procedures
Pre-Entry Preparation Procedures
Pre-Entry Evaluation Procedures
Procedures for Atmospheric Testing
Termination of Entry and Cancellation of Entry Permit
Employee Information and Training
EH&RS Information

Introduction

Over 1 ½ million workers enter confined spaces on an annual basis.  Serious injury or death in a confined space can be the result of asphyxiation, engulfment, electric shock, falls, and heat stress.  The Occupational Safety and Health Administration (OSHA) estimates that 85 percent of these accidents can be prevented if proper safety precautions at job sites are implemented.  This poses a serious problem for exposed workers and their employer.

The OSHA Permit-Required Confined Space Standard, 29 CFR 1910.146, establishes specific requirements to ensure that the hazards of confined spaces in the workplace are evaluated and adequately controlled.  In an effort to ensure Columbia University's continued commitment to providing the safest possible workplace, and to comply with this standard, the Office of Environmental Health and Radiation Safety/Environmental Health and Safety (EH&S) has prepared the Columbia University Confined Space program.

This program will include; a written Confined Space policy; the identification, evaluation, and labelling of Morningside Campus Confined Spaces; employee training and certification; implementation of a confined space permitting system, and the identification of responsible individuals and their roles during confined space procedures. EH&S will review this written policy on an annual basis, or when changes occur to 29 CFR 1910.146 that prompt revision of this document, or when operational changes occur within the University that require a revision of this document.  Additionally, EH&S will review the permit-required confined space program, using the cancelled permits retained within 1 year after each entry and revise the program as necessary, to ensure that employees participating in entry operations are fully protected from permit space hazards.

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Appendix A: Columbia University Morningside Campus Emergency Procedures
Appendix B:Columbia University Morningside Campus Confined Space Permit
Appendix C:Morningside Campus Permit Required Confined Spaces
Appendix D:Glossary of Terms

Confined Space

  • A space that is large enough, and so configured, that an employee can bodily enter and perform assigned work. 
  • A space that has limited or restricted means for entry or exit. 
  • A space that is not designed for continuous employee occupancy.

Examples: bins; boilers; digesters; ventilation ducts; utility vaults; pipelines; tunnels; tanks; trenches; vessels; vats; silos; open top spaces more than 4 feet deep such as pits, tubs, and excavations, or any space with limited ventilation or suspect atmosphere.

Confined Spaces are classified into two main categories; permit-required and non-permit required.

Permit-required confined space

A Permit Required Confined Space is any space having the following charcteristics;

  • Its primary function is something other than human occupancy and is large enough and is so configured that an employee can enter and perform assigned work. 
  • Limited openings for entry and exit. 
  • Not designed for continuous worker occupancy.

The following can also be characteristics of a permit required confined space:

  • Unfavorable natural ventilation. 
  • Potential for toxic or oxygen deficient atmosphere. 
  • Potential for engulfment, such as hoppers, and silos for sand and gravel. 
  • Has an internal configuration such that an entrant could be trapoped or asphyxiated by inwardly converging walls or by a floor that slopes downward and tapers to a smaller crosssection. 
  • A space that contains any other recognized serious safety or health hazard.
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Non-permit required confined spaces

Non-permit required confined spaces are confined spaces that do not have, or have the potential to, contain any hazard or hazardous atmosphere capable of causing death or serious physical harm.

If it can be demonstrated that the only hazard posed by the permit-required space is an actual or potentially hazardous atmosphere, and continuous forced air ventilation can safely maintain the permit space, then the space can be considered a non-permit required confined space pending satisfactoiry air monitoring results.

All Morningside Campus Confined Spaces Will Be Considered Permit-Required Until EH&RS Has Had an Opportunity to Assess the Work Area.

Morningside Campus Responsibilities

EHRS

  • Develop and implement the Morningside Campus Confined Space Program. 
  • Develop written Permit Required Confined Space policy and amend as necessary. 
  • Assist departments identify, label, and document Morningside Campus permit required confined spaces. Create and maintain a listing of permit required confined space locations on the Morningside Campus ( Appendix C ). 
  • Conduct evaluations of confined spaces, and classify as either a Permit Required Confined Space or Non-Permit Required Confined Space. 
  • Conduct atmospheric testing to verify that conditions in the permit space are acceptable for entry throughout the duration of an authorized entry. 
  • Develop, conduct, and document, employee Confined Space training. 
  • Issue and maintain Confined Space Entry Permits. 
  • Maintain and distribute confined space entry equipment including tripod, air monitoring instrumentation, harnesses, as necessary. 
  • Review outside contractor written Confined Space policies, training certificates,  and Material Safety Data Sheets's (MSDS's).  These materials must be forwarded to EH&RS, at least two working days prior to the start of work, by Supervisor or Project Manager prior to the commencement of work. 
  • Recommend personal protective equipment (PPE) if necessary.
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Employee Supervisors

  • Notify EH&S in writing of upcoming permit required confined space activities at least two working days prior to commencement of work. If there are any questions as to whether or not a work area is considered a confined space, EH&S must be contacted, prior to the commencement of work, to evaluate the proposed work space. 
  • Identify those employees who will be involved with confined space work and ensure that they have received confined space certification training.  EH&S will maintain a list of those employees who have received this training. 
  • Obtain a Confined Space Permit from the EH&S office prior to work in a permit-required confined space. 
  • Perform any necessary lockout/tagout procedures needed to ensure safe entry.  (See Pre-Entry Preparation Procedures section of this policy). 
  • Obtain the appropriate personal protective equipment (PPE), if necessary,  insofar as feasible engineering and work practice controls do not adequately protect employees.  Consult with EH&S on proper PPE selection. 
  • Obtain the proper intrinsically safe lighting equipment to enable employees to see well enough to work safely and to exit the space quickly in an emergency. 
  • Obtain barriers and shields to protect workers from pedestrian and vehicular traffic. 
  • Obtain the appropriate ladders needed for safe ingress and egress by authorized entrants. 
  • Ensure rescue, retrieval, and emergency equipment is available to extract or treat injured personnel. 
  • Obtain any other equipment necessary for safe entry into and rescue from permitted spaces at our facility. 
  • Ensure employees know emergency procedures (i.e. emergency phone numbers, emergency phone locations, fire extinguisher locations). 
  • Make arrangements with Morningside Campus Security for gate access if necessary.
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Project Mangers (Regarding Outside Contractors)

When Columbia University utilizes an outside contractor to perform work within a permit required confined space, the CU project manager or supervisor must:

  • Obtain contractors written confined space policy and confined space training certifications for each employee who will be involved with the entry.  Forward copies of this information to EH&S for review prior to the commencement of work for review. 
  • Obtain Material Safety Data Sheets (MSDS's) for any chemical or product to be used during the confined space activity and forward to EH&S prior to the commencement of work for review. 
  • Obtain a Confined Space Permit from the EH&S office prior to work in a permit-required confined space. 
  • Inform the contractor that the workplace contains permit spaces and that permit space entry is allowed only through compliance with the Columbia University confined space policy. 
  • Perform any necessary pre-entry space preparation procedures needed to ensure safe entry.  (See Pre-Entry Preparation Procedures section of this policy). 
  • Obtain the appropriate personal protective equipment (PPE), if necessary,  insofar as feasible engineering and work practice controls do not adequately protect employees.  Consult with EH&S on proper PPE selection. 
  • Obtain the proper intrinsically safe lighting equipment to enable employees to see well enough to work safely and to exit the space quickly in an emergency. 
  • Obtain barriers and shields to protect workers from pedestrian and vehicular traffic. 
  • Obtain the appropriate ladders needed for safe ingress and egress by authorized entrants. 
  • Ensure rescue, retrieval, and emergency equipment is available to extract or treat injured personnel. 
  • Obtain any other equipment necessary for safe entry into and rescue from permitted spaces at our facility. 
  • Ensure employees know emergency procedures (i.e. emergency phone numbers, emergency phone locations, fire extinguisher locations). 
  • Make arrangements with Morningside Campus Security for gate access if necessary. 
  • Apprise the contractor of any precautions or procedures that Columbia University has implemented for the protection of employees in or near permit spaces where contractor personnel will be working. 
  • Ensure outside contractor personnel are familiar with Morningside Campus emergency procedures, emergency phone numbers, and emergency phone locations ( Appendix A ).
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Outside Contractors

In addition to complying with the CU Confined Space policy, each contractor must:

  • Submit a written confined space policy to CU Project Management prior to the commencement of work. 
  • Submit employee confined space training certificates for each employee that will work on the Morningside Campus to CU Project Management prior to the commencement of work. 
  • Submit MSDS's for any products containing hazardous ingredients that will be used within the confined space to CU Project Management prior to the commencement of work. 
  • Coordinate confined space entry operations with the CU Project Manger and EH&RS. 
  • Follow emergency procedures set forth by this policy. ( Appendix A )

Employees

  • Follow procedures set forth in this confined space policy and training.
  • Know the responsibilities of designated role (i.e attendant, entrant).
  • Notify supervisor of any problems.
  • Follow emergency procedures. ( Appendix A

Identification of Morningside Campus Confined Spaces

Morningside Campus has been evaluated to determine if any work areas are permit-required confined spaces and to identify and evaluate the hazards associated with these spaces.  Permit required confined spaces have been identified, and all affected employees will be notified by posting signage or by any other effective means of the existance and location of the permit spaces.  A sign will be posted stating the following; "DANGER – CONFINED SPACE - ENTRY PERMIT REQUIRED" at each permit-required confined space. A list of all Morningside Campus permit required confined spaces will be maintained by EH&S (See Appendix C ). Updated versions of this appendix will then be distributed to supervisors and project managers.

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Designated Roles

When a permit-required confined space entry is to take place, the supervisor or project manager, will designate the persons who will have active roles in the entry operation.  Additionally, the duties of each such employee will be identified, and provided with the required training required by the training section of this policy.  A typical confined space entry team may include, but is not limited to, the following:

  1. Authorized entrants
  2. Attendants
  3. Entry supervisors
  4. Atmospheric monitoring personnel
  5. Certifying personnel
  6. Rescue/Emergency services personnel

The supervisor or project manager, must develop procedures prior to the commencement of confined space operations for the following:

  1. Summoning rescue and emergency services
  2. Rescuing entrants from permit spaces
  3. Providing necessary emergency services for rescue
  4. Preventing unauthorized personnel from attempting a rescue
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Authorized Entrant

  • Must know the hazards that may be encountered during entry, including information on the mode, signs or symptoms, and consequences of the exposure. 
  • Must 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 required by this section. 
  • Must know how to properly use personnel protective equipment (PPE) provided.  
  • Must alert the attendant whenever: 
    • The entrant recognizes any warning sign or symptom of exposure to a dangerous situation. 
    • The entrant detects a prohibited condition.
  • Must exit from the permit space as quickly as possible whenever: 
    • An order to evacuate is given by the attendant or the entry supervisor. 
    • The entrant recognizes any warning sign or symptom of exposure to a dangerous situation. 
    • The entrant detects a prohibited condition. 
    • An evacuation alarm is activated.

Authorized Attendants

Attendants are individuals stationed outside one or more confined spaces who monitor the authorized entrants.  Authorized attendants:

  • Must know the hazards that may be faced during entry, including information on the mode, signs or symptoms, and consequences of the exposure. 
  • Must be aware of possible behavioral effects (i.e. disorientation, faulty judgement) of hazard exposure in authorized entrants. 
  • Must continuously maintain an accurate count of authorized entrants in the permit space and ensure that the means used to identify authorized entrants accurately identifies who is in the permit space. 
  • Must remain in a predesignated location outside the permit space during entry operations until relieved by another 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 entrant. 
    • If the attendant detects a situation outside the space that could endanger the entrants. 
    • If the attendant cannot effectively and safely perform all the duties stated in this section. 
  • Summon rescue and other emergency services as soon as the attendant determines that 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 no duties that might interfere with the attendant's primary duty to monitor and protect the entrants. 
  • Performs non-entry rescues.
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Entry Supervisors

Entry supervisors are responsible for determining if acceptable entry conditions are present prior to entry, for authorizing entry and overseeing entry operations, and for terminating the entry.  An entry supervisor may also serve as an attendant or authorized entant of properly equipped and trained.  Depending on the nature of the confined space work, the Entry Supervisor may be the project supervisor, project manager, EH&S personnel, or other designated person.  However, this individual will be identified prior to issuiing a confined space permit.

Entry Supervisor reponsibilities;

  • Must know 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. 
  • Verifies that rescue services are available and that the means for summoning them are operable. 
  • Ensures removal of 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. 
  • Terminates the entry and cancels the permit as required in accordance with this policy.
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Rescue and Emergency Services

The Morningside Campus will utilize the New York City Fire Department whenever an emergency situation arises pertaining to permit-required confined space work.  Prior to authorizing the entry, the emergency procedures must be reviewed with all involved with the entry.

Rescue and emergency services workers are employees who enter permit spaces to perform rescue services.  These individuals must have the knowledge and skills of authorized entrants.  In addition, they must be trained to do their assigned rescue duties.  Rescue service members must know the proper use of PPE equipment and rescue equipment.  They will also have basic first aid and cardio pulmonary resuscitation (CPR) training, with at least one member holding a valid certificationin first aid and CPR. 

Morningside Campus Permit-Required Confined Space Entry Procedures

The following steps are to be followed by Morningside Campus project supervisors, project managers, or any other individual who will be overseeing work that involves entering confined spaces:

  1. Determine if the upcoming work, or project, will involve entry into permit-required confined spaces by consulting Appendix C (List of Morningside Campus Permit Required Confined Spaces) of this policy. If the work area is on the list, contact EH&S to inform them of the upcoming permit-required confined space work and request a Confined Space Entry Permit.

    Note: If there is any question as to whether or not the work space is a confined space, consult EH&S to conduct an evaluation.  This request should be made well in advance of the scheduled start of work.

    If it has been determined that the work will involve entering a permit-required confined space the following procedures must be followed;
     
  2. Identify the appropriate trained personnel who will be involved in the work operation.

    Note: Only those employees who have received confined space certification training (approved by EH&S ) will be allowed to conduct confined space work.

    Note: If work is to be performed by an outside contractor, a copy of the company's written confined space policy, employee training certificates, and any MSDS's must be submitted to EH&S at least two days prior to the commencement of work for review.
     
  3. Follow  steps in " Pre-Entry Preparation Procedures " section of this policy.
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All Columbia University Confined Space Entry permits will be authorized and distributed from the EH&S office located at 350 Mudd during normal office hours.  In addition, EH&S requires a minimum of two working days notification prior to the proposed start date to ensure all equipment maintained by EH&S is available.  Any entry into a permit required confined space without approval, or in consulatation with EH&S, will result in disciplinary action.

Pre-Entry Preparation Procedures

  • These procedures are the responsibility of Morningside Campus project supervisors, project managers, or any other individual who will be overseeing work that involves confined spaces.  These items, if applicable, must be carried out before a Confined Space Permit will be issued. 
  • Isolate the permit space - Confined spaces that contain equipment or operations that through the activation of electricity, air, or hydraulics, may injure an employee or cause property damage must be isolated by lock-outs and tags or other positive means of preventing an accident. All involved employees must take part in the lockout/tagout procedures. All electrical and mechanical systems must be tested prior to entry to ensure actual isolation of the systems. 
  • Purge, inert, flush, or ventilate the permit space as necessary to eliminate or control atmospheric hazards. 
  • Provide pedestrian, vehicle, or other barriers as necessary to protect entrants from external hazards. This may include, but is not limited to, the following methods: set-up cones, post signs, partition-off the area with caution tape, erect barricades, arrange for traffic control with the Morningside Security Office. 
  • Confined Space operations involving entry into hot and cold environments may require use of appropriate protective clothing. Consult with EH&S prior to selecting any form of personnel protective equipment (PPE), this may include; safety glasses, gloves, chemical resistant suits, hearing protection, etc. 
  • Equipment used in confined space work operations will only be issued to those employees who are trained in their use.  This may include:
     
    1. Ventilating equipment needed to obtain acceptable entry conditions. 
    2. Communications equipment necessary to enable the authorized entrant(s) and attendant maintain constant communication and to enable the attendant to summon rescue services without leaving his/her post. 
    3. Personal protective equipment when feasible engineering and work practice controls do not adequately protect employees. 
    4. Lighting equipment needed to enable employees to see well enough to work safely and to exit the space quickly in an emergency. 
    5. Barriers and shields
       
  • Obtain equipment, such as ladders, needed for safe ingress and egress by authorized entrants. 
  • Obtain rescue and emergency equipment except to the extent that the equipment is provided by or for rescue services. 
  • Obtain any other equipment necessary for safe entry into and rescue from permit spaces. 
  • Make necessary arrangements with Morningside Campus Security office if access through various gates is necessary for contractors and/or equipment. 
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Pre-Entry Evaluation Procedures

Atmospheric testing of the permit space conditions will be evaluated by EH&S prior to any entry operations.  Outside contractors who provide their own safety personnel, may also conduct the atmospheric testing as long as EH&S determines their means of assessing atmospheric conditions are acceptable.  Conditions will be tested in the permit space to determine if acceptable entry conditions exist before entry is authorized to begin, except that, if isolation of the space is impractical because the space is large or is part of a continuous system (such as a sewer), pre-entry testing shall be performed to the extent feasible before entry is authorized and, if entry is authorized, entry conditions will be continuously monitored in the areas where authorized entrants are working.

Procedures for Atmospheric Testing

Atmospheric testing for confined space entry is required for two distinct purposes:

  • Evaluation of the hazards of the permit space, and
  • Verification that acceptable entry conditions for entry into that space exist.

All atmospheric evaluations will be conducted by the University Industrial Hygienist, or other designated individual, from the EH&S office.

Evaluation Testing

EH&S will ensure that the atmosphere of a permit-required confined space is analyzed using equipment of sufficient sensitivity and specificity to identify and evaluate any hazardous atmospheres that may exist or arise.  This is required to ensure that appropriate permit entry procedures specific to the operation can be developed and acceptable entry conditions stipulated for that specific space. The internal atmosphere will be tested, with a calibrated direct-reading instrument, for the following conditions in the order given:

1.  Oxygen content.  (19.5% - 23.5%)

OSHA Mandated

2.  Flammable gases and vapors.

OSHA Mandated

3.  Potential toxic air contaminants.

OSHA Mandated

4.  Airborne combustible dusts

Site Specific

_____________________________

Site Specific

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Verification Testing

The atmosphere of a permit space which may contain a hazardous atmosphere will be tested for residues of all contaminants identified by evaluation testing using permit specified equipment to determine that residual concentrations at the time of testing and entry are within the range of acceptable entry conditions.  Results of testing (i.e., actual concentration, etc.) will be recorded on the permit in the space provided adjacent to the stipulated acceptable entry condition.  The atmosphere will be verified, with a calibrated direct-reading instrument, for the following conditions in the order given

1.  Oxygen content.  (19.5% - 23.5%)

OSHA Mandated

2.  Flammable gases and vapors.

OSHA Mandated

3.  Potential toxic air contaminants.

OSHA Mandated

4.  Airborne combustible dusts

Site Specific

Duration of Testing

Measurement of values for each atmospheric parameter will be made for at least the minimum response time of the test instrument specified by the manufacturer.

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Testing Stratified Atmospheres

When monitoring for entries involving a descent into atmospheres that may be stratified, the atmospheric envelope will be tested a distance of approximately 4 feet (1.22 m) in the direction of travel and to each side.  If a sampling probe is used, the entrant's rate of progress will be slowed to accommodate the sampling speed and detector response.  The stratified atmosphere will be tested, with a calibrated direct-reading instrument, for the following conditions in the order given:

1.  Oxygen content.  (19.5% - 23.5%)

OSHA Mandated

2.  Flammable gases and vapors.

OSHA Mandated

3.  Potential toxic air contaminants.

OSHA Mandated

4.  Airborne combustible dusts

Site Specific

_____________________________

Site Specific

Order of Testing

A test for oxygen will be performed first, because most combustible gas meters are oxygen dependent and will not provide reliable readings in an oxygen deficient atmosphere. Combustible gases will be tested next, because the threat of fire or explosion is both more immediate and more life threatening, in most cases, than exposure to toxic gases and vapors. If tests for toxic gases and vapors are necessary, they will be performed last.

Confined Space Entry Permits

Confined Space Entry Permits will be maintained and issued by the EH&S office. Terminated entry permits will also be kept on file in the EH&S office.

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Content of Confined Space Entry Permit

The Columbia University Confined Space Entry Permit will contain the following information:

  • The permit space to be entered. 
  • The purpose of the entry. 
  • The date and the authorized duration of the entry permit. 
  • The authorized entrants within the permit space, by name or by such other means to enable the attendant to determine quickly and accurately, for the duration of the permit, which authorized entrants are inside the permit space. This requirement may be met by inserting a reference on the entry permit as to the means used, such as a roster or tracking system. 
  • The employee(s), by name, currently serving as attendant(s). 
  • The employee, by name, currently serving as entry supervisor, with a space for the signature or initials of the entry supervisor who originally authorized entry. 
  • The hazards of the permit space to be entered. 
  • The measures used to isolate the permit space and to eliminate or control permit space hazards before entry. 
  • Those measures can include the lockout or tagging of equipment and procedures for purging, inerting, ventilating, and flushing permit spaces.

The acceptable entry conditions.

  • The results of initial and periodic tests, accompanied by the names or initials of the testers and by an indication of when the tests were performed. 
  • The rescue and emergency services that can be summoned and the means (such as the equipment to use and the numbers to call) for summoning those services. 
  • The communication procedures used by authorized entrants and attendants to maintain contact during the entry. 
  • Equipment, such as personal protective equipment, testing equipment, communications equipment, alarm systems, and rescue equipment, to be provided for compliance with this program. 
  • Any other information whose inclusion is necessary, given the circumstances of the particular confined space, to ensure employee safety. 
  • Any additional permits, such as for hot work, that have been issued to authorize work in the permit space.
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Permit System

  • To ensure accessibility of the confined space equipment, only one confined space entry permit will be active during any 8-hour shift. A new permit may be issued during the same shift only after the preceding permit has been canceled. 
  • Before entry begins, the Entry Supervisor, identified on the permit, will sign the entry permit to authorize entry. 
  • The completed permit will be made available at the time of entry to all authorized entrants by posting at the confined space access opening so that the entrants can confirm that pre-entry preparations have been completed. All adjacent openings will be monitored/controlled by the confined space permit. 
  • The duration of the permit may not exceed the time required to complete the assigned task or job identified on the permit without approval of EH&S.

Equipment Notes

Equipment necessary for safe confined space work operations will be made available at no cost to employees and will be used and made accessible according to the following guidelines:

  • EH&S will maintain air testing and monitoring equipment. 
  • Supervisors or project managers will provide barriers and shields, equipment necessary for safe ingress/egress, explosion-proof and non-spark producing tools. 
  • EH&S will maintain and secure the following equipment: fall protection (shock-absorbing lanyards), extraction equipment (tripod, winch), body harnesses, and ventilating equipment. 
  • The employee's department will provide any necessary personal protective equipment. 
  • If the confined space contains, or is suspect to contain, combustible gases, employees will use explosion-proof or non-spark producing tools ONLY. Welding tanks are strictly prohibited in confined spaces.
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Concluding the Entry

  • When work operations are complete, the authorized entrant(s) will inform the attendant that he/she plans to exit the space. 
  • The attendant will instruct the entrant(s) to survey the work area and verify that there are no stray tools in the space before exiting. If feasible, all tools should be removed from the space before the entrant(s) exits. 
  • The attendant will visually check that all authorized entrants have exited the space. 
  • The confined space entry point(s) will be secured by the attendant. 
  • The entry permit will be removed, canceled by the Entry Supervisor, and original returned to EH&S within 24 hours or before the end of the following work day.

After the permit is cancelled, reentry of the space is prohibited.  All borrowed equipment must be cleaned and returned to EH&S .

Termination of Entry and Cancellation of Entry Permit

An active confined space permit may be terminated under the following conditions:

  • The entry operations covered by the entry permit have been completed. 
  • A condition that is not allowed under the entry permit arises in or near the permit space.

EH&S will retain each canceled entry permit for at least 1 year to facilitate the review of the permit-required confined space program.  Any problems encountered during an entry operation will be noted on the pertinent permit so that appropriate revisions to the permit space program can be made.

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Non-Permit Required Confined Space Certification

When there are changes in the use or configuration of a non-permit confined space that might increase the hazards to entrants, EH&S will reevaluate that space and, if necessary, reclassify it as a permit-required confined space.

Permit to Non-Permit Reclassification

A space classified by EH&S as a permit-required confined space will be reclassified as a non-permit confined space under the following conditions:

  • If the permit space poses no actual, or potential, atmospheric hazards and if all hazards within the space are eliminated without entry into the space, the permit space may be reclassified as a non-permit confined space for as long as the non-atmospheric hazards remain eliminated. 
  • If it is necessary to enter the permit space to eliminate hazards, such entry will be performed under the assumption that a hazard exists.  If testing and inspection during that entry demonstrate that the hazards within the permit space have been eliminated, the permit space may be reclassified as a non-permit confined space for as long as the hazards remain eliminated.

Note: Control of atmospheric hazards through forced air ventilation alone does not constitute elimination of the hazards. Periodic monitoring will be conducted to ensure forced air ventilation maintains a safe worker environment for reclassification to a non-permit confined space.

EH&S will document the basis for determining that all hazards in a permit space have been eliminated, through a certification that contains as a minimum; the date, the location of the space, and the signature of the person making the determination. The certification shall be made available to each employee entering the space.

If hazards arise within a permit space that has been declassified to a non-permit space, each employee in the space shall immediately exit the space and notify their supervisor.  EH&S will then reevaluate the space and determine whether it must be reclassified as a permit space, in accordance with other applicable provisions of this instruction.

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Retrieval Systems

Only non-entry rescue procedures will be conducted by Morningside Campus employees.  Any other method of rescue will be performed by the emergency rescue team on call.  The emergency rescue phone number will be conspicuously listed on the confined space permit.

Retrieval Systems will meet the following requirements:

  • Each authorized entrant will use a full body harness, with a retrieval line attached at the center of the entrant's back near shoulder level, or above the entrant's head. 
  • The other end of the retrieval line will be attached to a mechanical device or fixed point outside the permit space in such a manner that rescue can begin as soon as the rescuer becomes aware that rescue is necessary.  A mechanical device will be available to retrieve personnel from vertical type permit spaces more than 5 feet deep. 
  • If an injured entrant is exposed to a substance for which a Material Safety Data Sheet (MSDS) or other similar written information is required to be kept at the worksite, that MSDS or written information will be made available to the medical facility treating the exposed entrant.

Employee Information and Training

Training will be provided so that all employees whose work is regulated by this program acquire the understanding, knowledge, and skills necessary for the safe performance of the duties assigned under this program.  It is the responsibility of the employee's supervisor to ensure all employees involved with confined space work receive the proper training.  EH&S will either provide the training, or make arrangements with an oustide vendor, to provide the training.

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Training will be provided to each affected employee:

  • Before the employee is first assigned duties under this program. 
  • Before there is a change in assigned duties. 
  • Whenever there is a change in permit space operations that presents a hazard about which an employee has not previously been trained. 
  • Whenever there are deviations from the permit space entry procedures required by this program or that there are inadequacies in the employee's knowledge or use of these procedures.

The training will establish employee proficiency in the duties required by this program through testing and will introduce new or revised procedures, as necessary, for compliance with this program.

EH&S will certify through recordkeeping that the employee training and testing required by this program has been accomplished. The certification will contain each employee's name, the signatures or initials of the trainers, and the dates of training. The certification will be available for inspection by employees and their authorized representatives.  A certificate of completion will be issued by EH&S to the employees upon successful completion of the training program.

Non-Morningside Campus employees (i.e. oustdie contractors) involved with permit space work , will be required to submit training certificates to EH&S prior to the commencement of work.  It is the reponsibility of the project manager to ensure that this documentation is submitted to EH&S in a timely fashion.  Without this information, EH&S will not allow any confined space work to take place.

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EH&S Information
Environmental Health and Radiation Safety/Environmental Health and Safety (EH&S)
S.W. Mudd Building, Suite 350
500 West 120th Street, Mail Code 2215
New York, New York 10027
854-8749 (Phone)
316-4937 (Fax)
ehrs@columbia.edu

EH&S Normal Office Hours
Monday – Friday:  9:00 a.m. to 5:00 p.m.

Appendix A:
Columbia University Morningside Campus Emergency Procedures

The following Emergency Procedures are for the Columbia University Morningside Campus community only.  Columbia University personnel should contact Columbia University Morningside Security for the following emergency situations Medical, Fire, Criminal Activity, Chemical Spill, or Radioactive Spill at:

x99 (On Campus)
854-5555 (Off Campus)

For other non-emergency issues please contact the Environmental Health and Radiation Safety office during normal office hours Monday through Friday 9:00 a.m. to 5:00 p.m. at 854-8749.

After normal hours, weekends, and holidays please contact the CU Security Office.

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Appendix B:
Columbia University Morningside Campus Confined Space Permit

Click on a link for the Permit (HTML / PDF / WORD)

Appendix C:
Morningside Campus Permit Required Confined Spaces

Note:  This appendix will be amended as new permit-required confined spaces are identified.

The following areas have been identified as permit-required confined spaces.  Entry into these spaces should only take place once a completed Comfined

  • CEPSR Powerhouse Boiler Room - Boilers #1-4
  • CEPSR Powerhouse  - Condensate Tanks (2)
  • Grove Area/Uris – Underground Storage Tanks (UST's) (9)
  • Mudd Lower Garage - Ejector Pit Tank (1)

Appendix D: Glossary of Terms

Air ejectors, or jet-air movers: blow air or steam through a tube, creating a low pressure area, thereby causing large quantities of air to be drawn into the tube.
Air purifying respirators: remove contaminants by passing the breathing air through a purifying element. Also known as APR's. 
Atmospheric supplying respirators: provide a source of clean breathing air from a remote location; the air is supplied to the worker from either a stationary or portable source.
Atmospheric hazards: (contaminated air), including atmospheres that are asphyxiating, toxic, or oxygen-enriched.
Attendant: an individual stationed outside the confined space to monitor the authorized entrant.
Authorized entrant: an employee who is authorized by an employer to enter a permit space.
Axial flow fans: draw in air and discharge air along the path of the shaft. That is, the air flows in a straight line through the fan.
Belly: the space between the lip and toe of trench.
Belly in/wall slough: a collapse caused when a large mass of soil falls from the side of a trench and leaves a large overhang.
Benching: relies on the maximum allowable slope principal but employs one or more vertical sided portions.
Blanking or blinding: 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.

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Block out: a process for isolating objects that can move or fall.
Boiling point: the temperature at which a liquid turns into a vapor. (Unit I).
Cave-in: the separation of material (rock or soil) from the side of the excavation into the excavation.
Centrifugal flow fans: draw in air parallel to the shaft, but turn the air go degrees and discharge it perpendicular to the shaft.
Closed-circuit SCBA: exhaled air is recycled by removing the carbon dioxide with an alkaline scrubber and by replenishing the consumed oxygen with oxygen from a solid, liquid, or gaseous source.
Combustible gas indicators (CGI): measures the concentration of a flammable vapor or gas in air, indicating the results as a percentage of the lower explosive limit (LEL) of the calibration gas.
Combustible liquids: a liquid that has a flash point of 100°F (Fahrenheit)or more.
Confined space entry permit: explains the hazards in the space and how these hazards will be controlled.
Confined space supervisor: the responsible individual who authorizes entry; makes certain all work conditions are safe, only properly trained workers are doing appropriate tasks, and a confined space entry permit has been issued.
Double block and bleed: 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.
Duct work: contains the air stream and directs it where you want it to go. It may consist of rigid material or flexible hoses or tubing.
Engulfment: occurs when a worker in a confined space is trapped or enveloped by solid or liquid material.
Entrant: the individual who will actually enter the confined space.
Entry permit: a written document provided by the employer that specifies the conditions of entry into a hazardous confined space.
Entry: the action by which a person passes through an opening into a permit required confined space; occurs as soon as any part of the entrant's body breaks the plane of an opening into the space.
Excavation: any man-made cut, cavity, trench, or depression in an earth surface, formed by earth removal.
Finance: command function responsible for tracking all costs related to an incident.
Flammable liquid: a liquid that has a flash point below 100°F or 36°Celsius (C).
Flash point: the minimum temperature at which a liquid generates enough vapor to form an ignitable mixture with air.
Hazardous atmosphere: 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.
Heat stress: results from a combination of temperature within the space, exertion, and use of personal protective equipment.
Ignition temperature: the minimum temperature that a liquid must be raised to initiate or cause self-sustained combustion.

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Immediately dangerous to life or health (IDLH): any condition that poses an immediate or delayed threat to life or that would cause irreversible adverse heath effects or that would interfere with an individual's ability to escape unaided from a permit space.
Inerting: 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.
Isolation: the process by which a permit required space is removed from service and protected against the release of energy and material into the space.
LC50: lethal concentration of a substance in air that will kill 50% of test animals when inhaled over a period of time, usually one hour.
LD50: the amount of substance that when fed to or applied on test animals, will kill half of the animals in the test. It is the lethal dose for 50% of the animals being tested under specific conditions.
Liquid splash-protective suits: are designed to keep liquids off the wearer's skin.
Line breaking: 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.
Lip: usually refers to the area at the top of both sides of a trench.
Lip slide: often caused by piling the excavated spoil too close to the edge, thereby creating a load on the lip of the trench.
Local negative pressure ventilation: a method of ventilation that places an exhaust intake close to the contaminant's point of origin.
Lockout/tagout: the most common means of isolating an energy source.
Logistics: command function responsible for providing facilities and services to support personnel at the incident, such as food, areas for rehabilitation and emergency medical treatment.
Lower explosive limit (LEL): the concentration of flammable vapors in the air is below a level which will result in a flame, given an ignition source.
Mechanical hazards: could include uncontrolled electricity, unintentional activation of equipment, falling objects, inadequate footing, or releases of steam or compressed air.
Mechanical ventilation: supplies air to the space (using positive pressure) or exhausts it from the space (using negative pressure).

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Miscibility: the ability of a gas or liquid to dissolve in another gas or liquid.
Molecular weight: the atomic weight of all atoms in a specific molecule.
Negative pressure/exhaust ventilation: pulls contaminated air out of a space.
Negative-pressure respirators: also known as demand respirators, draw air into the face-piece via the negative pressure created by user inhalation.
Operations section: responsible for most of the tactical planning and direct action.
Open-circuit SCBA: air is exhaled directly into the ambient atmosphere.
Oxygen deficient atmosphere: an atmosphere with an oxygen level below 1g.5%.
Oxygen enriched atmosphere: an atmosphere with an oxygen level greater than 21%.
Oxygen meter: an instrument that detects the concentration of oxygen in air.
Permissible exposure level (PEL): average concentration that must not be exceeded during 8-hour work shift of a 40-hour work week.
Permit system: an employer's written procedure for preparing and issuing permits for entry.
Permit-required confined space: a confined space with one or more of the following characteristics:

  • Contains or may contain a hazardous atmosphere. 
  • Contains a material that may engulf a person inside. 
  • Has an internal shape that could allow a person to be trapped or asphyxiated, such as inwardly converging walls or a floor that slopes downward and tapers to a smaller cross-section. 
  • Contains any other recognized serious safety or health hazard.

Permit-required confined space program (permit space program): an employer's overall program for controlling, and, where appropriate, for protecting employees from, permit space hazards and for regulating employee entry into permit spaces.
pH: a logarithmic scale which can measure the acidity or alkalinity of materials. The scale ranges from 0 to 14, with 7 considered neutral.
Planning: command function responsible for collecting, evaluating, and disseminating information about the incident and available resources.

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Positive-negative/push-pull ventilation: flushes the atmosphere by supplying and exhausting large volumes of air. It doesn't reduce the total amount of contaminants released, but moves them out of the confined space into the atmosphere.
Positive-pressure respirators: maintain a positive pressure in the face-piece during both inhalation and exhalation.
Positive pressure/supply ventilation: pushes air into a space, causing contaminated air to exit through any available openings.
Recommended exposure level (REL): average concentration limit recommended for up to a 1 0-hour workday during a 40-hour workweek.
Rescue service: the personnel designated to rescue employees from a hazardous confined space.
Safety Officer: assesses hazardous and unsafe situations in an emergency incident.
Self-contained breathing apparatus (SCBAs): a device which supplies grade d breathing air from a pressurized source carried by the user.
Shield system: a structure or system that normally does not prevent a cave-in but is able to withstand the soil forces caused by a cave-in and thereby protect employees within the structure. Shields may be permanent structures or may be designed to be portable and moved along the trench. Shields used in trenches are usually referred to as "trench boxes" or "trench shields".
Shoring: a system of uprights (vertical members of a trench shoring system) which bear against the soil, walers (horizontal members of a trench shoring system) which- hold the uprights against the soil, and braces (cross members of a trench shoring system) which force the walers tightly against the uprights. Walers are also called stringers or rangers.
Short-term exposure level (STEL): 15-minute exposure limit that must not be exceeded during the workday.
Side wall shear: a collapse caused when an entire wall of earth shears-away from the side.
Sloping: a method of protecting employees against cave-ins by cutting back the sides of an excavation to a safe slope.
Solubility: the ability of one substance to mix with another.
Specific gravity: refers to the weight of a liquid or solid in comparison to an equal volume of water.
Spoil: the soil, rocks, or other materials removed from a trench.
Supplied-air respirators (SAR's): respirators connected to a remote source of grade d breathing air by an airline hose.
Testing: the process by which the hazards that may confront entrants of a permit space are identified and evaluated.
Trench: a narrow excavation (in relation to its length) made below the surface of the ground.
Threshold limit value-ceiling (TLV-C): concentration that should never be exceeded.
Threshold limit value-short-term exposure limit (TLV-STEL): 15-minute exposure limit that should not occur more than 4 times during the workday.
Threshold limit value-time weighted average (TLV/TWA): average concentration limit for a normal 8-hour workday and a 40-hour workweek that should not cause adverse effects.
Toe: the area on both sides of the floor of a trench.
Upper explosive limit (UEL): the concentration of flammable vapors is above a level which will result in a flame given an ignition source. There is not enough oxygen to support combustion (the mixture is too rich to ignite).

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Vapor density: the tendency of a gas or vapor to rise or fall in air. Air has a vapor density of 1.0; gases and vapors with vapor densities less than 1.0 will rise in air; those with vapor densities greater than 1.0 will sink in air.
Vapor protective suits: should be used when the chemical(s) encountered are volatile, particularly hazardous, and have known skin toxicity.
Vapor pressure: the ability of a liquid to move from the liquid state to the gas state (a vapor). Vapor pressure is often measured in millimeters (mm) of mercury (Hg).
Ventilator: a high powered fan which forces large amounts of air into a work area.

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