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TECHNICAL COMMITTEE ON Confined Space Safe Work Practices

AGENDA Second Draft Meeting

St. Petersburg, FL April 7-9, 2015

8 AM-5 PM EDT*

Continental Breakfast served each Am at 7:30 AM. Lunch provided on Day One only. *Meeting times subject to modification by the Chair

1. Welcome. Don English, Chair.

2. Introduction of Committee Members and Attendees.

3. Approval of Meeting Minutes (attached-April 7-10, 2014).

4. Revision Timeline for Document Revision (Fall 2015 cycle-attached).

5. Staff presentation. Nancy Pearce.

Revision Process-Second Draft.

NFPA Data Initiative.

6. Task group reports/Chapter Reviews and Review of Public Comments.(attached)

7. Task Group meetings (TBD as needed).

8. Other Business/Next Steps.

9. Schedule Next Meeting.

10. Adjourn.

Address List No PhoneConfined Space Safe Work Practices CNS-AAA

Nancy Pearce03/09/2015

CNS-AAA

Leslie D. English

Chair254 South Jackson StreetGrove Hill, AL 36451

SE 3/1/2011CNS-AAA

Adam C. Jones

SecretaryBuechel Fire Protection District4101 Bardstown RoadLouisville, KY 40218

E 10/18/2011

CNS-AAA

Rick Argudin

PrincipalCapital Safety5740 West Little York, Suite 179Houston, TX 77091

M 07/29/2013CNS-AAA

Edward K. Boring

PrincipalHilton Head Island Fire Rescue40 Summit DriveHilton Head Island, SC 29926International Association of Fire ChiefsAlternate: Rodney Foster

E 10/20/2010

CNS-AAA

Christopher S. Buehler

PrincipalExponent, Inc.10850 Richmond Avenue, Suite 175Houston, TX 77042

SE 03/03/2014CNS-AAA

Louis A. Donsbach, Jr.

PrincipalUS Steel CorporationOne North Broadway, 91E2/TS 526Gary, IN 46402-3101

U 10/18/2011

CNS-AAA

Timothy R. Fisher

PrincipalAmerican Society of Safety Engineers1800 East Oast Oakton StreetDes Plaines, IL 60018-2187


Nicole Gorman

PrincipalENERCON Services Nova Scotia202 Brownlow Avenue, Unit D#100Dartmouth, NS B3B 1T5 Canada

M 08/11/2014

CNS-AAA

Alfred W. Keiss

PrincipalMed-Tex Services, Inc.6940 State Road, Building EPhiladelphia, PA 19135-1541Alternate: Robert J. Masonis, Sr.


Steven E. Kosch

Principal3M Company3M Cottage Grove, Building 143-01Cottage Gove, MN 55016

M 03/07/2013

CNS-AAA

Richard S. Kraus

PrincipalAPI/Petroleum Safety Consultants210 East Fairfax Street, Apt. 600Falls Church, VA 22046-2909American Petroleum InstituteAlternate: William E. Moody

U 3/4/2009CNS-AAA

Edmund L. Lydon, Jr.

PrincipalNortheast Hospital Corporation85 Herrick StreetBeverly, MA 01915-1790New England Healthcare Engineers SocietyAlternate: Danny J. Collins

U 08/09/2012

CNS-AAA

Glenn E. Mate

PrincipalGuilford Fire Department, EMT-Local 4177Fairfield Regional Fire School584 Moose Hill RoadMonroe, CT 06468

E 3/4/2009CNS-AAA

Joseph R. Mathews

PrincipalSprinkler Fitters Local 692 JATC14004 McNulty RoadPhiladelphia, PA 19154United Assn. of Journeymen & Apprentices of thePlumbing & Pipe Fitting IndustryAlternate: Mark R. Ronecker

L 3/4/2009

1



CNS-AAA

Glenn E. McGinley, II

PrincipalOhio Public Employment Risk Reduction Program4448 Prairie Creek LaneMaumee, OH 43537-9020

E 8/5/2009CNS-AAA

David McLaughlin

PrincipalOregon OSHAPO Box 14480Salem, OR 97309-0405

E 03/07/2013

CNS-AAA

Jim E. Norris

PrincipalBunge North America11720 Borman DrivePO Box 28500St. Louis, MO 63146-1000National Oilseed Processors Association

U 3/4/2009CNS-AAA

Michael Palmer

PrincipalEnSafe Inc.308 North Peters Road, Suite 200Knoxville, TN 37922American Industrial Hygiene Assn/Confined SpacesCommitteeAlternate: Bayless L Kilgore

SE 08/09/2012

CNS-AAA

Bob A. Rusczek

PrincipalCertified Safety and Health11 Arbor LaneWilbraham, MA 01095Alternate: Adam J. Goodman


James L. Tyler

PrincipalVestas1417 NW Everett StreetQuad 4.09Portland, OR 97209-2652American Wind Energy AssociationAlternate: Michele Myers Mihelic

U 10/28/2014

CNS-AAA

Bob Vigdor

PrincipalTyco/Scott Safety4320 Goldmine RoadMonroe, NC 28110International Safety Equipment Association

M 03/07/2013CNS-AAA

David Wagner

PrincipalIndustrial Scientific Corporation1001 Oakdale RoadOakdale, PA 15071Alternate: Andrew Saunders

M 10/27/2009

CNS-AAA

Laura Hartline Weems

PrincipalCenter for Toxicology and Environmental Health5120 Northshore DriveNorth Little Rock, AR 72118


William H. Weems

PrincipalSafe State ProgramUniversity of AlabamaPO Box 870388Tuscaloosa, AL 35487Alternate: Kenneth W. Oldfield

SE 08/09/2012

CNS-AAA

Richard Wright

PrincipalWright Rescue Solutions, Inc.2002 Tupelo CourtPanama City, FL 32405Alternate: Dennis M. O'Connell

SE 3/1/2011CNS-AAA

Leonard A. Young, Jr.

PrincipalMassachusetts Water Resources Authority90 Tafts AvenueWinthrop, MA 02150-3334American Federation of State, County & MunicipalEmployees

L 08/09/2012

2



CNS-AAA

John Zimlich, Jr.

PrincipalLouisville Gas & Electric16660 Dixie HighwayLouisville, KY 40272

U 03/05/2012CNS-AAA

Danny J. Collins

AlternateNortheast Fire Safety and ConsultingPO Box 3025Plattsburgh, NY 12901New England Healthcare Engineers SocietyPrincipal: Edmund L. Lydon, Jr.

U 10/28/2014

CNS-AAA

Rodney Foster

AlternateMidwest City Fire Department8201 East RenoMidwest City, OK 73130International Association of Fire ChiefsPrincipal: Edward K. Boring

E 03/07/2013CNS-AAA

Adam J. Goodman

AlternateS-E-A Limited1110 Benfield BoulevardMillersville, MD 21108Principal: Bob A. Rusczek

SE 03/03/2014

CNS-AAA

Bayless L Kilgore

AlternateEnsafe Inc.1148 College StreetBowling Green, KY 42101American Industrial Hygiene Assn/Confined SpacesCommitteePrincipal: Michael Palmer


Robert J. Masonis, Sr.

AlternateNewport Beach Fire Department (retired)1686 Rice Canyon RoadFallbrook, CA 92028-8719Principal: Alfred W. Keiss

SE 03/03/2014

CNS-AAA

Michele Myers Mihelic

AlternateAmerican Wind Energy Association1501 M Street NW, Suite 1000Washington Dc, DC 20005-1769Principal: James L. Tyler

U 10/28/2014CNS-AAA

William E. Moody

AlternateAir BP150 West Warrenville RoadNaperville, IL 60563-8473American Petroleum InstitutePrincipal: Richard S. Kraus

U 08/11/2014

CNS-AAA

Dennis M. O'Connell

AlternateRoco Rescue Inc.26 Cobalt LaneWestbury, NY 11590Principal: Richard Wright


Kenneth W. Oldfield

AlternateAlabama Fire College7291 Gadsden HighwayTrussville, AL 35173-1688Principal: William H. Weems

SE 08/11/2014

CNS-AAA

Mark R. Ronecker

AlternateSprinkler Fitters 268 JATC1544 South 3rd StreetSt. Louis, MO 63104United Assn. of Journeymen & Apprentices of thePlumbing & Pipe Fitting IndustryPrincipal: Joseph R. Mathews

L 07/29/2013CNS-AAA

Andrew Saunders

AlternateHoneywell Inc.7004 NW 99th WayTamarac, FL 33321Principal: David Wagner

M 03/07/2013

3



CNS-AAA

Nancy Pearce

Staff LiaisonNational Fire Protection Association1 Batterymarch ParkQuincy, MA 02169-7471

1/11/2012

4

*Adobe Connect

TECHNICAL COMMITTEE ON

Confined Space Safe Work Practices MINUTES-First Draft Meeting

Quincy, MA April 7-10, 2014

Attendees:

Don English AL

Rick Argudin Capital Safety TX

Edward Boring Hilton Head Island Fire Rescue SC

Christopher Buehler* Exponent, Inc. TX

Aaron Duff Bristol-Myers Squibb Company NJ

Adam Goodman* S-E-A Limited MD

Adam Jones Buechel Fire Protection District KY

Alfred Keiss Med-Tex Services, Inc. PA

Richard Kraus API/Petroleum Safety Consultants VA

Edmund Lydon Northeast Hospital Corporation MA

Glenn Mate Guilford Fire Department, EMT-Local 4177 CT

Glenn McGinley* Ohio Public Employment Risk Reduction OH

Jim Norris Bunge North America MO

Dennis O'Connell Roco Rescue Inc. NY

Michael Palmer EnSafe Inc. TN

Mark Ronecker Sprinkler Fitters 268 JATC MO

Bob Rusczek Certified Safety and Health MA

Andrew Saunders* Honeywell Inc. FL

Bob Vigdor Tyco/Scott Safety NC

David Wagner Industrial Scientific Corporation PA

Laura Weems Ctr for Toxicology and Environmental Health AR

William Weems Safe State Program AL

Richard Wright* Wright Rescue Solutions, Inc. FL

Leonard Young Massachusetts Water Resources Authority MA

John Zimlich Louisville Gas & Electric KY

Nancy Pearce NFPA Staff Liaison MA

Guests

Terry Krug ASSE Z117.1 Committee Chair, ExOSHA Ill

Timothy Healey ASSE Z 117.1, Hartford Steam Boiler CT

NFPA Staff Guests

Guy Colonna

Nancy Wirtes

Joanne Goyette

Eric Nette

Lisa Yarussi

*Adobe Connect

1. The meeting was called to order at 8:00 AM. Don English, Chair, welcomed the committee and explained how the meeting would be conducted over the next several days. Chapter task group chairs were asked to present a review of public inputs for the chapter with recommendations as to which suggested changes should be accepted and which should not. Don asked task group chairs to point out which public inputs were substantive and which were editorial in nature so that the Committee could focus on the review of substantive changes. He explained that the Committee would then be asked to vote on accepting the recommended changes for the chapter as a whole unless there was a controversial issue that required further discussion. Once all the chapter changes were accepted, the Committee would use the new chapter revisions as a basis for any additional changes to be made for the remainder of the meeting. 2. Committee members and attendees introduced themselves and their affiliation. Chris Dubay, VP of Codes and Standards welcomed the group and congratulated the Committee for getting the preliminary draft completed. Guests joining the meeting over the four days included many Quincy NFPA staff, Terry Krug, Chair of ASSE Z 117.1 (Day Two) and Timothy Healey, ASSE Z117.1 committee member (Day 4). 3. Meeting Minutes from Feb 11th, 2014 adobe connect/conference call were approved. 4. Nancy Pearce, NFPA Staff, reviewed the First Draft revision process and timeline with the Committee. Nancy also provided a PowerPoint summary of the requirements of the NFPA Manual of Style. 5. Before moving ahead with additional revision of the preliminary draft, Adam Jones, Committee Secretary, reviewed the basic document tenets with the committee and outstanding issues still to be decided by the committee for consistency throughout the document. Basic tenets already agreed upon included:

Document will use the term confined space rather than permit required confined space

Document should cover all confined spaces and all hazards independent of industry

Document should be able to be used in other countries

Document should not conflict with OSHA Permit Required Confined Space Standard or other existing, well recognized standards such as ASSE Z117.1

Document should in no cases be less stringent than OSHA 1910.146 so that NFPA 350 can be used to supplement OSHA’s requirements. Stricter recommendations are OK.

All confined spaces should be “evaluated” prior to entry Still to be decided were issues such as:

What should the initial evaluation format look like? Permit, other

Should air monitoring be required for all spaces?

What is the role of owner/operator, contractor vs. employer? Terminology needs to be consistent.

Who issues the permit? Permit issuer versus Entry supervisor

What terminology should be used throughout document? Gas versus Atmospheric monitoring

What are acceptable atmospheric conditions for entry? After significant discussion it was decided that the initial evaluation for all confined spaces would be called a pre-evaluation form and that a permit would be required if any of the pre-evaluation answers indicated that a hazard or potential hazard existed. This pre-evaluation document would be part of the form used for the permit. It was also decided that air monitoring would be the default for pre-entry evaluation. However, verbiage would be added to explain that in cases where it is clear that a hazardous atmosphere would never exist (for example a ventilation duct which had been running that was shut off right before entry) there is an option for entering without pre atmospheric monitoring. It was decided that the term owner/operator would be used and defined for consistency throughout the document. The term entrant employer was also added and defined. It was also ultimately decided that the term permit issuer would be eliminated from the document and that all pre-entry evaluations and permits would be signed by the entry supervisor. It was also decided that a “gas tester” would use a “gas monitor” to perform “atmospheric monitoring”. The committee also decided that atmospheric conditions that were acceptable for entry would be O2 (19.5-22%), LEL (10%) and Toxics (half the acceptable exposure limit). The upper level oxygen limit of 22% will be used since there is nothing in nature that would cause oxygen levels to increase therefore the 22% is a trigger that should be used to determine the source oxygen. There was some discussion about the use of OSHA’s 23.5% which reportedly was based on allowable Grade D breathing air oxygen upper limits. It was noted that marine chemists have used 22% upper limit for many years.

*Adobe Connect

6. Task group reports/Chapter review and review of Public Inputs. Task group chairs provided verbal or PowerPoint

Presentations on the public inputs that were reviewed and which were recommended for incorporation into the next chapter draft. Recommended substantive changes were discussed and the full committee voted on the new chapter drafts.

7. Terry Krug, ASSE Z117.1 Chair addressed the committee on Day 2. He indicated that he understood that this was a “best practices” guide and not a standard and would like to see this document become a “How To” document to assist in compliance with various standards including OSHA 1910.146 and ASSE Z117.1. He indicated that he did not see any duplication or conflict with the ASSE document. Terry provided a number of comments and suggestions to the committee. These included:

Should refine what the trigger is for a permit-What is a serious hazard?

Refine and expand on inerting and requirements related to entry

Add notes about bump testing to clarify that humidity (including breathing into the sensor) can lead to interferences)

Clarify that SCBA is required for entry monitoring for unknown atmospheres

Recommend that any oxygen level less than 20.9% be investigated.

Recommend explanatory material for oxygen limits. Terry also provided notes from his review of the preliminary draft document for the chapter task groups to review. Terry stayed for the full day meeting and participated in committee discussions. 8. Nicole Gorman of Encon, a Canadian Wind Turbine company called in to the meeting to discuss the possibility of incorporating annex material on confined spaces in wind turbines into the document. Nicole presented the unique challenges dealing with wind turbine confined spaces and provided a draft outline of the issues for possible incorporation into the document. After lengthy discussion, the committee decided not to add annex material specific for any single industry at this time. The committee indicated that the intent of the document was to address the hazards of all confined spaces and hazards generically so that the document can apply to wind turbines as well as other more unique spaces. Nicole and the wind turbine industry will be asked to make comments to specific sections of the document at second draft if there are requirements that need to be clarified for their particular type of entry. 9. Casey Grant from the Research Foundation addressed the group on Day 3. Casey presented a fatality case he had been involved with a number of years ago where he believed that a confined space was involved. He also explained what the Research Foundation Code Fund could do to possibly assist the committee in their work as the document continues to develop. 10. Tim Healey, ASSE committee member, addressed the committee on Day 4. He indicated that he reviewed the modified chapter drafts that were emailed out so far and is pleased with the direction the committee is taking with the document being a guide and not a standard. Tim submitted several PIs that were reviewed and incorporated into the revised document. Tim stayed for the full day meeting and participated in committee discussions. 11. Nancy explained that the next meeting (second draft) would have to be scheduled after the comment closing date of November 14, 2014 of but before May 1, 2015. The committee generally agreed that the February March timeframe would work best for the meeting. Several options for meeting locations were discussed including Jacksonville, Fort Lauderdale, Dallas, New Orleans and San Antonio. A poll will be sent to the full committee on dates and locations later in the year.

12. Meeting was adjourned at 3:45 PM on April 10, 2015.

2015 FALL REVISION CYCLE *Public Input Dates may vary according to standards and schedules for Revision Cycles may change. Please check the NFPA Website for the most up‐to‐date information on Public Input Closing Dates and schedules at

www.nfpa.org/document# (i.e. www.nfpa.org/101) and click on the Next Edition tab.

Process Stage

Process Step

Dates for

TC

Dates forTC with CC

Public Input Closing Date for Paper Submittal* 11/29/2013 11/29/2013

Public Input Closing Date for Online Submittal (e‐PI)* 1/3/2014 1/3/2014

Final Date for TC First Draft Meeting 6/13/2014 3/14/2014

Public Input Posting of First Draft and TC Ballot 8/1/2014 4/25/2014

Stage Final date for Receipt of TC First Draft ballot 8/22/2014 5/16/2014

(First Draft) Final date for Receipt of TC First Draft ballot ‐ recirc 8/29/2014 5/23/2014

Posting of First Draft for CC Meeting 5/30/2014

Final date for CC First Draft Meeting 7/11/2014

Posting of First Draft and CC Ballot 8/1/2014

Final date for Receipt of CC First Draft ballot 8/22/2014

Final date for Receipt of CC First Draft ballot ‐ recirc 8/29/2014

Post First Draft Report for Public Comment 9/5/2014 9/5/2014

Public Comment Closing Date for Paper Submittal* 10/10/2014 10/10/2014

Public Comment Closing Date for Online Submittal (e‐PC)* 11/14/2014 11/14/2014

Final Date to Publish Notice of Consent Standards (Standards that received no Comments)

11/28/2014 11/28/2014

Appeal Closing Date for Consent Standards (Standards that received no Comments)

12/12/2014 12/12/2014

Final date for TC Second Draft Meeting 5/1/2015 1/23/2015

Comment Posting of Second Draft and TC Ballot 6/12/2015 3/6/2015

Stage Final date for Receipt of TC Second Draft ballot 7/3/2015 3/27/2015

(Second Final date for receipt of TC Second Draft ballot ‐ recirc 7/10/2015 4/3/2015

Draft) Posting of Second Draft for CC Meeting 4/10/2015

Final date for CC Second Draft Meeting 5/22/2015

Posting of Second Draft for CC Ballot 6/12/2015

Final date for Receipt of CC Second Draft ballot 7/3/2015

Final date for Receipt of CC Second Draft ballot ‐ recirc 7/10/2015

Post Second Draft Report for NITMAM Review 7/17/2015 7/17/2015

Tech Session Notice of Intent to Make a Motion (NITMAM) Closing Date 8/21/2015 8/21/2015

Preparation Posting of Certified Amending Motions (CAMs) and Consent Standards

10/16/2015 10/16/2015

(& Issuance) Appeal Closing Date for Consent Standards (15 days) 10/31/2015 10/31/2015

SC Issuance Date for Consent Standards (10 days) 11/10/2015 11/10/2015

Tech Session Association Meeting for Standards with CAMs 6/6‐9/2016 6/6‐9/2016

Appeals and Appeal Closing Date for Standards with CAMs 6/29/2016 6/29/2016

Issuance SC Issuance Date for Standards with CAMs 8/4/2016 8/4/2016

Approved___ October 30, 2012 Revised____March 7, 2013____________

Public Comment No. 1-NFPA 350-2014 [ Global Input ]

Inconsistency: 7.14 and 8.4.1 states Oxygen levels should be 19.5-22.0 % while the permit B.1 states19.0-22.5%. OSHA 1910.146(b) states 19.5-23.5%.

Statement of Problem and Substantiation for Public Comment

Inconsistency: 7.14 and 8.4.1 states Oxygen levels should be 19.5-22.0 % while the permit B.1 states 19.0-22.5%. OSHA 1910.146(b) states 19.5-23.5%.

Proposal: keep information as stated by OSHA 1910.146 (b) for acceptable Oxygen entry levels.

Related Item

First Revision No. 7-NFPA 350-2014 [Chapter 8]

Submitter Information Verification

Submitter Full Name: MATT BENNETT

Organization: CHARTER COMMUNICATIONS

Street Address:

City:

State:

Zip:

Submittal Date: Mon Sep 08 13:21:42 EDT 2014

National Fire Protection Association Report http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara...

1 of 340 12/12/2014 2:22 PM

Public Comment No. 274-NFPA 350-2014 [ Section No. 1.1.1 ]

1.1.1

This guide is intended to provide information to help protect workers who enter confined spaces.


Clarification

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Submitter Full Name: TERRY W KRUG

Organization: EXOSHA INC

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Submittal Date: Thu Nov 13 17:04:08 EST 2014


2 of 340 12/12/2014 2:22 PM


1.1.1

This guide is intended to provide information to protect workers who enter and work in confined spaces.


Encompass working in confined spaces as well as it is mentioned in other areas of the document.

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Public Input No. 1-NFPA 350-2013 [Section No. 1.1.1]


Submitter Full Name: Nicole Gorman

Organization: ENERCON Services Nova Scotia

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3 of 340 12/12/2014 2:22 PM


1.1.1

This guide is intended to provide information to protect workers who enter confined , work inside of, andwork outside of and adjacent to confined spaces.


this will encompass all of the activities listed in this chapter as well as those in all of the subsequent chapters of the proposed document

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Submitter Full Name: Richard Kraus

Organization: API/Petroleum Safety Consultan

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Submittal Date: Tue Sep 23 08:16:16 EDT 2014


4 of 340 12/12/2014 2:22 PM


1.1.4

This guide provides information on how to understand confined space safety and safeguard personnel fromfire, explosion, safety, and health hazards that are commonly associated with confined space entry andwork .


The list with the word "safety" is hard to understand. I removed the word safety for that reason. I also added "and work" to help encompass the work that is being performed in a confined space as well.

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Public Input No. 2-NFPA 350-2013 [Section No. 4.3]




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5 of 340 12/12/2014 2:22 PM


1.1.8

This guide provides information regarding hazards adjacent to confined spaces that might affect the safeconditions necessary for entry and work in aconfined a confined space.


correct spacing aconfined

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Submitter Full Name: EMERY THOMAS

Organization: CONOCOPHILLIPS

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Submittal Date: Wed Nov 05 19:14:24 EST 2014


6 of 340 12/12/2014 2:22 PM


1.1.8

This guide provides information regarding hazards adjacent to confined spaces that might affect the safeconditions necessary for entry and work in aconfined a confined space.


Space needed between "a" and "confined"

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7 of 340 12/12/2014 2:22 PM


2.3.1 AIHA not AIAH Publications.

American Industrial Hygiene Association, 3141 Fairview Park Drive, Suite 777, Falls Church, VA 22042.

“Prevention through Design: Eliminating Confined Spaces and Minimizing Hazards.” AIHA Confined SpacesCommittee. https://www.aiha.org/government-affairs/PositionStatements/PtD%20Conf%20Space%20AIHA%20-%20BOD%20Approved.pdf.


Incorrect spelling of AIHA

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Affilliation: ANSI Z117.1

Street Address:

City:

State:

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8 of 340 12/12/2014 2:22 PM


2.3.2 ANSI Publications.

American National Standards Institute, Inc., 25 West 43rd Street, 4th Floor, New York, NY 10036.

ANSI/AIHA/ASSE Z10, Occupational Health and Safety Management Systems, 2012.

ANSI Z49.1, Safety in Welding, Cutting, and Allied Processes, 2012.

ANSI/ASSE Z 117.1, Safety Requirements for Confined Spaces, 2009.

ANSI/ASSE Z590.3, Prevention Through Design: Guidelines for Addressing Occupation Hazards & Risks inthe Design & Redesign Processes, 2011.

ANSI/AIHA Z 244 Control of Hazardous Energy - Lockout/Tagout & Alternative Methods


Applicable additional ANSI standards on LOTO

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Affilliation: ANSI/ASSE

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9 of 340 12/12/2014 2:22 PM


2.3.3 API Publications.

American Petroleum Institute, 1120 1220 L Street, NW, Washington, DC 20005-4070.

API 653, Tank Inspection, Repair, Alteration, and Reconstruction, 2009.

API 2003, Recommended Practice on Protection Against Ignitions Arising out of Static, Lightning, and StrayCurrents, 2008.

API 2009, Safe Welding and Cutting Practices in Refineries, Gasoline Plants, and Petrochemical Plants,2002.

API 2015, Requirement for Safe Entry and Cleaning of Petroleum Tanks, 2001.

API 2016, Guidelines and Procedures for Entering and Cleaning Petroleum Storage Tanks, 2001.

API 2027, Ignition Hazards and Safe Working Practice for Abrasive Blasting of Atmospheric Storage Tanksin Hydrocarbon Service, 2002.

API 2201, Safe Hot Tapping Practices in the Petroleum & Petrochemical Industries, 2003.

API 2202, Guidelines for Protecting Against Lead Hazard when Dismantling and Disposing of Steel fromTanks that Have Contained Leaded Gasoline, 1991.

API 2207, Preparing Tank Bottoms for Hot Work, 2007.

API 2217A, Guidelines for Safe Work in Inert Confined Spaces in the Petroleum and PetrochemicalIndustries, 2009.

API 2219, Safe Operations of Vacuum Trucks in Petroleum Service, 2005.


editorial corrects address

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Public Input No. 216-NFPA 350-2013 [Chapter 2]




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10 of 340 12/12/2014 2:22 PM


2.3.7 Other Publications.

Merriam-Webster’s Collegiate Dictionary, 11th edition, Merriam-Webster, Inc., Springfield, MA, 2003.

Gabel, D., Hasit, Y., and Thompson, K., Design Considerations in Water, Wastewater, and StormwaterUtility Security, American Society of Civil Engineers (2008).

CSA Z1006-10, Management of Work in Confined Spaces , 2010 edition.


Added the CSA standard for confined space work to help encompass other countries to provide a cohesive picture.

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Public Input No. 4-NFPA 350-2013 [Section No. 8.8.2.2]




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11 of 340 12/12/2014 2:22 PM

Public Comment No. 334-NFPA 350-2014 [ Section No. 2.4 ]

2.4 References for Extracts in Mandatory Sections.

NFPA 51B, Standard for Fire Prevention During Welding, Cutting, and Other Hot Work, 2014 edition.

NFPA 70® , National Electrical Code® , 2014 edition.

NFPA 77, Recommended Practice on Static Electricity, 2014 edition.

NFPA 99, Health Care Facilities Code, 2015 edition.

NFPA 302, Fire Protection Standard for Pleasure and Commercial Motor Craft, 2015 edition.

NFPA 326, Standard for the Safeguarding of Tanks and Containers for Entry, Cleaning, or Repair, 2015edition.

NFPA 1006, Standard for Technical Rescuer Professional Qualifications, 2013 edition.

NFPA 1026, Standard for Incident Management Personnel Professional Qualifications, 2014 edition.

NFPA 1451, Standard for a Fire and Emergency Service Vehicle Operations Training Program, 2013edition.

NFPA 1521, Standard for Fire Department Safety Officer Professional Qualifications, 2015 edition.

NFPA 1561, Standard on Emergency Services Incident Management System and Command Safety, 2014edition.

NFPA 1670, Standard on Operations and Training for Technical Search and Rescue Incidents, 2014edition.


Section title referenced “Mandatory Sections” where this guideline does not have any Mandatory Sections, Although this normally works with the NFPA style, this section title should be modified as confusion to users will arise.

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Submittal Date: Fri Nov 14 11:02:38 EST 2014


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3.3.3 Accidents.

Unplanned events that result in injuries or damage that interrupts routine operations.


3.3.2 and 3.3.3 are almost the exact same definition. Redundant to have both.

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13 of 340 12/12/2014 2:22 PM


3.3.4 Adjacent Space.

Those spaces in all directions from subject a confined space, including points of contact, internal andexternal, such as decks, sumps, floating roofs, secondary containment areas, interstitial spaces, underfloors, supports, tank tops, and bulkheads. [326, 2015]


Removed subject space and replaced it with confined. It ensures the same terminology is used throughout the document.

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Public Input No. 6-NFPA 350-2013 [Section No. 10.1.2 [Excluding any Sub-Sections]]




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14 of 340 12/12/2014 2:22 PM


3.3.5 Administrative Controls (Work Practice Controls).

Changes in work Work procedures such as written safety policies, rules, supervision, schedules, andtraining with the goal of reducing the duration, frequency, and severity of exposure to hazardous chemicalsituations.


Definition of administrative controls (work practice controls) starts with “Changes in work procedures such a safety policies, rules, …Remove “Changes in” not relevant to the definition.

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Submittal Date: Mon Nov 10 18:21:16 EST 2014


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Changes in work procedures such as written safety policies, rules, supervision, schedules, and training withthe goal of reducing the duration, frequency, and severity of exposure s to hazardous chemicalsituations. hazards . ( this takes in account physical hazards like noise, ergonomic, vibration,etc).


This takes in account other hazards than chemical.

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Changes in work procedures such as written safety policies, rules, supervision, schedules, and training withthe goal of reducing the duration, frequency, and severity of exposure to hazardous chemical situations.


Not sure why there was a focus on just chemical hazards. I removed the work chemical to broaden the scope of hazards.

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3.3.8 Atmospheric Monitoring.

The act of using a portable or fixed gas monitor to sample the atmosphere in or around a confined spaceto determine the level of hazardous, gaseous contaminants present.


Atmospheric monitoring can be fixed or portable.

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3.3.9 Attendant.

Person stationed immediately on the outside of the space, assigned to oversee and support entrantswhile they are in a confined space. (if this definition is left as is it could include an office personnelat a desk looking at a camera, or a person leaving the portal area to get some rope or gloves)


The attendant needs to be stationed immediately on the outside not 10 feet or more away from the portal.

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3.3.9 Attendant.

Person A competent person assigned to oversee and support entrants while they are in a confined space.


clarifies that an attendant should be a competent person.

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Public Input No. 8-NFPA 350-2013 [Section No. 10.1.2.2 [Excluding any Sub-Sections]]




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3.3.11 Bump Testing.

A brief exposure of the gas monitors/sensors to to a level of specific gas above the sensor's alarm setpoint to verify sensor and alarm functionality, not as a measure of gas monitor/sensor accuracy.


The bump test gas needs to be at a concentration above the alarm set points.

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3.3.13 Competent Person.

One who is designated in writing and who is capable of identifying existing and predictable hazards in thesurroundings or working conditions that are unsanitary, hazardous, or dangerous to employees, and whohas authorization to take prompt corrective measures to eliminate them.


The definition of Competent Person recommend to remove “…designated in writing...”

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3.3.13 Competent Person.

One who is designated in writing by the employer and who is capable of identifying existing andpredictable hazards in the surroundings or working conditions that are unsanitary, hazardous, or dangerousto employees, and who has authorization to take prompt corrective measures to eliminate them.


The employer needs to specify in writing otherwise BaBa give permission.

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3.3.13 Competent Person Supervisor .

One who is designated in writing and who is capable of identifying existing and predictable hazards in thesurroundings or working conditions that are unsanitary, hazardous, or dangerous to employees, and whohas authorization to take prompt corrective measures to eliminate them.


It mentions that someone that can take prompt corrective measures. In most organizations, that is the Supervisor who has that authority.

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Public Input No. 9-NFPA 350-2013 [Section No. 10.1.2.2.1]




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3.3.15 Confined Space Rescue Service.

The confined space rescue team designated by the owner/operator or entrant employer to rescue victimsfrom within confined spaces, including operational and technical levels of industrial, municipal, and privatesector organizations external service providers .


Aligns the terminology with the CSA standard on confined spaces.

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Public Input No. 10-NFPA 350-2013 [Section No. 10.1.2.2.2 [Excluding any Sub-Sections]]




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3.3.19 Engineering Controls.

A method of eliminating or reducing exposure to a chemical or physical hazard through the use ofengineered specially designed machinery or equipment.


Do not use the word defined in the definition.

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3.3.19 Engineering Controls.

A method of eliminating or reducing exposure to a chemical or physical hazard through design, elimination,alternate lower hazard design or the use of engineered machinery or equipment.


Provides a more complete and properly focused definition of "Engineering Controls"

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3.3.21 Entrant Employer.

The person(s) or organization responsible for personnel under their employ who make entry into a specificconfined space.


The word specific narrows the scope too much.

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Public Comment No. 308-NFPA 350-2014 [ New Section after 3.3.22 ]

Entry.

When a person enters any bodily part into a confined space.


Defines entry and the fact that even if you put your hand in, your entering a confined space and should follow necessary procedures.

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Public Input No. 11-NFPA 350-2013 [Section No. 10.1.2.2.3.1(A)]




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3.3.22 Entry Supervisor.

The person(s) responsible for overseeing entry operations for a given confined space (they may or maynot be the competent person for the task) .


Needed for clarification because someone may ask if the entry supervisor is the competent person for rescue or selection of respirators.

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3.3.24* Explosionproof.

Referring to an apparatus enclosed in a case that is capable of withstanding an explosion of a specifiedgas or vapor that might occur within it and of preventing the ignition of a specified gas or vapor surroundingthe enclosure by sparks, flashes, or explosion of the gas or vapor within and that operates at such anexternal temperature that a surrounding flammable atmosphere will not be ignited thereby. [70, 2014]


grammer correction

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3.3.28 Gas Tester.

Qualified person(s) responsible for operating a gas monitor and able to interpret results for atmosphericmonitoring.


The atmospheric tester must be able to interpret results not just take the readings.

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3.3.32 Hierarchy of Controls.

A system used to minimize or eliminate exposure to hazards.

Hazardous Atmosphere. An atmosphere that may expose employees to death, incapacitation,impairment of their ability to self rescue, injury from one of the following:

Atmospheric oxygen < 19.5% or > 23.5%/volume

Flammable gas or vapor > 10% LFL

Any substance which has a published PEL and is over it's IDLH level of that substance

Any other atmospheric condition that is IDLH


Hierarchy of controls is not a needed term. It should be substituted with Hazardous Atmosphere because it is discussed in many parts of the guide especially in the definition of permit space.

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3.3.34 Hot Work.

Any activity that creates a source of ignition, including, but not limited to, welding, cutting, open flames,frictional heat or sparks, smoking, operation of internal combustion engines and use of nonapproved andnonauthorized electrical equipment. .(unapproved electrical equip doesn't create a source of ignition,although it my be a potential)


Unapproved equipment does not create an ignition source by itself. It could under certain circumstances be an ignition source. We are defining Hot Work.

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IDLH.

Immediately dangerous to life or health.


Important abbreviation. Maybe there should be a section just for abbreviations? For example; LEL, LFL, etc.

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3.3.36 Inert Gas.

A nonreactive, nonflammable, noncorrosive gas such as argon, nitrogen, and carbon dioxide. ornitrogen. (Carbon dioxide is not inert, it has a PEL and will increase a human's heart rate if elevatedenough)


Carbon dioxide is not inert or non-reactive. It helps regulates the breathing rate and has a PEL. So argon and nitrogen are good examples of inert gasses.

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3.3.37 Inerting.

The displacement of gas or vapors and oxygen (air) using an inert gas to eliminate the possibility of apotentially hazardous or flammable atmosphere in a confined space. ( Delete hazardous becausenitrogen is hazardous by lowering the oxygen levels)


Delete hazardous because nitrogen is hazardous by displacing the oxygen.

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3.3.39* Job Hazard Analysis (JHA).

A safety management risk assessment (RA) technique that is used to define and control the actual orpotential hazards associated with any process, job, or procedure that has actual or potential hazards .


Clearer wording modifying hazards.

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3.3.41 Lower Explosive Limit (LEL).

The lowest volume concentration of a combustible gas flammable gas or vapor or combustible dustthat when mixed with air will ignite creating a when ignited may create a fire or explosion.


To properly define LEL flammable vapor or gas needs to be mentioned along with combustible dust and you need the mixture with air to be correct and an ignition source hot enough to make the reaction occur. Just having all those elements present without an ignition source will not cause a fire or explosion.

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3.3.45* Occupational Exposure Limit (OEL) .

The maximum amount in air of a hazardous material that a worker should be exposed to for a givenperiod of time, also known as permissible exposure limit ( PEL - OSHA), recommended exposure limit (REL - NIOSH), and threshold limit value ( TLV - ACGIH).


The exposure limits must be in air and the abbreviations of the OEL is necessary for clarification.

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3.3.48 Peak Value.

The highest measured concentration of combustible or toxic gas components and the lowest measuredlevel of oxygen as detected by , as indicated by a gas monitor.


Peak value is not the lowest level of oxygen. Change needed for clarification.

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Public Comment No. 304-NFPA 350-2014 [ Sections 3.3.56, 3.3.57 ]

Sections 3.3.56, 3.3.57

3.3.56 Rescue Attendant.

A person who is qualified to be stationed outside a confined space to monitor rescue entrants, summonassistance, and perform non-entry rescues.

3.3.57 Rescue Entrant.

A person entering a confined space for the specific purpose of rescue. Are these two definitionsnecessary? I think they confuse the reader and no other publication has them that I know of?


These two definitions need to be deleted. They are not necessary and add confusion to the role of the attendant and entrant.

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3.3.68 Safety Officer.

A member of the incident command staff responsible for monitoring and assessing safety hazards orunsafe situations and for developing measures for ensuring personnel safety. [1026, 2014]


Insert text as shown: A member of the incident command staff …. As the context of safety officer in this document is specifically related to an incident command function, and not a normal industrial safety officer (representative).

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TITLE OF NEW CONTENT Serious Hazard.

An existing or potential biological, chemical, mechanical, atmospheric, environmental or physicalagent that has the potential to cause death, or serious physical or phychological harm.


This definition is needed to ensure the difference is made between a confined space and a permit space. A permit space is a confined space that contains or potentially could contain a serious hazard and without a definition the reader would not be able to make that distinction.

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4.1* Identification and Documentation of Permit Required Confined Spaces.

The owner/operator is responsible for evaluating and documenting confined permit spaces in the entirefacility, including, but not limited to, detached buildings, structures, sewers and drainage, trenches, tanks,vessels, containers, tunnels, vaults, manholes, and property grounds to determine if there are confinedspaces present that are configured so they could be entered by employees, contractors, the public, orvisitors to the facility. (The Chapter title should also be changed to Identification of Permit RequiredConfined Spaces Within a Workplace. This evaluation of permit spaces is consistant with otherstandards and regulations and does not confuse the reader or put an extra burden that is notrequired by law)


This is very important concept to get right from the beginning. Every confined space meeting the definition does not require all the bells and whistles of a permit space. So the difference between a confined space and a permit space is the presence or potential of containing a serious hazard. So the identification of confined spaces that pose serious issues is the thrust of this guide as well as other standards including OSHA. If this guide does not label spaces and address their work activity gearing toward how other organizations have defined confined space and permit spaces it will confuse the reader thinking that all spaces that are confined spaces under the definition need all the requirements of the entire document, the reader would be overwhelmed. So lets be consistent with regulatory standards as much as possible and ensure we stay in line with existing standards like ANSI Z117.1 and define Permit spaces based on the existence or potential to contain serious hazards. My changes in this chapter reflect permit spaces.

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4.2 Identification of Confined Permit Spaces During Construction.

All construction activity should be evaluated to determine if confined spaces may be present or created atany time during various construction phases. If confined spaces are identified, these evaluations should bedocumented and managed in accordance with a confined space program.


Change from confined space to permit space to be consistent.

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4.2 Identification of Confined Permit Spaces During Construction.

All construction activity should be evaluated to determine if confined permit spaces may be present orcreated at any time during various construction phases. If confined spaces are identified, these evaluationsshould be documented and managed in accordance with a confined space program.


Change confined space to permit space.

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4.2 Identification of Confined Spaces During Construction.

All construction activity should be evaluated to determine if confined spaces may be present or created atany time during various construction phases. If confined spaces are identified, these evaluations should bedocumented and managed in accordance with a the applicable owner/operator's or contractor's confinedspace program.


there is a need to specify the applicable program...just saying "a program" is not specific enough

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4.3 Determination of Confined Spaces needing a Permit .

Spaces that should be evaluated to determine if they could be confined spaces permit spaces includethose that have all three of the following characteristics, and contains or has the potential to contain aserious hazard :

(1) Are large enough and so configured that a person can bodily enter and perform assigned work.

(2) Have limited or restricted means for entry and exit. Any space that requires a ladder to access orrequires a worker to crawl or contort his or her body to enter or exit could be considered a confinedspace restricted . Nonstandard staircases such as spiral stairs or ships ladders could also beconsidered to have limited access or restricted means of egress. Often, these spaces are locatedbelow grade or require descent into a space. There are also confined spaces, such as water tanks,HVAC systems, and wind turbines that are typically located aboveground. Other spaces, by virtue ofthe distance a worker would have to travel to exit the space in an emergency, may be considered tohave limited means of exit.

(3) Are not designed for continuous human occupancy. These are spaces where employees would notnormally be assigned for work. They are spaces where a desk, computer, or phone would not beplaced but that might need to be entered for nonroutine inspection, maintenance, or repair work. Utilityvaults, crawl spaces, tanks, and below-grade structures are examples of spaces that typically are notdesigned for continuous human occupancy. There are also structures that might be confined spacesthat need to be worked on internally during construction, such as a pipe or a tank that needs to bewelded. (This last sentence does not reflect not designed for continuous occupancy)


This verbiage is consistent with previous recommendations and adds clarification..

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4.3 Determination of Confined Spaces.

Spaces that should be evaluated to determine if they could be confined spaces include those that have allthree of the following characteristics:

(1) Are large enough and so configured that a person can bodily enter and perform assigned work.

(2) Have limited or restricted means for entry and exit. Any space that requires a ladder to access orrequires a worker to crawl or contort his or her body to enter or exit could be considered a confinedspace. Nonstandard staircases such as spiral stairs or ships ladders could also be considered to havelimited access or restricted means of egress. Often, these spaces are located below grade or requiredescent into a space. There are also confined spaces, such as water tanks, HVAC systems, and windturbines that are typically located aboveground. Other spaces, by virtue of the distance a worker wouldhave to travel to exit the space in an emergency, may be considered to have limited means of exit.

(3) Are not designed for continuous human occupancy. These are spaces where employees would notnormally be assigned for work. They are spaces where a desk, computer, or phone would not beplaced but that might need to be entered for nonroutine inspection, maintenance, or repair work. Utilityvaults, crawl spaces, tanks, and below-grade structures are examples of spaces that typically are notdesigned for continuous human occupancy. There are also structures that might be confined spacesthat need to be worked on internally during construction, such as a pipe or a tank that needs to bewelded.

(4) Usually contain hazardous material, environment or can trap personnel. Hazardous materialsare usually the chemicals left in the confined spaces like explosive, corrosive ot toxic chemicals.Environemnt dangers Inlude but not limited to oxygen deficiency and explosive atmosphere referredby LEL. Trapping usually takes place by the structural change like exit closed from cave in or materialinflow.


The proposed change would help clarify more about the definition of confined spaces and their determination.

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Submitter Full Name: Muhammad Ahmed

Organization: British American Tobacco

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Submittal Date: Thu Sep 11 15:16:08 EDT 2014


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4.4 Signs.

Confined spaces Permit spaces should have posted signs, tags, or labels denoting them as confinedspaces needing a permit and prohibiting unauthorized entry. In facilities with similar, recognizable ormultiple, confined permit spaces, (such as storage tank facilities or workplaces with multiple manholes),the owner/operator may choose to identify such spaces with facility signage and/or identify the spaces intheir written confined space programs in lieu of individual signs or labels. Signs, tags, or labels should havewording similar to the following:

DANGER — PERMIT REQUIRED CONFINED SPACE

DO NOT ENTER WITHOUT AUTHORIZATION


This language is necessary for consistency with permit spaces.

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4.4 Signs.

Confined spaces should have posted signs, tags, or labels denoting them as confined spaces andprohibiting unauthorized entry. In facilities with similar, recognizable or multiple, confined spaces, (such asstorage tank facilities or workplaces with multiple manholes), the owner/operator may choose to identifysuch spaces with facility signage and/or identify the spaces in their written confined space programs in lieuof individual signs or labels. Signs, tags, or labels should have wording similar to the following:

DANGER — CONFINED SPACE

DO NOT ENTER WITHOUT AUTHORIZATION

I think a universal sign of confined space be added in the standard that will be more useful andappealing to novice


More clarity will be available to against any unauthorized entrants

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Submitter Full Name: Muhammad Ahmed

Organization: British American Tobacco

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4.6.1

Owner/operators should inform all individuals working in or around confined permit spaces of thepotentially hazardous nature of confined permit spaces on their property, regardless of whether or notthey are employees.


Changes for consistency.

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4.6.2*

Employers sending employees to a location where it is reasonably anticipated that they may work in oraround confined permit spaces should make sure those employees know how to identify confinedspaces and are aware of the hazards associated with them.


Consistency.

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Public Comment No. 325-NFPA 350-2014 [ Section No. 5.1 [Excluding any

Sub-Sections] ]

The terms confined space, non-permit-required confined space, and permit-required confined space maycause confusion among employers and workers. To minimize such confusion, this guide uses only the termpermit required confined space or permit space and makes provisions for identifying and evaluatingthe hazards of all confined spaces, requiring permits if hazards are identified . If those hazards areserious, then the space is labeled as a permit space .


This language clarified the confined space and permit space issues.

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Public Comment No. 95-NFPA 350-2014 [ Section No. 5.1 [Excluding any Sub-Sections]

]

The terms confined space, non-permit-required confined space, and permit-required confined space maycause confusion among employers and workers. To minimize such confusion, this guide uses only the termconfined space and makes provisions for identifying and evaluating the hazards of all confined spaces,requiring permits for entry if hazards are identified.


specific to require permits for ENTRY when hazards are indicated

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Public Input No. 755-NFPA 350-2013 [Section No. 5.1 [Excluding any Sub-Sections]]




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5.1.2

Table 5.1.2 shows the terminology used in commonly referenced confined space entry documents such as29 CFR 1910.146, ANSI/ASSE Z 117.1, API 2015, and API 2016, and how the terms relate to those givenin this guide.

Table 5.1.2 Terminology for Confined Space Entry in Various Standards and Documents

Standardor

Document Term Used

TermUsed inNFPA350 Comments

29 CFR1910.146

Confined spaceConfinedspace

NFPA 350 uses the same definition asOSHA for a confined space.

29 CFR1910.146

Permit required confined spaceConfinedspace

NFPA 350 does not distinguish betweenpermit required confined spaces andconfined spaces. All confined spaceswith hazards need permits for entry.

ANSI/ASSEZ117.1

Non-permit-confined spaceConfinedspace

All confined spaces need pre-entryevaluation prior to entry. If no hazardsare identified and no hazards will beintroduced, then no permit will berequired.

29 CFR1910.146

Reclassification (downgraded) entryConfinedspaceentry

Not defined in NFPA 350. A confinedspace with hazards that have beeneliminated after the pre-entry evaluationwill not require a permit.

29 CFR1910.146

Alternate procedures entryConfinedspaceentry

Not defined in NFPA 350. A confinedspace where all hazards have beenevaluated and the only hazard is apotentially hazardous atmosphere thatis being controlled with effectiveventilation would be issued a permit forentry that contains restrictions requiringventilation and continuous monitoring.

API 2015and 2016

Nonconfined space (a confined spacethat is no longer a confined space due toreconfiguration)

None

If a space does not meet all thespecifications for a confined space, thenit is not a confined space and NFPA 350does not apply.

NFPA 326

Nonconfined space (for purposes of tankentry, cleaning, or repair a space thatpreviously was a confined space but nolonger meets any of the requirements fora confined space or a permit requiredconfined space, such as a tank with alarge door sheet cut into the side)

None


CSAZ1006-10

Confined space - a workspace that isfully or partially enclosed, is no designedor intended for continious humanoccupancy, and has limited or restrictedaccess or egress, or an internalconfiguration, that can complicate firstaid, evacuation, rescue, or otheremergency response services

ConfinedSpace


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Included CSA definition of confined space.

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5.1.2

Table 5.1.2 shows the terminology used in commonly referenced confined space entry documents such as29 CFR 1910.146, ANSI/ASSE Z 117.1, API 2015, and API 2016, and how the terms relate to those givenin this guide.

Table 5.1.2 Terminology for Confined Space Entry in Various Standards and Documents

Standardor

Document Term Used

TermUsed inNFPA350 Comments

29 CFR1910.146

Confined spaceConfinedspace

NFPA 350 uses the same definition asOSHA for a confined space.

29 CFR1910.146

Permit required confined spaceConfinedPermitspace

NFPA 350 does not distinguish betweenpermit required confined spaces andconfined spaces. All confined spaceswith serious hazards need permits forentry.

ANSI/ASSEZ117.1

Non-permit-confined spaceConfinedspace

All confined spaces need pre-entryevaluation prior to entry. If no hazardsare identified and no hazards will beintroduced, then no permit will berequired.

29 CFR1910.146

Reclassification (downgraded) entryConfinedspaceentry

Not defined in NFPA 350. A confinedspace with hazards that have beeneliminated after the pre-entry evaluationwill not require a permit.

29 CFR1910.146

Alternate procedures entryConfinedspaceentry

Not defined in NFPA 350. A confinedspace where all hazards have beenevaluated and the only hazard is apotentially hazardous atmosphere that isbeing controlled with effective ventilationwould be issued a permit for entry thatcontains restrictions requiring ventilationand continuous monitoring.

API 2015and 2016

Nonconfined space (a confined spacethat is no longer a confined space dueto reconfiguration)

None


NFPA 326

Nonconfined space (for purposes oftank entry, cleaning, or repair a spacethat previously was a confined spacebut no longer meets any of therequirements for a confined space or apermit required confined space, such asa tank with a large door sheet cut intothe side)

None



This change helps to clarify previous recommendations.

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5.3.2 Permit.

A permit should be issued by the entry supervisor for all confined spaces with containing or has thepotential to contain serious hazards identified in accordance with Chapter 13.


Language adds clarification.

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5.4 Entry Conditions.

Entry into confined permit spaces by assigned qualified entrants should be permitted only after the entrysupervisor has indicated that acceptable entry conditions (see, Section 5.5 and 5.6 ) have been met,andafter a pre-entry evaluation has been performed and permit issued, if applicable.


Clarification and consistency

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5.5 Basic Requirements and Considerations.

Prior to entering a confined space, the following should be identified and evaluated:

(1) All inherent, potential, introduced, and adjacent hazards of the confined space should be anticipated,identified, and evaluated in accordance with a written confined space entry program and guidanceprovided in Chapters 6 and 7.

(2) All hazards should be eliminated, controlled, or mitigated in accordance with Chapters 8 and 9.

(3) An authorized entry supervisor qualified in accordance with Chapter 11 should be assigned tooversee the work.

(4) Only authorized entrantsqualified entrants qualified in accordance with Chapter 11 should beassigned to enter the space.

(5) Anattendant An attendant qualified in accordance with Chapter 11 should be assigned for permitentries to attend during confined space entry and work .

(6) If atmospheric monitoring is required, a gas testerqualified tester qualified in accordance withChapter 11 should be assigned.

(7) If ventilation is required, a ventilation specialistqualified specialist qualified in accordance withChapter 11 should be assigned.

(8) If energy sources are required to be isolated or controlled, anisolation an isolation specialist qualifiedin accordance with Chapter 11 should be assigned.

(9) If required, qualified rescuers and/or services as well as appropriate rescue equipment should beavailable in accordance with Chapter 10.

(10) Any other required permits, including, but not limited to, hot work, are issued.

(11) A pre-entry evaluation and/or confined space entry permit should be issued and signed by the entrysupervisor in accordance with Chapter 13.

(12) A pre-entry meeting should be held with all personnel entering or working in or adjacent to theconfined space to discuss the work to be performed, job requirements and assignments, actual andpotential hazards, and methods of eliminating or controlling the hazards as listed in the conditions onthe permit. A Job Hazard Analysis is an important tool to utilize before confined space entry.

(13) Communication between the entrant and the attendant and the attendant and rescuer, if required,should be established in accordance with Chapter 8.

(14) Permit entry should not occur until all conditions for entry established on the permit have been met. Ifconditions change the permit should be cancelled, operations ceased, and the entrant shouldimmediately vacate the space.


Corrected minor mistakes.

Included reference to JHA as they are important to use before confined space entry.

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Public Input No. 15-NFPA 350-2013 [Chapter 2 [Title Only]]




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Prior to entering into a confined permit space, the following should be identified and evaluated:


(2) All hazards should be eliminated,controlled,or mitigated in accordance with Chapters 8 and 9.


(4) Only authorized entrantsqualified in accordance with Chapter 11 should be assigned to enter thespace.

(5) Anattendant qualified in accordance with Chapter 11 should be assigned for permit entries.

(6) If atmospheric monitoring is required, a gas testerqualified in accordance with Chapter 11 should beassigned.

(7) If ventilation is required, a ventilation specialistqualified in accordance with Chapter 11 should beassigned.

(8) If energy sources are required to be isolated or controlled, anisolation specialist qualified inaccordance with Chapter 11 should be assigned.


(10) Any other required permits, including, but not limited to, hot work are issued.


(12) A pre-entry meeting should be held with all personnel entering or working in or adjacent to the spaceto discuss the work to be performed, job requirements and assignments, actual and potential hazards,and methods of eliminating or controlling the hazards as listed in the conditions on the permit.

(13) Communication between the entrant and the attendant and the attendant and rescuer, if required,should be established in accordance with Chapter 8.



Consistency

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Prior to entering a confined space, the following should be identified and evaluated:


(2) All hazards should be eliminated,controlled,or mitigated in accordance with Chapters 8 and 9.


(4) Only authorized entrantsqualified in accordance with Chapter 11 should be assigned to enter thespace.

(5) Anattendant An attendant qualified in accordance with Chapter 11 should be assigned for permitentries.

(6) If atmospheric monitoring is required, a gas testerqualified in accordance with Chapter 11 should beassigned.

(7) If ventilation is required, a ventilation specialistqualified in accordance with Chapter 11 should beassigned.

(8) If energy sources are required to be isolated or controlled, anisolation specialist qualified inaccordance with Chapter 11 should be assigned.


(10) Any other required permits, including, but not limited to, entry, cold work, testing criteria and hot workare issued.


(12) A pre-entry meeting should be held with all personnel entering or working in or adjacent to the spaceto discuss the work to be performed, job requirements and assignments, actual and potential hazards,and methods of eliminating or controlling the hazards as listed in the conditions on the permit.

(13) Communication between the entrant and the attendant and the attendant and rescuer, if required,should be established in accordance with Chapter 8. Where there are internal obstructions or wherethe space is so configured that visual contact between the attendant and the entrant is not possilble atall times, other means such as video cameras, should be considered.



item (5) editorialitem (1) specifies other permits in addition to hot work

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5.6 Roles and Responsibilities.

Every workplace that has one or more confined spaces that can be entered, as identified in Chapter4,should have personnel assigned to perform the responsibilities of the following roles as applicable. Thesame person can hold many of these roles as long as safe conditions are not violated :

(1) Owner/operator and/or entrant employer

(2) Entrant

(3) Attendant

(4) Entry supervisor

(5) Gas tester

(6) Ventilation specialist

(7) Rescuer (could be attendant for non-entry rescue)

(8) Rescue team or rescue service

(9) Standby worker

(10) Isolation specialist


Lets the reader know that more than one person can have many roles.

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Public Input No. 16-NFPA 350-2013 [Chapter 2 [Title Only]]




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5.6 Roles and Responsibilities.

Every workplace that has one or more confined permit spaces that can be entered, as identified inChapter 4,should have personnel assigned to perform the responsibilities of the following roles asapplicable:

(1) Owner/operator and/or entrant employer

(2) Entrant

(3) Attendant

(4) Entry supervisor

(5) Gas tester

(6) Ventilation specialist

(7) Rescuer (could be attendant for non-entry rescue)

(8) Rescue team or rescue service

(9) Standby worker

(10) Isolation specialist


Consistency.

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5.7.1

Owners/operators, contractors and entrant employers should subcontractors should ensure that allemployees who work in and around confined spaces have the necessary awareness, understanding,knowledge, and skills to safely perform their duties in or around confined spaces.


all employers, not just entrant employers, need to provide this

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5.7.2

Owners/operators, contractors and entrant employers should subcontractors should ensure that allemployees engaged in confined space operations have been educated, trained, and/or qualified as follows:

(1) Before beginning initial work and/or duty assignments

(2) Before assignment to a different type of work or duty other than initially assigned

(3) Wherevera change occurs in operations, equipment, materials, procedures, guidelines, workassignment, or duties that creates or has the potential to create a hazard for which the employee hasnot been previously trained, educated, or qualified

(4) Wherever an owner/operator and entrant employer has reason to believe an employee requiresretraining or additional education due to inadequacies in the employee’s performance or skill orbecause the employee deviates from the confined space program permit requirements or procedures


applies to ALL employers, not just entrant employers

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5.8 * Training Verification.

Owners/operators, comtractors and entrant employers subcontractors should verify, in writing, thatemployees who work in and aorund confined spaces have been trained, educated, or qualified as required.The verification should contain the names of the employees;the means used to determine that theemployees understand the specific requirements of the training or work to be performed; the signature,name, or initials of the trainer(s), educator(s) or qualifier(s); the specific subjects and content; and thedate(s) the training, education, or qualification was completed, in accordance with Chapter 11.


applicable to all employers not just entrant employers

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6.1.4

After all hazards have been identified and risks have been assessedappropriate assessed appropriatemeans to eliminate, control, or mitigate hazards should be implemented in accordance with Chapter 8.


Typo

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Submitter Full Name: Donald Raffo

Organization: General Dynamics, Electric Boa

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Submittal Date: Wed Sep 10 12:27:24 EDT 2014


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6.2.1 Intelligence Gathering.

Hazard preplanning starts with the collection of information that could be useful prior to determining actualand potential hazards where when planning for confined space operations. This intelligence gatheringincludes, but is not limited to, review of any previous permits concerning that space or adjacentspaces , using previously prepared hazard surveys, preplans, schematics, blueprints, work orders,equipment guides, safety data sheets, manuals, control measures, and prior experience from previousentries and knowledge from workers familiar with the space. Identification and determination of probablehazards and an understanding of the operations and processes associated with the space may also behelpful.


Consistency.

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6.2.1 Intelligence Gathering.

Hazard preplanning starts with the collection of information that could be useful prior to determining actualand potential hazards where hazards when planning for confined space operations. This intelligencegathering includes, but is not limited to, using previously prepared hazard surveys, preplans, schematics,blueprints, work orders, equipment guides, safety data sheets, manuals, control measures, and priorexperience from previous entries and knowledge from workers familiar with the space. Identification anddetermination of probable hazards and an understanding of the operations and processes associated withthe space may also be helpful.


change “…where planning…” to … when planning…

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Public Comment No. 332-NFPA 350-2014 [ Section No. 6.2.2.1 ]

6.2.2.1 Engineering Controls.

Some common engineering controls include, but are not limited to, the following:

(1) Hazard-specific area and personal atmospheric testing and monitoring equipment

(2) Area and local ventilation, inerting, or purging equipment, including vapor recovery equipment, ifneeded

(3) Isolation and/or lockout/tag out devices and equipment

(4) Hazardous material and waste collection, disposal, and/or containment equipment

(5) Lighting equipment

(6) Barricades and road blocks

(7) Breathing-air supply and equipment

(8) Decontamination stations and eye wash and showers

(9) Appropriate ladders, tripods and rescue equipment including harnesses, lifelines,

(10) Any special equipment such as GFCI, emergency generators, non-sparking tools, heatstress clothing and test equip (WBGT)


Added items to be more comprehensive.

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6.2.2.2 Administrative Controls and Personal Protective Equipment .

Some common administrative controls include, but are not limited to, the following:

(1) Qualified personnel assigned for all identified tasks

(2) Confined space, respiratory protection, isolation, hot/cold work, and other applicable programs,regulations, and industry standards

(3) Hazardous and toxic exposure amounts and time limits

(4) Personal and respiratory protection equipment

(5) Designated areas for specific equipment, work, breaks, and nonrelated activities

(6) Identified rescue personnel and/or services

(7) Entry, hot work permit, and restrictions and limitations

(8) Applicable regulatory permit requirements

(9) Outside services needed such as cranes, waste disposal, and so on


Clarification of heading matching contents.

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6.3.2

Hazard sources can be directly or indirectly associated with working in and around confined spaces.Indirect hazards are hazards that are not integral to, or are outside of, the space but can still affect it. Directand indirect hazards include the following: (The three examples are direct and indirect hazards)

(1) Those associated with confined spaces and inherently present in or around the space

(2) The result of product(s) stored in or around the space

(3) The result of processes taking place within or near the space


Examples of direct and indirect hazards.

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Public Comment No. 339-NFPA 350-2014 [ Section No. 6.3.4.1.2 ]

6.3.4.1.2

Inherent hazards to be identified include,but are not limited to, the following:

(1) Limited access into the space. Space for which ladders or scaffolding are needed to reach the portal,to enter and exit the space, or to perform work therein. Elevated spaces require differentconsiderations for entry and rescue than those that are at ground level, including fall protection.

(2) Size and shape of the portal. The restrictive nature of some portals makes access with certain typesof PPE difficult or impossible or requires entrants to contort their bodies while entering or exiting. Anelevated, open, unprotected edge or portal may create a fall hazard.

(3) Size and shape of the space/vessel. Inwardly converging walls or a funnel-shaped discharge canentrap an entrant; congested or dark spaces can inhibit mobility or create slip, trip, and fall hazards.

(4) Products or processes in the space. Chemicals, thermal stress, noise, steam, pressurization,mechanical equipment, operations, and other activities associated with the use of the space cancreate hazards. Disturbing product residue during entry or work can release a contaminant thatproduces a hazard not detected during pre-entry testing.

(5) Fixed equipment within the space. Piping systems, conduits, ducts, machinery,pressurized lines, andfire suppression systems should be evaluated for potential hazards and locked out/tagged out, tested,gas-freed, and/or inerted if needed to reduce the risk.

(6) Structural weaknesses due to rusting of iron, should be evaluated such as fixed ladders,floors, pipes and space supports prior to using them for anchoring or support.


Added structural weakness as a hazard.

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6.3.4.2.2

Examples of introduced hazards include the following:

(1) Atmospheric hazards. Ventilating a space may introduce contaminants from the following:

(2) Sources outside the space via an ill-placed supply-air duct

(3) Contaminated air drawn from internal combustion engine exhaust

(4) Oxygen-deficient air drawn from another space or source

(5) Product off-gassing captured by forced ventilation and contaminated adjacent areas

(6) Chemical hazards. Products used in cleaning, abating, painting, or coating need to be checked forreactivity with other chemicals that might be present. Chemicals may produce hazardous vapors orgases and/or displace or consume oxygen due to the nature of the confined space. The applyingand drying of flammable paints may cause an explosive atmosphere.

(7) Compressed hazards. Compressed gas used for welding, cutting, inerting, hot work, or firesuppression systems pose a hazard due to their contents (e.g., toxic or flammable gases), ability todisplace or enrich the atmospheric oxygen content (e.g., carbon dioxide fire extinguishing systems),and their potential to become a projectile if damaged. Compressed gas hoses, valves, and regulatorsshould be thoroughly inspected, evaluated, and leak checked prior to being brought into a confinedspace. Due to the inherent risks, compressed gas cylinders (except SCBAs) should not normallybe introduced into confined spaces.

(8) Hot work. Hazardous atmospheres and flammable conditions created by hot work such as welding,cutting, grinding, drilling, and burning, which can produce fumes, release gases, deplete or enrich thespace’s oxygen content, or produce an ignition source, such as sparks from the work or the tool itself, should be conducted following a hot work permit . (This was an incomplete sentenceneeding revision)

(9) Electrical hazards. Electrical equipment that is not low voltage or intrinsically safe, lighting, powertools, and extension cords, can produce electrical shock, trip hazards, and ignition sources. Additionalconsideration should be given to unexpected sources of electrical energy/ignition source such as staticelectric discharge that may be generated by the use of airlines/pressure lines or even exhaust fans.GFCI protection should be considered when using AC power.

(10) Slip, trip, and fall hazards. Ladders or scaffolding used to reach portals, gain entry, or access insidethe space can produce slip, trip, fall, and entanglement hazards. Equipment, cables, hoses, tools,ventilation ducts and other items brought into the space may create slip, trip, and entanglementhazards.


Needed examples for clarification.

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6.3.4.2.2



(a) Sources outside the space via an ill-placed supply-air duct

(b) Contaminated air drawn from internal combustion engine exhaust

(c) Oxygen-deficient air drawn from another space or source

(d) Product off-gassing captured by forced ventilation and contaminated adjacent areas

(2) Chemical hazards. Products used in cleaning, abating, painting, or coating need to be checked forreactivity with other chemicals that might be present. Chemicals may produce hazardous vapors orgases and/or displace or consume oxygen due to the nature of the confined space.

(3) Compressed hazards. Compressed gas used for welding, cutting, inerting, hot work, or firesuppression systems pose a hazard due to their contents (e.g., toxic or flammable gases), ability todisplace or enrich the atmospheric oxygen content (e.g., carbon dioxide fire extinguishing systems),and their potential to become a projectile if damaged. Compressed gas hoses, valves, and regulatorsshould be thoroughly inspected, evaluated, and leak checked prior to being brought into a confinedspace. Due to the inherent risks, compressed gas cylinders should not normally be introduced intoconfined spaces.

(4) Hot work. Hazardous atmospheres and flammable conditions created by hot work such as welding,cutting, grinding, drilling, and burning, which can produce fumes, release gases, deplete or enrich thespace’s oxygen content, or produce an ignition source, such as sparks from the work or the tool itself.

(5) Electrical hazards. Electrical equipment that is not low voltage or intrinsically safe, lighting, powertools, and extension cords, can produce electrical shock, trip hazards, and ignition sources.Additional consideration should be given to unexpected sources of electrical energy/ignition sourcesuch as static electric discharge that may be generated by the use of airlines/pressure lines or evenexhaust fans.



Perhaps too specific, but chapter 6 does not address radiological hazards from NORM or external nuclear gauges. Nuclear gauges should be part of the isolation process and verified independently. It may be beneficial to identify nuclear gauges as a potential hazard source due to their prevalence in the refining and chemical industries. Recommend to include this in the appropriate section(s).

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6.3.4.2.2



(a) Sources outside the space via an ill-placed supply-air duct

(b) Contaminated air drawn from internal combustion engine exhaust

(c) Oxygen-deficient air drawn from another space or source

(d) Product off-gassing captured by forced ventilation and contaminated adjacent areas

(2) Chemical hazards. Products used in cleaning, abating, painting, or coating need to be checked forreactivity with other chemicals that might be present. Chemicals may produce hazardous vapors orgases and/or displace or consume oxygen due to the nature of the confined space.

(3) Compressed hazards. Compressed gas used for welding, cutting, inerting, hot work, or firesuppression systems pose a hazard due to their contents (e.g., toxic or flammable gases), ability todisplace or enrich the atmospheric oxygen content (e.g., carbon dioxide fire extinguishing systems),and their potential to become a projectile if damaged. Compressed gas hoses, valves, and regulatorsshould be thoroughly inspected, evaluated, and leak checked prior to being brought into a confinedspace. Due to the inherent risks, compressed gas cylinders should not normally be introduced intoconfined spaces.

(4) Hot work. Hazardous atmospheres and flammable conditions created by hot work such as welding,cutting, grinding, drilling, and burning, which can produce fumes, release gases, deplete or enrich thespace’s oxygen content, or produce an ignition source, such as sparks from the work or the tool itself.

(5) Electrical hazards. Electrical equipment that is not low voltage or intrinsically safe, lighting, powertools, and extension cords, can produce electrical shock, trip hazards, and ignition sources.Additional consideration should be given to unexpected sources of electrical energy/ignition sourcesuch as static electric discharge that may be generated by the use of airlines/pressure lines or evenexhaust fans.



Recommend including the terms “inerting” or “blanking” as a type of introduced atmospheric hazard and reference those terms to section 8.4.4.

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6.3.5.2.1*

As electricity travels from its source and returns to that source, either through a wire, conductive material,or through the ground, it makes a complete circuit. If anything, such as a human body, comes in contactwith the current-carrying wires and has lower resistance than the wire, electricity will follow the path ofleast is effectively grounded, electrocution is possible. Electricity follows all paths of resistance toground not only the path of lease resistance.


Inaccurate statement regarding electrify follows the path of least resistance.

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6.3.5.2.1*

As electricity travels from its source and returns to that source, either through a wire, conductive material,or through the ground, it makes a complete circuit. If anything, such as a human body, comes in contactwith the current-carrying wires and has lower resistance than the wire, electricity will follow the path of leastresistance any path to ground .


Electricity will follow any path to ground, no only the path of least resistance. Electricity will flow in all parallel paths.

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Submitter Full Name: JAMES TYLER

Organization: VESTAS

Affilliation: American Wind Energy Association (AWEA)

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6.3.5.3 Physical Hazards.

These hazards include hazards other than mechanical or chemical that would cause harm to the body,including, but not limited to, noise, engulfment, falls, wet/slick surfaces, slip/trip hazards, lighting, radiation,vibration, and extremes of temperature and pressure. Entrapment hazards are where the shape orconfiguration of the vessel itself can exert enough force on the body to cause death by strangulation,constriction, or crushing and may include narrow cross sections, sloping floors, funneling configurations, orother internal configurations that can entrap. Physical hazards include explosion and fire hazards createdby various chemical agents such as flammable liquids, paints, solvents, and methane, as well ascombustible settled dust in excess of 1⁄32 in., and airborne concentrations that impair visibility to less than 5ft are indicators of potential explosive conditions. Concentrations of explosive/flammable vapors that havereached their LEL /LFL lower explosive /flammable limit and have not exceeded their UEL/UFL Upperexplosive/flammable limit are capable of explosion. There is no effective PPE for an explosiveenvironment, control or elimination is recommended. Generally, atmospheres that have reached 10% oftheir LEL/LFL are considered hazardous and should require additional precautions and actions prior toentering a space. LFL/LEL is the lowest concentration of gas or vapor in air in which burning will takeplace. .(The use of LFL is also used throughout this document and is not defined. LEL is defined but inmany cases has been replaced with LFL. Use of the terms should be consistent. Also, the discussion ofrespiratory protection is not needed under this section)


The use of LFL is used throughout this document and is not defined. LEL is defined but in many cases has been replaced with LFL. Use of the terms should be consistent. Also, the discussion of respiratory protection is not needed under this section.

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6.3.5.5* Atmospheric Hazards.

NIOSH statistics indicate that atmospheric hazards are the most common cause of death in confinedspaces. Oxygen deficiency and enrichment atmospheres are also hazardous. The normal amount ofoxygen is 20.8 percent to 20.9 percent in the air. Where oxygen is lower than 20.8 percent, there may be achemical or process consuming or displacing oxygen; where it is higher, there may be a source of oxygenbeing introduced to the space. Oxygen deficiency may lead to atmospheres that cannot sustain life and thatmay become immediately dangerous to life and health. Oxygen-enriched atmospheres greater than 22%oxygen may create a fire or explosion hazard. The following are the most common atmospheric hazards:

(1) Oxygen deficiency (less than 20.8 percent), which may be caused by the following:

(a) Oxygen displacement by other gases and vapors, such as inert gases or by evaporatingliquids

(b) Oxygen consumption through rusting metals (oxidation), combustion, respitory respiratoryconsumption by workers, or organic decay of aqeous molasses or oils drying ofpaints

(c) Oxygen absorbtion, where oxygen molecules adhere to the surface od a of a solid bodysuch as damp carbon

(2)

(3)

(4)

(5)

Concentration

(a)

(b)

(6) Toxic atmospheres, which contain substances that are poisonous and may cause injury or deathindependent of oxygen concentration. The effect of contamination may be immediate (acute) or maybe cumulative(chronic), taking substantial time for symptoms to affect entrants.

(7) Hypobaric and hyperbaric conditions, which may be present in both extreme in both extreme shigh and low altitudes and pressurized spaces may also affect air monitoring devices. (Seealso A.6.3.5.4.)


Clairification

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* Flammable/explosive atmospheres, which may be caused by the following:

Vaporization of flammable liquids

Byproducts of chemical reactions

Oxygen enrichment (greater than 22% oxygen)

LEL c oncentration of combustible dust

Methane from soil gases near a nearby landfill


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6.3.5.7 Psychological Hazards.

Confined spaces, restricted movement, excessive noise, and PPE restriction may create psychologicalhazards. Some entrants may easily become claustrophobic or stressed, which may cause them tohyperventilate and alter their ability to reason and make sound decisions. Entrants should be evaluatedprior (by who) prior to entry to ensure they are capable of performing assigned duties and should becontinuously monitored for psychological stress. Entrants exhibiting physiological stress should be deniedentry or removed immediately. (Suggest this section be deleted. Not sure if a field person is capable ofmaking psychological determinations)


Suggest this section be deleted. Not sure if a field person is capable of making psychological determinations. If so, then the person responsible for this determination should be defined.

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6.4.1

Following hazard identification, the entry supervisor should conduct an assessment to determine the actualand potential risks to entrants and other confined space workers.Risk assessment is a process in which theexpected severity of illness, injury, or property damage that an identified hazard may cause is coupled withthe probability of that level of hazard occurring. Risk assessment enables prioritization of resources andindicates whether or not a hazard needs to be eliminated to establish acceptable entry parameters. If thelevel of risk is greater than what is acceptable(as described in the owners / operators confined spaceprogram) , control measures should be determined by the entry supervisor to eliminate, control, or mitigatethe risk to an acceptable level.


Guidance on whom should provide risk acceptance / tolerance criteriaInsert text as noted: ……. the level of risk is greater than what is acceptable (as described in the owners /operator confined space program), control measures ……Acceptability of risk should be described in the owners/operators HSE programs and either included or referenced in the confined space program.

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6.4.2

The general steps needed to provide acceptable entry conditions include, but are not limited to, thefollowing:

(1) Investigate thoroughly. Using information in this guide, entry supervisors should conduct a thoroughinvestigation of existing or potential hazards that could pose a danger to entrants and confined spaceworkers. Entry supervisors should then ensure entry requirements are documented on permits andthat entrants and workers know what the hazards are, where and when they may be located orexpected, and what control measures are appropriate for each hazard.

(2) Conduct a hazard evaluation to determine the risks. Entry supervisors should develop hazardscenarios that describe the environment, possible exposures, actions, or events that could precipitatea hazard, and the outcome should the hazard occur. Hazard scenarios should determine what can gowrong, how the event may occur, what the consequences may be, and how likely the event is tohappen. Consideration should also be given to the entry supervisors and entrants themselves,because their level of training, experience, and use of PPE can contribute to or create hazards in andaround confined spaces. For example, wearing chemical protective clothing to prevent skin contact foran extended period of time in a hot environment may create heat stress hazards.

(3)

(4) Prioritize the risks. The entry supervisor should prioritize and note which of the hazards pose thehighest risk and focus on controlling or eliminating those first.

(5) Determine control measures. Entry supervisors should know it is always best to eliminate hazardswherever possible regardless of the probability or severity of the hazard. If that is not feasible, the nextbest strategy is to use engineering controls to reduce exposures. Engineering controls include, but arenot limited to,local exhaust ventilation to remove contaminants, general dilution ventilation to supplyfresh air to the space, and substitution of materials so that chemicals are not introduced or producedduring work in the space. Other types of control measures include administrative controls and PPE.Administrative controls include such measures as posting ; employee rotation to control toxicexposure, noise exposures or heat stress by administratively restricting time in the space, posting warning signs on confined spaces; ensuring , ensuring that personnel are trained how toidentify, evaluate, and control hazards; and developing and implementing appropriate confined space,isolation, hot work, and other safety programs.PPE should be used when engineering andadministrative controls are not sufficient to reduce or eliminate the hazards as PPE does not reduce orremove the hazard. (See also, Chapter 8.)

(6) Verify control measures. Entry supervisors should ensure that the control measures chosen do notintroduce additional hazards that have a higher level of risk or change the risk. For example, ifventilation ducts block the exit for entrants, it may be determined that the risk of not having theventilation outweighs the risk posed by the blocked exit.

(7) Determine if the level of risk is acceptable. Entry supervisors should determine if the risk has beenreduced to an acceptable level,as determined by the organization or the supervisor, with the controlmeasures chosen. For example, the risk assessment might conclude that a complicated, redundantventilation system is required for entry. A facility in-house confined space entry team might concludethey are uncomfortable and unfamiliar with implementing such a system and determine that they willnot complete the entry; instead, they conclude the risk is too great and decide to not conduct entryoperations choosing instead to hire a professional contractor.

(8) Implement and train. After the controls are implemented, entry supervisors should ensure thatpersonnel involved in the entry operations are informed of the hazards, risk assessmentdeterminations, specific control measures,and if the those control measures may pose a hazard.

(9) Institute ongoing assessment. Entry supervisors should ensure that the identification and evaluationof hazards is an on-going process as conditions often change in a confined space due to inherent,introduced, and adjacent hazards. Entry supervisors should conduct regular visual and atmosphericmonitoring of the space to ensure conditions do not change. Personnel should be aware that changingconditions may indicate the need to evacuate the space and re-evaluate it.

* Assess and evaluate risks. Entry supervisors should conduct a risk assessment to evaluate thehazards. This assessment can be quantitative, semiquantitative, or qualitative based on the needs ofthe situation and the identified hazards. Examples include performing air monitoring in the space (e.g.,for oxygen levels, flammability, and toxic chemicals) and performing a visual inspection to determine ifthere are physical hazards. There are numerous methods for conducting risk assessments; one suchmethod is outlined in ANSI/AIHA Z10-2012, Occupational Health and Safety Management Systems.


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Clarification.

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6.4.2



(2) Conduct a hazard evaluation to determine the risks. Entry supervisors should develop hazardscenarios that describe the environment, possible exposures, actions, or events that could precipitatea hazard, and the outcome should the hazard occur. Hazard scenarios should determine what can gowrong, how the event may occur, what the consequences may be, and how likely the event is tohappen. Consideration should also be given to the entry supervisors and entrants themselves,because their level of training, experience, and use of PPE can contribute to or create hazards in andaround confined spaces. For example, wearing chemical protective clothing to prevent skin contactfor an extended period of time in a hot environment may create heat stress hazards.

(3)


(5) Determine control measures. Entry supervisors should know it is always best to eliminate hazardswherever possible regardless of the probability or severity of the hazard. If that is not feasible, thenext best strategy is to use engineering controls to reduce exposures. Engineering controls include,but are not limited to,local exhaust ventilation to remove contaminants, general dilution ventilation tosupply fresh air to the space, and substitution of materials so that chemicals are not introduced orproduced during work in the space. Other types of control measures include administrative controlsand PPE. Administrative controls include such measures as posting warning signs on confinedspaces; ensuring that personnel are trained how to identify, evaluate, and control hazards; anddeveloping and implementing appropriate confined space, isolation, hot work, and other safetyprograms.PPE should be used when engineering and administrative controls are not sufficient toreduce or eliminate the hazards as PPE does not reduce or remove the hazard. (See also, Chapter8.)




(9) Institute ongoing assessment. Entry supervisors should ensure that the identification and evaluationof hazards is an on-going process as conditions often change in a confined space due to inherent,introduced, and adjacent hazards. Entry supervisors should conduct regular visual and atmosphericmonitoring of the space to ensure conditions do not change. Personnel should be aware thatchanging conditions may indicate the need to evacuate the space and re-evaluate it.

* Assess and evaluate risks. Entry supervisors should conduct a risk assessment to evaluate thehazards. This assessment can be quantitative, semiquantitative, or qualitative based on the needs ofthe situation and the identified hazards. Examples include performing air monitoring in the space(e.g., for oxygen levels, flammability, and toxic chemicals) and performing a visual inspection todetermine if there are physical hazards. There are numerous methods for conducting riskassessments; one such method is outlined in ANSI/AIHA Z10-2012, Occupational Health and SafetyManagement Systems.


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Within this section (hazard evaluation) it states that the entry supervisor should conduct an assessment to determine the actual and potential risks to the entrants and other confined space workers and further states that the entry supervisor should assess and evaluate the risks etc.

Risk assessments normally should not be conducted solely by one individual and almost always should include those involved with the work activities.

Recommend that this is changed to reflect that the entry supervisor should lead the assessment and include entrants, confined space works and those involved with the work.

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100 of 340 12/12/2014 2:22 PM

6.4.2



(2) Conduct a hazard evaluation to determine the risks. Entry supervisors should develop hazardscenarios that describe the environment, possible exposures, actions, or events that could precipitatea hazard, and the outcome should the hazard occur. Hazard scenarios should determine what can gowrong, how the event may occur, what the consequences may be, and how likely the event is tohappen. Consideration should also be given to the entry supervisors and entrants themselves,because their level of training, experience, and use of PPE can contribute to or create hazards in andaround confined spaces. For example, wearing chemical protective clothing to prevent skin contactfor an extended period of time in a hot environment may create heat stress hazards.

(3)


(5) Determine control measures. Entry supervisors should know it is always best to eliminate hazardswherever possible regardless of the probability or severity of the hazard. If that is not feasible, thenext best strategy is to use engineering controls to reduce exposures. Engineering controls include,but are not limited to,local exhaust ventilation to remove contaminants, general dilution ventilation tosupply fresh air to the space, and substitution of materials so that chemicals are not introduced orproduced during work in the space. Other types of control measures include administrative controlsand PPE. Administrative controls include such measures as posting warning signs on confinedspaces; ensuring that personnel are trained how to identify, evaluate, and control hazards; anddeveloping and implementing appropriate confined space, isolation, hot work, and other safetyprograms.PPE should be used when engineering and administrative controls are not sufficient toreduce or eliminate the hazards as PPE does not reduce or remove the hazard. (See also, Chapter8.)




(9) Institute ongoing assessment. Entry supervisors should ensure that the identification and evaluationof hazards is an on-going process as conditions often change in a confined space due to inherent,introduced, and adjacent hazards. Entry supervisors should conduct regular visual and atmosphericmonitoring of the space to ensure conditions do not change. Personnel should be aware thatchanging conditions may indicate the need to evacuate the space and re-evaluate it.

* Assess and evaluate risks. Entry supervisors should conduct a risk assessment to evaluate thehazards. This assessment can be quantitative, semiquantitative, or qualitative based on the needs ofthe situation and the identified hazards. Examples include performing air monitoring in the space(e.g., for oxygen levels, flammability, and toxic chemicals) and performing a visual inspection todetermine if there are physical hazards. There are numerous methods for conducting riskassessments; one such method is outlined in ANSI/AIHA Z10-2012, Occupational Health and SafetyManagement Systems.


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“… assessment can be quantitative, semi quantitative, or qualitative…”

For confined space entry risk assessment to date have never seen a quantitative method used. Recommend to remove quantitative and state that qualitative and semi quantitative being the most widely used methods.

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A vital, reiterative part of reducing hazards is communication. It starts after the identification of hazards andthe employer communicates them to all persons involved with the entry or working around a confinedspace.


Clarity

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6.5.2

The authorization for entry procedure and permit should outline how communication during the entry, work,and exit stages will be conducted, ensuring that authorized entrants and attendants can maintain contactduring entry and throughout the work shift. Because voice communications may Where the potentialextists for voice communications to be hampered by noise, PPE, distance, and so forth spaceconfiguration or other blockage , two forms of communication should be used.


two forms are only needed where required due to blockages

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6.5.3

The risks and potential exposures of the entry as well as the signs and symptoms of exposure need to becommunicated to the entrant and the attendant. The supervisor should ensure that they are familiar withassigned equipment, such as PPE, atmospheric testing equipment, alarm systems, and and the rescueequipment available as well as alarms and means of communtication .


for clarity. alarm SYSTEMS are not necessarily equipment, need to add communications

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6.5.6

The entry supervisor needs to ensure that the attendant(s) has the means to notify the designated rescueteam, the notification method is operable, and the rescue team is aware of the entry .


Clarification.

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Public Comment No. 102-NFPA 350-2014 [ Section No. 6.6.1 [Excluding any

Sub-Sections] ]

Safety datasheets data sheets (SDS) should be available and reviewed for recent materials that previouslyhave been stored or used in a confined space being entered, have been used to purge a confined spacebeing entered, or are being brought into the space being entered.


editorial and consistency with other sections

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7.1 General.

The purpose of this chapter is to outline the steps necessary for testing and evaluating confined spaceatmospheres for gaseous hazards and to help determine the equipment necessary for this task. Thischapter does not cover evaluating or testing for nongaseous hazards such as dusts, particulates, or otherpotential atmospheric hazards.


As stated this chapter does not include evaluating or testing for nongaseous hazards such as dust, particulates, or other potential atmospheric hazards.

While this is understandable it does however feel like it is somewhat incomplete. Is it possible to at least refer to various standards or guidelines covering the nongaseous air monitoring? Or – …… consultation with Safety and Health or Industrial Hygiene professionals ….. be added here.

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Atmospheric monitoring should be performed using the procedures described in this chapter prior to anyconfined space entry to determine if the atmosphere within the space is safe for entry. Atmosphericmonitoring may not be necessary if the documented initial hazard evaluation, as described in Chapter 6, hasdetermined that there is no potential for atmospheric hazards to exist in the space. Atmospheric monitoringis performed for two distinct purposes:

(1) Pre-entry testing to evaluate the initial hazard(s)

(2) Pre-entry testing to determine if any changes occurred fron the time of the initial evaluation

(3) Continuous or periodic monitoring of the atmosphere within the space (see Section 7.14) as requiredby the applicable confined space program or as determined by the entry supervisor.


there are 2 phases to pre entry monitoring as notedThere are many instances where continuous monitoring is NOT required. For example, the space may become or has been free of contaminants and monitoring may be only needed to evaluate initial entry and start of work to assure no disturbances occur. It is i9ndustry practice to provide for periodic monitoring where acceptable.

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The atmosphere of a confined space should be tested for all potential hazardous atmospheric contaminantsas identified in the initial hazard evaluation (see Chapter 6) before each entryby a gas tester.Theappropriate testing equipment should be used to determine that the atmospheric concentrations at the timeof entry are within the range of acceptable entry conditions as described in 8.4.2. The results of the testing(e.g., actual gas concentrations) should be recorded along with the stipulated acceptable entry conditionsaccording to the permit recommendations in Chapter 13. All gas monitors should be equipped with theproper sensors to detect the potential atmospheric hazards being tested and certified for use in theenvironment where it is being used. Refer to the gas monitor manufacturer’s specifications and hazardouslocation certifications .


what is this??? Needs a definition

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If the confined space has not been opened or the atmosphere is not immediately accessible for testing, theentry supervisor should open the confined space just enough to allow insertion of a probe for testing. Anypotential hazard, including, but not limited to, pressure and electric shock should be eliminated, controlled,or mitigated prior to opening the space. Some manhole covers may have a small opening to allow theinsertion of a sampling hose gas detector sampling tube or lowered via rope .


Gas detection equipment can also be lowered into spaces via a rope. Singling out sampling tubes may be too limiting especially considering the depth of the confined space being entered.

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Submittal Date: Fri Sep 12 12:53:43 EDT 2014


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7.3.7

As much of the confined space’s horizontal and/or vertical areaas possible should be tested by use of apump and remote probe or sample hose from the outside before the space is entered for further testing.


typo corrected

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7.3.10

Where testing for entries involving a vertical descent, the atmosphere should be tested according to theprocedures outlined in 7.13.2 . this chapter.


7.13.2 is incorrect

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7.3.11

If the confined space requires a horizontal entry, atmospheric monitoring should be performed according to7.13.3 . procedures in this chapter.


7.13.3 is incorrect

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7.3.13

Whereas the pre-entry test determines the initial air quality before the confined space is entered, it isimportant there may be a need to continually or periodically monitor for changes in the atmosphere duringwork operations inside the space, depending on the actual or potential hazards, to ensure that a safeatmosphere is maintained. (See Section 7.14 .)

.


There are many instances where continuous monitoring is NOT required. For example, the space may become or has been free of contaminants and monitoring may be only needed to evaluate initial entry and start of work to assure no disturbances occur. Remember, this committee has chosen to regard ALL confined spaces as permit required even if they actually may be categorized otherwise such as a non-permit required confined space. . Also it is industry practice to provide for periodic monitoring where acceptable.

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If hazardous atmospheric conditions as described in Section 7.14 are detected during pre-entry testing,entry should be prohibited until corrective actions are taken and retesting verifies acceptable atmosphericconditions in accordance with the applicable confined space program and entry permit . Entry into the spaceusing appropriate respiratory protection may be considered acceptable corrective action provided theatmosphere does not contain flammable or combustible vapors in excess of the acceptable entry conditions.


need to tell where to find acceptable atmospheric conditions

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7.3.15.1

If any results from atmospheric monitoringexceed monitoring exceed the acceptable limits for entrydescribed in Section 7.17, all work within the confined space should cease and the space should beevacuated immediately.


editorial

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7.4.2 Selection of Monitor.

Confined space monitors should be calibrated, direct-reading, continuous-monitoring gas monitors. Themonitor should detect for oxygen (O2) content, flammable gasses and vapors (LFL LEL ), and potential

toxic gases, all of whichare which are minimum requirements. The hazard evaluation will determine if it isnecessary to monitor for specific gases, including, but not limited to, carbon monoxide (CO), hydrogensulfide (H2S), ammonia (NH3), or volatile organic compounds (VOCs), such as benzene. Each of these

hazardous gases can require unique sensor technology to be detected properly. In addition, real-time andintegrated monitoring of other potential atmospheric hazards, such as welding fumes and particulates,might be necessary per the hazard identification and hazard evaluation.


Suggest the use of LEL throughout the document. It is defined and used more than LFL, also corrected a typo.

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7.4.3 Portable vs. Fixed Monitors.

Portable gas monitors should be used for confined space entry atmospheric monitoring. In confined spaceswhere fixed gas detectors are installed, portable gas monitors should be used for pre-entry testing andeither carried into or worn by the entrant in the space.


portable monitors may not necessarily be worn but may be carried INTO THE SPACE.

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7.4.4.1

Direct-reading gas monitors used to evaluate or verify confined space atmospheres should provide areading accuracy of ± 20 percent or better of the actual gas concentration in all use conditions that arecovered within the monitors’ operating specifications.

The following comments are the opinion of the AIHA’s Real‐Time Detec on Systems Commi ee but are not AIHA

comments.

7.4.4 Monitor Accuracy

7.4.4.1

Direct‐reading gas monitors used to evaluate or verify confined space atmospheres should provide a reading

accuracy of ± 20% or be er of the actual gas concentra on in all use condi ons that are covered within the

monitors opera ng specifica ons

Manufacturers of direct‐reading gas monitors used to evaluate or verify confined space atmospheres should

provide documenta on that the equipment performs within the accuracy requirements specified in applicable

na onal or interna onal standards (which may be different for flammable gas, oxygen concentra on or toxic

gases) over the range of condi ons recommended for use. In the field, users should verify that the equipment

provides a reading within appropriate specifica ons using standard gas mixtures traceable to na onal or

interna onal standards.


The way it is currently written does not adequately protect the worker.

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7.4.4.2

The gas tester should verify that gas monitors using correlation or response factors to determine the levelof a gas or vapor concentration that is different from that for which the sensor or gas monitors is calibratedhave an accuracy of ± 30 percent or better with the correlation factor applied. For example, a monitorequipped with a PID calibrated to isobutylene can be used to detect the level of trichloroethylene in aconfined space. The monitor reading should be multiplied by a correlation or response factor, specified bythe manufacturer, to determine the relative concentration of trichloroethylene in the space. The accuracy ofthe value after the reading has been multiplied by the correlation factor should be better than ± 30 percent.The gas monitor manufacturer should be consulted for information related to response factors and gasmonitor performance.



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7.4.5 Limits of Detection.

The minimum detection limit (MDL),which is the smallest level of a gas that can be detected within thespecified accuracy or repeatability of the monitor, should be less than 2 percent for oxygen, 2 percent LFLLEL for combustible gases, and at least one order of magnitude lower than the published permissibleexposure limit (PEL) or threshold limit value (TLV), whichever is lower, for toxic gases. The levels can bedetermined from manufacturers’ specifications. For example, the current OSHA PEL for chlorine (Cl2) is a

ceiling limit of 1.0 ppm. The MDL for a chlorine monitor should be less than or equal to 10 percent of 1.0ppm, or 0.1 ppm. Lower MDLs provide for greater reading stability and confidence around gasconcentration action points and reduce or eliminate false or nuisance alarms due to detector or sensorinstability.


Suggest use of LEL throughout the document

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7.4.5 Limits of Detection.

The minimum detection limit (MDL),which is the smallest level of a gas that can be detected within thespecified accuracy or repeatability of the monitor, should be less than 2 percent for oxygen, 2 percent LFLfor combustible gases, and at least one order of magnitude lower than the published permissible exposurelimit (PEL) or threshold limit value (TLV), whichever is lower, for toxic gases. The levels can be determinedfrom manufacturers’ specifications. For example, the current OSHA PEL for chlorine (Cl2) is a ceiling limit

of 1.0 ppm. The MDL for a chlorine monitor should be less than or equal to 10 percent of 1.0 ppm, or 0.1ppm. Lower MDLs provide for greater reading stability and confidence around gas concentration actionpoints and reduce or eliminate false or nuisance alarms due to detector or sensor instability.



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7.4.7.6.1

Gas monitors used toevaluate to evaluate or verify confined space atmospheres should be certified by themanufacturer to test and perform in accordance with relevant guidelines for RFI/EMI.


Corrected typo and suggest that RFI and EMI be spelled out. Not everyone knows what they mean. If not they should be defined.

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Gas Where required by owner/operator or contractor/subcontractor confined space programs or byapplicable regulations, gas monitors used by confined space personnel for personal monitoring may beused in either diffusion or aspirated mode.


It is not industry practice to have every individual use a perso0nal monitor either inside or outside a confined space. Personal monitors should be used as required by applicable programs.

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7.7.2.1

Confined space Where required by the applicable confined space program and entry permit or byapplicable regulations, confined space entrants should wear a gas monitor at all times during entry. ItWhen used, it is critical that the monitor or sample input does not get covered by clothing or PPE or it willno longer be measuring the in order that it properly measures the atmosphere.


it is not industry practice THAT ALL entrants use individual monitors at all times. Use should be as required by program or regulations.

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7.7.2.2

Confined space Where required by the confined space program, entry permit or regulations, confinedspace attendants should wear a direct-reading gas monitor , or one should a portable monitor should beplaced in the a nearby area outside the of the confined space. This would allow Where there is apotential for outside atmospheric contamination, this provides a means for the attendant to monitor theenvironment outside the confined space to make sure it is not changing. If ventilation is exhausting toxicmaterials outside the space, it could affect the area immediately outside the space, includingthe includingthe attendant, even if the confined space itself is not showing elevated readings. Likewise, if a toxic orcombustible atmosphere develops outside the confined space, it could affect the environment in theconfined space. The sooner the attendant can be made aware of changes, the sooner a decision can bemade whether or not to stop operations and vacate the space.


it is not industry practice to continually monitor outside atmosphere. Also, suppose entry is into a plenum in an office where people are working. Where is the need to monitor outside air???? There are specific cases where this is needed and should be recognized and required ON THE PERMIT...not across the board for all entries

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7.8.1.1

The gas monitor should be programmed to sense to detect a set concentration of specific gases aligned tothe configuration of the gas monitor for calibration purposes. For example, the gas monitor might beprogrammed to read 20.9 percent oxygen (O2), 32 percent methane (LEL), 25 ppm hydrogen sulfide (H2S),

and 50 ppm carbon monoxide (CO) during the calibration process. The gas monitoris then exposed to ablend of the same calibration gases with identical defined concentrations . The gas monitor then “calibrates”what it is programmed to see against what it is being exposed to. This is a span calibration. Through thisprocess, the gas monitor will either pass or fail the span calibration. If the calibration or the gas monitorfails, the unit should be removed from service and tagged for maintenance. If the gas monitor passes, it isready for confined space monitoring.


Suggest replacing sense with detect. Detect is commonly used vs sense which is not.

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7.10.3

The gas tester qualified person should perform the test by applying a known concentration of each of thetarget gases to the gas monitor/sensors individually or in combination and verifying that each sensorresponds in a positive manner and that all gas monitor alarms are activated accordingly. The gas testerqualifed person should refer to the manufacturer’s instructions and recommendations for performing abump test.


Gas tester and gas detector terminology can be very confusing. Both can be confused with the hand-held, portable gas detector. Reading through this section intermingles the physical person with the physical device.

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7.13.1

The atmosphere in and around a confined space should remain safe during entry operations. Atmosphericconditions can change quickly or gradually over time; and without continuous air monitoring, aircontaminants may increase or the oxygen percentage maydecrease or increase, creating dangerousconfined space atmospheric conditions. Entrants, attendants, and other personnel may be unaware ofchanging conditions if the air quality was only initially monitored and determined to be acceptable. Theatmosphere within and outside the confined space should be monitored continuously or periodically asrequired by the applicable confined space program, regulations and/or entry permit and as determined bythe entry supervisor to ensure continued safe working conditions.


There are many instances where continuous monitoring is NOT required. For example, the space may become or has been free of contaminants and monitoring may be only needed to evaluate initial entry and start of work to assure no disturbances occur. It is industry practice to provide for periodic monitoring where acceptable and for continuous monitoring in situations where atmospheric conditions may change for the worse.

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7.13.2

Entry supervisors, gas testers, attendants, and entrants should be aware that there are many reasons whyair quality may deteriorate in and around confined spaces, including,but not limited to, air contaminantsgenerated by activities inside or outside the space, increased temperatures causing additional chemicalvaporization, and existing or new hazards that have not been adequately controlled or mitigated. Wherethe potential exists for such changes, monitoring should be conducted continuously or periodically inaccordance with the requirements of the applicable confined space program, entry permit and regulations.


there is no need for this type of monitoring where that is no potential for contamination. Where the potential exists, then monitoring should be periodic or continuous as required.

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7.13.3

Continuous air monitoring is the best method to ensure or periodic air monitoring, in accordance with theapplicable confined space program, regulations or entry permit, may be required by the entry supervisorto determine that air quality remains acceptable throughout confined space entry operations, includingthose spaces that have been initially tested and declared to be vapor and gas free . .


There are many instances where continuous monitoring is NOT required. For example, the space may become or has been free of contaminants and monitoring may be only needed to evaluate initial entry and start of work to assure no disturbances occur. At other times, the confined space may no longer be a "permit required" space and there is no need for monitoring. It also is industry practice to provide for periodic monitoring where applicable and acceptable.

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7.14 Acceptable Atmospheric Limits for Entry.

Where levels are outside the following parameters, entry is allowed only after control measures asindicated in Chapter 8 are applied:

(1) Oxygen content is between 19.5 percent and 22.0 percent;

(2) Flammable gases and vapors are below 10 percent of the LFL or LEL of the material involved

(3)



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* Potential toxic air contaminants are at or below one half the OEL — typically the action level — asdetermined by the written confined space program.


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Where atmospheric levels are outside the following parameters, entry is allowed only after controlmeasures as indicated in Chapter 8 are applied: supervisors may permit entry as provided for inregulations or the applicable confined space program, by requiring appropriate control measures such asthose indicated in Chapter 8.

(1) Oxygen content is between 19.5 percent and 22.0 percent;


(3)


as written this is very restrictive and is not feasible in many instances. As proposed, this allows for safe variances.

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* Potential toxic air contaminants are at or below one half the OEL — typically the action level —as determined by the written confined space program.

Note: There may be situations where regulations or the applicable confined space program provides forentry under conditions other than those indicated above. An example of this is entry under inert conditions.


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Where levels are outside the following parameters, entry is allowed only after control measures as indicatedin Chapter 8 are applied:

(1) Oxygen content is between 19.5 percent and 22 23 .0 5 percent;


(3)


Note: an acceptable oxygen content up to 23.5% is in use by several organizations, can NFPA provide reference guidance in Appendix A which supports the oxygen ranges indicated as acceptable. Also referenced in sections 8.5.6 & 12.7.1

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* Potential toxic air contaminants are at or below one half the OEL — typically the action level — asdetermined by the written confined space program.


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Gas Monitor Cleaning

Periodic cleaning of the gas monitor will enhance the longevity of the unit. However, some silicone basedgeneral purpose cleaners can poison or destroy the internal gas sensor. For example, LEL sensors moresusceptable to poisioning to general purpose cleaners like Simple Green.) A multi-purpose neutral cleanershould be used to remove dirt, film, grease, nicotine and other inorganic contaminants.


Cleaning the gas detector can severely degrade the performance of the unit if an incompatible cleaner is used. If the gas detector is left turned on in a space that is not a confined space and Simple Green is in use, the LEL sensor will be poisoned. There may be others GP cleaners that affect other sensor types.

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7.16.1

The owner/operator or entry supervisor should ensure that the gas tester has been trained to complete theduties and responsibilities of the role in accordance with Chapter 11.



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7.17 Record Retention.

Owners/operators should maintain records pertaining to gas monitor calibration, bump testing, andmaintenance along with records of personal exposures and results of confined space atmosphericmonitoring for a minimum of 1 year or according to all applicable industry standards and regulations .

Additional Proposed Changes

File Name Description Approved

NFPA_350_7-17_Changes.docx

7.17 Record Retention…along with records of personal exposures and results of atmospheric monitoring for a minimum of 1 year. or according to all industry standards and regulations.Rationale: The term “atmospheric monitoring” includes confined space clearance tests and aligns with the terminology used in section 8 and that should be the consistent term of choice for the purposes of this standard. The term “personal exposures” is a broad term and not specific to confined space operations while the term “atmospheric monitoring” is a more germane term for confined space operations. Some interpret personal exposure records to include confined space entry test and carry a 30-year record retention. This interpretation is a deviation from a classical definition of personal exposure record and is not relevant for the purposes of the NFPA standard. This is an important distinction. The O&G and other industries have differing interpretations and including this term in this NFPA standard complicates the issue. Therefore, we should exclusively establish the record retention at 1 year for NFPA 350. Keeping records beyond that for the sake of confined space entry serves no useful purpose.


7.17 Record RetentionThe term “atmospheric monitoring” includes confined space clearance tests and aligns with the terminology used in section 8 and that should be the consistent term of choice for the purposes of this standard. The term “personal exposures” is a broad term and not specific to confined space operations while the term “atmospheric monitoring” is a more germane term for confined space operations. Some interpret personal exposure records to include confined space entry test and carry a 30-year record retention. This interpretation is a deviation from a classical definition of personal exposure record and is not relevant for the purposes of the NFPA standard. This is an important distinction. The O&G and other industries have differing interpretations and including this term in this NFPA standard complicates the issue. Therefore, we should exclusively establish the record retention at 1 year for NFPA 350. Keeping records beyond that for the sake of confined space entry serves no useful purpose.

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7.17 Record Retention. Owners/operators should maintain records pertaining to gas monitor calibration, bump testing, maintenance and results of confined space atmospheric monitoring for a minimum of 1 year


8.1 Purpose

The purpose of this chapter is to provide best practices for eliminating, mitigating, or controlling hazardsthat either already exist in in or around confined spaces, or are created during entry to into and/orworking in or around confined spaces.


this chapter ALSO covers hazards outside of the space

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The hazard identification and risk assessment process as specified in Chapter 6 requires that hazards beeliminated or , mitigated or controlled to a safe level. This chapter addresses common confined spacehazards. Confined spaces, however, may have unique hazards that are not addressed in this best practiceguide. Nonetheless, the hazards need to be either eliminated or , mitigated or controlled using effectivecontrol methods appropriate and effective methods .


provides for mitigation (se 8.1)

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The hazard identification and risk assessment process as specified in Chapter 6 requires that hazards beeliminated or controlled to a safe level. This chapter addresses common confined space hazards. Confinedspaces, however, may have unique hazards that are not addressed in this best practice guide. Nonetheless,the hazards need to be either eliminated or controlled using effective control methods.One method forcontinuous improvement is nearmiss/good catch reporting, resolution and documentation.


Brian Mckay's paper "Measures of Effects of Near Miss Reporting has been requested and sent to NFPA Standards AdmiinistratorThe concept of near miss applies to NFPA 350 sections 6.5.1., 3.3.5 definitions , and to preplan and permit as well as MOC sections. It is an important part of training and communications and essential to the fabric of NFPA 350

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Submitter Full Name: cait casey

Organization: Aspen Risk Management Group

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Entry supervisors should ensure that atmospheric hazards identified during atmospheric monitoring havebeen eliminated, mitigated, or controlled prior to entry. Methods to remove hazardous atmospheres fromconfined spaces include, but are not limited to, cleaning; displacement or dilution via ventilation, inerting ,( which could create additional hazards, such as low oxygen; ), purging; or removal by other approvedmethods (see 8.4.2to 8.4.3). Prior to entry, a gas tester should perform atmospheric monitoring inaccordance with Chapter 7 to confirm the space is safe to enter.


parens used for clarification that it only applies to inerting

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8.4.1 Acceptable Entry Conditions.

Where levels are outside the following parameters, entry should be allowed only after the following controlmeasures are taken:

(1) Oxygen content between 19.5 percent and 22.0 percent

(2) Flammable gases and vapors below 10 percent of the lower flammable limit (LFL or LEL) of thematerial involved

(3) Potential toxic air contaminants at or below one half the occupational exposure limit (OEL) asdetermined by the written confined space program

Additional Proposed Changes

File Name Description Approved

NFPA_350_8-41_3_Changes.docx

8.4.1 Acceptable Entry Conditions(3) potential toxic air contaminants at or below one half of the Occupational Exposure Limit (OEL).Rationale: The practice within Chevron and elsewhere to manage exposures to the OEL. There are other activities such as medical surveillance that are triggered by one half the OEL (sometimes referred to as an Action Level) that is included in some regulatory standard. Applying that “Action Level” concept to confined space entry is a misapplication. Exposures are sufficiently managed at or below the OEL.


8.4.1 Acceptable Entry Conditions(3) potential toxic air contaminants at or below one half of the Occupational Exposure Limit (OEL).Rationale: The practice within Chevron and elsewhere to manage exposures to the OEL. There are other activities such as medical surveillance that are triggered by one half the OEL (sometimes referred to as an Action Level) that is included in some regulatory standard. Applying that “Action Level” concept to confined space entry is a misapplication. Exposures are sufficiently managed at or below the OEL.

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Submitter Full Name: Todd Wilhite

Organization: Chevron

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8.4.1 Acceptable Entry Conditions (3) potential toxic air contaminants at or below one half of the Occupational Exposure Limit (OEL). Rationale: The practice within Chevron and elsewhere to manage exposures to the OEL. There are other activities such as medical surveillance that are triggered by one half the OEL (sometimes referred to as an Action Level) that is included in some regulatory standard. Applying that “Action Level” concept to confined space entry is a misapplication. Exposures are sufficiently managed at or below the OEL.


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Entry

into inert atmospheres should not be allowed except in limited circumstances. Entrysupervisors should be aware that ventilation will not always eliminate all of the atmospheric hazards withina confined space. If hot work is to be conducted within a confined space that contains flammable orcombustible vapors or liquids, one method to control the ignition hazard is

todisplaceto displace any oxygen in the atmosphere within the space with an inert gas. Inert gas can also be used todisplace oxygen where flammable materials or atmosphere cannot be removed prior to entry.

Entry supervisors should

Owners/operators and contractors/subcontractors should not permit entry into confined spaces with inertatmospheres except in limited circumstances in accordance with the owner/operator or contractor'sconfined space program. Persons engaged in inert entry operations, including entry supervisors, entrants,attendants, rescuers and others should be trained, experienced and qualified in this specific of activity.Entry supervisors should require entrants to use approved air-supplied respirators for entry into inertatmospheres. In addition, where vertical entry into inert spaces is required, the entrant should be equippedwith a full body harness connected to an approved A Frame device securred to the top of the space. Enrtysupervisors should preplan entry and work operations, particularly where inert entry is into amulti-level space or a space with interior obstructions (such as a catalytic reactor or similar vessel).Rescuers should preplan rescue scenarios covering different potential situations, preferably with rescue tobe conducted from outside the space.

Entry into inerted confined spaces in the petroleum and petrochemical industries should be in accordancewith the requirements of API Publication 2217A Guidelines for Work in Inert Confined Spaces in thePetroleum Industry. Entry into other inert spaces should be in accordance with NFPA 326 and otherapplicable standards and regulations.


provides for guidance for entry into petroleum tanks

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8.4.4.2

Entry supervisors should be aware that tanks, vessels, containers, and equipment adjacent to a confinedspace entry and/or a confined space work areaare area are potential sources of flammable, combustible,or toxic vapors, gases, or hazardous materials. If the entry supervisor deems such conditions as potentiallyharmful to the confined space, the hazard should be eliminated, controlled, or mitigated prior to permittingentry and/or any work or hot work in the space or adjacent area.


editorial

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8.4.4.6

Entry into inert atmospheres should not occur except in well-controlled situations where no other option forentry is available. If entry into an inert atmosphere is inert (or othwer oxygen deficient) atmosphere isneeded, a combination full face-piece pressure demand supplied air respirator (SAR) with auxiliaryself-contained breathing apparatus (SCBA) escape mechanism or a full face-piece pressure demand SCBAwith a minimum 30 min.cylinder should be provided to and used by entrants. Entry supervisors, attendantsand entrants should be aware that leakage or exhaust of breathing air into an inert (or flammable)atmosphere may create a hazard by reducing the effectiveness of the inert concentration and by possiblyincreasing the oxygen level ( thus affecting the explosive limits of a flammable atmosphere).

8.4.4.6.1 Where any entry requires supplied breathing air, the owner/operator andcontractor/subcontractor should assure that the respiratory breathing air supplier adheres to practices thateliminate the potential for insufficient oxygen content in an air supply cylinder and the possibility of crosscontamination of the cylinder air with other gases. They should assure that only certified compressorsourced breathing air meeting CGA 7.1 Grade D quality(or equivalent) is used for SAR requiredentries. Air supply clyinders should dedicated to breathing air service and be secured with sealed valves(and racks) and controlled to to prevent cross contaminatiion.

8.4.4.6.2.After cylinders and racks are in place at the job site and prior to each day's (or shift's) use, aqualifed person should test each breathing air cylinder (to be used) to assure the proper oxygen content.

8.4.4.6.3 The entry supervisor should assure that respiratory protective equipment (racks, cylinders, hoses,retrieval gear, helmets and masks) is designed, supplied and used to minimize risk and human error duringentry work and in emergency situations by checking critical respiratory protection components prior topermiting entry.

8.4.4.6.4 Owners/operators and contractors/subcontractors should develop and implement respiratoryprotection programs that include medical evaluation, and training and fit testing should be developed andimplemented before providing entrants with respirators respiratory equipment .


for example, released breathing air into an inert space containing pyrophorics or other flammables can create a fire hazard

there is a whole missing piece in this guide about control of respiratory air and use of respiratory equipment which this proposed change addresses.

A number of fatalities have occurred due to poor respiratory practices.

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8.4.4.7.1 *

Entry supervisors in the maritime industry should conduct inertingin inerting in accordance with NFPA 306, which includes a section on inerting procedures for marine vessels and in accordance with ISGOTT.


EDITORIAL and adds ISGOTT which contains criteria for inerting marine vessels.

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8.4.4.7.1 *

Entry supervisors in the maritime industry should conduct inertingin inerting in accordance with NFPA 306,which includes a section on inerting procedures for marine vessels. A certified Marine Chemist may berequired to oversee the inerting operation if hot work will be conducted.


The maritime industry operates under a different section of OSHA and generally when inerting a space for hot work a NFPA certified Marine Chemist is required under OSHA regulations.

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8.5.5

Where performing hot work above a tank, container equipment, vessel, sewer, pit, pipeline, drainage ditch,or similar areas containing, or having the potential to contain, flammable or combustible materials, entrysupervisors should make sure that precautions are taken to shield the area below from falling sparks andhot materials, such as slag. In addition, precautions should be taken to ensure that vapors from thesespaces cannot reach the hot work area.

Entry supervisors should also give consideration to adjacent spaces above and below the hot work beingconducted. Where welding takes place on an elevated surface, all surfaces below the elevated platform inthe vicinity of the welding are potentially at risk. A wet fire blanket or a welding blanket can be used toprotect sewer openings, open confined space manways, ditches, piping, and so on, containing flammableor combustible liquids or vapors from sparks and slag.


Recommend some comment be made to avoid hot work above a tank, container etc. while entry work is going on and only if it cannot be avoided to take the appropriate measures etc.

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8.5.6

Prior to issuing a hot work permit, entry supervisors should ensure that gas testers conduct atmosphericmonitoring in adjacent open confined spaces within 50 ft (15 m) horizontally of the hot work area to confirmthat there are no adjacent hazards that could impact or be impacted by the hot work. Entry supervisorsshould ensure that hot work is not authorized or performed unless atmospheric testing indicates thatoxygen levels are less than 22 percent by volume, and the LFL LEL (if applicable) is less than 10percent,or where oxygen and flammable levels are permitted to meet other requirements established by theapplicable confined space and hot work programs. In such cases, the entry supervisor should indicate thespecific requirements on the hot work permit and check that appropriate permit precautions are taken.


Suggest use of LEL throughout document

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8.5.6

Prior to issuing a hot work permit, entry supervisors should ensure that gas testers conduct atmosphericmonitoring in adjacent open confined spaces within 50 ft (15 m) horizontally of the hot work area to confirmthat there are no adjacent hazards that could impact or be impacted by the hot work. Entry supervisorsshould ensure that hot work is not authorized or performed unless atmospheric testing indicates thatoxygen levels are less than 22 percent by volume, and the LFL LEL (if applicable) is less than 10percent,or where oxygen and flammable levels are permitted to meet other requirements established by theapplicable confined space and hot work programs. In such cases, the entry supervisor should indicate thespecific requirements on the hot work permit and check that appropriate permit precautions are taken.


Suggest LEL throughout document

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8.5.13.1.4

NFPA 326contains 326 contains minimum procedures that permit repair, hot work, or other operations thatcould potentiallycreate potentially create a fire, an explosion, or other hazard wherever hot work isperformed on tanks or containers containing flammable, combustible, or other hazardous vapors, liquids, orsolid residues. The American Welding Society also has information regarding hot work operations.


Corrected typos.

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8.5.13.3 Shipyard/Maritime.

In shipyard/maritime settings,29 CFR 1915.11 to 1915.16 and 1915.51 to 1915.57, and NFPA 306contain306 contain information on hot work performed in the maritime industry. In addition, the latest edition of theInternational Safety Guide for Oil Tankers and Terminals (ISGOTT) provides considerable guidance forconfined space and hot work activity in oil tankers and terminals.


Corrected Typo

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8.5.13.4.2 API Recommended Practice 2009, Safe Welding and Cutting and Hot Work Practices inthe Petroleum and Petrochemical Industries.

This document provides guidelines for safely conducting welding, cutting, or other hot work activities inrefineries, gas plants, petrochemical plants, and other facilities in the petroleum and petrochemicalindustries. It provides specific guidance on evaluating procedures for certain types of work on equipment inservice. It does not coverregulation cover regulation or code compliance; hot tapping; welding techniques;normal, “safe work” practices; or entry into or work in inert environments.


Corrected typo

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8.5.13.4.4 API Recommended Practice 2016, Guidelines and Procedures for Entering and CleaningPetroleum Storage Tanks.

This recommendedpractice recommended practice supplements the requirements of ANSI/API 2015,Requirements for Safe Entry and Cleaning of Petroleum Storage Tanks.API 2016 provides guidance andinformation on the specific aspects of tank cleaning to assist inconducting safe tank cleaning operations inaccordance with the requirements of ANSI/API 2015.


Corrected typo

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All sources of energy — mechanical, electrical, hydraulic, chemical, or stored energy — in confined spacesthat could impact worker safety should be eliminated be eliminated or controlled using the appropriateisolation or lockout/tagout procedures in accordance with the owner/operator or contractor/subcontractorisolation program prior to issuance of an entry permit. 29 CFR 1910.147 covers the prevention of accidentalstartup of equipment and machinery or release of stored energy. 29 CFR 1910.333 contains specificrequirements for de-energizing and locking out electrical equipment. OSHA electrical safe work practicesrequirements were derived from NFPA 70E, whichprovides comprehensive electrical safety information toprevent shock, arc, and other electrical safety hazards.


lockout etc, does not eliminate the source it only controls it.

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8.6.3

Pipes and lines containing materials that could enter into the confined space should be disconnected and/ drained, or blanked, bled double blocked and bled , flushed, purged, or otherwise isolated prior to entry bythe isolation specialist.


need to drain portions of disconnected lines leading into space. Lines should be double blocked and the portion between the blocks should be bled (or drained)

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8.6.4

Pipes and lines that run through a confined space that will be worked on from inside the space need to bedisconnected and drained, and /or double blocked and blanked, bled, flushed, purged, or isolated asneeded by an isolation specialist beforework begins.


see 8.4.3 Need to double block and bleed in between blocks. also drain line within the space.

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8.6.4

Pipes and lines that run through a confined space that will be worked on from inside the space need to bedisconnected and/or blanked, bled, flushed, purged, or isolated as needed by an isolation specialistbeforework before work begins.


Corrected typo

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8.6.5

Pipes and lines that run through but do not terminate within a confined space do not need to bedisconnected or isolated as indicated in 8.6.3provided that the entry supervisordetermines supervisordetermines that the materials in these lines are not impacted by the work being done in the space anddoand do not create a hazard to workers in the space.


editorial

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8.6.6 *

Where it is necessary for equipment equipment to continue to operate (not be isolated) in order to performwork within the space, the entry supervisor should ensure that the work is performed using approvedalternative methods or that control measures provide effective protection for workers in the space.


for clarification

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Bonding is the joining of objects to form an electrically conductive path that ensures electrical continuity andthe capacity to safely conduct any current likely to be generated. Entry supervisors, attendants, entrants,and all workers in and adjacent to confined spaces should be aware that equipment, accessories, andappurtenances used in confined space entry, ventilation,cleaning, and other operations,may be capable ofgenerating an electrostatic charge. Entry supervisors should ensure that such objects are electricallybonded to the confined space to avoid generating static electric sparks.


Bonding should be defined in the definition section. It should not be introduced here, this makes the document to wordy.

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Entry supervisors should be aware that flammable or combustible liquids, vapors, and gases or combustibledusts and fibers may be released both in and around a confined space during working, ventilation, inerting,or gas freeing, or whereworking removing when removing , agitating, or cleaning residue inside the space.All confined space personnel should be aware that in addition to hot work (see Section 8.4), ignitionsources that should be eliminated or , mitigated or controlled include, but are not limited to, the following:

(1) Internal combustion engines located within an unsafe area, such as less than 50 ft downwind from,near, or adjacent to the space

(2) Non-explosion-proof electrical equipment and electrical equipment not rated for the location orproposed operation

(3) Non-bonded/non-grounded electrostatic generating equipment, such as welding machines, fans andeductors, vacuum trucks, portable generators, pumps, etc.

(4) Nonapproved lighting equipment

(5) Smoking or open flames

(6) Blast cleaning equipment and blasting operations

(7) Grinding and cutting equipment and operations

(8) Unprotected pyrophoric iron sulfide deposits within the space

(9) Nonapproved heating equipment, such as space heaters, hot plates, etc.

(10) Vacuum trucks and vacuum operations

(11) Nonapproved communication devices, including cell phones, two-way radios, and pagers


for clarity, added "mitigated" for consistency

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Fall protection should be maintained for all those working in and around confined spaces where falls greaterthan 4 ft (1.2 m) could occur. Confined space fall hazards should be managed using the following fallprotection hierarchy:

(1) Elimination. Removal of the hazard by covering all vertical entry points until entry is required

(2) Protection. Use of OSHA- approved guardrail systems to provide a controlled access zone around allvertical entry points

(3) Restriction. Use of positioning or restraint devices to eliminate the possibility of a fall for all personneloutside of the immediate vertical entry point

(4) Fall arrest. Use of OSHA- approved fall arrest/belay devices to limit the maximum arresting forces tobelow 1800 lb for a fall greater than 4 ft above the lower level of the vertical entry point for allpersonnel exposed to a fall hazard during confined space operations


no need to mention OSHA. OSHA not applicable to those not covered by OSHA

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Falls into confined spaces can occur whereenteringor working where entering, working inside of or workingoutside a confined space. Floor and wall openings that leadinto lead into or mey be within confined spacesshould be protected to prevent falls from occurring. There are a number of ways to do this as listed in8.10.1.1 through 8.10.1.3.


falls may also occur inside spaces

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Falls into confined spaces can occur whereenteringor when entering or working outside a confined space.Floor and wall openings that leadinto lead into confined spaces should be protected to prevent falls fromoccurring. There are a number of ways to do this as listed in 8.10.1.1 through 8.10.1.3.


Typo correction.

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8.10.2.1

Where utilizing fixed ladders, entrants should maintain three points of contact should be maintained atcontact at all times. Where the ladder extends Ladders extending beyond 20 ft it should ft should beequipped with a ladder climbing system or a secondary form of protection, such as a self retracting deviceor a belay line attached to a suitable anchor point able to withstand 5000 lb (2268 kg) of force orengineered with a 2:1 safety factor.


specifies who uses the ladders

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8.10.2.3

Whereworkersneed Where entrants need to be lowered vertically into the confined space, a secondaryform of protection should be used, such as a self-retracting device or a belay line attached to a suitableanchor point able to withstand 5000 lb (2268 kg) of force or engineered with a 2:1 safety factor.


only entrants enter spaces. also editorial change

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8.10.2.3

Whereworkersneed Where workers need to be lowered vertically into the a confined space, a secondaryform of protection should be used, such as a self-retracting device or a belay line attached to a suitableanchor point able to withstand 5000 lb (2268 kg) of force or engineered with a 2:1 safety factor.


Typo correction

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Entry supervisors should ensure that approved in-space lighting used in accordance with Section 8.5provides enough illumination so that all surfaces and obstructions are clearly visible to those working in thespace. Portable lighting should be approved for the location in which it is used in accordance withentrants the applicable confined space program and permit requirements .


as proposed, sentence makes no sense. Lighting should be in accord with applicable programs, permits, etc not in accord with entrant

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8.11.5

Wherever surfaces remain slippery or wet, entry supervisors can useportable should consider the use ofnon-combustible portable floor mats or duck boards to raise the entry base above the level of the liquidsurface inside the confined space.


the use of combustible materials inside the space should be limited

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8.12 Lighting.

Entry supervisors can use approved, safe lighting in accordance with the applicable confined spaceprogram. The lighting selection should consider any hazards presented by the presence of flammable orcombustible liquids, vapors, or gases in accordance with 8.7. Additional lighting options include, but are notlimited to, approved helmet lights, approved low-voltage portable lighting, and so on approved flashlights,and other approved lighting sources .

Entry supervisors and workers should also be aware that cyalume lights (i.e., glow sticks) can be used asbackup lighting should the primary lighting fail and can also be used to mark a means of ingress and egressin poorly lit or extended confined spaces.


added "approved" took away "and so on" which is meaningless

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8.13 Animals and Insects.

Entry supervisors and all other confined space personnel should recognize that confined spaces are idealhideouts for animals and insects. The confined space should be visually inspected by the entry supervisorprior to entry, and any potentially dangerous animals or insects should be safely removed or otherwiseeliminated. The owner/operator or contractor/subcontractor can arrange for traps to be lowered into thespace for insects or animals such as skunks or raccoons; however, if available, a pest control company orlocal animal control agency should be the first consideration. If be removed or eliminated. If anextermination chemical is used, it might be necessary to have the environment in and around the spacereassessed prior to permitting entry. The gas tester should include the pesticide hazard when retesting. Theentry supervisor should determine if the space needs to be ventilated and if respiratory protection and/orprotective clothing and gloves should be worn by the gas testers and workers to prevent skin exposure tothe chemicals.


To much detail, suggest shortened version.

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8.14.1

Entry supervisors should make sure that all confined space workers wear approved PPE including, but notlimited to, eye protection, head protection, foot protection, hand protection, protective clothing, respiratoryprotection and hearing protection as required by the entry or hot work permit. Workers should be aware thatinjuries can be prevented or mitigated by the use of PPE (see Section 6.7). Additional PPE the entrysupervisor might consider includes, but is not limited to, knee and elbow pads, forcrawlspaces forcrawlspaces and cooling vests for hot environments.


sometimes PPE does not fully protect. also editorial change

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8.14.3.1

Owners/operators and contractors/subcontractors should consider the general PPE requirements including,but not limited to, hazard assessments, maintenance, and training provided in 29 CFR 1910.132applicable regulations and standards when developing PPE programs. Although the OSHA standardscover The OSHA standard 29 CFR 1910.132, which covers general industry in the U.S. only , theyprovide information provides information which may be used by contractors and non-coveredorganizations for developing theie own PPE programs elsewhere .


removes specific reference to OSHA as not all users are covered by OSHA. Adds additional information to help those not covered.

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9.1.1

Ventilation Confined space ventilation is used for two reasons: to remove or control atmosphericcontaminants and to control temperature for comfort. However, in most confined space applications,controlling atmospheric contaminants is the primary purposeof purpose of ventilation. Ventilation iscommonly used to establish initial safe conditions (prior to initial entry initial and subsequent entries ) andmight be necessary is also used to maintain safe conditions during entry where there are is a potential forchanging atmospheric conditions within a space (e.g., presence of residues or during hot work). . Causesof changes in internal atmospheres include, but are not limited to, presence or disturbance of residues,vapors or fumes during hot work activity, outside influences, and use of chemicals inside the space forcleaning.


corrects editorial error. provides information for other causes of atmosphere changes, Adds use of ventilation for working inside space

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9.1.3 *

Where considering ventilation, the entry supervisor and ventilation specialist shouldunderstand shouldunderstand the differences between ventilation and purging. These terms are often used interchangeably,but actually apply to different atmospheric hazard control situations. Ventilation generally introducesprovides for fresh, uncontaminated air to enter into a space and controls contaminants in that spacethrough mixing through mixing and dilution. Purging uses is the use of air, steam, or an inert gas todisplace air the atmosphere within the space. (See 9.3.)


changed for clarification. correct error

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Mechanical ventilation uses one is the use of one or more air-moving devices (e.g., fan, blower, eductor)are used to either push fresh air into into the confined space or pull air from out of the confined spaceand circulate it to introduce fresh air and space , (thus creating a slight vacuum allowing fresh air to enterinto the space from other portals) and remove contaminants or mix and dilute air within a space. There aretwo types of mechanical ventilation: general (or dilution) and local exhaust. . Local exhaust may also beused within the space to mix and circulate the introduced air.


this is changed to more specifically explain the process

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Mechanical ventilation uses one or more powered air-moving devices (e.g., fan, blower, eductor) are usedto either push air into or pull air from the confined space and circulate it to introduce fresh air and removecontaminants or mix and dilute air within a space. There are two types of mechanical ventilation: general (ordilution) and local exhaust.


Suggest adding the word powered, this will make it clear that natural ventilation cannot be considered as mechanical ventilation.

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Public Comment No. 29-NFPA 350-2014 [ Section No. 9.2.2.1 [Excluding any

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General ventilation can be achieved via the introduction of an uncontaminated supply air or by exhaustingcontaminated air from within the confined space using a powered ventilator , or a combination of bothtechniques.


Using the word powered eliminates using natural ventilation as a method.

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Public Comment No. 30-NFPA 350-2014 [ Section No. 9.2.2.1.1 [Excluding any

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Supply ventilation uses one or more air powered air -moving devices oriented so that outsideuncontaminated air is pushed into the confined space. Depending upon the size and configuration of thespace and capacity of the air-moving devices, ducting might be necessary to direct the supply air a greaterdistance into the space to reach areas where entrants will work.


This makes it clear that the ventilator is powered and not natural ventilation

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9.2.3 Comfort Ventilation.

The entry supervisor should perform a hazard evaluation and risk assessment to determineif determine ifheat or cold stress conditions exist and provide heated for heated or cooled ventilation as necessarytoavoid the effects of prolonged exposure to extreme temperature conditions.


editorial

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9.3.1.1

The entry supervisor should consider the following as part of the evaluation for identifying and selecting anappropriate ventilation method for controlling a hazardous atmosphere within a confined space:

(1) Whether to use purging, inerting, or ventilation

(2) The size and configuration of the confined space, including the number and location of openings thatcan be used for ventilation and entrant ingress and egress.

(3) The capacity requirements forselected for selected ventilation equipment

(4) If the confined space was used to store or containone contain one or more hazardous materials

(5) The current use of the confined space , which might contribute to the existence of hazards within thespace

(6) Whether work processes in or adjacent to the space could introduce atmospheric hazards into theconfined space

(7) The type of ventilation equipment available


editorial

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9.3.1.2 *

Based upon the volume of the confined space, the capacity of the air-moving device(s), and the nature ofthe hazardous atmosphere within the space (see 9.3.2), the ventilation specialist should determine the timeneeded for a single air change and the required number the number of air changes required to ensure astable atmosphere within the confined space. The number of required air changes should be based uponthe ventilation equipment manufacturer’s specifications and in accordance with the confined spaceprogram and any applicable regulatory requirements or consensus standards.


adds confined space program which may have company specific requirements.

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9.3.1.2 *

Based upon the volume of the confined space,the capacity of the air-moving device(s), and the nature ofthe hazardous atmosphere within the space (see 9.3.2), the ventilation specialist should determine the timefor a single air change and the required number of air changes to ensure a stable atmosphere within theconfined space. The number of required air changes should be based upon the ventilation equipmentmanufacturer’s specifications and in accordance with any applicable regulatory requirements or consensusstandards.


This section does not provide valuable direction. Also, many land storage tanks may be to big and have limited openings for ventilation and a minimum number of air changes cannot be obtained. Many places throughout this document you make suggestions for specifications and limits, if you keep this section a minimum number of air changes should be suggested.

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9.3.1.2 *

Based upon the volume of the confined space,the capacity of the air-moving device(s), and the nature ofthe hazardous atmosphere within the space (see 9.3.2), the ventilation specialist should determine the timefor a single air change and the required number of air changes to ensure a stable atmosphere within theconfined space. The number of required air changes The volume of air required should be based upon theventilation equipment manufacturer’s specifications and in accordance with any applicable regulatoryrequirements or consensus standards.


Amend the text as shown

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9.3.2 Contaminant Characterization.

Where selecting and designing a ventilation system, the ventilation specialist should consider the physicaland chemical properties of gases, vapors, dusts, and all other contaminantsthat contaminants that mightbe present in a confined space. Considerations should include, but not necessarily be limited to, thefollowing:

(1) Characteristics of air, vapor, gas, and dust movement within the space

(2) Vapor density forgases Density for gases and vapors

(3) Specific gravity of liquids or residues

(4) Vapor pressure and emission rate

(5) Effect(s) of space temperature on air contaminants

(6) Flammability characteristics, such asflammable as flammable range for gases and vapors or MECfor dusts

(7) Flash points

(8) Boiling points

(9) Recommended exposure limits, such asPEL as PEL , TLV, or equivalent

(10) Stability characteristics of contaminants


"vapor" density does not apply to gases. Also numerous editorial

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9.3.3.1.2

The ventilation specialist should ensure that supply ventilation is only used when a clean source of makeupor return air is available. If compressed air is used in the ventilation system as a power source (e.g., in apneumatic system) or as a source of supply air, it must meet the requirements for Grade D air.


The specification or standard body for Grade D air should be provided, is it from a CGA standard or other standard? The user should be able to locate it to determine the parameters of Grade D air

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9.3.3.2.3

The ventilation specialist should ensure that exhaust ventilation is evaluated so that the air-movingdevice(s) are located to capture contaminants or safely vent as described in 8 .4.2.2


Add text as noted

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9.3.4 * Purging Applications and Design.

The purging medium should be determined by the ventilation specialist based on contaminantcharacteristics, configuration of the confined space, and the entry or work objective.

9.3.4.1 *

Where purging is required to safely enter a storage tank or other confined space that previously containeda flammable liquid,it is important to reduce the potential for fire or explosion.The ventilation specialistshould purge the confined space with an inert gas to reduce the oxygen level within the confined space.

CAUTION

Inert gas purging can create an immediately dangerous to life and health (IDLH) condition within theconfined space and appropriate respiratory protection for entrants might be required for safe entry.

9.3.4.1.1

Where an inert gas purge is used to displace flammable vapors that exceed or are within the flammablerange, the inert gas should be introduced by the ventilation specialist into the space and maintained untilthe flammable vapor concentration has been reduced to approximately 1 percent by volume,which is theLFL LEL for typical petroleum products.

9.3.4.1.2

Once the flammable vapor concentration has been lowered to 1 percent by volume, the ventilationspecialist can then resume purging with fresh air to displace the remaining flammable vapors and toincrease the oxygen content to ambient fresh-air levels.

9.3.4.1.3 *

While monitoring atmospheric conditions during the inerting process, the gas tester should be aware thatthe flammable vapor concentrations in the inerted atmosphere cannot be detectedby catalytic bead–typesensors and the testing equipment manufacturer should be consulted to determine any necessary steps tocollect accurate measurements.

9.3.4.2

The ventilation specialist should purge the confined space with fresh air to displace toxic contaminants oroxygen deficient air and return the confined space atmosphere to acceptable air levels as specified on theentry permit.

9.3.4.3

The ventilation specialist should purge the confined space with an inert gas wherever hot work will beperformed on or adjacent to a confined space that has not been thoroughly cleaned and freed of flammablegases, vapors, and residues in accordance with the safe work practices specified in NFPA 51B.

9.3.4.4

The entry supervisor should alert all workers performing work near confined spaces that have been inertedthatthe that the inert gas might displace the oxygen in localized areas near the space and create unsafelevels of oxygen.


Changed LFL to LEL to be consistent. Also, corrected typo.

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9.3.4 * Purging Applications and Design.

The purging medium should be determined by the ventilation specialist based on contaminantcharacteristics, configuration of the confined space, and the entry or work objective.

9.3.4.1 *

Where purging is required to safely enter a storage tank or other confined space that previously containeda flammable liquid,it is important to reduce the potential for fire or explosion.The ventilation specialistshould purge the confined space with an inert gas to reduce the oxygen level within the confined space.

CAUTION


9.3.4.1.1

Where an inert gas purge is used to displace flammable vapors that exceed or are within the flammablerange, the inert gas should be introduced by the ventilation specialist into the space and maintained untilthe flammable vapor concentration has been reduced to approximately 1 percent by volume,which is theLFL for typical petroleum products.

9.3.4.1.2


9.3.4.1.3 *


9.3.4.2

The ventilation specialist should purge the confined space with fresh air to displace toxic contaminants oroxygen deficient air and return the confined space atmosphere to acceptable air levels as specified on theentry permit.

9.3.4.3

The ventilation specialist should purge the confined space with an inert gas wherever hot work will beperformed on or adjacent to a confined space that has not been thoroughly cleaned and freed of flammablegases, vapors, and residues in accordance with the safe work practices specified in NFPA 51B.

9.3.4.4

The entry supervisor should alert all workers performing work near confined spaces that have been inertedthatthe inert gas might displace the oxygen in localized areas near the space and create unsafe levels ofoxygen.


I believe that this should not be in Chapter 9 and purging should be its own chapter due to the many issues involved in purging a space

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Public Comment No. 226-NFPA 350-2014 [ Section No. 9.3.4.1 [Excluding any

Sub-Sections] ]

Where purging is required to safely enter a storage tank or other confined space that previously contained aflammable liquid,it is important to reduce the potential for fire or explosion.The ventilation specialist shouldpurge the confined space with an inert gas to reduce the oxygen level within the confined space. The entrysupervisor should assure that a means of securing the inert gas valve is provided in order to preventtampering with the gas flow.

CAUTION



the rste of flow could be changed accidentally or purposely thereby creating a hazardous atmosphere in the inerted space.

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9.3.4.1.1

Where an inert gas purge is used to displace flammable vapors that exceed or are within the flammablerange, the inert gas should be introduced by the ventilation specialist into the space and maintained untilthe flammable vapor concentration has been reduced to approximately 1 percent by volume,which is 20%of the LFL for typical petroleum products value, for the specific contents .


Modify text as shown

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9.3.4.1.2

Once the flammable vapor concentration has been lowered to 1 percent by volume, the ventilationspecialist can then resume purging with fresh air to displace then introduce fresh air in order to displacethe remaining flammable vapors and to increase the oxygen content within the space to ambient fresh-airlevels.


for clarity Fresh air is NOT used for purging (as this would indicate) - see definitions

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9.3.4.1.2



Modify text as shown.

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9.3.4.1.3 *

While monitoring atmospheric conditions during the inerting process, the gas tester should be aware thatthe flammable vapor concentrations in the inerted atmosphere cannot be detectedby detected by catalyticbead–type sensors and the testing equipment manufacturer should be consulted to determine anynecessary steps to collect accurate measurements.


editorial

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9.3.4.1.3 *



Suggest moving to either a purging section under its own chapter or to the meter section. It would be a better fit there.

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9.3.4.2

The ventilation specialist should purge the confined space with should provide for fresh air to beintroduced into the confined space to displace toxic contaminants or oxygen deficient air and return theconfined space atmosphere to acceptable air atmospheric levels as specified on the entry permit.


ventilation is NOT purging -- see previous comments and definitions in this chapter

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9.3.4.3

The ventilation specialist should purge the confined space with an inert gas wherever hot work will beperformed on or adjacent to a confined space that has not been thoroughly cleaned and freed of flammablegases, gase, tanks or vessels in flammable or combustible services, vapors, and residues in accordancewith the safe work practices specified in NFPA 51B. Where hot work is to be performed on or adjacent tolines, appurtenances, tanks or vessels in flammable or combustible liquid service, the pocedures for hottapping and welding provided in applicable API Recommended Practices should be followed.


API guides provide for safe hot work to be performed without the need to purge and inert equipment.

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9.3.4.4

The entry supervisor should alert all workers performing work near confined spaces that have been inertedthatthe that exhausted inert gas might displace might displace the oxygen in localized areas near thespace and create unsafe levels of oxygen in areas where workers may be present .

9.3.4.4.1

Because inert gas typically is lighter than hydrocarbon gases, the hydrocarbon gas and vapors will exitfrom the lower portion of the space when inert gas is introducted at an upper level. The ventilationspecialist should be aware that an amount of inert gas equal to several volumes of the space to be inertedis required to replace the atmosphere in the space. The incoming inert gas should have sufficient energyvelocity to disperse and penetrate to all areas within the space. It is important to take gas and oxygenmeasurements at various times, levels and areas within the space the check the efficiency andcontinuance of inerting operations.

9.3.4.4.2

Entry supervisors, ventilation specialists and attendants should be aware that a mixture of inert gas andhydrocarbon gas or vapors can become flammable when vented and mixed with air and assure thatappropriate measures are in place to eliminate or cottrol any sources of ignition in the discharge area.

9.3.4.4.3

In the event that the inert gas system fails to deliver the required amount of inert gas or fails to maintainpositive inert pressure in the space, the entry supervisor, ventilation specialist and attendant should takeimmediate action to vacate the space and repair the inert gas system before reentry is permitted. entrysupervisors should be aware that regulations may require the failure of an inert system to be repored thethe authority having jurisdiction.

9.3.4.4.4

Where the confined space contains pyrophoric iron sulphide deposits, such as may be found in crude oiltanks and process vessels in the petroleum, petrochemical and marine industries, m owners/operators andcontractors should immediately repair and restart the inert gas system in order to prevent an ignition withinthe space. In the event that it is impossible or impractical to resume ineerting operations, alternate meansof protection should be considered and provided for in the preplanning stage of operations. .


there is a need to include a minimum of information regarding safe inerting practices.

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9.3.4.4

The entry supervisor should alert all workers performing work near confined spaces that have been inertedthatthe inert gas might displace the oxygen in localized areas near the space and create unsafe levels ofoxygen isolate an area where the inert gas may collect and prevent workers from entering the area until thepurging operation is complete .


Notifying workers that they may enter a low oxygen environment is not a good practice. The area should be roped off/isolated until the operation is over and it is deemed safe to re-enter.

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Sub-Sections] ]

This includes fan (blower) systems and venturi-type devices that exhaust only (e.g., eductors) and fan orblower systems .


rearranged for clarity ( and fans used most so should come first)

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9.4.2.2

It is recommended that the ventilation specialist use flexible ducting that includes a means tobond orground to bond the duct materialand material and the air-moving device device to the space to controlthe generation of static electricity and dissipate ground the system to dissipate any accumulated staticelectric charge.


duct work is connected to the fan creating a bond. the fan should be bonded to the space to prevent sparks. The system should be grounded to dissipate any built up change

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9.4.3 * Thermal Oxidizers.

Where ventilating tanks and , vessels and other confined spaces with flammable atmospheres, localenvironmental regulations often restrict emissions. The entry supervisor or ventilation specialist shoulddetermine if a gas-freeing or vapor-freeing tank is necessary to safely use exhaust ventilation with thedischarge the exhaust ventilation discharge needs to be connected to a thermal oxidizer unit or vaporrecovery system, and if so, provide for the necessary equipment .


rewritten to make more sense (clarity)

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9.4.4 * Bonding/Grounding.

Static electricity is created wherever surfaces are separated, through movement, such as air movingthrough wherever air moves through a fan, blower, or ducting. Where When ventilation is used onto dilute or remove flammable gas or vapor concentrations, the ventilation specialist should control allignition sources. Regulations and best practices require that all air-moving devices be properly bonded orgrounded to the space and grounded to ensure the dissipation of any accumulated static charge within theventilation system. This includes ducting and attachments appurtenances attached to the air-movingdevice.


changes fopr correctness. One must first BOND separate objects (fan to tank) to provide for same equal charge and then must GROUND to dissipate the charge.

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9.5.3 *

The entry supervisor and ventilation specialist should evaluate the confined space for stratifiedatmospheres (see Chapter 7) and ensure that ventilation ductwork is positioned to remove ordisplacecontaminants displace contaminants .


editorial

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9.5.4

The entry supervisor and ventilation specialist should identify and implement any necessary precautions tocontrol or remove all ignition sources from the area where there is a potential for the presenceof flammable gases and vapors within the flammable range inside the confined space,at the point ofventilation discharge or in areas adjacent to the space.


This section should be combined with 9.5.6

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9.5.5

The ventilation specialist should ensure that all air-moving devices and related equipment are bonded andgrounded.


This is covered in 9.4.4 and suggest eliminating it here.

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9.5.6

Where flammable gases or vapors are exhausted from within a confined space, the ventilation specialistshould ensure that the discharge point from all exhaust ventilation processes (i.e., those not connected toscrubbing systems or other contaminant control systems) are located a minimum of 3.7 m (12 ft) abovegrade. The selection of the exhaust discharge point should ensure that exhausted contaminants aredirected away from areas that might contain sources of ignition and areas where personnel might beworking and directed to a location that will reduce the likelihood of re-entrainment. Alternately, if dischargecannot be controlled, then the entry supervisor should assure that all souces of ignition and personnel aresituated a safe distance from the area of potential contamination.


provides a alternative if discharge cannot be controlled

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9.5.6

Where flammable gases or vapors are exhausted from within a confined space, the ventilation specialistshould ensure that the discharge point from all exhaust ventilation processes (i.e., those not connected toscrubbing systems or other contaminant control systems)are located a minimum of 3.7 m (12 ft) abovegrade. The selection of the exhaust discharge point should ensure that exhausted contaminants aredirected away from areas that might contain sources of ignition and areas where personnel might beworking and directed to a location that will reduce the likelihood of re-entrainment.


What is the source or citation of the 3.7 meter above grade specification? It may be helpful to explain why and how this minimum distance was chosen. (such as in Appendix A)

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9.5.7.1

Where the ventilation specialist uses the method described in 9.5.7(2 1 ), the following conditions apply:

(1) The connection between the eductor and the confined space should be airtight.

(2) Air should be drawn through the confined space to allow cross ventilation and removal of vapors.

(3) All equipment should be bonded and grounded.


The reference to (.5.7.1(2) is incorrect based upon the details provided in this sub section.

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9.5.7.2

Where the ventilation specialist uses the method described in 9.5.7(2) , the following conditions apply:

(1) If a fill opening that extends into the confined space is used as an air supply point, the portion of thefill pipe that extends into the space should be removed. If entry is required to remove the fill pipe froma space with a flammable atmosphere, then the space might require inerting prior to entry.

(2) The air should be supplied from an approved compressor or blower that has been checked fordelivery of Grade D air that is free of contaminants.

(3) The air-diffusing pipe, if used, should be bonded to the confined space to control the accumulationand discharge of static electricity.


This should be combined with 9.5.7.1 as they apply to the same section.

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9.5.8.2*

Based upon the results of a hazard evaluation and risk assessment, the ventilation specialist shoulddetermine an appropriate method to condition or warm the air within the confined space as appropriate forthe environment and work.


Consider a statement or wording to evaluate the exhaust of any heating device that may produce an atmospheric hazard such as CO from a salamander type heater.

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9.5.9 * Purging.

The ventilation specialist should determine if purging can be safely implemented based upon the results ofa hazard evaluation and risk assessment.


This should be in a purging section.

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9.5.10 Atmospheric Monitoring.

9.5.10.1

The gas tester should conduct atmospheric testing in accordance with Chapter 7 and as directed by theentry supervisor.

9.5.10.2

If the hazard evaluation and risk assessment indicates that atmospheric conditions within the confinedspace can change adversely or without warning, the entry supervisor and ventilation specialist shouldensure continuous forced mechanical ventilation and continuous air monitoring is maintained during allentry and work.

9.5.10.3 *

If the hazard evaluation and risk assessment indicate that atmospheric conditions will not be maintainedwithin acceptable levels at all times during entry and work, the ventilation specialist should use flowmonitoring, alarms, secondary power systems, and similar backup systems to ensure the safety of entrantsand the integrity of the ventilation system and fresh air supply.

9.5.10.4

Where ventilation cannot or does not completely eliminate a recognized atmospheric hazard, otherprotective measures or methods for controlling air contaminants and protecting entrants should bedetermined by the entry supervisor prior to entry authorization.


This should be in Chapter 7 and not covered in this section.

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10.1.1 General.

Recognition and prevention of existing and potential hazards associated with confined space entry andoperations may be the best method to avoid the need for rescue. Conducting a proper hazard evaluationand eliminating, mitigating, or controlling all hazards should reduce or eliminate the chance of harm toentrants, thereby also reducing the need for potential rescue. Owners/operators and contractors shouldtrain or educate entrants to understand and protect themselves from potential hazards, including the properselection and proficient use of personal protective equipment (PPE). Entrants should be trained that whenthey recognize a threat they should immediately exit the space on their own power, which is better thanwaiting until they are incapacitated and require rescue. There are two types of rescue options: non-entryrescue, in which ill or injured entrants are removed without the rescuers entering the space, and entryrescue, in which rescuers enter the space to properly remove ill or injured entrants. The informationprovided in this guide should be applied by all owners/operators and contractirs who are responsible for theselection or provision of a response capability for rescue emergencies within confined spaces and who areassociated with confined space operations. The elements associated with rescue program requirementsshould be identified in the hazard evaluation and risk assessment conducted by the owner/operator andcontractor .


contractors are often responsible to provide for rescue resources

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Public Comment No. 46-NFPA 350-2014 [ Section No. 10.1.2.2.3.1 [Excluding any

Sub-Sections] ]

In entries where portable anchor devices and manufactured systems are employed with only one entrant,retrieval system configurations can be very simple. Where the need for multiple entrants occurs or specificstructural restrictions in and around the space exist, configuring the systems canbe can be complicated.


Corrected a typo. Also, I am not sure that this section adds anything to the document, consider eliminating it. It does not really tell you anything except that it may be difficult.

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10.1.2.4

Owner/operators and contractors should implement procedures for the following attendant operations:

(1) Recognizing the need for confined space search and rescue

(2) Initiating contact and establishing communications with victims where possible

(3)

(4) Advising the responding rescuers of the situation and potential hazards

(5) Recognizing confined spaces

(6)

(7)


contractor's attendants are often employes

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* Recognizing and identifying the hazards associated with non-entry confined space emergencies

* Identifying the need for and performing a non-entry retrieval, based on the conditions present

* Implementing the emergency response system for confined space emergencies


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10.1.3.4 Rescue Response Modes.

The degree and rapidity of response should be driven principally by the anticipated hazards. Those spacesthat contain known hazards should receive greater scrutiny and perhaps more rapid or complex responsebased on the hazards. Consideration should also include those spaces where technical rescue may berequired to move an ill or injured entrant to a stable environment once extracted from the space. Rescuecapabilities should be evaluated to ensure they are appropriate to the response. Many emergencyresponse agencies do not have the training or equipment to respond to confined space emergencies.Simply summoning them to react to these specialized emergencies without ascertaining that they arecapable is unacceptable. It is important that the qualifications of the rescue service be assessed andverified in advance of an emergency in accordance with the recommendations provided in Section 10.2.Consideration should be given to three basic modes of rescue response:

(1) Tier 1 — Those that have no recognized hazards but could require technical rescue for extractionshould a worker become incapacitated

(2) Tier 2 — Those with non-life-threatening hazards requiring rapid intervention

(3) Tier 3 — Those with life-threatening hazards requiring immediate intervention

10.1.3.4.1* Tier 1 Response Mode.

A Tier 1 response mode may be indicated if a hazard evaluation has been performed (in accordance withChapter 6), and although the space contains no potential for hazards, its configuration would prohibitentrants from being easily removed if they were to become incapacitated, either due to medical illness orinjury. At the minimum, this should be applicable to any vertically oriented space greater than 4 ft (1.2 m) inheight, whether or not retrieval equipment is in place. A Tier 1 capability suggests that a fully trained rescueteam meeting NFPA 1670, Chapter 7, technician level, is available to respond within 5 minutes to the siteand is capable of setup and rescue entry within 12–15 minutes of arrival on site. in a timely mannercommensurate with the level of risk.


A Tier 2 response mode is indicated if a space contains no IDLH or other potentially immediatelife-threatening hazards but does contain other actual or potential hazard that could incapacitate entrants orprevent them from exiting the space without assistance (self-rescue evacuation ). A Tier 2 capabilitysuggests that a fully trained rescue team meeting NFPA 1670, Chapter 7, technician level, is on site withappropriate capability to make safe entry for rescue. The team should be equipped and mobile, capable ofsetup and rescue entry within 12-15 minutes of incident occurrence in a timely manner commensurate withthe level of risk .


A Tier 3 response mode is indicated if work is occurring inside a space that contains an IDLH or otherimmediately life-threatening hazard, either actual or potential. A Tier 3 capability suggests that a fullytrained rescueteam meeting requirements stated in NFPA 1670, Chapter 7, technician level, is standing byin the immediate area with appropriate capability to make safe entry for rescue. This team should becompletely set up rigged, ready, tested and capable of rescue entry within 2 minutes of incidentoccurrence. The rescueteam should be dedicated to this singular entry with no other responsibilities.


Paragraph 10.1.3.4 is much too limiting for some industries. Wind industry, for example, has machines most often located in very remote areas. Machines in the northeast are accessible in winter time by snow cats. We often work in teams of two unless the scope of work has risks that require a 3rd or 4th person on the team. The added members serve as an on-location rescue team. (All personnel are trained in excess of OSHA 1910.146) . Adding a suggested 12 - 15 minute response time would cost wind industry many millions of dollars per year to arrange for rescue services (adding them organically, hiring dedicated 3rd party rescue services or a combination both or other options.)

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10.1.3.4.3 * Tier 3 Response Mode.

A Tier 3 response mode is indicated if work is occurring inside a space that contains an IDLH or otherimmediately life-threatening hazard, either actual or potential. A Tier 3 capability suggests that a fullytrained rescueteam meeting requirements stated in NFPA 1670, Chapter 7, technician level, is standing byin the immediate area with appropriate capability to make safe entry for rescue rescue the entrant,preferably without requiring rescuer entry. It is preferable in IDLH/inert atmospheres to conduct rescueoperatons from outside the space without the need for rescuer entry . This team should be completely setup and capable of rescue entry within conducting a rescue within 2 minutes of incident occurrence. Therescueteam rescue team should be dedicated to this singular entry with no other responsibilities.


Numerous fatalities and injuries have occurred to rescuers entering IDLH/inert atmospheres, even when prescribed PPE. The safest way to conduct such rescues is from outside the space.

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Confined The rescue requirements of confined space rescue programs should be audited annually by thea designated person (or team) responsible for rescue services selection as defined in 10.2.2.2. Auditsshould be conducted annually or whent a management of change occurs affecting the space or operationsand in accordance with the owner/operator’s or contractor's confined space program requirements orapplicable government regulations. The owner/operator should also review the rescue program andcontractor should review the rescue requirement following each rescue operation and make adjustments tothe program if needed.


Clarifies that audits are not needed annually. In many cases a specific type of entry my be carried out once every 5 to 10 years (as in an industry turn around) and there is no need for annual review.provides for a review when MOC occurs.

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Performance evaluations are a principal means of deciding who is qualified among a group of prospectiverescue service providers. Performance evaluations should be conducted by the owner/operator orcontractor prior to considering a rescue service and then periodically to ensure thatthe provider’sperformance is still satisfactory. Performance should be evaluated by means of simulated rescue operationsin which the rescue service removes dummies, mannequins, or persons from actual confined spaces orfrom representative confined spaces resembling all the spaces to which the rescue service could berequired to respond in an emergency within their jurisdiction. Representative confined spaces should, withrespect to opening size, configuration, and accessibility, simulate the types of confined spaces from whichrescue could be performed.


there is a need to show who performs the evaluation of rescue service

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Performance evaluations are a principal means of deciding who is qualified among a group of prospectiverescue service providers. Performance evaluations should be conducted prior to considering a rescueservice and then periodically to ensure thatthe that the provider’s performance is still satisfactory.Performance should be evaluated by means of simulated rescue operations in which the rescue serviceremoves dummies, mannequins, or persons from actual confined spaces or from representative confinedspaces resembling all the spaces to which the rescue service could be required to respond in an emergencywithin their jurisdiction. Representative confined spaces should, with respect to opening size, configuration,and accessibility, simulate the types of confined spaces from which rescue could be performed.


Corrected typo

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The owner/operator and contractor should conduct a hazard evaluation and risk assessment of theresponse area and should determine the feasibility and type of incidents that might require confined spacerescue operations.


the contractor may be responsible to provide rescue and should therefore do the evaluation

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10.3.1 Components.

These assessments should include, but not be limited to, the following:

(1) Evaluation of the environmental, physical, social, and cultural factors influencing the scope,frequency, and magnitude of a potential incident

(2) The impact these factors may have on the ability of the owner/operator operatorand/or contractor torespond to an incident and to continue operating while minimizing threats to rescuers at an incidentsite.

(3) Identification and maintenance of a list of the type and availability of internal resources needed fortechnical search and rescue incidents.

(4) Identification of the type and availability of external resources needed to augment existing capabilitiesin confined space rescue incidents

(5) Determination of the potential to respond to rescue incidents that might involve nuclear or biologicalweapons, chemical agents, or weapons of mass destruction, including those with the potential forsecondary devices. If the owner/operator determines that a hazard evaluation exists for rescueresponse into a nuclear, biological, explosive, and/or chemical environment, appropriate training andequipment for response personnel should be provided.


the contractor could be responsible for response and determining if operations should continue

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10.3.2 Acquisition of Resources.

Where an advanced level of search and rescue capability may be needed in a given confined space,owner/operators and contractors should have a system in place to utilize the most appropriate resource(s)available through the use of local experts, agreements with specialized resources, and mutual aid. Theowner/operator's or contractor's confined space program should establish procedures for the acquisition ofthe external resources needed for specific emergencies in and associated with confined spaces. A list ofthe resources should be maintained and updated at least once a year. Additionally, the list should bereviewed and updated by the owner/operator and contractor prior to a planned entry requiring advancedcapability.


contractors often are responsible for these items

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10.5 Regulatory Compliance.

The owner/operator and contractor should comply with all applicable local, state, and federal laws andregulations and should ensure that rescue personnel adhere to program requirements.


contractors are also required to do this

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The owner/operator or contractor should train responsible personnel in procedures for developingpre-incident emergency action plans to prepare the rescue service for safe practices associated with rescuefrom specific and generic confined spaces for which they provide rescue. This process should includedetermining, reviewing, accessing, and using relevant components of applicable national, state, industry,and local response plans.


contractors also responsible for these items for their personnel

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11.1 * General.

All persons engaged in confined space activities and operations should be competent and qualified. Thereare numerous entities that may be involved, individually or working together, in confined space entry andrelated activities. These include, but are not limited to, owners/operators, contractors/subcontractors,facility personnel, rescue services and visitors, as well as other persons and operations both within andoutside of the confined space. This chapter covers the duties, responsibilities, qualifications, andcompetencies of these individuals as related to confined space activities. This chapter lists requirements forall persons and tasks that might be required for entry. It is important to recognize that there are at leastthree key positions required for a basic confined space entry that requires permitting: the entry supervisor,the entry attendant, and the entrant. In addition to these three positions, rescue should be provide asoutlined in Chapter 10. In many applications one or more of these persons (often the entry supervisor) canhandle other tasks addressed in this chapter (e.g., permit issuer, ventilation specialist, standby worker ,including, but not limited to gas testing, issuing permits, conducting ventilation and providing standbyservices ).


adds contractors and rescuers. also is more definitive as to additional duties.

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11.2.1.2

As defined in the applicable confined space program, entry should occur occurs when any part of theentrant’s body breaks the plane of a confined space opening that provides for entry access .


Changed wording to make when an entry occurs clear.

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11.2.2.1.2

Entrants should be aware of the hazards that might be encountered during entry, including the confinedspace hazards and controls noted on the permit and be able to verbally identify these to theentrysupervisor.


this was missing and the sentence makes no sense with out the qualifier

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11.2.2.6

Entrants should react to emergencies as trained and directed, including, but not limited to, self -rescue orevacuation of the confined space.


Self-rescue can be mistaken as a rescue plan. Self-rescue throughout the document should be changed to self evacuation to prevent the implication of using self-rescue as a rescue plan.

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11.2.3.1

An entrant should be able to understand and verbally identify to the entry supervisor the governmentalcomply with applicable governmental regulations that pertain to the planned confined space entry and workas explained by the entry supervisor or included in the entry permit .


it is unrealistic to expect entrants to know all government regulations. There is a need to know and understand requirements applicable to the operations and it is the responsibility of the entry supervisor to cover these in the pre-job and daily safety meetings.

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11.2.3.2

An entrant should understand and be able to verbally identify to the entry supervisor the use, limitations,and hazards of materials, substances, and equipment approved for use within the specific confined space(e.g., tools, personal protective equipment, energy isolation devices, gas testers atmosphere testinginstruments , and chemicals) before entry.


Suggest this use of monitoring equipment.

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11.2.3.4

An entrant should understand and be able to verbally explain to the entry supervisor before entry how tointerpret and respond to air monitor atmosphere meter displays and alarms.


When describing atmosphere sampling instrumentation the wording should be the same throughout the document

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Public Comment No. 51-NFPA 350-2014 [ Sections 11.2.3.4, 11.2.3.5, 11.2.3.6, 11.2.3.7 ]

Sections 11.2.3.4, 11.2.3.5, 11.2.3.6, 11.2.3.7

11.2.3.4

An entrant should understand and be able to verbally explain to the entry supervisor before entry how :

How to interpret and respond to air monitor displays and alarms.

11.2.3.5

An entrant should understand and be able to verbally explain to the entry supervisor before entry all

An understanding of all sections of the confined space entry permit that are applicable to the entrants’duties.

11.2.3.6

An entrant should understand and be able to verbally explain to the entry supervisor before entry personal

An understanding of personal warning signs and overexposure symptoms, including actions that mustbetaken in the event of exposure.

11.2.3.7

An entrant should understand and be able to verbally explain to the entry supervisor before entry applicableemergency

Emergency procedures to be taken within or around the confined space.


Section should be consolidated to make it shorter and easier to understand

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11.3.2.1

Attendants should understand and be able to verbally identify to the entry supervisor the the following:

The hazards inside and outside the specific confined space that might occur during entry, includinginformation

Information on the modes, signs or symptoms, and consequences of exposure to entrants.

11.3.2.1.1

Each attendant should verify that

That his or her name is listed on the entry permit.

This may require initialing or signature, as required by the entry supervisor.

11.3.2.1.2

Attendants should be constantly observing

Observe , monitoring, and evaluating the conditions in and around the confined space to ensure thatcompliance with the requirements of the permit are maintained throughout the entry

.

11.3.2.1.3

Attendants should monitor adjacent

Adjacent areas outside the confined space for changing conditions that might affect safe entry work oractivities.


This section should be short and consise

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11.3.3.3

Attendants should know and be able to verbally identify to the entry supervisor the use, limitations, andhazards of materials, substances, and equipment approved for use outside the specific confinedspace,including, but not limited to, tools, PPE, energy isolation devices, atmospheric measuring devicesinstruments and associated alarms, and chemicals.


Suggest change for consistency.

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11.3.4.3

Attendants should be able to communicate with entrantsin entrants in order to evacuate the confinedspace when conditions arise that might endanger the entrant.


Corrected typo

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11.4.1.2 *

Entry supervisorscan supervisors can also be designated on the permit(s) as attendants, gas testers,ventilation specialists, isolation specialists, and entrants in accordance with the applicable confined spaceprogram.Entry supervisors should be trained and/or qualified in accordance with the respectiverequirements provided in this chapter for alternative activities.


Corrected typo.

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11.4.2.1.3

Assigned entrysupervisors Where required by the applicable confined space program or regulations, theassigned entrysupervisor should remain at the confined space work site to control operations unlessrelieved by another competent, qualified, and authorized entrysupervisor entry supervisor . The relievingentry supervisor should initial or sign the permit(s) to document the change of responsibility, if applicable.


it is industry practice to often have one supervisor at a site where there may be multiple crews conducting simultaneous entries. Also some operators require a full-time on site entry supervisor and others do not.

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11.4.2.1.3

Assigned entrysupervisors should remain at the confined space work site to control operations unlessrelieved by another competent, qualified, and authorized entrysupervisor entry supervisor . The relievingentry supervisor should initial or sign the permit(s) to document responsibility if applicable.


Corrected typo

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11.4.2.1.4

Entry supervisors should ensure that personnel involved with the confined space operations are informedwhen another person assumes the entrysupervisor entry supervisor role.


Corrected typo

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11.4.2.1.6

Entry supervisors should be trained and qualified as gas testers detection equipment if duties requiremaintaining, testing, and operating gas monitors detection equipment , including interpreting and analyzingtest results.


Inconsistent use of terminology. Suggest landing on one term and using the same term throughout document.

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11.4.3.3

Entry supervisors should know the proper use of atmospheric monitors and atmospheric monitoringinstruments and be able to understand, analyze, and interpret monitor interpret instrument readings inorder to provide for safe entry and work in confined spaces.


Used instrument for conformity.

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11.5.2 Rescuer Duties and Responsibilities.

11.5.2.1

Prior to the start of confined space operations (such as during pre-planning), rescuers should evaluate theinternal and external physical, atmospheric, and other hazards specific to the confined space that might beencountered during a rescue situation.

11.5.2.2

Rescuers should respond in accordance with the established response plan — upon arrival, they shouldestablish a command system and develop an action plan as appropriate to the situation.

11.5.2.3

Rescuers should ensure that all required rescue and PPE is inspected and in good working order prior tostart of confined space operations.

11.5.2.4

Rescuers should determine if a non-entry rescue or an entry-required rescue is needed.

11.5.2.4.1

Rescuers may conduct the rescue from outside the confined space and without the need for rescuer entry.

11.5.2.4.2

Training for rescuers should be similar to that for entrants. Rescuersshould meet the same entryrequirements applicable to entrants should the rescue require entry into the space.

11.5.2.5

Rescuers should develop a pre-emergency action plan with the ability to respond in an organized andappropriate manner that includes, but is not limited to, the following:

(1) Determining the alarm or notification method specific to the facility or operation

(2) Assessing the incident and identifying potential related hazards

(3) Determining if rescue is to be external or internal

(4) Determining the appropriate PPE and respiratory protection required for entry

(5) Organizing equipment and personnel prior to start of rescue operations

(6) Determining signals or communication to be used during rescue

(7) Planning the specific step-by-step operations of the rescue

(8) Responding to the incident and performing rescue

(9) Conducting a post-incident evaluation and taking necessary action to correct pre-emergency rescueplans where needed

11.5.2.6

Rescuers should consider the rescue requirements with respect to entrants’ self-rescuecapabilities,physical and mental condition, hazards, equipment, communications, confined spaceconfiguration, and other rescue-related conditions prior to starting rescue operations.


This was covered in Rescue Chapter, redundant and should be eliminated

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11.6.2.1

Gas testers should determine proper selection of monitoring equipment instrumentation based on theatmospheric hazards that are present or that could be encountered during confined space operations.


Used instrumentation for consistency.

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11.6.2.2

Gas testers should inspect, calibrate, test, and adjust equipment adjust instruments prior to use.


Changed for consistancy

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11.6.3.2

Gas testers should be trained and qualified in the appropriate selection, inspection, calibration, adjustment,and use of monitoring equipment instruments .


Changed for consistency.

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11.6.4.1

Gas testers should be able to demonstrate the competencies required for a gas tester and an entrant andunderstand permit requirements for entering confined spaces, conducting monitoring, and recordingmonitoring results.



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11.6.4.2

Gas testers should be able to select, inspect, adjust, calibrate, bump test, and properly use requiredequipment instrumentation .


Changed for consistancy

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11.7.2.3

/ Owners/operators should identify and designate those individuals (facility personnel, contractors, andcontract personnel under facility supervision) who are educated, trained, competent, and/or qualified toperform specific confined space–related duties, including, but not limited to, supervising operations, issuingpermits, entering into confined spaces, conducting atmospheric monitoring, providing rescue, performingattendant duties, overseeing ventilation, and conducting hot or cold work operations within or associatedwith confined spaces. Owners/operators should designate and identify the individuals and their duties in thewritten confined space program in accordance with Chapter 12.


Corrected typo

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11.7.2.5

Prior to entry, owners/operators should conduct a confined space entry safety meeting in accordance withChapter 5 to ensure that assignedentry assigned entry supervisors, gas testers, entrants, attendants,ventilation and isolation specialists, rescuers, and workers are apprised of and understand the hazardsassociated with the confined space activity.


editorial

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11.7.2.7.2

Owners/operators should debrief contractors at the conclusion of entry operations regarding the permitthe confined space program that was followed and regarding any hazards confronted or created inconfined spaces during entry operations. Where the debriefing indicates a need to change programrequirements, owners/operators and contractors should revise confined space programs accordingly.


appears to be an error in referencing a "Permit" program as that is another subject not always just confined space entry

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11.8.2.3

Contractorsand Contractors and owners/operators should review the applicable confined space programand determine what is needed to conduct entry and work operations in compliance with programrequirements. The confined space program applicable to the operations may be that of theowner/operator,the contractor, or both.


editorial, need to specify what program

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11.8.2.4

If contractorsdo contractors do not agree to use the owner/operator’s confined space program, they shoulddevelop and implement their own confined space program in accordance with regulatory requirements,industry standards, applicable safe work practices and procedures, and Chapter 12 of this guide. Thecontractor’s confined space program should not conflict with and may be used to supplement theowner/operator’s confined space program.


editorial

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11.8.2.14

If rescue service is provided by the contractors/subcontractors, contractorsshould contractors shouldidentify, evaluate, and qualify assignedrescuers assigned rescuers or rescue and emergency services anddevelop and implement procedures for summoning rescuers and emergency services.


editorial

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11.9.2.4

Ventilation specialists should ensure that if the exhausted atmospheremight atmosphere might becombustible or flammable, ignition sources in and around confined spaces be spaceshave been eliminatedor controlled prior to ventilation.


editorial

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11.9.2.6

Ventilation specialists should never use pure oxygen or oxygen above normal atmospheric levels toventilate a confined space for a number of reasons, including but not limited to the following:

(1) Oxygen above normal levels will negatively affect the readings on gas detection instruments.

(2) Oxygen above normal levels will increase the flammable range of combustible and flammablegases, dusts, and vapors, creating a fire or explosion hazard.

(3) Oxygen above normal levels is not safe for entrants to breathe.


This does not seem like a qualification and it goes into to much detail, this falls under the gas tester. If it is left in this section it should be shortened to: The ventilation specialist must understand the effects of high oxygen levels and ventilate properly.

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11.9.2.10

Ventilation specialists should not direct ventilation flows toward occupied areas, as well as toward areasthat might compromise air quality in occupied spaces.


Significant correction "not" is very critical here for good job planning

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11.10.1 * General.

Isolation is the process of removing a confined space from service and completely protecting the spacefrom the unwanted release of energy, liquids, gases, chemicals, and other materials into the space throughfixed or temporary connections to the space, as well as disconnecting and de-energizing potentiallyhazardous machinery and equipment within or attached to the space. Isolation may be permanent ortemporary. Isolation operations should be performed by isolation specialists, who should be trained,educated, or qualified and competent to perform required isolation duties. Isolation specialists should beassigned and authorized by the owner/operator or contractors, as appropriate, in accordance with therequirements of the applicable permits, isolation, or the lockout/tagout program and the confined spaceprogram. At the conclusion of confined space operations, isolation specialists may also be required by theowner/operator or contractor to de-isolate the space in preparation for return to service . .


need to tell why specialist is required at the end

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11.10.3.1

Isolation specialists should understand and comply with the requirements of confined space, isolation(lockout/tagout) and permitprograms permit programs , industry procedures and practices, andgovernmental regulations that pertain to isolation.


Corrected typo

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11.12.1.2.6

All confined space personnel should be retrained, educated,or qualified when regulatory requirementschange or the confined space program is revised .


Recommend adding when confined space entry program changes not just regulatory changes.

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11.12.2 Rescue Training.

The AHJ should The rescue provider organization should provide for training in the responsibilities that arecommensurate with the needs of the organization.


Insert revised text

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11.12.2 Rescue Training.

The AHJ should provide for training in the responsibilities that are commensurate with the needs of theorganization.


AJH should be spelled out.

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11.12.5 Documentation of Training.

The rescue service supervisor (or the owner/operator if or contractor, if responsible for rescue) should beresponsible for the documentation of all required rescuer training, education, and qualification. Thedocumentation should be maintained and available for inspection by individual team members or theirauthorized representatives, governmental agencies, and the owner/operator who has arranged for therescue service.


contractor may have this responsibiulity

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11.12.6 Fitness.

The rescue service supervisor (or the owner/operator if or contractor, if responsible for rescue) shouldensure that rescuers are psychologically, physically, and medically capable and qualified to performassigned duties and functions for the specific confined space operations, including search and rescueand,as required, training exercises in accordance with Chapter 10 of NFPA 1500.


contractor may have responsibility

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11.12.7.1

Rescuers should be provided with and trained, educated, or qualified to properlyuse properly use PPE andrescue equipment necessary for rescues from inside and around confined spaces according to theirdesignated level of competency.


editorial

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11.12.7.5

Rescuers should be certified to the level of first responder or equivalent according to U.S. Department ofTransportation (DOT) First Responder Guidelines.


delete and renumber. DOT has NOTHING to do with confined space entry. DOT does do not even regulate entry for TTs and TCs. Also would eliminate use of many municipal responders especially for small businesses.

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12.1.1 General.

Before confined space operations begin and workers enter the confined space for any reason, theowner/operator or entrant employer should develop and implement a written confined space program. Thewritten program should be made availableto available to all employees and/or their representatives, andshould include, but not be limited to, the following:

(1) Program responsibilities

(2) Identification of confinedspaces confined spaces

(3) Identification of personnel involved in the confined space entry

(4) Standard operatingprocedures operating procedures , such as atmospheric monitoring and ventilation

(5) Entry permits

(6) Other facilitysafetypermits facility safety permits and procedures

(7) Rescue Emergency, communications and rescue procedures

(8) Training

(9) Resources

(10) Program auditing

(11) Medical qualifications

(12) Regulatory and bestpractices

(13) A written confined space policy where only qualified contractors will enter the confined space thatexplains the following:

(a) How the owner/operator or employer determines contractors are qualified

(b) How confinedspacehazards confined space hazards are communicated to contractors

(c) How relevant facility safety information is communicated to contractors

(d) How contractors aredebriefed are debriefed after entry is completed


adds provisions for communications and emergency procedureseditorial corections

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There should be one person assigned as the program administrator for the company’s or facility’s confinedspace entry program. This person can be the owner/operator, employer, or other individual assigned by theowner/operator or employer. This individual should be identified in the written confined space program. Theprogram should also establish the roles and responsibilities of all individual positions involved in confinedspace entries. As a minimum, the name of the program administrator should be listed along with a list ofauthorized entrants, attendants, and entrysupervisors entry supervisors in a separate document, whichshould be reviewed and updated as needed. Roles such as gastester gas tester ,ventilationspecialist ventilation specialist , isolationspecialist isolation specialist , standby person, hot/coldwork, etc., should also be identified in the program and assigned to a program administrator . Otherindividuals, if needed, can be assigned to the attendant or entrysupervisor by the entry supervisor . Chapter11 provides a list of roles and required training.


a lot of the last 2 sentences did not make any sense so they have been corrected. also editorial changes

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There should be one person assigned as the program administrator for the company’s or facility’s confinedspace entry program. This person can be the owner/operator, employer, or other individual assigned by theowner/operator or employer. This individual should be identified in the written confined space program. Theprogram should also establish the roles and responsibilities of all individual positions involved in confinedspace entries. As a minimum, the name of the program administrator should be listed along with a list ofauthorized entrants, attendants, and entrysupervisors entry supervisors in a separate document, whichshould be reviewed and updated as needed. Roles such as gastester gas tester ,ventilationspecialist ventilation specialist , isolationspecialist isolation specialist , standby person, hot/coldwork, etc., should be identified in the program and assigned to a program administrator. Other individuals, ifneeded,can be assigned to the attendant or entrysupervisor entry supervisor . Chapter 11 provides a list ofroles and required training.


Corrected typos

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12.2.2 Employee Involvement.

Employers shouldensure that Where required by regulations or by their employer, employees whosupervise or perform confined space operations , and/ ( or their authorized representatives, are ) maybe provided an opportunity to be involved in the development and implementation of the written theiremployer's written confined space program.


This is not necessarily required as for example, a contractors employees are not involved in developing an owner's program. Owner employees are not involved in contractor program development and implementation. At very most employees may be involved in their own employer's program development not someone else.

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The written Where required by regulations or by the applicable confined space program, written confinedspace programs should be reviewed at least annually by the owner/operator or entrant employer and theworkers involved in the confined space operations to determine if the program is effective in providing safeoperations for confined space entries. This review may not be necessary if no entries have occurred duringthe year, if there have been no changes in reqguations and if no Management of Changes have occurred inequipment, materials or operations affecting designated confined spaces.


there is no need to review or change programs if there ahs been no activity or MOC changes

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12.4.1

If a confined space–related near miss, accident, injury or equipment failure occurs, the confined spaceprogram should be audited reviewed and modified as if necessary to , modified to address anydeficiencies before any additional entries are made , prior to permitting subsequent entries .


changed to clarify modification needed only if needed

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12.4.2

The written confined space program should be approved, signed, and dated by seniormanagement by appropriate management as designated in the program .


"senior" management is too broad .. in a large corporation it could refer to the CEO or Board of Directors. The change is more accurate as it refers to management designated in the program itself, which could be facility or area manager, or a VP of operations, or owner of small entity, etc.

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12.5 * Identification of Confined Spaces.

Owners/operators or entrant employers should conduct a hazard safety analysis audit of all confinedspaces in accordance with Chapter 4. The recognized inherent and adjacent actual and potential hazardsshould be documented, including the most probable hazards that can be introduced based on work likely tobe performed in the space(s).


qualifies employer, adds actual and potent ial hazards, editorial changes,

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12.6 Program Procedures.

The written confined space program should describe the procedures used to evaluate confined spacehazards. Entry supervisors should use the criteria listed in Chapters 6 and 7 to identify and evaluatehazards, and the procedures listed in Chapters 7 and 8 to control or , mitigate or eliminate the hazards.


add mitigate reflect previous criteria

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12.7.1 *

The written confined space program should also specify atmospheric conditions that prohibit entry undernormal conditions. The program should indicate that if acceptable atmospheric quality criteria are not met,or if a hazardous atmosphere develops during occupancy, all entrants must exit immediately. For example,entry should be allowed if any of the following conditions exists only when the or when proper protectivemeasures delineated in this document, such as the use of PPE, are taken:

(1) Oxygen is lower than 19.5 percent or higher than 22.0 percent.

(2) Hydrogen sulfide is greater than 10 ppm.

(3) LEL is greater than 10 percent.

(4) Carbon monoxide is greater than 35 ppm.


provides for entry if listed conditions are not all fully met

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12.7.1 *

The written confined space program should also specify atmospheric conditions that prohibit entry undernormal conditions. The program should indicate that if acceptable atmospheric quality criteria are not met,or if a hazardous atmosphere develops during occupancy, all entrants must exit immediately. For example,entry should be allowed if any of the following conditions exists only when the proper protective measuresin this document are taken:

(1) Oxygen is lower than 19.5 percent or higher than 22.0 percent.

(2) Hydrogen sulfide is greater than 10 ppm. the accepted exposure limits

(3) LEL is greater than 10 percent.

(4) Carbon monoxide is greater than 35 ppm. accepted exposure limits


Prior to this you provided information on TLV's, PEL and other exposure limits, now you are limiting it to OSHA PEL's. The document should be consistent.

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12.7.2

The written confined space program should specify when and how atmospheric monitoring is conducted.For example, the program should specify if workers must wear or use monitoring devices during the entireentry, or if the attendant will be performing atmospheric monitoring, or both.


no need to wear monitors ... portable may be used

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The written confined space program should contain information about the use and maintenance ofmechanical ventilation equipmentto be used for equipment for confined space entry , including where theyare located and who is to be responsible for maintaining these systems. determining ventilationrequirements. The work plan for a specific confined space entry should delineate the tyoe and size ofventilation equipment to be used, its placement and exhaust criteria..


clarifies requirement in accordance with industry practices. Each entry/job is unique. the program cannot comprehend all of the possibilities involved in a specific ventilation..this has to be done at the job plan level

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The written confined space program should state that all rescue services provisions should be identifiedprior to entry and during work site analysis in accordance with Chapter 10. The program should also makeclear that the rescue service is responsible for all rescue or assigned rescuer is responsible for rescueoperations. It should state that wherever possible, all confined where applicable (in accordance withChapter 10) confined space entries should be done with entrants wearing a full-body harness attached toeither a mechanical retrieval device or to a fixed object outside the space. Personal fall arrest may benecessary depending on the configuration of the confined space relative to entry operations. Whileself-rescue and non-entry rescue arealways are always a consideration they might not always be possible.Therefore, a comprehensive emergency rescue response should be developed. developed for each typicalconfined space configuration..


rescue my be by a qualified attendant therefore rescue "services" is a poor word to use. Chap 10 does not require ALL entries to use harness, etc. There are entries on non-permit type spaces where this is not needed. changes to show where confined space planning is needed. editorial change

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12.9.2

The owner/operator or entrant employer should indicate the type of personal fall arrest equipment that willbe used for entries involving descent from heights .


no need for this for horizontal entry

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12.11 Energy Control Isolation Program (Lockout/Tagout).

If there is an energy source (s) that can create a hazard in or around the confined space during entryoperations, then the written confined space program should identify an isolation specialist to address thesesituations the situation . (See Chapter 8.) Additional information can be obtained by cross-referencing theemployer’s energy control isolation program.


correct tenses. this is called "ISOLATION PROGRAM' in chapter 8. stick to same terminology throughout document

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12.16 Contractors.

The written confined space program shouldprovide a means for contractors should provide the method(s)by which contractors and subcontractors, where operating with within a controlling facility, to be informedof all hazards and potential hazards within and aroundall around all confined spaces where they areworking . If a joint operation or entry (i.e., entrant employers’ entrant employees and owner/operatoremployees) isto is to be conducted, the applicable permits should detail operationsmanagementandoperations management control and the person (s ie: entry supervisor ) responsible for the entry .Employers should ensure that the program details how contractors/subcontractors are debriefedafterconfined after confined space operations and entries, and how how the debriefing should bedocumented and who is responsible for the debriefing . The program should also indicate that if applicableprocedures are not followed, the contractor/subcontractorcan subcontractor can be subject to discipline,including work stoppage and/or removal from the facility.


changed for clarity and specifity

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12.16 Contractors.

The written confined space program shouldprovide should provide a means for contractors andsubcontractors, where operating with a controlling facility, to be informed of all hazards and potentialhazards within and aroundall confined spaces. If a joint operation or entry(i.e., entrant employers’employees and owner/operator employees) isto be conducted, the applicable permits should detailoperationsmanagementand operations managementand the person(s) responsible.Employers shouldensure that the program details how contractors/subcontractors are debriefed afterconfined after confinedspace operations and entries, and how the debriefing should be documented. The program should alsoindicate that if procedures are not followed, the contractor/subcontractorcan be subject to discipline,including work stoppage and/or removal from the facility.


Corrected typo

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12.18 * General Fitness for Duty Evaluation.

Owner Where required by applicable regulations, owner /operators or entrant employers should ensure thatthe written confined space program includes evaluation procedures for the physical and mental capabilitiesof personnel assigned to work in confined space operations. The program should consider allactual andpotential hazards and operations,and can reference industry and regulatory medical evaluation procedures,including, but not limited to, respiratory protection capability, toxic exposure determinations, andphysiological and psychological stresses that might be present during confined space entries, such asclimbing, ladders, heat stress, and claustrophia.


this is NOT mandatory or required in many localities and in fact, is not allowed in certain countries, It should only be considered where required by law.

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12.18 * General Fitness for Duty Evaluation.

Owner/operators or entrant employers should ensure that the written confined space program includesevaluation procedures for the physical and mental capabilities of personnel assigned to work in confinedspace operations. The program should consider allactual all actual and potential hazards andoperations,and can reference industry and regulatory medical evaluation procedures, including, but notlimited to, respiratory protection capability, toxic exposure determinations, and physiological andpsychological stresses that might be present during confined space entries, such as climbing, ladders, heatstress, and claustrophia.


Corrected typo. Also mental evaluations are tricky and normally cannot be done by deck level individuals, not sure this part should be included.

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The entry supervisor should perform a pre-entry evaluation immediately prior to all entries into a confinedspace. If hazards or potential hazards are identified that cannot be eliminated prior , mitgated orcontrolled prior to entry, then the entry supervisor should not issue a permit.


this documents provides for mitigation and control in addition to elimination

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The entry supervisor should perform a pre-entry evaluation immediately prior to all entries into a confinedspace. If hazards or potential hazards are identified that cannot be eliminated be controlled prior to entry,then the entry supervisor should not issue a permit.


Not all hazards can be eliminated, but may be controlled to allow entry.

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13.1.1

The permit (or pre-entry evaluation or permit ) should be displayed at the confined space location.Permits should be marked as cancelled after workthe time allowed on the permit has expired, the work is completed or a change in conditions requires anew permit.


permits are time sensitive

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13.1.3

Permits should be limited to one shift. If work activity exceeds one shift the permit should be reissued orrevalidated . In addition, permits should be considered cancelled if personnel change.


Recommend adding to …permit should be reissued… add or revalidated

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13.2 Pre-Entry Evaluation and Permit Elements.

A pre-entry evaluation and permit should be developed or adopted to meet the needs of the work activitiesof the owner/operator or employer. The evaluation and permit

The permit can be a single form or two separate forms. Subsections13.2.1 through 13.2.11 detailelements of each form, how they should be used, and why they are important. Each element can bemodified to meet job task requirements and/or the responsible party’s program management requirements.Each element of the permit has an in-depth section that the owner/operator, entrant employer,entrysupervisor, attendant, and entrant should be familiar with and addressed as required under thetraining program . At a minimum, the elements listed in 13.2.1 through 13.2.11 should be addressed on theowner’s/operator’s or employer’s pre-entry evaluation/permit. An example of a combination pre-entryevaluation/permit is provided in Figure B.X.

13.2.1 Confined Space Identification.

The confined space should be clearly identified on the permit and include the following: .

(1) Location. The location of the confined space should be as precise as possibleand possible and mayinclude, if necessary, the address of the location, street or crossroads near the site, building locationand/or number, room or space number, and global positioning system (GPS) coordinates. If there is aspace similar to the one on the permit, additional information should be added to the permit to ensurethe correct space is identified by all personnel.

(2) Description.A detailed description of the space can assist personnel in correctly identifying theconfined space. For example, a description might include the type of space (e.g., tank, silo, vault), itsfunction (e.g., fuel oil waste, grain hopper), and/or its physical attributes (type of material, color, size,shape, etc.).

13.2.2 Work Activities.

The work activities to be performed in the confined space should be clearly identified on the permit andinclude the following:

(1) Time. The permit should indicate thedate the date (s) and time(s) the permit is valid . Permits are voidonce the permit date(s)/time(s) have expired along with an expiration date and time .

(2) Work. The permit should outline the specific work to be conducted in the space. If there is a change inthe scope of work or its location, a new permit might need to be issued. Work not identified on thepermit should not be done without the approval of the entry supervisor and might require a newpermit.

13.2.3 Pre-Entry Evaluation.

All confinedspaces should have a pre-entry evaluation. The intent of this evaluation is to make sure theconfined space is examined before any work activity begins toconfirm to confirm hazardous conditions donot inherently exist or will not be introduced to, or are not adjacent to, the confined space. Evaluation The entry supervisor or a qualified person trained in confined space work and the hazards should sign offon the evaluation. If no hazardous conditions exist, work can proceed. If any hazards do exist, theentrysupervisorshould entry supervisor should complete the permit appropriately to ensure safe entry.

13.2.4 Hazard Identification.

The entry supervisor should identify all actual and potential hazards on the permit and indicate methods toeliminate, control, or mitigate the hazards to reduce risk to an acceptable level.The entry supervisor shouldensure personnel areinformed aboutall hazards in and around the space, including inherent hazards,introduced hazards, and adjacent hazards.


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13.2.4.1 Inherent Hazards.

Inherent hazards include, but are not limited to, the design, structure, configuration, size, and physicalcondition of the space, as well as any equipment within the space. (See Chapter 6.) It might not bepossible to eliminate or controlthese hazards, but measures can be taken to assess their risks and takeprecautions. For example, where a steep ladder is needed to enter a fuel tank. The ladder’s configurationis not changeable, but the way in which supplies are brought into the space can be altered. The workerdoes not have to carrysupplies down the ladder; instead, they can be lowered down.

13.2.4.2 Introduced Hazards.

Introduced hazards are typically brought into the space by workers or because of the work process. Theintroduction of materials, personnel, and work processes should be evaluated carefully to ensure that theydo not create a hazardous condition. These are hazards that can be controlled or eliminated, making thema key element in a risk assessment. An example of an introduced hazard is the materials brought into aspace to clean, such as solvents used to clean a tank, which can create a hazardous levelatmosphere.Thecondition of the space can be altered by the work process,for example, where workers disturb settledmaterials, such as fish processing or other biological waste. The disruption of the materials can allowtrapped levels of hydrogen sulfide gas to be released, which can create a hazardous atmosphere.

13.2.4.3 Adjacent Hazards.

Adjacent hazards are not in the confined space but are in close proximityand can impact operations in thespace by entering through openings or other means. Examples of adjacent hazards include, but are notlimited to, toxic smoke from a nearby fire or hot work, flammable vapors from a spill or release outside thespace, and introduction of a hazard through a common wall with an adjacent space where work is inprogress. Entry supervisors should recognize that adjacent hazards exist, or can potentially exist, shouldrecognize and inspect the surrounding area, and should provide safeguards to eliminate, control, ormitigate all adjacent hazards.

13.2.4.4 Hazard Control.

The entry supervisor should identify all hazards and provide should provide requirements to eliminate,control, or mitigate them mitigate hazards on the permit. (See Chapter 8.) Where hazards are inherent,they should be recognized and measures should be developed to reduce worker risk. Controls should beclearly outlined on the permit, and include such measures as outlined in 13.2.4.4.1 through 13.2.4.4.5.

13.2.4.4.1 Atmospheric Monitoring.

The entry supervisor should understand and include atmospheric monitoring requirements on the permitsfor applicable hazardous conditions,whichinclude, but are not limited to, oxygen deficient, oxygen enriched,flammable or explosive, toxic, irritant/corrosive, or asphyxiating atmospheres. Atmospheric monitoringmight be required intermittently or continuously. The frequency of monitoring depends on the work beingperformed and other potential introduced or adjacent hazards that could alter the atmospheric conditions inand around the confined space Atmospheric monitoring requirements should be listed on the permit . Thepermit should detail what atmospheric monitoring should be done, by whom, and at what levels personnelshould exit the space.

13.2.4.4.2 Atmospheric Ventilation.

The entry supervisor should understand ventilation Ventilation methods and requirements . The entrysupervisor should verify that ventilating a confined space with fresh air before and during confined spacework can reduce or remove atmospheric contaminants. Ventilation, especially during warmer months, canalso provide relief from thermal stress. The permit should outline what ventilation should be used prior toand during entry. If ventilation will block access into or out of the space, the permit should outlineprocedures to ensure worker safety during operations be listed on the permit .

13.2.4.4.3 Personal Protective Equipment (PPE).

The permit should address entrant and attendant PPE requirements. Also, if workers need to carry escapedevices or additional PPE for specific work, such as cleaning or painting, that equipment carry additionalPPE it should also be addressed.

13.2.4.4.4 Other Permits.

All additional permits needed for the confined space should be listed on the entry permit (e.g., hotwork, linebreak, electrical work, etc.).

13.2.4.4.5 Grounding and Bonding.

If the confined space or the ventilation or equipment brought into the space need to be grounded orbonded, then that information should be indicated on the permit as a control Any items required to begrounded should be listed on the permit .


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13.2.5 Communications.

The entry supervisor should select and indicate on the permit the appropriate methods of communication,and should document how communication will be maintained, as follows: such as

(1) Verbal. Acceptable if line of sight is maintained

(2) Radio. Permit to indicate test intervals

(3) Rescue request. Permits indicate how rescueteam rescue team will be notified

13.2.6 Rescue.

Confined spacerescue methodsshould be understood before entry into a confined space. Regardless ofwhether a confined space has hazards or not, the owner/operator or employer should ensure rescue isavailable and appropriate. All confined spaces should have a rescue incident action plan, which describeshow rescue will be attempted. The incident action plan should be available to entry supervisors, attendants,and entrants. The incident action plan should be The rescue plan should be attached to the entry permitalong with contact information .The emergency response team should be notified of all confined entries,including their location, hazards, and duration. The following are the four types of rescue:

Self-rescue. Rescue before needing assistance.The entrant or attendant identifies a prohibited ordangerous condition and exits under their own power. Self-rescue is not a primary rescue method that canbe utilized under a permit.

External retrieval. The attendant activates a rescue system outside the confined space to remove orassist the entrant out.

Rescue available. There is a rescue service that has been identified, evaluated, and able to respond in atimely manner should there be a need.

Rescue stand-by. A rescue service is standing by the confined space, ready and equipped to makeimmediate entry.

13.2.7 Entrants.

The following information should be clearly identified on the permit:

Name should be printed on the entry permit.

Entrant should sign the entry permit, indicating

(1) Entrants name, indicating that they have been trained in confined space entry and have reviewedall the hazards associated with the permit-specific entry,including which condition changes wouldrequire their immediate evacuation. For multiple entrants, a sign-in sheet can be attached to thepermit.

13.2.8 Attendant.


Name should be printed on the entry permit

The attendantshould sign the entry permit,

(1) Attendants name indicating that they have been trained in confined space entry and have reviewedall the hazards associated with the permit-specific entry.

The attendant must be aware of all potential hazards in the confined space,including possible behavioraleffects related to hazard exposure. An attendant must remain in constant contact with the entrant, untilrelieved by another attendant,maintain communication with the entrant, monitor activities, and orderevacuations, where needed. The attendant also performs non-entry rescue or summons a rescue team, ifnecessary, andcannot perform any other duty that might interfere with the primary duty of ensuring thesafety of the entrant. If the work or hazards change from what is stated on the permit, the attendant shouldre-evaluate the space and obtain a new permit.

(1)

13.2.9 Entry Supervisor.

The entry supervisor is responsible for all aspects of the entry and issuance of the entry permit. The entrysupervisor should sign the permit, indicating that they have been trained in confined space entry and havereviewed all the hazards associated with the permit-specific entry. They must be aware of all potentialhazards in each space and the standard operating procedures and equipment required for each entry.


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13.2.10 Cancel Permit.

Each permit should have an area on the permit to mark the permit as canceled. A permit can be canceledat the end of the work activity by the attendant or entrant, or at anytime by the attendant, entrant,supervisor, or safety professional because of hazards. The reason the permit was cancelled should bedocumented on the permit, for example, work was completed or conditions changed.

13.2.11 Rescue and Emergency Contact.

The entry permit should indicate emergency rescue and contact information.


Section is to wordy, most items are detailed in other chapters. Items required on the permit should be listed and if help is needed the reader can refer to other chapters. The basic elememts on a permit should be listed here and not responsibilities as they are outlined elsewhere

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A pre-entry evaluation and permit should be developed or adopted to meet the needs of the work activitiesof the owner/operator or entrant employer. The evaluation and permit can be a single form or two separateforms. Subsections13.2.1 through 13.2.11 detail elements of each form, how they should be used, and whythey are important. Each element can be modified to meet job task requirements and/or the responsibleparty’s confined space and other applicable program management requirements. Each element of thepermit has an in-depth section that the owner/operator, entrant employer, entrysupervisor, attendant, andentrant should be familiar with and addressed, as required under the training program. At a minimum, theelements listed in 13.2.1 through 13.2.11 should be addressed on the owner’s/operator’s or entrantemployer’s pre-entry evaluation/permit. An example of a combination pre-entry evaluation/permit is providedin Figure B.X.


specifies entrant employer. specifies types of programs

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13.2.1 Confined Space Identification.

The confined space should be clearly identified on the permit and include the following: .

(1) Location. The location of the confined space should be as precise as possibleand include, ifnecessary, the address of the location, street or crossroads near the site, building location and/ornumber, room or space number, assigned facility equipment or confined space identificaton number,and global positioning system (GPS) coordinates. If there is a space similar to the one on the permit,additional information should be added to the permit to ensure the correct space is identified by allpersonnel.

(2) Description.A detailed description of the space can assist personnel in correctly identifying theconfined space. For example, a description might include the type of space (e.g., tank, silo, vault), itsfunction (e.g., fuel oil waste, grain hopper), and/or its physical attributes (type of material, color, size,shape, etc.).


adds equipment in addition to building

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(1) Time. The permit should indicate thedate the date (s) and time(s) the permit is valid. Permits are voidonce the permit date(s) / or time(s) have expired.

(2) Work. The permit should outline the specific work to be conducted in the space. If there is a change inthe scope of work or its location , a new permit might need to be that has the potential to create orintroduce hazards not anticipated in the initial permit, a new permit should be issued. Work notidentified on the permit should not be done without the approval of the entry supervisor and mightshould require a new permit if the potential exists for exposyre to hazards not anticipated in theoriginal permit .


provides for issuance of new permits if potential new hazards are anticipated

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(1) Time. The permit should indicate thedate(s) and time(s) the permit is valid. Permits are void once thepermit date(s)/time(s) have expired.

(2) Work. The permit should outline the specific work to be conducted in the space. If there is a change inthe scope of work or its location, a work should stop until it is evaluated if a new permit might needneeds to be issued. Work not identified on the permit should not be done without the approval of theentry supervisor and might require a new permit.


Recommended changes for clarity and to reflect good practice

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(1) Time. The permit should indicate thedate the date (s) and time(s) the permit is valid . Permits are voidonce the permit date(s)/time(s) have expired including an expiration date .

(2) Work. The permit should outline the specific work to be conducted in the space. If there is a change inthe scope of work or its location, a new permit might need to be issued. Work not identified on thepermit should not be done without the approval of the entry supervisor and might require a new permit.


Edited for clarification

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13.2.3 Pre-Entry Evaluation.

All confinedspaces confined spaces should have a pre-entry evaluation. The intent of this evaluation is tomake sure the confined space is examined before any work activity begins toconfirm to confirm the bothexisting and potential hazardous conditions do not inherently exist or will not be introduced to, or are notadjacent to, within or adjacent to the confined space . Evaluation and that the potential for hazardousconditions to arise during confined space operations is considered. The entry supervisor or a qualifiedperson trained in confined space work and the hazards existing and potential hazards should sign off onthe evaluation. If no hazardous conditions exist, work can proceed. If any hazards do exist, theentrysupervisorshould entry supervisor should complete the permit appropriately to indicating theappropriate elimination, mitigation and control measures to be implemented to ensure safe entry.


editorial changes. adds consideration of potential hazards. Provides clarification that permit provides for elimination, mitigation or control methods

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13.2.4.4.5 Grounding and Bonding.

If the confined space or the ventilation or equipment brought into the space need to be grounded If anyequipment used for confined space operations, including, but not limited to ventilation equipment; welding,grinding or cutting equipment; cleaning equipment; pumps; or compressors needs to be grounded and/ orbonded, then that information should be indicated on the permit as a control.


provide specific information on what needs to be bonded.

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13.2.6 Rescue.

Confined spacerescue methodsshould space rescue methods should be understood before entry into aconfined space. Regardless of whether a confined space has hazards or not, the owner/operator oremployer entrant employer should ensure rescue is available and appropriate to the space andoperations . All confined spaces should have a rescue incident action plan , which describes how rescuewill be attempted. The incident action plan should be available to entry supervisors, attendants, andentrants. The incident action plan should be attached to the entry permit. The Where an emergencyresponse team is required by the incident rescue plan, the team should be notified of all applicableconfined entries, including their location, hazards, and duration. The following are the four types of rescue:

(1) Self-rescue. Rescue before needing anyone's assistance.The entrant The entrants ( or attendant)identifies a prohibited or dangerous condition and exits exit under their own power. Self-rescue is nota primary rescue method that can be utilized under and should not be included in a permit.

(2) External retrieval Attendant Rescue . The attendant activates assists the entrant to vacate thespace. The attendant may activate and use a rescue system ( outside the confined space to removeor assist the entrant out ) .

(3) Rescue

available

(4) Av ailable . There is a rescue service that has been identified, evaluated, and able to respond in atimely manner should there be a need.

(5) Rescue stand-by. A rescue service is standing by the confined space, ready and equipped to makeimmediate entry.


editorial changes. information added for clarification

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13.2.7 Entrants.


(1) Name Entrants names should be printed on the entry permit.

(2) Entrant Entrants should sign the entry permit, indicating that they have been trained in confinedspace entry and have reviewed all the hazards associated with the permit-specific entry,includingwhich condition changes would require their immediate evacuation. For multiple entrants, a sign-insheet can be attached to the permit.


indicates whose name is needed. editoirial

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13.2.8 Attendant.


(1) Name Attendant's name should be printed on the entry permit

(2) The attendantshould attendants should sign the entry permit, indicating that they have been trainedin confined space entry and have reviewed all the hazards associated with the permit-specific entry.The attendant must be aware of all potential hazards in the confined space, including possiblebehavioral effects related to hazard exposure. An attendant must remain in constant contact with theentrant, until relieved by another attendant, maintain communication with the entrant, monitoractivities, and order evacuations, where needed. The attendant also performs non-entry rescue orsummons a rescue team, if necessary, andcannot and cannot perform any other duty that mightinterfere with the primary duty of ensuring the safety of the entrant. If the work or hazards change fromwhat is stated on the permit, the attendant should order entrants to vacate, re-evaluate the spaceand obtain , and advise the entry supervisor in order to issue a new permit.


editorial and for clarification of duties

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14.4 Contractor.

Owners Contractors /operators or employers subcontractors should ensure contractor permitsdocumenting air monitoring results and qualifications of their entrants are retained for at leastoneyear. least one year or longer, if required by applicable regulations or confined space programs. .


owners and not responsible for maintaining records for contractor employees. If owner issues permits, then owners will have a copy of the permit on file with this information

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15.1 Purpose.

The purpose of this chapter is to provide This chapter provides information for establishing a managementof change (MOC) system for confined spaces. An MOC system identifies and evaluates potential impactsto confined space entrants and the necessary safety measures for changes other than the replacement-in-kind type or modifications to the confined space space operations. Its purpose is to establish andimplement procedures needed to provide for continuous safe operating conditions and work practiceswhenever changes or modifications, other than changes in kind, occur in confined space classification,configuration, equipment, materials, contents, and/or work tasks content, scope of work, operatingprocedures, processes and personnel as well as changes to owner/operator and contractor confined spaceand other applicable programs, industry practices and regulatory requirements. Owners/operators shouldconduct MOC reviews whenever permanent or temporary changes impact upon confined spaces in theirfacilities .


this more explicitly details the purpose of and requirements for MOC and clarifies that changes in kind are exempted

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15.1 Purpose.

The purpose of this chapter is to provide information for establishing a management of change (MOC)system for confined spaces. An MOC system identifies and evaluates potential impacts to confined spaceentrants and the necessary safety measures for changes other than the replacement-in-kind type ormodifications to the confined space configuration, equipment, materials, contents, key personnel and/orwork tasks.


MOC also needs to include critical or key personnel

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15.2 Responsibilities and Communication for Implementing MOC.

For an MOC system to function effectively, confined space owners/operators or employers, entrants,attendants, supervisors, and rescuers and contractors/subcontractors and their employees should be ableto recognize deviations and changes that are significant enough to trigger an MOC review. Once adeviation or change triggers an MOC review, facility owners/operators or employers assign qualifiedand contractors/subcontractors should assign qualified personnel and resources to determine whatchanges, if any, are needed in the their confined space program and hazard control measures.Owners and other applicable programs. Owners /operators and contractors/subcontractors should thenimplement make appropriate the changes in their programs and procedures to ensure confined spaceoperations are conducted safely. Measures should then be implemented to eliminate, mitigate or controlany new or different hazards arising from the identified changes.


rearranged for clarity in appropriate order of action . Term contractor/subcontractor used throughout,

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Sub-Sections] ]

The MOC process should be developed, implemented, communicated, and documented by theowner/operator and contractor/subcontractor to ensure the changes and deviations affecting confinedspaces are reviewed and authorized. The MOCprocess MOC process should ensure that changes toequipment, processes, personnel, procedures, or materials affecting confined spaces are properly reviewedagainst the original confined space hazard assessment data. The MOC process, if well implemented, Atimely and correctly implemented MOC process can help prevent confined space accidents associated withchanges or modifications to confined associated with confined space work operations .


tells "who" should do this. Replaces "well" which is nebulous. adds "are" editorial

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15.3. 1 2

Upon completion of the MOC review, the person(s) conducting the review should originate and submit anMOC form to the owner/operator or contractor/subcontractor for authorization prior to implementing anychange affecting a confined space. An example management of change form is shown in Figure D.1.


15.3.1 and 15.3.2 should be flip flopped to be chronologically correct

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15.3. 2 1

Owners/operators and contractors/subcontractors should assign qualified persons familiar with theapplicable equipment, processes, materials, and operations to review the MOC form. These qualifiedpersons should identify potential MOC issues, develop preventive and protective measures, and proposechanges to the confined space program, as well as other applicable programs, for approval andimplementation by the owners/operators or contractors/subcontractors.


15.3.1 and 15.3.2 should be flip flopped to be chronologically correct

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15.3.3

After changes to the confined space program have been implemented but prior to entry into confinedspaces , the MOC form should be reviewed and authorized by reviewed by the entry supervisor prior toauthorizing entry into confined spaces . The entry supervisor should ensure all confined space programrequirements and documentation have been fully addressed or updated and , and that any changeswereimplemented and changes were consistent with the original or updated confined space classification andhazard assessment documentation prior to providing authorization for confined space entry.


rearranged for continuity and clarity

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15.4.1 Equipment Changes Affecting Confined Space.

Owners/operators and contractors/subcontractors should initiate an MOC process wherever the addition,modification , or removal of equipment might require new or revised hazard evaluations, processes,procedures, documentation, or training for the confined space work. Examples of changes to confinedspace equipment include, but are not limited to, the following:

(1) Physical configuration of the space (e.g., external or internal dimensions of space, constructionmaterials, physical condition)

(2) Entry or internal access portals and paths, including the number, size, and configurations that canaffect ingress/egress routes)

(3) Internal equipment, (e.g., agitators, dampers, piping, obstructions, safety critical equipment, systemparts, etc.)

(4) Instrumentation and monitoring (e.g., monitors, electrical controls, program/control logic or set/alarmpoints, calibration, testing, process controls, etc.)

(5) Electrical, hydraulic, pneumatic, or mechanical equipment, or change of electrical classification ofequipment

(6) Reclassification of the space so it is no longer a confined space


equipment change can create a new hazard

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15.5 MOC Completion and Verification.

Owners/operators and contractors/subcontractors should develop and implement an MOC verificationprocess to confirm that the potential safety impacts and consequences from the proposed changes ordeviations have been properly addressed. The MOC form should verify that all required MOC action itemsare complete; the confined space classification/hazard assessments have been updated; and the confinedspace program, entry procedure, and rescue plan have been revised accordingly; and the confined spaceis safe to enter . The entry supervisor should determine the requirements for safe entry, issue the necessarypermits, and ensure compliance to commence confined space operations. An MOC completion andverification process should confirm, but not be limited to, the following items:

(1) Construction and equipment in accordance with design specifications

(2) Confined space safety, operating, maintenance, and emergency procedures are in place and areappropriate for the planned activity

(3) An updated confined space classification and hazard assessment has been performed andrecommendations have been implemented before startup

(4) Requirements and authorizations in the MOC have been met

(5) Retraining, re-education, or requalification of each affected employee in regard to the the changeshas been completed and documented

(6) Assurance that all requirements and authorizations in the MOC have been fulfilled and documented


the MOC has nothing to do whit whether the confines space is safe to enter or not. This is the purpose of a permit ... which assures compliance with the changes in the applicable programs that were required by the MOC process.

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15.5 MOC Completion and Verification.

Owners/operators and contractors/subcontractors should develop and implement an MOC verificationprocess to confirm that the potential safety impacts and consequences from the proposed changes ordeviations have been properly addressed. The MOC form should verify that all required MOC action itemsare complete; the confined space classification/hazard assessments have been updated; the confinedspace program, entry procedure, and rescue plan have been revised accordingly; and the confined space issafe to enter. The entry supervisor should determine the requirements for safe entry, issue the necessarypermits, and ensure compliance to commence confined space operations. An An MOC completion andverification process should confirm, but not be limited to, the following items:

(1) Construction and equipment in accordance with design specifications

(2) Confined space safety, operating, maintenance, and emergency procedures are in place and areappropriate for the planned activity

(3) An updated confined space classification and hazard assessment has been performed andrecommendations have been implemented before startup

(4) Requirements and authorizations in the MOC have been met

(5) Retraining, re-education, or requalification of each affected employee in regard to the the changeshas been completed and documented

(6) Assurance that all requirements and authorizations in the MOC have been fulfilled and documented


This is not part of the MOC

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Public Comment No. 199-NFPA 350-2014 [ Section No. A.3.3.39 ]

A.3.3.39 Job Hazard Analysis (JHA).

For a JHA, the job is first broken into a sequence of steps. Each step should analyze some major task,which will consist of a series of movements. The analyst then looks at each series of movements within thatbasic task.

Next, all the hazards or potential hazards associated with each step are identified. It is important that theentire environment be considered to determine every conceivable hazard that might exist.

Finally, based on the basic job steps and the potential hazards, it can be determined what actions arenecessary to eliminate, control, or minimize mitigate hazards that could lead to accidents, injuries, damageto the environment, or possible occupational illness. Each safe job procedure or action must shouldcorrespond to the job steps and identified hazards.


replaces "must" (mandatory) with "should". Replaces "minimize" with "mitigate" as used throughout the guide

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Submittal Date: Sat Sep 27 15:51:22 EDT 2014


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A.3.3. 70 Span Calibration. 73 Supplier Air Respirator (SAR)

SAR units for rescue must should maintain a separate egress cylinder capable of providing enough air forsafe exit should the air hose or air supply malfunction.


corrects referenced section. replaces mandatory "must" with "should"

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A.3.3. 70 Span Calibration. 73 Supplied Air Respirator (SAR)

SAR units for rescue must maintain a separate egress cylinder capable of providing enough air for safe exitshould the air hose or air supply malfunction.


Title and reference correction

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Public Comment No. 201-NFPA 350-2014 [ Section No. A.8.4.2.5 ]

A.8.4.2.5

An example of an unseen and odorless harmful chemical would be a tank that contains, orhascontained has contained , leaded gasoline and that has not been cleaned and declared lead-vapor freemust . The interior of the tank should be cleaned to the bare metal and the atmosphere then tested forlead-in-air hazards to ensure safe entry without air-supplied respiratory protection.


editorial. corrects complete sentence. adds requirements for air supplied so dust masks are not used

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A.9.1.3

The entry supervisor and qualified ventilation specialist should understand the differences betweenventilation, purging, and inerting. They should be able to select the appropriate hazard control methodnecessary for removing or controlling a hazardous atmosphere within the confined space. While the termsare frequently used interchangeably, they are distinct hazard control methods. Ventilation generallyintroduces fresh, uncontaminated air into a space and controls atmospheric contaminants in that the spacethrough mixing and dilution. Purging uses air, steam, or inert gas to displace the air create asafe atmosphere in the space by dispersion, mixing, or dilution. Inerting is the use of an inert gas or fluegas to displace or expunge the atmosphere within the space. Purging typically uses water, fuel oil, steam,or nonreactive chemicals to physically displace the atmosphere within the space. (See Section 9.3 forguidance on appropriate methods of ventilation.)


corrects definition of purging

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A.9.2.1.2

Where relying on natural ventilation as the sole means for implementing ventilation of a confined space it isimportant that continuous , continuous or periodic atmospheric monitoring is used should be used toconfirm the conditions within the space remain safe for the duration of the entry operation.


9.2.1.2 provides for periodic also. removes mandatory "is" with "should be"

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A.9.3.4.1

For additional guidance on use of inert gases to gas-free spaces previously containing flammable liquids,see NFPA 306 or , NFPA 326 or API 2217A Inert Entry Standard .


adds definitive guide for inert entry into flammable and combustible spaces

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Public Comment No. 205-NFPA 350-2014 [ Section No. A.10.1.2.4(6) ]

A.10.1.2.4(6)

It is important that attendants be trained to recognize whether they should entrant attemptretrieval entrant retrieval .

Employers shouldensurethat should ensure that attendants understand the implications of attemptingretrieval in various situations. For example, say a significant fall takes place due to a interior collapse ofscaffolding not related to the atmospheric hazard. If the entrant is complaining of numbness of the lowerextremities, it is not prudent to extract the entrant with the retrieval system and possibly causingspinalcausing spinal injury. The attendant should know how to assess each emergency quickly as to whether thehazards or entrant's condition necessitates or even permits rapid removal. Items to be considered by theattendant in making an assessment include, but are not limited to, the following:

(1) What is the mechanism or cause of injury (atmospheric, mechanical, etc.)?

(2) What is the entrant’s chief complaint? What is the injury or illness?

(3) What is the entrant’s level of consciousness (talking coherently, disoriented, or nonresponsive)?

(4) What are the current hazards (immediately life-threatening, low-hazard, or no hazards related to theemergency)?

These and other questions can be used to perform a rapid risk-versus-benefit matrix to decide whether toattempt to retrieve an entrant from a confined space emergency where retrieval equipment is an option. Ifthe conditions are immediately life threatening and the only choice is to activate the retrieval system or thepatient is likely to die, then retrieval is the correct response. If the entrant’s condition and the hazards arenot immediately life threatening or if the entrant’s condition could be worsened by retrieval, then entryrescue might be the appropriate option and the rescue service should be notified.


editorial. corrects language

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Public Comment No. 206-NFPA 350-2014 [ Section No. A.10.1.3.4.1 ]

A.10.1.3.4.1

Tier 1 response usually involvesrescues involves rescues from spaces not addressed by regulatorystandards. While responses in such spaces might not require rescue capability of any sort, it should berecognized that medical emergencies occurring within these spaces can create difficult rescues. It isimportant that owner/operators and contractors conduct an assessment of each planned work activity todetermine requirements for a rescue capability. If there is a need for potential rescue, the owner/operator orcontractor should assess resources for a qualified rescue capability appropriate to the anticipatedemergency. All rescue resources should be available and capable of responding in a timely manner. Thisshould be addressed prior to making entry into spaces requiring Tier 1 response.


editorial.. adds contractors

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Public Comment No. 228-NFPA 350-2014 [ Section No. A.10.1.3.4.3 ]

A.10.1.3.4.3

With immediate life-threatening hazards, the speed of rescuer access to the entrant should becommensurate with the need for life-saving measures associated with cardiac arrest. It is generallyconsidered that, without intervention, cessation of heart function in normal conditions will result in at leastsome irreversible brain death within 4 to 6 minutes. This is the reasoning behind the recommendationsassociated with Tier 3 response, especially where non-entry rescue (retrieval) is not possible.

Pre-incident emergency action planning should always establish required response logistics. While Tier 3response generally suggests a single dedicated rescue team for a single space, conditions may exist thatallow a singlerescue team to address multiple entries in the same immediate area. The following should beconsidered when making this determination:

(1) The walking transition time between the most remote two entry/egress points is 1 minute or less.

(2) The team is able to divide its forces so that at least one rescuer is located at each entry/egress pointwith communications capability to allow immediate notification of other team members in the event ofan emergency or, where there are multiple entry sites in close proximity, the rescuer is able to monitora number of sites.

(3) All rescue equipment needed to perform entry rescue is set up within a suitable distance at eachentry/egress point or multiple points and every team member possesses the appropriate PPE to makeimmediate entry. For example , to provide for rescue of an entrant without rescuer vertical entry into aspace, the entrant should be equipped with a full body harness connected to a suitable A-Frame liftingdevice. Rescuers descending into the space should be similarly equipped and connected.

(4) In the event of an emergency at one entry/egress point, operations at the remaining entry/egresspoints should be terminated immediately so that the entrants exit the space and the rescue teammember attending that entry/egress point can respond to the emergency at another point within 1minute to begin or assist in rescue operations.

This may not be possible with multiple simultaneous entries monitored by only one team since Tier 3 entriesare associated with immediate life-threatening emergencies that require extremely rapid intervention.


In IDLH/inert atmospheres it is preferable that rescuers do not enter unless absolutely necessary. Rescue should be from outside the space.

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Public Input No. 707-NFPA 350-2013 [Section No. A.10.1.3.4.3]




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A.10.9.1


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Confined space rescue teams should have enough qualified members to accomplish every functionrequired to achieve the rescue objective.The size and capability of a team will depend on many factors,including, but not limited to; the condition of the entrant, the size and shape of the space, the size of theaccess opening, and the hazards present. The positions described in 10.9.1(1) through 10.9.1(5)suggestthe minimum the number of roles that should be filled be considered to perform an entry-type rescue.Many rescues will rescues may require additional functions such as ventilation, rope rescue support, orcommunication that will may require additional trained resources. Pre-incident planning of representativespaces is a key element to determining the size and capabilities of the team rescue team . TableA.10.9.1provides guidance for determining team size depending on the conditions of the space andanticipated rescue methods.

Table A.10.9.1 Confined Space Rescue Team Staffing Decision Table

IF THEN

The confined space has no obstructions or entanglement hazards andthe entrant is properly attached to a retrieval system,

One rescuer is needed to performa non-entryrescue.

The confined space has obstructions or entanglement hazards, theentrant is notattached to a retrieval system, no potential atmospherichazards exist,and vertical extraction isnot required,

Three rescuers are needed toperform an emergency entry toeffect rescue:

1 rescue attendant

2 rescue entrants

The confined space has obstructions or entanglement hazards, theentrant is not attached to a retrieval system, no potential atmospherichazards exist,and vertical extraction is required,

Five rescuers are needed toperform an emergency entry toeffect rescue:

1 rescue attendant

2 rescue system operators (withassistance from plant personnel)

2 rescue entrants

The confined space has obstructions or entanglement hazards, theentrant is notattached to a retrieval system, potential atmospherichazards exist, SARcannot be used (requiring SCBA ) and verticalextraction is not required,

Five rescuers are needed toperform an emergency entry toeffect rescue:

1 rescue attendant

2 person entry team

2 rescue entrants

The confined space has obstructions or entanglement hazards, theentrant is not attached to a retrieval system, potential atmospherichazards exist (requiring SAR ),and vertical extraction is not required,

Six rescuers are needed toperform an emergency entry toeffect rescue:

1 rescue attendant

2 rescue entrants

2 backup rescue entrants

1 air supply operator

The confined space has obstructions or entanglement hazards, theentrant is not attached to a retrieval system, potential atmospherichazards exist, SAR cannot be used (requiring SCBA ) and verticalextraction is required,

Seven rescuers are needed toperform an emergency entry toeffect rescue:

1 rescue attendant2 rescuesystem operators (with assistancefrom plant personnel)

2 rescue entrants2 backup rescueentrants

The confined space has obstructions or entanglement hazards, theentrant is not attached to a retrieval system, potential atmospherichazards exist (requiring SAR),and vertical extraction is required,

Eight rescuers are needed toperform an emergency entry toeffect rescue:

1 rescue attendant

2 rescue system operators (with


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IF THEN

assistance from plant personnel)

2 rescue entrants

2 backup rescue entrants

1 air supply operator

An employee activates a fall arrest system and is suspended in aharness requiring rope rescue,

Four rescuers are needed toperform a pickoff rescue:

1 rescue attendant

2 rescue system operators (withassistance from plant personnel)

1 rescuer


see A10.9.1(1) As A10,9,1 is written (before changes) this would require a mandatory minimum number of rescuers per situation. The minimum is determined by the confined space program and rescue program in effect for the space and intended entry/work...not by a table. The table is just a guide as stated at the very end

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Public Comment No. 395-NFPA 350-2014 [ Section No. A.11.1 ]

A.11.1 Possible Crossover of Responsibilities for Persons involved in Confined Space Entry

All personnel engaged in confined space–related activities may have responsibilities in addition to theirprimary assignment provided that they are trained, educated, or qualified in accordance with therequirements of Chapter 11. Table A.11.1 lists some, but not all, possibilities:

Table A.11.1 Possible Crossover of Responsibilities for Persons involved in Confined Space Entry

TitlePossible Additional

Responsibilities/CompetenciesNotes

Entrant Gas tester, rescuer Entrants should know how to performself-rescue.

Attendant Entry supervisor, rescuer, gas tester,ventilation specialist, isolationspecialist

It is best practice fort he attendant to haveno other duties, however If performingother duties that interfere with the primaryattendant duties, assigned attendantshould be relieved by another qualifiedattendant.

Entry Supervisor Entrant, rescuer, gas tester,ventilation specialist, isolationspecialist

Designated entry supervisor may performmultiple tasks if qualified to do so,including, but not limited to, entering thespace for inspection or atmospherictesting, checking isolation andde-isolation, approving ventilation, issuingpermits, and assisting rescue. The entrysupervisor should be qualified in multipleareas in order to ensure that eachrequirement of the permit continues to bemet during entry operations.

Rescuer Entrant, gas tester, isolationspecialist, standby worker

All rescuers (except those restricted torescue from outside the space) should bequalified as entrants. Rescuers may alsoneed to conduct atmospheric testing orcheck that isolation has not failed prior toentry. Rescuers assigned to be on sitemay perform other duties, if qualified,when not engaged in rescue operations.

Gas tester Entrant, isolation specialist,attendant, standby worker

Gas testers entering spaces should bequalified as entrants. Gas testers mayperform other duties, if qualified, when notconducting atmospheric testing.

Owner/operator,contractor/subcontractor

Entry supervisor, isolation specialist,ventilation specialist, entrant,attendant, gas tester, standbyworker, rescuer

Owners/operators andcontractors/subcontractors may performany confined space activities for whichthey are qualified.


Need to stress this point again, so the appendix and main text match

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Public Comment No. 87-NFPA 350-2014 [ Chapter E ]

Annex E Informational References

(Just a general comment on the whole document. This document provides a good basis for entry intolandside spaces and goes above and beyond the OSHA requirements. However, I believe it is toowordy and has many repetitive sections. During the review I suggest that the editors try to shorten thedocument and make it concise while maintaining basic information. In my opinion it should be written asa standard with checklists. In some sections it appears to be more of a novel. The definition sectionshould be more developed so when you are reading the standard you can refer back to it. Also, in thesection where the responsibilities are defined they should not be defined again later in the document.However, as a technical committee member I know how difficult this effort is and this is an outstandingfirst cut.)


Just a general comment on the whole document. This document provides a good basis for entry into landside spaces and goes above and beyond the OSHA requirements. However, I believe it is too wordy and has many repetitive sections. During the review I suggest that the editors try to shorten the document and make it concise while maintaining basic information. In my opinion it should be written as a standard with checklists. In some sections it appears to be more of a novel. The definition section should be more developed so when you are reading the standard you can refer back to it. Also, in the section where the responsibilities are defined they should not be defined again later in the document. However, as a technical committee member I know how difficult this effort is and this is an outstanding first cut.

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