Chapter 34
CONFINED SPACES

Contents

Approved by Barbara Tuse
Revised 07/12


34.1 Policy

34.2 Scope and Applicability

34.3 Roles and Responsibilities

34.4 Definitions

34.5 Required Work Processes Work Process A. LBNL Confined Space Inventory
Work Process B. Classification of Spaces
Work Process C. Safe Work Procedures
Work Process D. Entry into Inventoried Spaces by LBNL Employees or Affiliates (Does Not Include Subcontractors)
Work Process E. Entry into Inventoried Spaces by Subcontractors
Work Process F. Training
Work Process G. Program Effectiveness Review and Assurance
34.6 Appendices Appendix A. LBNL Implementation of Permit-required Confined Space Decision Flowchart
Appendix B. Confined Space Evaluation Worksheet
Appendix C. PRCS Reclassification Certification
Appendix D. PRCS Alternate Entry Procedure Certification
Appendix E. Permit-required Confined Space Entry Debrief

Confined spaces are work locations that meet regulatory definitions and require rigorous additional analysis and Work Authorization in addition to the usual safe work practices and procedures required by Integrated Safety Management Systems.

NOTE:
. . . . . Denotes a new chapter or section.
. . . . . . . . Denotes the beginning of changed text within a section.
. . . . . . . . Denotes the end of changed text within a section.

____________________

34.1 Policy

  1. Management of LBNL’s Confined Spaces, including Permit-required Confined Spaces, is in accordance with the requirements of the Occupational Safety and Health Administration (OSHA) standard—Code of Federal Regulations (CFR), Title 29, Part 1910.146 (29 CFR 1910.146)—and the additional requirements in this PUB-3000 chapter. The OSHA Permit-required Confined Space Decision Flowchart (29 CFR 1910.146 Appendix A), reproduced in this PUB-3000 chapter as Appendix A, forms the basis of LBNL’s Confined Space Program.
    Exception: Pits, excavations, trenches, and confined spaces entered by subcontractors under the subcontractor’s approved Permit-required Confined Space Program may be managed by LBNL’s Construction Safety Program under the requirements of Title 8, California Code of Regulations, Construction Safety Orders; and General Industry Safety Orders, Article 108, "Confined Spaces," Section 5157, which is the functional equivalent to 29 CFR 1910.146.
  2. LBNL staff, affiliates, visitors, and others who perform work at LBNL (excluding subcontractors operating under their own approved Permit-required Confined Space Program) may not enter any Permit-required Confined Space (PRCS) unless:
    1. The hazards within have been eliminated and the PRCS has been reclassified for non-permit entry per OSHA 29 CFR 1910.146(c)(7) and the procedures herein; or
    2. The only hazard in the PRCS is an actual or potential hazardous atmosphere; that condition is controlled through continuous ventilation; and the entry is performed under an Alternate Entry Procedure per OSHA 29 CFR 1910.146(c)(5) and the procedures herein.

    If the above conditions cannot be met, then a subcontractor must be engaged to perform the entry under the subcontractor’s approved Permit-required Confined Space Program.
  3. Prior to any subcontractor entering a Permit-required Confined Space, the subcontractor’s Permit-required Confined Space Program must be reviewed by LBNL’s Confined Space Program Manager and approved by the Construction Safety Manager and the Activity Lead responsible for the subcontract. Subcontractor reclassification, Alternate Entry Procedure, or permit entry into a PRCS is conducted under the documentation that is part of the subcontractor’s approved PRCS program.

34.2 Scope and Applicability

This PUB-3000 chapter applies to

  1. All spaces at LBNL, including those classified or not classified as
    and
  2. All employees, visitors, affiliates, and subcontractors who perform work at LBNL.

34.3 Roles and Responsibilities

Division Directors

Environment, Health, and Safety (EH&S) Division

Activity Leads

Entry Supervisors

Construction Safety Entry Supervisors

Subcontractors

34.4 Definitions

Activity Lead: The person who

Confined space: A space that

Non-permit Confined Space: 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.

Permit-required Confined Space: A confined space that has one or more of the following characteristics:

Eliminated: Removed by a means that does not require active intervention to maintain. For example, Lock Out/Tag Out of rotating machinery or physical blocking of a hydraulic ram would be considered elimination. Traffic control or continuous forced air ventilation would not be considered elimination.

Entry Supervisor: The person responsible for determining whether acceptable entry conditions are present at a permit-required space where entry is planned, for authorizing entry and overseeing entry operations, and for terminating entry as required by this document and applicable regulations. Only Entry Supervisors may authorize entry into Permit-required Confined Spaces. Entry Supervisors must be so designated by the Confined Space Program Manager.

Construction Safety Entry Supervisor: A member of LBNL’s EH&S Division Construction Safety staff who has also been designated as an Entry Supervisor.

See also definitions in 29 CFR 1910.146, which are incorporated by reference.

34.5  Required Work Processes

Work Process A. LBNL Confined Space Inventory
Work Process B. Classification of Spaces
Work Process C. Safe Work Procedures
Work Process D. Entry into Inventoried Spaces by LBNL Employees or Affiliates (Does Not Include Subcontractors)
Work Process E. Entry into Inventoried Spaces by Subcontractors
Work Process F. Training
Work Process G. Program Effectiveness Review and Assurance


Work Process A. LBNL Confined Space Inventory

confined space flowchart

  1. The LBNL Confined Space Inventory lists LBNL spaces that have been evaluated and classified as
    1. Not a Confined Space
    2. Non-permit Confined Space (NPCS)
    3. Permit-required Confined Space (PRCS)

    The Confined Space Inventory and its supporting documentation are maintained by the EH&S Division and are LBNL’s central repository of information regarding the entry safety aspects of these spaces. For each space, information collected includes:


    Information from the LBNL Confined Space Inventory is exported to the Facilities Maximo® work control system based upon location (LBNL building and room number, for inventoried spaces associated with buildings) or Facilities Asset No. (for inventoried spaces not associated with buildings). Whenever the Maximo® work control system generates a work request, it checks to see if there is an inventoried space associated with the location or asset referenced in the work request. If so, it extracts the inventory information, and appends it to the work request. In this manner, the Activity Lead and assigned personnel for that particular work have the Confined Space Inventory information available to aid in work planning.[1]

  2. During work planning, Activity Leads must review the work area to evaluate its potential for containing inventoried spaces.
    1. The work request, if present, may list the space and supporting information (e.g., Safe Work Procedure) as contained in the LBNL Confined Space Inventory.
    2. The absence of a listing does not mean that NPCS or PRCS is not present. It means that an evaluation has not been performed and recorded.
    3. The absence of a listing, or the classification of a space as Not a Confined Space, does not mean that a hazard is not present. Hazards may exist (e.g., an exposed edge posing a fall hazard) that are unrelated to the classification.
    4. The Confined Space Program Manager must be consulted for evaluation and classification of spaces (see Work Process B below).

Work Process B. Classification of Spaces

  1. If any individual suspects that:
    1. A space not listed in the LBNL Confined Space Inventory is a confined space, or
    2. A space is listed in the LBNL Confined Space Inventory, but the classification is not correct,

    then he/she must contact the Confined Space Program Manager to classify or review the classification of the space.

  2. The Confined Space Program Manager has sole (delegable) authority for classification of spaces.
  3. The Confined Space Program Manager classifies a space by
    1. Evaluating the space;
    2. Determining its classification as Not a Confined Space, a Non-permit Confined Space, or a Permit-required Confined Space using the Confined Space Evaluation Worksheet;
    3. Determining if a Safe Work Procedure is necessary for entry into that space; and if so
    4. Developing the Safe Work Procedure in consultation with the entrants and the space owner.
  4. Some spaces across LBNL are categorically classified as Not a Confined Space, a Non-permit Confined Space (NPCS), or a Permit-required Confined Space (PRCS). Categorical classification means that the space has been classified based upon general characteristics of the space, and that categorical classification applies unless the individual space has been specifically classified as otherwise and listed in the LBNL Confined Space Inventory as such. Generally, the categorical classification information is contained in the LBNL Confined Space Inventory under "General Safe Work Procedure."

    Categorical classification is via the criteria specified in OSHA 1910.146 and Section 34.4 (Definitions) above. If a space does not meet the regulatory definition of "Confined Space" or "Permit-required Confined Space," this does NOT imply that the space is without hazards. Hazards may exist that are unrelated to the regulatory classification. Other work control processes and/or permit requirements, including but not limited to General Safe Work Procedures, may govern work in the space.

    If the space is categorically classified as a PRCS, then it may or may not be individually labeled. Communication of categorical classification is made via this document and via ongoing training.

    If at any time any person feels that a categorical classification of a space is incorrect, he/she must contact the Confined Space Program Manager to make a determination (see Step 1 of this PUB-3000 work process, Work Process B, above).

    Examples of categorically classified spaces are listed below:

    1. Sanitary sewer manholes, lift stations, and wet sumps are Permit-required Confined Spaces with hazardous atmosphere as the defining characteristic.
    2. Components of the storm-water system are either Not a Confined Space, a Non-permit Confined Space, or a Permit-required Confined Space.
      1. Storm-water pipes less than or equal to 18 inches in diameter are Not a Confined Space.
      2. Storm-water pipes greater than 18 inches in diameter are Non-permit Confined Spaces with associated Safe Work Procedures.
      3. Catch basins less than or equal to 36 inches deep are Not a Confined Space.
      4. Catch basins greater than 36 inches deep are Non-permit Confined Spaces with associated Safe Work Procedures.
      5. Storm-water manholes are Permit-required Confined Spaces with hazardous atmosphere (oxygen deficiency) being the defining characteristic.
    3. Electrical and telecommunication manholes are Permit-required Confined Spaces with hazardous atmosphere (oxygen deficiency) being the defining characteristic. (Note: Vaults are not categorically classified; they are individually classified, and the information is listed in the LBNL Confined Space Inventory.)
    4. Fuel storage tanks, whether aboveground or underground, are Permit-required Confined Spaces with hazardous atmosphere (vapor) being the defining characteristic (exception: those that cannot be entered are Not a Confined Space).
    5. Cryogen (e.g., liquid nitrogen) storage tanks (fixed locations at buildings) are Permit-required Confined Spaces with hazardous atmosphere (oxygen deficiency) being the defining characteristic (exception: those that cannot be entered are Not a Confined Space).
    6. Elevator pits and shafts are Permit-required Confined Spaces with the presence of a recognized safety and health hazard (e.g., crushing by the elevator car) being the defining characteristic (exception: elevator pits less than or equal to 36 inches deep are Not a Confined Space).

Work Process C. Safe Work Procedures

Safe Work Procedures (SWPs) are steps or precautions developed by LBNL that provide guidance for working in spaces listed in the LBNL Confined Space Inventory. Although not required by the OSHA Permit-required Confined Spaces requirements in 29 CFR 1910.146, LBNL has found them to be valuable in guiding not only regulatory compliance, but also safe work.

Safe Work Procedures are established by the Confined Space Program Manager in cooperation with the custodian and entrants of a space. Once established, they are filed in the LBNL Confined Space Inventory and associated with the space(s) to which they apply. Entrants who enter that space, regardless of whether the space is Not a Confined Space, a Non-permit Confined Space (NPCS), or a Permit-required Confined Space (PRCS), must adhere to the requirements of the SWP. If the circumstances of a particular piece of work do not allow adherence to the requirements of the SWP, the SWP must be revised or supplemented as necessary and reviewed by the Confined Space Program Manager.

Safe Work Procedures may be either general or specific.

Work Process D. Entry into Inventoried Spaces by LBNL Employees or Affiliates (Does Not Include Subcontractors)

  1. Pre-Entry

    Prior to entry into any inventoried space, the Activity Lead must:

    1. Review the work request (if available) for that activity;
    2. Consult the LBNL Confined Space Inventory to determine the classification of that space;
    3. Inspect the work space to verify that conditions within the space are as described in the LBNL Confined Space Inventory, or to note changed conditions; and
    4. Notify the Confined Space Program Manager of any changed conditions.
  2. Entry into Spaces That Are Classified as "Not a Confined Space"

    If the work includes entry into a space classified as "Not a Confined Space," then the Activity Lead must determine whether an applicable Safe Work Procedure (SWP) exists for entry into that space by consulting the LBNL Confined Space Inventory.

    1. If an SWP exists for entry into the space, then entry may proceed in accordance with that SWP and the Work Authorization for that work.
    2. If an SWP exists for entry into the space, but the circumstances of the work do not permit it to be performed in accordance with the SWP, then the SWP must be revised or supplemented. The Confined Space Program Manager reviews the changes to the SWP. Work may not proceed until the Confined Space Program Manager has concurred with the changes/supplements to the SWP. Work proceeds in accordance with the revised SWP and the Work Authorization for that work.
    3. If an SWP does not exist for that space, then entry may proceed per the Work Authorization for that work, including general and specific safe work practices for that work.
  3. Entry into Non-permit Confined Spaces

    If a Non-permit Confined Space (NPCS) must be entered as part of the work, the Activity Lead must do the following:

    1. Determine whether an applicable Safe Work Procedure exists for entry into that NPCS by consulting the LBNL Confined Space Inventory. If so, follow that procedure or modify it per Step 2.b above. If there are any questions on that procedure, contact the Confined Space Program Manager prior to executing the work.
    2. Determine whether the work may introduce a hazard into that space. Examples of hazards that may be introduced by the work include but are not limited to:
      1. Hazardous atmospheres (e.g., solvents, paints, welding)
      2. Fire (e.g., hot work, grinding)
      3. Electrical (e.g., exposed live electrical energy)
      4. Energy (e.g., removing guards)

      If the work may introduce a hazard, then the space may need to be reclassified as a PRCS, and LBNL workers will be prohibited from entering that space [see Section 34. 1 (Policy) above]. If the hazards can be successfully controlled, then this reclassification to a PRCS may not be necessary. Contact the Confined Space Program Manager to discuss further.

      If neither Step 3.a nor Step 3.b above applies, the entry may proceed per general safe work practices, including any specified for that work.

  4. Entry into Permit-required Confined Spaces
    1. If a Permit-required Confined Space (PRCS) must be entered as part of the work, the Activity Lead must do the following:
      1. Determine whether in fact the PRCS needs to be entered. There may be a Safe Work Procedure for that space allowing work from outside the space. If the desired work can be performed from outside the PRCS, then these requirements for entry do not apply. Work proceeds per that Safe Work Procedure. If there are any questions on that procedure, contact the Confined Space Program Manager prior to executing the work.
      2. Assign an Entry Supervisor to the work.
    2. The Entry Supervisor determines what the hazards or potential hazards are within that PRCS.
      1. Reclassification: If the hazards posed by the PRCS are not related to actual or potential hazardous atmosphere, and the hazards can be eliminated from outside the space prior to entry, the Entry Supervisor may temporarily declassify the PRCS to an NPCS per OSHA 29 CFR 1910.146(c)(7) by completing the "PRCS Reclassification Certification" prior to the entry.
        1. All spaces for information must be completed or marked "n/a" as applicable.
        2. Each hazards-analysis box must be completed, and a determination confirmed (checked off) that entry conditions are acceptable.
        3. If all hazards have been analyzed, eliminated if necessary, and confirmed as acceptable, the Entry Supervisor completes the final signature block at the bottom of the page, which temporarily declassifies the space as an NPCS.
      2. Alternate Entry Procedure: If the only hazard posed by the PRCS is actual or potential hazardous atmosphere, and continuous forced air ventilation is sufficient to maintain the PRCS safe for entry, then the Entry Supervisor may authorize entry via the Alternate Entry Procedure permitted by OSHA 29 CFR 1910.146(c)(5). This authorization is documented by completing the "PRCS Alternate Entry Procedure Certification" prior to the entry.
        1. All spaces for information must be completed or marked "n/a" as applicable.
        2. Each hazards-analysis box on page 1 must be completed, and a determination confirmed (checked off) that no non-atmospheric hazards exist within that PRCS.
        3. After air monitoring has been conducted (and recorded on page 1 continuing onto page 2) to document that the continuous forced air ventilation is sufficient to maintain the PRCS as safe for entry, the Entry Supervisor completes the final signature block at the bottom of the page, which authorizes entry under the Alternate Entry Procedure.
    3. If the hazards have been removed and the PRCS has been reclassified (Step 4.b.i above), or if the entry may be made under Alternate Entry Procedure (Step 4.b.ii above), the Entry Supervisor may authorize work to proceed per general safe work practices, including any specified for that work (e.g., Safe Work Procedure). When entry proceeds, the Entry Supervisor must:
      1. Continually evaluate conditions to assure that the terms of the entry remain valid (for entry under the Alternate Entry Procedure, this includes periodic air- quality testing to support the determination that continuous forced air ventilation protects workers in the space); and
      2. Remove all workers from the space if at any time hazards arise within the space, and re-evaluate the space to determine whether it must be reclassified for permit entry.
    4. If the PRCS cannot be temporarily reclassified as NPCS or entered under an Alternate Entry Procedure, then the Entry Supervisor must prohibit workers from entering the space, and advise the Activity Lead of the need to obtain the services of a qualified subcontractor to perform the work.

Work Process E. Entry into Inventoried Spaces by Subcontractors

  1. Pre-Entry

    Prior to a subcontractor entering any inventoried space, the Activity Lead must

    1. Consult the Confined Space Program Web site for subcontractor status, performance requirements, and the LBNL Confined Space Inventory to determine the classification of that space;
    2. Inspect the work space to verify that conditions within the space are as described in the Confined Space Inventory, or to note changed conditions;
    3. Notify the Confined Space Program Manager of any changed conditions;
    4. Transmit a copy of the updated inventory information to the subcontractor; and
    5. Retain a copy of the transmitted information for post-entry submittal to the Confined Space Program Manager.

    The Construction Safety Checklist, Job Hazards Analysis, or Non-Construction Subcontractor Job Hazards Analysis can provide information on whether the proposed work includes entry into inventoried spaces.

  2. Entry into Spaces That Are Classified as "Not a Confined Space"

    If the subcontractor must enter a space classified as "Not a Confined Space," then the Activity Lead must determine whether an applicable Safe Work Procedure (SWP) exists for entry into that space by consulting the LBNL Confined Space Inventory.

    1. If an SWP exists for entry into the space, then entry may proceed in accordance with that SWP and the Work Authorization for that work.
    2. If an SWP exists for entry into the space, but the circumstances of the work do not permit it to be performed in accordance with the SWP, then the SWP must be revised or supplemented. The Confined Space Program Manager reviews the changes to the SWP. Work may not proceed until the Confined Space Program Manager has concurred with the changes/supplements to the SWP. Work proceeds in accordance with the revised SWP and the Work Authorization for that work.
    3. If an SWP does not exist for that space, then entry may proceed per the Work Authorization, including general and specific safe work practices, for that work.
  3. Entry into Non-permit Confined Spaces

    If a subcontractor must enter a Non-permit Confined Space (NPCS), then the Activity Lead must do the following:

    1. Determine whether an applicable Safe Work Procedure exists for entry into that NPCS by consulting the LBNL Confined Space Inventory. If so, follow that procedure or modify it per Step 2.b above. If there are any questions on that procedure, contact the Confined Space Program Manager prior to executing the work.
    2. Determine whether the work may introduce a hazard into that space. Examples of hazards that may be introduced by the work include but are not limited to:
      1. Hazardous atmospheres (e.g., solvents, paints, welding)
      2. Fire (e.g., hot work, grinding)
      3. Electrical (e.g., exposed live electrical energy)
      4. Energy (e.g., removing guards)

    If the work may introduce a hazard, then the space may need to be reclassified as a PRCS. If the hazards can be successfully controlled, then this reclassification may not be necessary. Contact the Confined Space Program Manager to discuss further.

    If neither Step 3.a nor Step 3.b above applies, the entry may proceed per the Work Authorization for that work, including general and specific safe work practices for that work.

  4. Entry into Permit-required Confined Spaces

    If a subcontractor must enter a Permit-required Confined Space (PRCS), including entries into a PRCS after reclassification or under Alternate Entry Procedures, then the Activity Lead and Construction Safety Manager must do the following:

    1. Transmit the following information to the subcontractor:
      1. Inform the subcontractor that the work area contains PRCS, and that entry into PRCS is allowed only through compliance with a PRCS program meeting the requirements of OSHA 29 CFR 1910.146.

        NOTE: 8 CCR 5157 is functionally equivalent to 29 CFR 1910.146.

      2. Provide the subcontractor with all information contained in the LBNL Confined Space Inventory about the PRCS in or near the area where the subcontractor will be working, including the hazards identified and LBNL’s experience with the space(s) that makes them PRCS, and precautions or procedures that LBNL has implemented for the protection of employees in or near the PRCS.
    2. Approve the subcontractor’s PRCS program after obtaining the Confined Space Program Manager’s input as follows:
      1. Obtain a copy of the subcontractor’s PRCS program as a contract submittal.
      2. Provide the subcontractor’s PRCS program to the Confined Space Program Manager for review. Allow at least five workdays for review and resolution of comments.
      3. Direct the subcontractor during resolution of the comments. The Confined Space Program Manager does not direct the subcontractor.
      4. Prohibit the subcontractor from entering the PRCS until any issues with the subcontractor’s PRCS program have been resolved to the satisfaction of the Confined Space Program Manager.
      5. If the PRCS can be reclassified to an NPCS by elimination of the hazard, the Confined Space Program Manager may recommend that the Activity Lead approve the subcontractor’s PRCS program subject to this restriction.
    3. If there are multiple subcontractors who will simultaneously enter the PRCS, or if subcontractor and LBNL personnel will be working in or near the PRCS, convene a meeting of affected parties to discuss the work that will be performed in and around the PRCS. Coordinate entry operations such that employees of one subcontractor do not endanger LBNL employees or the employees of any other subcontractor.
      1. No subcontractor shall enter a PRCS under any reclassification, Alternate Entry Procedure, or permit until coordination procedures and authorizations have been agreed upon.
      2. The coordination procedures and authorizations must be documented in a written step-by-step timeline of activities.
    4. Assure that prior to subcontractor entry into a PRCS, an LBNL Construction Safety Entry Supervisor has reviewed the documentation prepared by the subcontractor (e.g, Reclassification or Alternate Entry Procedure Certification, entry permit, coordination procedures, and authorizations) and concur on its adequacy.
    5. Debrief the subcontractor at the conclusion of the PRCS entry operations regarding the permit space program followed, and regarding any hazards confronted or created in permit spaces during entry operations. The results of the debriefing must be documented on the Permit-required Confined Space Entry Debrief (Appendix D of this PUB-3000 chapter). A separate debrief must be completed for each subcontractor entering the PRCS.
    6. Submit the following information to the Confined Space Program Manager within seven calendar days of expiration of the permit, and retain the information with the project file:
      1. Inventory information transmitted to the subcontractor
      2. Completed Subcontractor PRCS Permits
      3. Debriefing documentation
      4. Documentation provided by the subcontractor of any changes in conditions encountered in or made to the Permit-required Confined Space.

Work Process F. Training

  1. With the exception of subcontractors covered by their own approved Permit-required Confined Space Program, any LBNL staff, affiliate, visitor, or other individual who performs work at LBNL and who will enter a space classified as a Non-permit Confined Space (NPCS) or a Permit-required Confined Space (PRCS), whether on a Safe Work Procedure, reclassification, Alternate Entry Procedure, or another work plan, must have current training in EHS0275 Confined Space Hazards and EHS0274 Confined Space Hazards Retraining (if applicable). This training requirement is delivered by the Job Hazards Analysis.
  2. With the exception of subcontractors covered by their own approved Permit-required Confined Space Program, any LBNL staff, affiliate, visitor, or other individual who performs work at LBNL and who functions as an Entry Supervisor shall be current in EHS0277 Confined Space Entry Supervisor. This training requirement is delivered via the individual being designated as an Entry Supervisor by the Confined Space Program Manager.

Work Process G. Program Effectiveness Review and Assurance

  1. The Confined Space Program Manager, Activity Lead, and Entry Supervisor must prohibit further entry into a Permit-required Confined Space Program (PRCS) and review entry operations whenever there is reason to believe that measures taken under this program may not protect employees. In particular, the Activity Lead and Entry Supervisor must notify the Confined Space Program Manager of:
    1. Any unauthorized entry of a PRCS,
    2. Detection of any hazard in a PRCS that is not covered in the permit,
    3. Detection of a condition prohibited by the permit,
    4. Occurrence of an injury or near-miss during entry,
    5. Change in use or configuration of the permit space, or
    6. Employee complaints about the effectiveness of the program.

    Additionally, the Confined Space Program Manager must review entry operations after:

    1. Any unauthorized entry of a PRCS,
    2. Detection of any hazard in a PRCS that is not covered in the permit,
    3. Detection of a condition prohibited by the permit,
    4. Occurrence of an injury or near-miss during entry,
    5. Change in use or configuration of the permit space, or
    6. Employee complaints about the effectiveness of the program.
  2. The Confined Space Program Manager must conduct an ongoing effectiveness (Technical Assurance) review of the program by reviewing (at least annually):
    1. A minimum of 75% of the PRCS Reclassification Certification and PRCS Alternate Entry Procedure Certification completed during the review period; and
    2. All Subcontractor PRCS Permits completed for PRCS entry during the review period.

    The review shall include:

    1. Reviewing each Certification/Permit for completeness and adherence to policy,
    2. Documenting that each individual who presents himself/herself as an Entry Supervisor has been so designated by the PRCS Program Manager, and
    3. Documenting that all individuals who entered the PRCS under either the Certification(s) or the Permit(s) have received proper training.

    Further details on Technical Assurance of the program are given in the LBNL Technical Assurance Plan (TAP). If any element of the TAP conflicts with details herein, the TAP governs.

___________________
Note:
1. As of March 2011, the electronic linkage between the LBNL Confined Space Inventory and the Facilities Maximo® work control system has not been established. Activity Leads must manually check the inventory at https://ehswprod.lbl.gov/ConfinedSpace/login.aspx to determine whether confined spaces exist within the work area.

_____________________

<< Chapter 33 || Table of Contents || Chapter 35 >>