Stanford University

Non-Permit Confined Spaces

California records an average of six deaths in confined spaces annually, 60% of which are would-be rescuers. Stanford employees may risk their health and lives by entering permit-required confined spaces with hazardous atmospheric conditions and/or physical safety hazards, including in sewers, vaults, storm drains, tanks, boilers, crawl spaces, acid pits, pipelines, bins, tubs, ducts, and vessels entered for repairs, inspection, and maintenance. See the Permit-Required Confined Spaces subtopic for more information.

Permit-required confined spaces (permit spaces) have at least one of the following characteristics:

  • Contain, or have the potential to contain, a hazardous atmosphere
  • Contain a material that has a potential for engulfing an entrant
  • Have an internal configuration such that an entrant could be trapped or asphyxiated by inwardly converging walls, or by a floor that slopes downward and tapers to a smaller cross section
  • Contain any other recognized serious safety or health hazard

Note that if any of the above characteristics is present, the space shall be classified as a permit-required confined space.

The Confined Space Program shall conform to Cal/OSHA requirements, which requires a written program. Where the word “shall” is used in this manual, requirements are mandatory by regulation.

These and other pertinent definitions pertaining to the Confined Space Program can be found in the Cal/OSHA Confined Spaces Regulations.

Responsibilities
  1. The responsibilities outlined below pertain to the administrative functions of the Confined Space Program, and should not be confused with the responsibilities of individuals performing permit-required confined space operations (e.g. entry supervisors, attendants, and entrants).

    Supervisors

    Supervisors (e.g. shop supervisors and facilities managers) are responsible for implementing and managing the Confined Space Program in their work area. Their responsibilities include:

    • Completing training to make confined space assessments
    • Labeling all permit-required confined spaces, or restricting access by other equally effective means (as instructed by EH&S)
    • Identifying hazards for each confined space by examining:
      • Past and current uses
      • Physical characteristics and configuration
      • Potential hazards (e.g. oxygen deficiency, flammability, toxicity, biological, mechanical, electrical, etc.)
    • Identifying all confined spaces which employees are required to enter, then providing a current inventory to EH&S
    • Informing employees and contractors working under their supervision of the existence, location, and dangers of all permit-required confined spaces, preventing entry into those spaces by unauthorized or unqualified personnel, and documenting all communications
    • Ensuring appropriate training is provided for all employees who will be entering confined spaces and maintaining employee confined space training records
    • Establishing a system for using entry permits and maintaining these records for one year
    • Providing equipment necessary for employees to perform work safely

    Employees

    Employees are responsible for:

    • Performing their duties in accordance with training received
    • Reporting any concerns or difficulties regarding the Confined Space Program to their supervisor

    Department of Environmental Health and Safety (EH&S)

    EH&S is responsible for the development, secondary implementation, and administration of the Confined Space Program. This involves:

    • Developing a Confined Space Evaluation Form to identify confined spaces, and assisting supervisors with evaluation, identification, and associated hazards
    • Developing a universal identification system to catalog confined spaces
    • Standardizing the selection of confined space entry equipment
    • Reviewing, updating, and evaluating the overall effectiveness of the Confined Space Program
    • Rendering a final determination of confined space classification when there is confusion or controversy
    • Assisting the supervisor in developing special procedures for handling hazards created by unique operations (e.g. cleaning and decontaminating work areas and equipment, performing hot work, inerting an atmosphere, etc.)
    • Providing confined space and permit-required confined space training, either internally or by outside consultants

    Project management

    • Project managers, zone managers, supervisors, and construction managers must ensure compliance with the Program, particularly with the section below regarding hiring and oversight of outside contractors who will be conducting confined space entry operations.
    • Departmentally-managed projects which involve confined space operations must also comply with the Program and must be approved by Facilities Project Management via the Departmentally Managed Project Release Memo.

    Contractors

    For some projects, contractors and subcontractors perform construction, maintenance, and related activities requiring entry into permit-required confined spaces. The University reserves the right to audit compliance with contractor specifications and suspend or terminate any contractor operation that is not in compliance.

    University responsibilities

    When contractors perform work that involves permit-required confined space entry, the Stanford University representative (e.g. supervisor, project manager, zone manager, etc.) shall:

    • Inform the contractor that the workplace contains permit-required confined spaces and that entry into those spaces is allowed only through compliance with 8 CCR 5156 – 5158
    • Apprise the contractor of any identified hazards and of Stanford’s experience with the space(s)
    • Apprise the contractor of any precautions or procedures that have been implemented for the protection of Stanford employees in or near permit-required confined spaces where contractor personnel will be working
    • Coordinate entry operations with the contractor when both Stanford employees and contractors will be working in or near permit-required confined spaces
    • Debrief the contractor after the entry operations regarding the program followed, and any hazard confronted or created by the contractor in the permit-required confined space during entry operations

    Additionally, the University must:

    • Inform the contractor that rescue services will not be provided by University employees. The contractor must establish site-specific coordination for rescues with the Palo Alto Fire Department (PAFD) or other rescue services compliant with regulations
    • Inform the contractor that the University will not provide, rent, or loan any instruments, safety equipment, or rescue equipment to any contractor. If the contractor is not properly equipped, the operation must not commence until the contractor remedies the situation

    Contractor responsibilities

    In addition to complying with the permit-required confined space requirements that apply to all employers, each contractor who is retained to perform permit-required confined space entry operations shall:

    • Obtain any available information regarding permit-required confined space hazards and entry operations from Stanford
    • Coordinate entry operations with Stanford when both Stanford and contractor personnel will be working in or near the permit-required confined spaces
    • Inform Stanford of the program that they will follow and of any hazards confronted or created in the permit-required confined spaces, either through a debriefing or during the entry operation
    • Comply with all applicable federal, state, and local regulations regarding confined space operations

    Additionally, contractors must:

    • Adhere to their company’s own confined space program
    • Use their own entry permits, monitoring equipment, rescue equipment, and ventilation equipment
    • Assign their company’s own personnel (e.g. attendant or entry supervisor)

    EH&S reserves the right to review the contractor’s confined space program, entry procedures, and associated equipment. EH&S may terminate the contractor’s entry operation if it is deemed unsafe or unsatisfactory for any reason.


Workplace Evaluation
  1. Determination of confined spaces

    A determination as to whether any spaces are permit-required confined spaces shall be conducted, with all spaces assigned one of three classifications:

    • Not a confined space
    • Non-permit-required confined space
    • Permit-required confined space

    Use the Confined Space Evaluation Worksheet to complete the determination.

    Reclassification of confined spaces

    Non-permit-required confined spaces may be reclassified as permit-required confined spaces when/if:

    • There are changes in the use or configuration of a non-permit-required confined space that might increase the hazards to entrants.
    • Hazards arise within a non-permit-required confined space which had been previously classified as a permit-required confined space. If this occurs, employees shall exit the space and the space’s classification shall be re-evaluated.

    A permit-required confined space may be reclassified as a non-permit-required confined space if all of the following conditions are met:

    • The permit-required confined space poses no actual or potential atmospheric hazards.
    • All hazards within the space are eliminated without entry into the space (for as long as the hazards remain eliminated). This includes any recognized health and safety hazards such as engulfment in solid or liquid material, electric shock, or moving parts.
    • Testing and inspection during the entry demonstrate that the hazards within the permit-required space have been eliminated (for as long as the hazards remain eliminated).

    Documentation of reclassification of confined spaces

    • The basis for determining that all hazards in a permit-required confined space have been eliminated shall be documented with a certification.
    • The certification shall contain the date, the location of the space, and the signature of the person making the determination.
    • This certification shall be made available to each employee entering the space.

    Posting of confined spaces

    • Danger signs must be posted (or other equally effective means used) to inform exposed employees of permit-required confined spaces.
    • Signs must read: “Danger – Permit-Required Confined Space, Do Not Enter.”

    Confined spaces at Stanford University

    The following are examples of confined spaces on campus:

    Permit-required:

    • Manholes (some or all)
    • Tanks (some or all)
    • Boilers (some or all)

    Non-permit-required:

    • Attics (some)
    • Crawlspaces (some)
    • Plenums (some)
    • Mechanical rooms (some)

    Note that the locations of confined spaces and permit-required confined spaces at Stanford are currently under review.

    Elevator mechanical spaces

    • Elevator mechanical spaces at Stanford University are generally considered confined spaces, but are not generally considered permit-required confined spaces.
    • If a hazardous or potentially hazardous atmosphere exists (e.g. a chemical leak, spill, or welding) within or in close proximity to an elevator pit, the pit will be reclassified as a permit-required confined space for the duration of the event. Employees who enter the pit under these circumstances must perform operations in accordance with Stanford University’s Confined Space Program and 8 CCR 5157.

Training
  1. General training for employees conducting non-permit-required confined space operations

    All employees who may participate in a confined space operation shall be trained. The training will address how to:

    • Identify and locate confined spaces
    • Recognize potential hazards
    • Recognize the effects of confined space hazards
    • Use personal protective equipment
    • Follow evacuation and rescue procedures

    Training for employees conducting permit-required confined space operations

    All employees who may participate in a permit-required confined space operation must additionally be trained in permit-confined space duties (i.e. in the roles of authorized entrants, attendants, and entry supervisors). The training will address:

    • Entry permit system and designation of personnel responsible for assigned duties
    • Maintenance, including calibration and testing, of air monitoring instruments
    • Preparations and protocol for atmosphere monitoring
    • Equipment isolation (lockout/blockout/tagout)
    • Purging and the use of forced mechanical ventilation
    • Use of rescue equipment and techniques

    Training schedule

    Employees shall be trained according to the following schedule:

    • Before they are assigned duties associated with the confined space operation
    • Before there is a change in their assigned duties
    • Whenever there is a change in permit-required confined space operations that presents a hazard about which an employee has not previously been trained
    • Whenever there are changes to the confined space entry procedures or problems with the employees’ knowledge of the procedures

    Training records

    • A document shall certify that training has taken place and will contain the employee’s name, signature of trainer(s), and training dates.
    • Supervisors shall keep records of health and safety training received by employees for at least three years, except for training records of employees who have worked for less than one year, which are provided to the employee upon termination of employment in accordance with Stanford’s Illness and Injury Prevention Program and 8 CCR 3203.

Program Evaluation
  1. EH&S shall review the Confined Space Program annually using canceled permits. EH&S must also review the Program if either the shop supervisor or EH&S believes that the entry procedures are not protecting employees adequately.

    The program must be revised, and deficiences corrected, before any entries are allowed.

    Examples of inadequacies include:

    • Unauthorized entry into a permit-required confined space
    • Detection of a hazard not listed in the permit
    • Detection of a condition prohibited by the permit
    • Injury or near miss during entry
    • Change in use or configuration of a confined space
    • Employee complaints about the Program’s effectiveness


Back to Top