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UMB POLICY ON PERMIT-REQUIRED CONFINED SPACE ENTRY
To define the University of Maryland Baltimore policy on Permit-Required Confined Spaces.
II. APPLICABLE REGULATION
29 CFR 1910.146, Permit- Required Confined Spaces for General Industry.
III. WORKPLACE EVALUATION
The University has evaluated the campus and has determined that it contains permit-required confined spaces. A list of confined spaces on the University campus shall be kept on file at the Office of Environmental Health and Safety (EHS) and the Office of Facilities Management (OFM).
IV. RESPONSIBILITIES OF THE OFFICE OF FACILITIES MANAGEMENT.
It is the responsibility of OFM to:
- Identify Facilities Management employees who may be required to enter a permit-required confined space and provide a list to EHS. Provide EHS with changes to the list as often as they occur;
- Identify "Entry Supervisors" and/or "Authorized Entrants" who will be responsible for ensuring that safe permitrequired confined space work practices are being followed and who will be authorized to sign Confined Space Entry Permits and provide a list of those individuals to EHS;
- Designate a person from OFM who will have overall responsibility for the confined space program;
- Ensure that only trained and authorized personnel enter confined spaces;
- Ensure that the procedures in this policy are complied with by all OFM and contractor supervisors and employees;
- Ensure that all confined space entry employees are physically qualified to work in permit-required confined spaces;
- Identify and post warning signs at all permit-required confined spaces on campus;
- Purchase all safety equipment necessary for safe worker entry into confined spaces;
- Immediately report all unsafe or potentially dangerous conditions to EHS;
- Conduct an annual review of all permit-required confined spaces to determine if there were any changes in reported hazards, any unauthorized entries, or any injuries or "near misses";
- Maintain all canceled entry permits on record for one (1) year from date of entry.
- Maintain, for three (3) years, records of all supervisory reviews, environmental testing results, and environmental monitoring equipment calibration results that relate to entering confined space. V. RESPONSIBILITIES OF THE OFFICE OF ENVIRONMENTAL HEALTH AND SAFETY
It is the responsibility of EHS to:
- Review and update this policy so that it is current with all regulations and technologies.
- Conduct periodic audits to ensure that the confined space entry procedures are being complied with.
- Maintain all personnel training records and certify in writing that employees are adequately trained.
- Develop, in coordination with OFM, specific hazard awareness and monitoring instrumentation training.
- When requested, evaluate all unsafe or potentially dangerous conditions existing within confined spaces.
- Conduct an annual review of the permit-required confined spaces program.
VI. PERMIT-REQUIRED CONFINED SPACE PROGRAM
A permit-required confined space program shall be developed by EHS and OFM. A copy of the program shall be kept at EHS and by each OFM supervisor who has employees that may be required to enter confined spaces. The program shall be reviewed annually and revised as necessary. It shall include at least the following:
- Measures necessary to prevent unauthorized entry;
- Identification and evaluation of the hazards of the permit spaces;
- Procedures and practices necessary for safe permit space entry operations;
- Equipment necessary to enter permit-required spaces;
- Procedures for the preparation, issuance, use, and cancellation of entry permits;
- Procedures for reclassifying permit spaces so that they may be entered without a permit or attendant;
- Designated responsibilities of personnel involved in entry operations;
- Procedures to coordinate entry operations with contractors if both University employees and contractors are entering the same space;
- Testing and monitoring procedures;
- Rescue and emergency procedures.
The University shall provide training to all employees required or permitted to enter permit-required confined space. Employees will acquire the understanding, knowledge, and skills necessary for the safe performance of their duties assigned during permit-required confined space entry. The training shall be provided to each affected employee:
- Before the employee is first assigned duties that involve permit-required entry;
- 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 is reason to believe either that there are deviations from the permit space entry procedures or that there are inadequacies in the employee's knowledge or use of these procedures.
In addition, employees required to monitor the atmosphere in a confined space shall have successfully completed training on the gas detector they will use prior to performing any confined space monitoring.
When contractors are required to enter University permitrequired confined spaces, the following policies apply:
- OFM shall inform the contractor that the campus contains permit spaces and that permit space entry is allowed only through compliance with a permit space program.
- EHS shall apprise the contractor of any hazards identified, the University's experience with the space, and what classifies it as a permit space.
- OFM and EHS shall coordinate entry operations with the contractor if University 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.
- EHS shall debrief the contractor at the conclusion of the entry operations on the permit space program followed and any hazards confronted or created in permit spaces during entry operations.
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