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Title:	Confined Space Hazards and Controls
Publication date:	8/18/2020
Effective date:	8/18/2020

BRIEF

Policy Summary

The Confined Space Program at Lawrence Berkeley National Laboratory (Berkeley Lab) ensures that employees who work in Confined Spaces, including Permit-Required Confined Spaces, are able to perform work safely.
A Confined Space is a space that:

Is large enough and so configured that an employee can bodily enter and perform assigned work.
Has limited or restricted means for entry or exit (for example, tanks, vessels, silos, storage bins, hoppers, vaults, and pits are spaces that may have limited means of entry).
Is not designed for continuous employee occupancy.

Who Should Read This Policy

Berkeley Lab employees, visitors, affiliates, and subcontractors who could be performing work that may include entry into a space that has been evaluated for classification as a Permit-Required Confined Space or that may be a Permit-Required Confined Space.

To Read the Full Policy, Go To:

The POLICY tab on this wiki page

To Read the EHS Program Details, Go To:

ES&H Manual Chapter 34

Contact Information

EHS Subject Matter Expert for Confined Space
EHS Division

Title:	Confined Space Hazards and Controls
Publication date:	8/18/2020
Effective date:	8/18/2020

POLICY

A. Purpose

The Confined Space Program at Lawrence Berkeley National Laboratory (Berkeley Lab) ensures that employees who work in Confined Spaces, including Permit-Required Confined Spaces, are able to perform work safely.
A Confined Space is a space that:

Is large enough and so configured that an employee can bodily enter and perform assigned work.
Has limited or restricted means for entry or exit (for example, tanks, vessels, silos, storage bins, hoppers, vaults, and pits are spaces that may have limited means of entry).
Is not designed for continuous employee occupancy.

B. Persons Affected

This policy applies to Berkeley Lab employees, visitors, affiliates, and subcontractors who could be performing work that may include entry into a space that has been evaluated for classification as a Permit-Required Confined Space or that may be a Permit-Required Confined Space.

C. Exceptions

Pits, excavations, trenches, and Confined Spaces entered by subcontractors under the subcontractor's approved Permit-Required Confined Space Program may be managed by Berkeley Lab's Construction Safety Program under the requirements of Title 8, California Code of Regulations, Construction Safety Orders, and General Industry Safety Orders, Article 108, Confined Spaces, Section 5157, which is the functional equivalent to 29 CFR 1910.146.

D. Policy Statement

A Confined Space is a space that:
1. Is large enough and so configured that an employee can bodily enter and perform assigned work.
2. Has limited or restricted means for entry or exit (for example, tanks, vessels, silos, storage bins, hoppers, vaults, and pits are spaces that may have limited means of entry).
3. Is not designed for continuous employee occupancy.
During work planning, Activity Leads must review the work area for potential Confined Spaces. Any potential Confined Space must be checked against the Confined Space inventory to determine classification of the space (Work Process A). The classifications will be:
1. Not a Confined Space (NCS).
2. Non-permit Confined Space (NPCS).
3. Permit-Required Confined Space (PRCS).
If the space is not listed in the inventory, the space must be classified by the Confined Space Manager (Work Process B).
If the space is classified as NCS, work proceeds according to the Safe Work Authorization process (Work Process C).
If the space is an NPCS or an Alternate Entry Procedure can be used, review training and qualifications (Work Process D).
If the space is a PRCS and cannot be reclassified, subcontractors must perform the work (Work Process E).
Review all Confined Space Entry Training Procedures (Work Process F)
Berkeley Lab staff, affiliates, visitors, and others who perform work at Berkeley Lab (excluding subcontractors operating under their own approved Permit-Required Confined Space Program) may not enter any PRCS unless:
1. The hazards within have been eliminated and the PRCS has been reclassified for non-permit entry or
2. The only hazard in the PRCS is an actual or potential hazardous atmosphere, that condition is controlled through continuous ventilation, and the entry is performed under an Alternate Entry Procedure E.

Roles and Responsibilities

Role	Responsibility
Division Director	Assures that entries into PRCSs under his or her division's control are made only in accordance with this chapter.
Environment, Health & Safety (EHS) Division	Administers the Berkeley Lab Confined Space Program. Provides training (Work Process F) to Berkeley Lab personnel involved in entry into Confined Spaces. Designates the Confined Space Program Manager. Conducts ongoing program effectiveness review and assurance (Work Process G).
Confined Space Manager	Classifies spaces as Not a Confined Space (NCS), a Non-permit Confined Space (NPCS), or a Permit-Required Confined Space (PRCS). Maintains the LBNL Confined Space Inventory. Designates Entry Supervisors. Develops Safe Work Procedures (SWPs) for work in spaces in consultation with space owners and entrants. Stops work if any hazards are not adequately controlled. Reviews PRCS Reclassification Certifications, PRCS Alternate Entry Procedure Certifications, and Subcontractor PRCS Permits. Reviews Subcontractor PRCS programs and provides comments to the Activity Lead.
Activity Leads	Review the work area and determine whether spaces that must be entered are included in the LBNL Confined Space Inventory. Review the LBNL Confined Space Inventory and determine whether an SWP exists for work in that space. For activities involving Berkeley Lab employee or affiliate entry into inventoried spaces, assign a properly trained and qualified Entry Supervisor for any entry into a PRCS and assure that entry proceeds only in accordance with Work Process B, Classification of Spaces. For activities involving subcontractor entry into inventoried spaces: Obtain review and approval from the Confined Space Program Manager. Approve Subcontractor PRCS programs and procedures. Co-approve (with the Construction Safety Entry Supervisor) documentation prepared by subcontractors for entry into PRCSs. Documentation includes but is not limited to Reclassification or Alternate Entry Procedure Certification, entry permit, coordination procedures, and authorizations. Assure that entry proceeds only in accordance with Work Process D, Entry into Inventoried Spaces by LBNL Employees or Affiliates (Does Not Include Subcontractors), and Work Process E, Entry into Inventoried Spaces by Subcontractors. Immediately report to the Confined Space Program Manager: Any unauthorized entry into a PRCS. Detection of any hazard in a PRCS that is not covered in the permit. Detection of a condition prohibited by the permit. Occurrence of an injury or near-miss during entry. Change in use or configuration of the permit space. Employee complaints about the effectiveness of the program. Activity Leads are NOT Entry Supervisors unless they have been separately so designated by the Confined Space Program Manager.
Entry Supervisors	Operate only in PRCSs within their specific area of technical expertise. Assure that entries into PRCSs at Berkeley Lab are made only as provided in this document and applicable regulations. See Work Process B, Classification of Spaces. Reclassify PRCSs to NPCSs and authorize entry thereto, or authorize entry into PRCSs via an Alternate Entry Procedure, as permitted by this program. Remove all entrants from the space whenever conditions change to create a hazard. Forward completed PRCS Reclassification Certification (Appendix C) and PRCS Alternate Entry Procedure Certification (Appendix D) to the Confined Space Program Manager after expiration of the certification. Immediately report to the Confined Space Program Manager: Any unauthorized entry of a PRCS. Detection of any hazard in a PRCS that is not covered in the permit. Detection of a condition prohibited by the permit. Occurrence of an injury or near-miss during entry. Change in use or configuration of the permit space. Employee complaints about the effectiveness of the program.
Construction Safety Entry Supervisors	Review, concur on adequacy, and co-approve (with the Activity Lead) documentation prepared by the subcontractor for entry into PRCSs. Documentation includes, but is not limited to, Reclassification or Alternate Entry Procedure Certification, entry permit, coordination procedures, and authorizations. Fulfill roles and responsibilities of "Entry Supervisor" above.
Subcontractors	Conform to the requirements of applicable regulations and this ES&H Manual chapter.

F. Definitions/Acronyms

Term	Definition
Confined Space	A space that: Is large enough and so configured that an employee can bodily enter and perform assigned work. Has limited or restricted means for entry or exit (for example, tanks, vessels, silos, storage bins, hoppers, vaults, and pits are spaces that may have limited means of entry). Is not designed for continuous employee occupancy.
Non-permit Confined Space	A Confined Space that does not contain or, with respect to atmospheric hazards, have the potential to contain any hazard capable of causing death or serious physical harm.
Permit-Required Confined Space	A Confined Space that has one or more of the following characteristics: Contains or has a potential to contain a hazardous atmosphere. Contains a material that has the potential for engulfing an entrant. Has an internal configuration such that an entrant could be trapped or asphyxiated by inwardly converging walls or by a floor that slopes downward and tapers to a smaller cross-section. Contains any other recognized serious safety or health hazard.
Eliminated	Removed by a means that does not require active intervention to maintain. For example, Lock Out/Tag Out of rotating machinery or physical blocking of a hydraulic ram would be considered elimination. Traffic control or continuous forced-air ventilation would not be considered elimination.

G. Recordkeeping Requirements

Role	Recordkeeping Requirement
Subject Matter Expert	LBNL Confined Space Inventory
EHS Division	Training Records (presentations and rosters)
Subject Matter Expert	Program Effectiveness Review and Assurance documents
Subject Matter Expert	PRCS Reclassification Certificates
Subject Matter Expert	PRCS Alternate Entry Procedure Certificates
	See ES&H Manual Chapter 6, Safe Work Authorizations, for records related to Safe Work Procedures.

H. Implementing Documents

Document Number	ES&H Manual Reference	Title	Type
07.07.006.001	Ch. 34	Confined Spaces	Program
07.07.006.002	Ch. 34, Work Process A	LBNL Confined Space Inventory	Work Process
07.07.006.003	Ch. 34, Work Process B	Classification of Spaces	Work Process
07.07.006.004	Ch. 34, Work Process C	Safe Work Procedures	Work Process
07.07.006.005	Ch. 34, Work Process D	Entry into Inventoried Spaces by LBNL Employees or Affiliates (Does Not Include Subcontractors)	Work Process
07.07.006.006	Ch. 34, Work Process E	Entry into Inventoried Spaces by Subcontractors	Work Process
07.07.006.007	Ch. 34, Work Process F	Training	Work Process
07.07.006.008	Ch. 34, Work Process G	Program Effectiveness Review and Assurance	Work Process

I. Contact Information