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City of University Park Fire Marshal Carl McMurphy instructs participants in fire safety during the Great SMU Escape.
Number: RMEHS.003
Effective Date: January 1997
Southern Methodist University (SMU) recognizes that certain environmental conditions within confined spaces are capable of causing serious injury and/or death to anyone who enters the spaces without taking proper precautionary measures. This operating procedure establishes a permit authorization system to ensure that all hazards are evaluated and that appropriate safety measures and controls are taken prior to and during each entry into confined spaces.
This operating procedure is written in accordance with the Occupational Safety and Health Administration’s (OSHA) workplace standard, 29 CFR 1910.146, Permit-Required Confined Spaces.
This operating procedure shall apply to all SMU personnel and all contract personnel working at all University-owned properties.
3.1 Department Heads and/or Directors -- are responsible for implementing this operating procedure within their departments, when applicable, and ensuring that their personnel fully comply.
3.2 Department Managers and/or Supervisors -- are responsible for identifying their personnel who are required to and authorized to enter confined spaces as defined in this operating procedure. Managers/supervisors must ensure that their personnel are properly trained and fully comply with the requirements identified in this procedure.
3.3 Employees -- are responsible for complying with the requirements of this operating procedure. Employees shall inform their manager/supervisor of any departures from this procedure.
3.4 EH&S Department -- is responsible for the development and maintenance of this procedure, providing resources for equipment and personnel training, and for auditing all operating units and/or departments for compliance to this procedure.
4.1 Attendant -- an individual stationed outside one or more permit-required spaces who monitors the authorized entrants and who performs all attendant’s duties as defined.
4.2 Authorized entrant -- any employee who is authorized by the University to enter a permit-required space.
4.3 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.
4.4 Confined space -- means a space that:
Is large enough and so configured that an employee can bodily enter and perform assigned work; and
Has limited or restricted means for entry or exit ( for example, tanks, vessels, silos, storage bins, hoppers, vaults, and pits are spaces that have limited means of entry.); and
Is not designed for continuous employee occupancy.
4.5 Double block and bleed -- means 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.
4.6 Emergency -- is any occurrence (including any failure of a hazard control or monitoring equipment) or event internal or external to the permit space that could endanger the entrants.
4.7 Engulfment -- means the surrounding and effective capture of a person by liquid or finely divided (flowable) solid substance that can be aspirated to cause death by filling or plugging the respiratory system or that can exert enough force on the body to cause death by strangulation, constriction, or crushing.
4.8 Entry -- The action by which a person passes through an opening into a permit-required confined space. Entry is considered to have occurred as soon as any part of the entrant's body breaks the plane of an opening.
4.9 Entry supervisor -- A manager, supervisor, project coordinator, designated employee or safety representative, who by training and experience is competent to determine if acceptable entry conditions are present, for authorizing and overseeing entry operations and terminating operations. Note: An entry supervisor may also serve as an attendant or as an authorized entrant as long as the individual is properly trained and equipped to perform each designated role.
4.10 Hazardous atmosphere -- Any atmosphere that may expose employees to the risk of death, incapacitation, impairment of ability to self-rescue (unable to escape unaided from a permit spaced), injury, or acute illness from one of the following causes:
Flammable gas, vapor or mist in excess of 10 percent of its lower flammable limit (LFL);
Airborne combustible dust at a concentration that meets or exceeds its LFL;
Atmospheric oxygen concentration below 19.5% (oxygen deficient) or above 23.5 % (oxygen enriched);
Atmospheric concentration of any substance in excess of its established permissible exposure limit (PEL) or threshold limit value (TLV), if applicable; or
Any atmospheric condition that is immediately dangerous to life or health.
4.11 Hot work -- any operations capable of providing an ignition source, including but not limited to welding, cutting, burning, brazing, grinding, etc.
4.12 Immediately dangerous to life or health (IDLH) -- any condition that poses an immediate or delayed threat to life or that would cause irreversible adverse health effects or that would interfere with an individual’s ability to escape unaided from a permit-required space.
4.13 Isolation -- the process by which a permit-required space is removed from service and completely protected against the release of energy and material into the space by such means as blanking or blinding; misaligning or removing sections of lines, pipes, or ducts; a double block and bleed system; lockout/tagout of all emergency sources; or blocking or disconnecting all mechanical linkages.
4.14 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.
4.15 Non-Permit Required Confined Space -- A confined space that does not contain or, with respect to atmospheric hazards, have the potential to contain any hazards capable of causing death or serious physical harm.
4.16 Permit-Required Confined Space -- A confined space that has one or more of the following characteristics:
Contains or has the potential to contain a hazardous atmosphere;
Contains either a liquid or solid substance, that has the potential for engulfing an entrant;
Has an internal configuration such that an entrant could be trapped or asphyxiated by inwardly converging walls or by a floor which slopes downward and tapers to a smaller cross-sectional section; or
Contains any other recognized serious safety or health hazard.
4.17 Retrieval system -- the equipment used for non-entry rescue of persons
from a
permit-required space. The equipment can include, but is not limited to,
retrieval lines, chest or full-body harness, wristlets, and a lifting device.
4.18 Testing -- the process by which the hazardous atmosphere (oxygen content, LFL, toxicity levels, etc.) are identified and evaluated by the employees prior to enter the permit-required space.
5.1 Identification of confined spaces -- In accordance with the OSHA definitions, the following confined spaces have been identified for the Southern Methodist University campus:
Permit-Required
Non-Permit Required
5.2 Labeling -- Warning signs or other means of notification shall be posted at the entrance of each University-owned permit-required confined space to inform employees of its existence and dangers. The notification wording shall be as follows:
DANGER
CONFINED SPACE
PERMIT REQUIRED
PRIOR TO ENTRY
5.3 Permit system -- Before entry into a permit-required confined space is authorized, the entry supervisor shall:
Ensure and document that all control measures, as defined in Sections 6.1 - 6.6, necessary for a safe entry are in place by preparing an entry permit (see Exhibit A);
Sign the entry permit to authorize entry;
Make the completed permit available at the time of entry to all authorized entrants for their review and signature; and
Ensure that the duration of the permit does not exceed the time required to complete the assigned job or task identified on the permit.
5.4 Entry termination -- The entry supervisor shall terminate entry and cancel the permit when:
The entry operations covered by the entry permit have been completed; or
A condition that is not allowed under the entry permit arises in or near the permit space.
Each canceled/completed entry permit shall be retained for a 1 year by the department conducting or supervising the entry to allow for auditing of the program’s effectiveness.
5.5 Entry permit -- The entry permit is used to authorize entry into a permit-required space as defined in Section 4.3. An example of the entry permit is provided in Exhibit A, and must identify:
The permit space to be entered;
The purpose of the entry;
The date and duration the permit is authorized for;
The authorized entrants names;
The authorized attendant(s);
The hazards of the space and measures used to isolate, eliminate and/or control the hazards prior to entry;
Acceptable entry conditions;
Results of initial and periodic atmosphere testing (oxygen, %LEL, etc.);
Rescue or emergency contacts;
Personal protective equipment, communication equipment, rescue equipment; and
Any additional permits that are required, such as lockout/tagout and/or hot work.
5.6 Duties of authorized entrant -- The authorized entrant shall:
Know the hazards that may be faced during entry and the proper use of the protective equipment.
Communicate with and alert the attendant whenever any symptoms or warning signs of an exposure or dangerous condition is recognized; or a prohibited condition arises.
The entrant must exit from the space immediately whenever these conditions arise, or if an order to evacuate is given by the attendant or entry supervisor.
5.7 Duties of Attendant(s) -- The attendant shall:
Remain outside the space during the entry operations until relieved by another attendant.
Know the hazards that may be encountered during the entry and
know what signs or
symptoms to look for that may indicate a problem with the personnel
entering the space.
Maintain communications with the entrant(s) as necessary to monitor entrant status and to alert entrants of the need to evacuate. Communications can be maintained by voice contact or by two-way radio, if available.
Monitor activities inside and outside of the space to determine if it is safe to remain in the space.
Have the authority to stop entry operations if he/she feels that conditions exist which may endanger the entrant(s).
In the event of an emergency, be responsible for initiating emergency or rescue activities by notifying the SMU Police Department (SMUDP) at 911, or by two-way radio, if available. At no time is the attendant to attempt entry and rescue until appropriate rescue personnel have arrived.
6.1 Isolation -- Prior to entry into a permit-required space, all piping or lines connected to the space shall be disconnected, blanked/blinded or closed and locked out. All electrical sources shall be disconnected or locked out and tested to verify prior to entry.
6.2 Atmospheric testing -- The atmosphere of the space to be entered shall be tested prior to and continuously during the entry. Entry supervisors, attendants and entrants shall be properly trained on the methods and equipment used for testing the confined space atmosphere. The atmospheric testing shall include oxygen content, per cent of lower flammable limit (LFL/UEL), and concentrations of known or suspected contaminants.
6.3 Hazardous atmosphere -- If the space contains an atmosphere that is hazardous, as defined in Section 4.10, the space must be purged, inerted, flushed or ventilated as necessary to eliminate or control the hazard to an acceptable atmosphere.
6.4 Acceptable atmospheres -- A confined space shall be considered to have an acceptable atmosphere if: a. Oxygen content is>19.5% to <23.5%; b. Flammable level is below 10% of the LFL/UEL; and c. Contaminant concentrations are below acceptable exposure limits.
6.5 Barriers -- Barriers or shields shall be placed around the space, as necessary, to prevent external hazards to the entrant(s) from either pedestrian or vehicle traffic.
6.6 Prohibitive Conditions -- In the event that entry must be made into a space that acceptable atmospheres can not be obtained and no feasible alternatives are available, the operation must be reviewed by the Environmental Health & Safety Department (EH&S).
In the event of an emergency, the attendant shall initiate rescue operations by notifying the SMU Police Department (SMUPD) by telephone - 911 or by two-way radio, if available. If rescue can be performed without entry into the space, then the attendant may initiate retrieval. Under no circumstances is the attendant to enter the space without appropriate emergency response support.
7.1 Rescue Equipment -- During any entry into a confined space, the entrant(s) must wear a harness and lifeline to allow for retrieval from outside of the space. Emergency responders entering a confined space to retrieve an entrant must also wear a harness and lifeline.
7.2 Breathing Equipment -- Emergency responders enter a confined space to retrieve an entrant must wear a self-contained breathing apparatus (SCBA).
7.3 Additional Equipment -- Additional personal protective equipment for the emergency responders will be determined based on the hazard that exist within the confined space.
8.1 Entry supervisors, attendants and authorized entrants -- All employees who are authorized as confined space entry supervisors, attendants and entrants shall be trained and certified in these operating procedures. The training shall be performed upon initial assignment of personnel and refresher training will be conducted annually. The training can be conducted by the department manager/supervisor or can be coordinated through the SMU EH&S Department. The training shall include:
Definition of a permit-required confined space;
Hazards and control measures;
Entry procedures;
Responsibilities of the entrant and attendant; and e. Rescue/Emergency procedures.
8.2 Contract Personnel -- Outside contractors hired to perform operations that include confined space entry shall be notified by the designated project coordinator of these operating procedures prior to initiating the job. If the contractor has their own company procedure for confine space entry, they shall provide a copy to the University for review and approval.
Contact the Environmental Health and Safety Department for an SMU Confined Space Entry Permit.
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