CONFINED SPACE PROGRAM EHS Director: Lindsey, Kayman, SM, CIH, Public Safety and Risk Management

Created 2016

Reviewed January 2019

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TABLE OF CONTENTS

Chapter Heading Page #

- Table of Contents 1

1.0 - Introduction 2

1.1 - Background 2

1.2 - Scope 3

1.3 - Responsibilities 4

1.4 - Entry into a Reclassified Space 5

1.5 - Confined Space Identification and Warning 5

1.6 - Reclassification of Non-permit Required Confined Space 5

1.7 - Reclassification of Permit Required Confined Spaces 6

1.8 - Unauthorized Entry 6

1.9 - Training 6

1.10 - Outside Contractors 6

Appendix A Definitions

Appendix B Permit-Required Confined Space Decision Flow Chart

Appendix C New Building and Haaren Hall Permit-Required Confined Spaces

Appendix D Job Hazard Analyses for Reclassified Permit Required Confined Spaces

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1.0 – INTRODUCTION

John Jay College of Criminal Justice (JJC) Environmental Health and Safety (EHS) has implemented the rules,

regulations and other mandated practices in this protocol to promote a safe work environment and to comply

with the Occupational Safety and Health Administration (OSHA) Permit-Required Confined Space Standard

(29 CFR 1910.146).

1.1 – BACKGROUND

Many workplaces contain spaces that are considered “confined” due to configurations that hinder the activities

of any employees that must enter, work in, and exit the spaces. For example, employees who work in certain

confined spaces generally must squeeze in and out through narrow openings and perform tasks while cramped

or contorted. OSHA uses the term “confined space” to describe such spaces.

OSHA defines a confined space as any space that is large enough and so configured that an employee can

bodily enter and perform assigned work, that has a restricted means of entry or exit, and that is not designed for

continuous employee occupancy. All of these criteria must be met for a space to be classified as confined.

Examples of confined spaces include tanks, pits, certain tunnels, utility vaults, and boilers.

In addition, there are many instances where employees that work in confined spaces face increased risk of

exposure to serious hazards. In some cases, confinement poses entrapment hazards. In other cases, confined

space work keeps employees closer to hazards, such as asphyxiating atmospheres or the moving parts of

machinery. OSHA uses the term “permit-required confined space” (permit space) to describe those spaces that

meet both the definition of confined space and pose health or safety hazards.

Permit-required confined space is a confined space that has one of the following characteristics: hazardous

atmosphere or potential to produce a hazardous atmosphere; engulfment hazard by a flowable material;

inwardly converging walls or a floor that tapers to a smaller cross-section so that an entrant could be trapped or

asphyxiated; equipment or stored energy hazards such as electrical current, hydraulic operators, or steam lines;

or other serious safety or health hazards.

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1.2 – SCOPE

At JJC, employee entry into a permit required confined space is prohibited. Employees may only enter permit-

confined spaces that have been reclassified or meet the conditions of Alternate Entry as a confined space.

When permit-confined space entry is required, a contractor with permit-confined space training will be retained

to perform this work. Contractors are included only in terms of maintaining compliance with the CUNY

regulations, although contractors must have a program that complies with OSHA requirements and is equivalent

to CUNY’s program.

The Confined Space Program includes a written confined space plan; the identification, evaluation, and labeling

of CUNY confined spaces; employee training and certification; implementation of a confined space permitting

system, and the identification of responsible individuals and tasks during confined space procedures. EHS

(EHS) at CUNY is responsible for evaluating the workplace to determine if spaces are permit-required confined

spaces.

The Confined Space Program should be used in conjunction with other EHS programs. Associated safe work

practices may include but are not limited to, personal protective equipment, fall protection, the handling of

hazardous materials, and isolation of energy sources (lockout/tagout).

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1.3 – RESPONSIBILITIES

The John Jay College Department of Facilities Management and other departments are responsible for carrying

out the Confined Space program in accordance with this written program and for keeping Environmental Health

and Safety informed of new employees who need required training, requesting necessary retraining, enforcing

compliance with the permit system, and notifying EHS upon discovery of any previously unidentified potential

permit-required spaces. Also, EHS shall be informed when confined space entry work by outside

personnel/contractors is scheduled.

At JJC, employees may only enter confined spaces or permit-confined spaces that have been reclassified as a

confined space. Entry into a permit-confined space is prohibited. When permit-confined space entry is

required, a contractor qualified to perform permit-confined space will be retained to perform this work at the

expense of the department that is requesting the entry.

EHS will administer and manage the confined space program. EHS will:

Develop a written Confined Space program and amend as necessary

Assist departments in evaluating compliance with the confined space program including identifying,

labeling, and documenting JJC permit required confined spaces

Arrange and conduct training for employees for confined space awareness.

Maintain the master list of permit-confined spaces (Appendix B).

Solicit input from users, through respective supervisors, during the annual review process.

Recommend personal protective equipment (PPE) if necessary.

Conduct atmospheric testing to verify that conditions in a reclassified permit space are acceptable for

entry throughout the duration of an authorized entry except in certain routine situations, late night work,

etc.

Conduct evaluations of confined spaces, and classify as either a Permit-Required Confined Space or

Non-Permit Required Confined Space

Review outside contractor written Confined Space policies, training certificates, and Safety Data Sheets

(SDS’s). These materials must be forwarded to EHS prior to the commencement of work.

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1.4– ENTRY INTO A RECLASSIFIED SPACE

At JJC, employees before entry into a reclassified confined space the supervisor will confirm that the required

safety measures have been implemented.

1.5 – CONFINED SPACE IDENTIFICATION AND WARNING

The New Building and Haaren Hall have been evaluated in order to determine the locations of permit-required

confined spaces. Permit-required confined spaces located inside buildings are identified and posted with

appropriate signs to discourage the entry of unauthorized individuals. In areas accessible to the public, permit-

required confined spaces will be secured to prevent unauthorized entry. EHS will identify, classify, and log the

location of confined spaces on campus. If a location is encountered on campus that appears to meet the

definition of a confined space, and it is not posted as such nor does it appear on the log, inform EHS.

1.6 – RECLASSIFICATION OF NON PERMIT REQUIRED CONFINED SPACE

A Non-Permit-confined Space is a confined space that contains secondary hazards (i.e., slips, falls, poor

lighting, etc.) that are not anticipated to cause death or serious physical harm under normal operating

conditions. Non-Permit Spaces do not contain a hazardous atmosphere or have a potential to contain a

hazardous atmosphere under normal conditions.

However, based on the activities to be performed or conditions inside the Non-Permit Space, additional hazards

may be introduced causing Permit-Required Confined Space procedures to be applicable. For example, hot

work or use a chemical products inside a confined space for maintenance proposes may trigger the potential for

a hazardous atmosphere and require permit entry procedures.

In this case, a reclassification of a Non-Permit Space to a Permit Space would be required.

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1.7 – RECLASSIFICATION OF PERMIT-REQUIRED CONFINED SPACES

A reclassified space is a permit required confined space that has been reclassified based on a combination of

criteria, including engineering calculations, monitoring, testing, process knowledge, a hazard assessment and

the activities to be performed inside the space. Hazard Analyses are included in Appendix D.

Reclassification may include considering a non-permit-confined space to be permit-required based on the

introduction or generation of atmospheric hazards, or physical hazards likely to cause serious injury or death. It

may also include considering a permit-required confined space to be non-permit required based on elimination

of hazards or potential for hazards.

1.8 – UNAUTHORIZED ENTRY

Unauthorized entrance will be prevented using a combination of signs and placards, training that identify

prohibited confined spaces and emphasize the risks of unauthorized entry, and physical barriers to bar or lock

the entrance, or entrance cover.

1.9 – TRAINING

Awareness training will be provided annually to Facilities employees to recognize permit required confined

spaces and to understand the safety issues involved.

1.10 – OUTSIDE CONTRACTORS

Departments that arrange for contractors to enter JJC permit-required confined spaces shall ensure that the

contractor submits to EHS written Confined Space policies, training certificates, and SDSs prior to the

commencement of work. EHS will apprise the contractor of any hazards identified, experience with the space

and what classifies it as a permit space.

Upon request, EHS will coordinate entry operations with the contractor if JJC personnel or other contractor

personnel are working in or near the confined space being entered. If employees of more than one employer are

working simultaneously as “Authorized Entrants” in a confined space, procedures to coordinate entry operations

must be developed and implemented.

Contractors that enter Permit Required Confined Spaces will be:

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Informed that permit-required confined spaces is allowed only through compliance with the JJC and

their own Permit Required Confined Space Program

Required to contact the John Jay Facilities supervisor at the completion of the entry to debrief the

supervisor on any hazards confronted or created during the entry.

Advised of any safety provisions that may be in place.

APPENDIX A – DEFINITIONS Acceptable Entry Conditions: The conditions that must exist in a permit space to allow entry and to ensure that employees involved with a permit-required confined space entry can safely enter into and work within the space. Alternate Entry: Under certain conditions described in the standard, the employer may use alternate procedures for worker entry into a permit space. For example, if an employer can demonstrate with monitoring and inspection data that the only hazard is an actual or potential hazardous atmosphere that can be made safe for entry using continuous forced air ventilation, the employer may be exempted from some requirements, such as permits and attendants. However, even in these circumstances, the employer must test the internal atmosphere of the space for oxygen content, flammable gases and vapors, and the potential for toxic air contaminants before any employee enters it. The employer must also provide continuous ventilation and verify that the required measurements are performed before entry. Attendant: An individual stationed outside one or more permit spaces who monitors the authorize entrants and who performs all attendant’s duties assigned in the employer’s permit space program. Authorized Entrant: An employee who is authorized by the employer to enter a permit space. Confined space: A space defined by the concurrent existence of all of the following conditions: Large enough and so configured that an employee can bodily enter and perform assigned work. Has limited or restricted means for entry or exit. Is not designed for continuous employee occupancy.

Dangerous Air Contamination: An atmosphere capable of causing death, injury, acute illness, or disablement due to the presence of flammable, explosive, toxic, or incapacitating substances. Enclosed space: Spaces that do not meet the definition of a confined space, but may require precautionary measures upon entering. Examples of enclosed spaces at KBCC are crawl spaces and service and service tunnels with existing general ventilation. Emergency: Any occurrence (including any failure of hazard control or monitoring equipment) or event internal or external to the permit space that could endanger entrants. Engulfment: The surrounding and effective capture of a person by a 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. Entry: The action by which a person passes through an opening into a permit-required confined space. Entry includes ensuing work activities in that space and is considered to have occurred as soon as any part of the entrant’s body breaks the plane of an opening into the space. Entry Permit: The written or printed document that is provided by the employer to allow and control entry into a permit space and that contains the information specified in paragraph (f) of this section. Entry Supervisor: The person (such as the employer, foreman, or crew chief) responsible for determining if acceptable entry conditions are present at a permit space where entry is planned, for authorizing entry and overseeing entry operations, and for terminating entry as required by this section. NOTE: An entry supervisor also may serve as an attendant or as an authorized entrant, as long as that person is trained and equipped as required by this section for each role he or she fills. Also, the duties of

Hazardous Atmosphere: An atmosphere that may expose employees to the risk of death, entry supervisor may be passed from one individual to another during the course of an entry operation. Incapacitation, impairment of ability to self-rescue (that is, escape unaided from a permit space), injury, or acute illness from one or more of the following causes: Atmospheric oxygen concentration below 19.5 percent or above 23.5 percent; 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;

NOTE: This concentration may be approximated as a condition in which the dust obscures vision at a distance of 5 feet (1.52 m) or less.

Atmospheric concentration of any substance for which a dose or a permissible exposure limit is published in Subpart G, Occupational Health and Environmental Control, or a Subpart Z, toxic and Hazardous Substances, of 29 CFR1910 and which could result in employee exposure in excess of its dose or permissible exposure limit;

NOTE: An atmospheric concentration of any substance that is not capable of causing death, incapacitation, and impairment of ability to self-rescue, injury, or acute illness due to its health effects is not covered by this provision. Any other atmospheric condition that is immediately dangerous to life or health.

Immediately dangerous to life or health (IDLH): Any condition that poses an immediate nor 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 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. NOTE: This procedure produces an IDLH Oxygen-deficient atmosphere. Lower Explosive Limit (LEL): The lowest concentration of a substance in air that will produce a flash of fire when an ignition source (heat, arc, or flame) is present. At concentrations lower than the LEL, the mixture is too ”lean” to burn. 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. Oxygen Deficient Atmosphere: means an atmosphere containing less than 19.5 percent oxygen by volume. Oxygen Enriched Atmosphere: An atmosphere containing more than 23.5 percent oxygen by volume. Permissible Exposure Level (PEL), Threshold Limit Value (TLV): The permissible amount of exposure to a toxic substance that an employee is allowed to receive in any given time period. This may be a Time Weighted Average (TWA) or a Threshold Limit Value (TLV). Permit required confined space: Permit-required confined space (permit space): A confined space that has one or more of the following characteristics: Contains or has a potential to contain a hazardous atmosphere; Contains a material that has a potential for engulfing an entrant;

Has an internal configuration such that an entrant could be trapped or asphyxiated by inwardly converging walls or by a floor which slopes downward and tapers to a smaller cross-section; or

Contains any other recognized serious safety or health hazard. Permit-required confined space program (permit space program): The employer’s overall program for controlling, and, where appropriate, for protecting employees from, permit space hazards and for regulating employee entry into permit spaces. Permit System: The employer’s written procedure for preparing and issuing permits for entry and for returning the permit space to service following termination of entry. Prohibited Condition: Any condition in a permit space that is not allowed by the permit during the period when entry is authorized. Rescue Service: The personnel designated to rescue employees from permit spaces. Retrieval System: The equipment (including a retrieval line, chest or full-body harness, wristlets, if appropriate, and a lifting device or anchor) used for non-entry rescue of persons from permit spaces. Testing: The process by which the hazards that may confront entrants of permit space are identified and evaluated. Testing includes specifying the tests that are to be performed in the permit space. NOTE: Testing enables employers both to devise and implement adequate control measures for the protection of authorized entrants and to determine if acceptable entry conditions are present immediately prior to, and during , entry. Threshold Limit Value-Ceiling Value (TLV-C): The concentration that should not be exceeded during any part of the working exposure. Threshold Limit Value-Short term Exposure Limit (TLV-STEL): The concentration to which workers can be exposed continuously for 15 minutes without suffering from irritation, chronic or irreversible tissue damage, narcosis of sufficient degree to increase the likelihood of accidental injury, impair self-rescue, or materially reduce work efficiency, provided that the daily TLV-TWA is not exceeded. Threshold Limit Value-Time Weighted Average (TLV-TWA): Established by the American Conference of Government Industrial Hygienists: the time weighted average concentration for a normal eight hour work day and a forty hour work week, to which all workers may be repeatedly exposed, day after day, without adverse effect. Time Weighted Average (TWA): The average exposure calculated over a set period of time. The National Institute for Occupational Safety and Health establishes these standards as Recommended Exposer Limits (for most industrial/workplace chemicals) to which nearly all persons can be exposed to for up to a 10-hour workday during a 40-hour workweek without any adverse health effects. Upper Explosive Limit (UEL): The highest concentration of a substance in air that will produce a flash of fire when an ignition source (heat, arc, or flame) is present. At concentrations higher than the UEL, the mixture is too “rich” to burn. Confined Space Entry Permit: A permit (Attachment A) that must be completely filled out by a Facilities supervisor prior to personnel entering a reclassified or alternative entry space (Attachment B). No permit shall be valid for more than 24 hours after the time of issue by the supervisor.

Does the workplace contain PRCS as defined by § Consult other applicable OSHA standards

Inform employees as required by § 1910.146©(2).

Will permit space be entered?

Will contractors enter?

Will host employees enter to perform entry

tasks?

Does space have known or potential hazards?

Can the hazards be eliminated?

Can the space be maintained in a condition

safe to enter by continuous forced air ventila-

tion only?

Prepare for entry via permit procedures.

Verify acceptable entry conditions. (Test re-

sults recorded, space isolated if needed, rescu-

ers/means to summon available, entrants

properly equipped, etc.)

Permit issued by authorizing signature. Ac-

ceptable entry conditions maintained through-

out entry.

Entry tasks completed. Permit returned and

cancelled.

Audit permit program and permit based on eval-

uation of entry by entrants, attendants , testers

and preparers, etc.

Prevent employee entry as required by § 1910.146©(3).

Do task from outside of space.

Task will be done by contractors’ employees. Inform contractor as

required by § 1910.146©(8)(i), (ii) and (iii). Contractor obtains infor-

mation required by § 1910.146©(9)(i),(ii), from host.

Both contractors and host employees will enter the space.

Coordinate entry operation as required by § 1910.146©(8)(iv)

and (d)(11). Prevent unauthorized entry

Prevent authorization entry

Not a PRCS. 1910.146 does not apply. Consult other OSHA

Employer may choose to reclassify space to non-profit re-

quired confined space using § 1910.146©(7).

Space may be entered under § 1910.146©(5).

Permit not valid until conditions meet permit specifications

Emergency exists (prohibited condition). Entrants evacuated, entry

aborts. (Call rescuers if needed.) Permit is void. Reevaluate program to

correct/prevent prohibited condition. Occurrence of emergency

(usually) is proof of deficient program. No re-entry until program (and

permit) is amended. (May require new program.)

APPENDIX B—PERMIT REQUIRED CONFINED SPACE DECISION FLOW CHART JJC

NO

NO

YES

NO

STOP

CONTINUE

YES

YES

YES

YES

YES

YES

NO

NO

NO

NO

NO

STOP

STOP

STOP

NO

NO

NO

YES

YES

Appendix C – NB and HH Confined Spaces May 2016 Page 1 of 2  

Space Name Bldg /Location Hazards of Space Hazard Controls PRCS? Reclassify?

PRCS

Sign?

Sewer Ejector Pits (all are deeper than 5 feet according to Facilities staff) 

 

HH‐ Pool chemical Room  HH Sub‐cellar meter room NB L3.Mo2 NB Custodial storage in L3 NB Across from fuel oil L3 

 Electrical, Drowning, Atmospheric (Oxygen Deficiency, toxic gas, flammable gas) infectious agents, slip, trip falls into the space, sharp surfaces

Drain pit, LOTO electrical and sewer sources,  Monitor air, use portable ventilation, Impermeable Personal Protective Equipment, Fall Protection worn by attendant, Emergency Retrieval  

Y  N  Y 

Sump Pits (all greater than 5 feet according to Facilities staff) 

HH Scene Shop (through two doors in the back, extra wide opening) Haaren Hall Pump Room (unlabeled door) NB L3.68.04 NB Across from L3.68.04 

Electrical, Atmospheric (oxygen/flammable/toxic)   Drowning.  Falls into pit slips, trips, sharp surfaces 

Drain pit, LOTO electrical and sewer sources, Monitor air, use portable ventilation, Impermeable Personal Protective Equipment, Fall Protection worn by attendant, Emergency Retrieval.  

Y   N  Y 

Lil Jay’s Cafe  Hatch – 4’6” down then 13’ vertical to perimeter of building 

Atmospheric.   

Ventilate  Dust Mask, Goggles, Coveralls  

Y  N  Y 

Gravity Water Tanks  NB Penthouse  Atmospheric  JJC staff do not enter.  LOTO, Fall protection on top of tank,  Ventilate, Emergency retrieval 

Y  Y‐ Alternate Entry 

N 

Access hatches that can be climbed into 

NB  ‐ L2.73.19 HH Library Adjunct            Office Lower Level HH 6th fl conf. room HH outside 6th fl bathrooms 

An exterminator got stuck in the library hatch until someone heard him yelling because he was not aware that there is a latch.   

 Flashlight  N  Y – Flashlight, Signage and other measures

N 

Elevator Pits – all greater than 5 feet 

Various  Falls into the space, Electrical 

LOTO  Y  Y – LOTO  N* 

Pool Surge Tank (9 feet)  HH Pool Chemical Room  Atmospheric, Drowning.   Individuals can fall in to pit 

Drain, LOTO valve allowing water inflow, Air monitoring,  Rescue equipment should be set up and worn by entrant  Fall protection worn by attendant.

Y  N  Y 

Appendix C – NB and HH Confined Spaces May 2016 Page 2 of 2

Space Name Bldg /Location Hazards of Space Hazard Controls PRCS? Reclassify?

PRCS

Sign?

Hatch leads to an opening near the gym skylight  

 HH603 

Also other side of gym 

 

Fall hazard at the end of the space 

 Use fall protection   Y  Y  Y 

 

APPENDIX D – Job Hazard Analyses Reclassified Spaces

Job Hazard Analysis  

1.  Lil Jays underground crawlspace 

Job Title: Lil Jays underground crawl space  

  Date: May 5, 2016  

Job Location: Lil Jays   

  Employees Completing Task: Plumbers 

Analyst : Lindsey Kayman  

  Task   

  Task Description:   Access to plumbing pipes under the building   Hazard Type:  

1.   2. Atmospheric   Hazard Description:  

  Exposure to oxygen deficiency,  electrical hazard (heat trace tape)   Consequence:  

  Electrical:  1. Electrical Shock 

 Oxygen deficiency:          1.   May displace oxygen and cause rapid suffocation 

  Hazard Controls:  

  Before entry:  Electrical: LOTO heat trace tape  Atmosphere:  Use ducted fan to ventilate space. Monitor air with a 4 gas meter before and continuously during entry.  Other: Use intrinsically safe flashlight. Attendant needed – 2 person job required for job task. Work to be conducted during business hours only.  

  Rationale or Comment 

  These hazard controls reclassify this space from a permit confined space to a confined space entry.   

 

 

 

APPENDIX D – Job Hazard Analyses Reclassified Spaces

Job Hazard Analysis  

 

2.  HH 6th Floor Hatch to Area above Gym Basketball Court 

Job Title: Crawl Space to Overhead Hatch  

Date: May 5, 2016  

Job Location: HH 6th Floor (s sides)   

Employees Completing Task: NA 

Analyst : Lindsey Kayman  

Task  There should be no reason to enter this crawlspace  

Task Description:  Access to skylights above basketball courts in the HH 4th floor gymnasiumHazard Type:  

Falls Hazard Description:  

Falls from above  Consequence:  

Fall  1.Severe injury/death from a fall  

  Hazard Controls:    Lock hatches.  Install anchor in advance and use fall  restraint system.   Before entry:  Other:  Fall Protection  Rationale or Comment 

There should be no need to enter this crawlspace.