University of California, Irvine (UC Irvine)
facilities have a variety of workspaces that have been identified as
confined spaces. Limited groups of UC Irvine employees will encounter
work that requires entry into a confined space. All employees that
participate or have duties in the Confined Space Management Program
will receive training to ensure that each individual has the understanding,
knowledge and skills necessary to safely perform all permit-required
confined space operations. Coordination of confined space work is the
responsibility of the department performing the work and Environmental
Health and Safety (EH&S), and is governed
by this Confined Space Management Program.
This Confined Space Management Program involves
training, signage and safety equipment, as appropriate; to be sure
that employees are kept vigilant in their work in and around confined
spaces and do not inadvertently or innocently enter into a confined
space. The potential for serious injury is high, thus it is important
that UC Irvine employees who may enter any confined space work with
EH&S to ensure that all necessary
safety precautions are considered and taken.
Employees who must enter confined spaces will receive training according
to the following schedule:
The Confined Space Management Program has been developed so that all
confined spaces at UC Irvine have been identified, evaluated and properly
labeled. It is our goal that UC Irvine employees work safely in all confined
Procedures for entering confined spaces are
established and enforced by the department performing the work and
EH&S, and apply to employees
who must enter the spaces.
The purpose of this program is to identify, document, evaluate, and
properly label all confined spaces on the UC Irvine campus, and to
allow only trained and authorized personnel enter such spaces. This
program also provides guidelines for all entries into confined spaces
on UC Irvine grounds and facilities to be accomplished in a safe and
healthful manner. Coupled with the required training and skills, this
program provides employees with the understanding, knowledge and skills
necessary to perform permit-required confined space entries.
The following individuals have responsibilities as part of the UC
Irvine confined space program.
4.1 Identifying Confined Spaces and Permit-Required Confined Spaces
UC Irvine identifies and evaluates workspaces to determine if any
are confined spaces.
The following three questions must be asked about each space being
evaluated for the purpose of determining if it is a confined
space . To meet the definition of a confined space,
it must meet all three of the following criteria:
- The space 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
- Is not designed for continuous employee occupancy.
If the answer to any of the three criteria
is “NO”, the space is
not considered a confined space and the regulation does not apply
to that situation.
If the space is deemed a confined space
according to the criteria above (answering “YES” to all three
above questions), it then must be determined if it meets the
definition of a permit-required confined
space. If the space is deemed to be a permit-required confined space,
employee entry is covered by Cal/OSHA (8 CCR 5157 (California Code
of Regulations)) unless it is a telecommunications utility manhole
or electrical vault. Telecommunication utility manholes/vaults are
regulated under Cal/OSHA 8 CCR 8616.
The employer must determine the hazard potential of a confined space
by asking these four additional questions about the space to determine
if it is permit-required. A permit-required confined space
means a space that has one or more of the following characteristics:
- Contains or has the potential to contain a hazardous
- Contains a material that has the potential for engulfing
- Has an internal configuration such that an entrant could
be trapped or asphyxiated by inwardly converging walls
or by a floor which slopes downward and tapers to a smaller
- Contains any other recognized serious safety or health
If the space meets ANY of the
four criteria, then the space has a “high
hazard potential” and is a permit-required confined space. A permit
system must be implemented according to Cal/OSHA regulations.
If all four criteria can be answered “NO”,
then the confined space is not considered permit-required and a
permit system is not required for a space of that type under the
These questions are generally applied to any hazards inherent in the
space or hazards in the surrounding area that may affect conditions
in the confined space. If entrants are to bring hazardous materials
into the space (e.g., welding gear, chemical cleaners, paints) then
a non-permit-required confined space may be temporarily reclassified
as a permit-required confined space.
4.2 Evaluating Permit-Required Confined Spaces
After identifying the spaces, the department performing the work
and EH&S are also responsible for performing and documenting an initial
evaluation/risk assessment. A Confined
Space Hazard Analysis form (Appendix A) can be used to document this information. Current copies of the
permit-required confined spaces list are to be kept in the department
performing the work and EH&S files. This list will be included
in the written Confined Space Management Program. Spaces should be
4.3 Labeling Confined Spaces
Based on the hazard evaluation, confined spaces are designated as
4.4 Entry into Confined Spaces
4.4.1 Permit-Required Confined Space Entry
Entry into a designated permit-required confined space is regulated
and can be accomplished by fulfilling all the requirements on the
Permit-Required Confined Space Entry
Permit (Appendix C) . For
Facilities Management activities, the permit must be completed
and signed by the job site's Supervisor, signed by the Trade's
Supervisor, and reviewed and signed by EH&S. For all other departments, the permit must be completed
and signed by the entrants' supervisor, and reviewed and signed by
EH&S. The permit must be posted at the job site throughout the
duration of the project and returned to the department performing the
work and to EH&S at the end of the project.
4.4.2 Non-Permit Required Confined Space Entry
Entry into a designated non-permit-required confined space is not
regulated and can be accomplished without a permit if the following
conditions are met:
- Prior to entry, a pre-entry checklist
for non-permit required confined space (Appendix B) must be filled out by
the person intending to enter the non-permit-required confined
space. This is to ensure that the space still meets the definition
of a non-permit required confined space. The form is also available
- If hazardous operations are to be conducted in
the space (e.g., welding, painting), the entrant must notify
who will evaluate the operations and determine if entry will
need to be conducted as an entry into a Permit-required confined
space. No UC Irvine employees are permitted to enter the space
under these conditions, and the entry must be performed in accordance
with this permit-required confined space program.
- The opening of the confined space shall be guarded by
a railing, temporary covers, or other barriers to prevent an
accidental fall and to protect workers in the space, as well as
people who are passing by the space.
- Proper personal protective equipment will be
used when EH&S deems necessary.
- Entrants have completed all training as required in Section
- All persons participating in the confined space entry
program understand and fulfill their respective Confined Space
Management Program responsibilities.
4.4.3 Permit-Required Confined Space Entry – Alternate Entry
If the space is defined as a permit-required confined space and
the only hazard posed by the permit space is an actual or potential
hazardous atmosphere, steps can be taken to enter this space under “Alternate
Entry Procedures.” Contact EH&S for assistance in determining
if alternate entry procedures may be used to enter a permit-required
4.4.4 Permit-Required Confined Space Entry – Reclassification
- An area classified as a permit-required confined
space may be temporarily reclassified as a non-permit space, if it poses
no actual or potential atmospheric hazards and if all hazards within
the space are eliminated without entry into it.
- Contact EH&S to assist in the reclassification
of a permit-required confined space.
- A written reclassification shall be created, signed,
and kept on file by the department performing the work and
- If all hazards are completely eliminated (i.e., no remaining
potential), the space can be considered a non-permit-required
space for the duration of the entry as long as the hazards remain
- Any change in the space resulting in re-introduction
of hazards will require the space to be vacated and re-assessed.
Entry will not be allowed until all hazards are eliminated.
4.5 Rescue Procedures and Emergency Services
4.5.1 Entry Rescue
- In case rescue is needed for a permit-required
confined space entrant, emergency services must immediately
be called by dialing 911 from a campus or external telephone. The
nearest available Fire Department will respond to the call. UC
Irvine has coordinated with the campus Orange County Fire Authority
(OCFA), and they have trained staff in permit-required confined
- Rescue services must be made immediately
available for all confined entries as UC Irvine employees in
various departments may be required to enter Permit-required confined
spaces on campus.
- If a contractor decides to enter a permit-required
confined space under their own Confined Space Management Program,
they must comply with the requirements for an immediately available
and properly trained rescue capability.
- Rescue equipment will be stored in the area
where the work performed by employees in that area will most
likely change the status of a confined space
- Although not required for non-permit entries,
UC Irvine has non-entry extraction equipment to be used over
the most-commonly-entered spaces (electrical vaults, manholes
and pressure vessels).
- When performing a vertical non-permit-required
entry (after reclassification of a permit space), the person
entering the space must wear a four-point full body harness with
a D-ring attached to the back.
- The extraction device would be connected
to the D-ring and would be attended by a second person (a buddy,
who is present for the non-permit entry and has been trained
in the operation of the extraction device).
- Should an unforeseen event occur (medical,
injury, etc.), the extraction equipment can be used to safely
and quickly remove a person from the space.
- The extraction device(s) must be regularly
inspected, certified, and maintained as required.
Required documentation for the Confined Space Management Program
at UC Irvine is maintained by the department performing the work and
EH&S and includes;
Training Requirements and Competency Assessment
All UC Irvine employees who participate or have duties in the Confined
Space Management Program will be trained so that each individual
has the understanding, knowledge, and skills necessary to assure
the safe performance of all confined space operations.
Confined Space training will be provided
by EH&S for UC Irvine
authorized employee entrants:
- Before the employee is first assigned to perform or
participate in a permit-required confined space entry;
- Before the employee is expected to perform duties during
confined space operations for which the employee has not previously
been trained; and,
- When it is determined that an employee has insufficient
knowledge or skills to perform assigned duties.
Irvine's Permit-required confined space entry training (Appendix
E) program establishes a minimum level of proficiency for each duty
to be performed in permit-required confined space entry operations.
Employees who successfully complete training on UC Irvine's Confined
Space Management Program will receive a formal training certificate
that indicates the employee's name, type of training received, dates
of training, and the signature of the trainer.
Refresher confined space entry training will be provided to UCI
employees every three years.
and External References
Code of Federal Regulations, Title 29 (29CFR), Standard 1910.146,
Permit Required Confined Space
Title 8, California Code of Regulations (8CCR), Section 5157, Permit
Required Confined Spaces
The definitions of key words used in this document are provided below:
Acceptable Entry Conditions: Environmental conditions
inside a permit-required confined space where there are no atmospheric
component(s) potentially hazardous to health or safety.
Attendant: A person designated to remain outside
the permit-required confined space and monitor conditions for any health
or safety impacts and perform the attendant's duties as described on
the entry permit.
Authorized Entrant : A person who has been
determined to be medically and physically capable to perform work in
a permit-required confined space and has the appropriate training and
certification for that entry. An authorized entrant requires training
when he or she is initially assigned to the job, and periodically,
when there is a change in personnel or process.
Blanking, Blinding, Line Blank : The absolute
closure of a gas or liquid filled line, pipe, or duct by the fastening
of a solid plate that completely seals the bore and is capable of withstanding
the maximum pressure of the line, pipe, or duct without leaking.
Confined Space: A space that has all of the following
- It is large enough and so configured that a person can
bodily enter; and
- It has limited or restricted means for entry or exit;
- It is not designed for continuous occupancy.
Confined spaces can be classified into two categories:
- Low-hazard confined space; and
- High-hazard permit-required confined space.
Low-hazard confined spaces are those confined spaces that do not contain
or have the potential to contain any atmospheric or other hazards capable
of causing death or serious physical harm. A low-hazard permit-required
confined space may become a high-hazard confined space if there are
hazardous materials brought into the space or if hazardous activities
are conducted in the space.
Permit-required confined spaces are those spaces that contain high
hazards and are based on their inherent hazard potential. For a high-hazard
permit-required confined space, an entry permit is used to ensure proper
hazard evaluation, safe entry, safe work and safe exit.
Emergency : Any occurrence or event internal
or external to the permit-required confined space that could endanger
the entrants, or any condition not permitted on the entry permit. This
includes any failures of hazard control, monitoring, communication,
or lighting equipment.
Emergency Rescue : The procedures by which
persons incapable of self-rescue are removed from a permit-required
Emergency Services : Local fire, police
and ambulance departments are responsible for emergency response and
emergency rescue efforts.
Emergency Conditions : Any permit-required
confined space situation where any airborne material encountered that
is measured or estimated to be at its Immediately Dangerous to Life
and Health (IDLH) or 10% Lower Explosive Limit (LEL) value is considered
an emergency condition - no entry will be made and the situation must
be mitigated by trained emergency response personnel.
Engulfment : The surrounding and effective
capture of a person by a liquid or finely divided (flowable) solid
substance that can be inhaled to cause death by filling or plugging
of the respiratory system or that can exert enough force on the body
to cause death by strangulation, constriction, or crushing.
Entry : (into a permit-required confined
space) - When any part of a person's body passes through the plane
of the opening of the space.
Entry Permit - The written or printed document that
is used to allow and control entry into a permit-required confined
Entry Supervisor - The person who is responsible
for contacting and working with EH&S and determining if acceptable
entry conditions are present for entry, for authorizing entry, overseeing
entry operations, and terminating any permit-required confined space
Hazardous Atmosphere, Potentially Hazardous Atmosphere -
An atmosphere that has the potential to cause death, incapacitation,
impairment of ability for self-rescue, acute illness, delayed illness,
or effects that can result in injury from one or the combined effects
of the following causes:
- A potentially flammable gas, vapor or mist in excess
of 10% of the lower explosive limit that has no toxic quality other
than dilution of available breathing air (e.g., methane);
- An airborne dust at a concentration such that it obscures
vision within a distance of five feet or less;
- A measured oxygen concentration inside the permit-required
confined space that differs (+/-) from the measured oxygen concentration
in the ambient air outside the permit-required confined space.
The precise value of normal oxygen in air is 20.946% oxygen by
volume, however, most instrumentation will display this value as
20.9% or 21%;
- An atmospheric contaminant that may cause an acute illness
(as set by the lowest limit value listed in the following standards)
in a concentration in excess of:
- Its assigned action level or ceiling values as identified
in the current Local, State and Federal regulations for chemical
contaminants and/or radioactive contaminants; or
- The latest edition of ACGIH Threshold Limit Values booklet.
- A physiologically inert gas that has only a simple asphyxiant
quality and is present in a concentration that reduces the available
oxygen in the breathable air below 19.5% (e.g., nitrogen, argon,
helium, but not carbon dioxide).
Hot Work - Any work that involves burning, welding,
riveting, or similar fire producing operations, as well as work which
produces a source of ignition, such as drilling, abrasive blasting,
and space heating.
Hot Work Permit - The written authorization to perform
hot work operations.
Immediately Dangerous to Life and Health (IDLH) -
Any condition that poses an immediate or delayed threat to life, and
would cause irreversible adverse health effects or interfere with an
individual's ability to escape unaided from a space. The IDLH also
represents a maximum concentration from which, in the event of respirator
failure, a person could escape within 30 minutes without experiencing
any irreversible health effects.
- IDLH can be used to describe three environmental conditions in
a permit-required confined space.
- It is the legal upper limit of use for air purifying
respirators (if the protection factor of the facepiece is not the
limiting factor). There are IDLH values available for only a limited
number of chemicals. The concentration of a material at its IDLH
value is usually so large, conventional instruments used for permit-required
confined space entry work will not be capable of measuring this
large value directly;
- It can represent a condition where the oxygen is less
than 16% by volume at which point the effects of low oxygen can
- For those chemicals where the lower explosive limit (LEL)
is lower than the IDLH value for toxic or incapacitating effects,
the LEL will be considered as the true IDLH value. ANY PERMIT-REQUIRED
CONFINED SPACE SITUATION WHERE ANY MATERIAL ENCOUNTERED THAT IS
MEASURED OR ESTIMATED TO BE AT ITS IDLH OR 10% LEL VALUE IS CONSIDERED
AN EMERGENCY SITUATION - NO ENTRY WILL BE MADE AND THE SITUATION
MUST BE MITIGATED BY TRAINED EMERGENCY RESPONSE PERSONNEL.
The only source for accepted IDLH values will be the National Institute
for Occupational Safety and Health (NIOSH) Pocket Guide To Chemical
Hazards, latest edition.
Inerting - The process of filling a space
with an inert non-flammable material for the purpose of displacing
or diluting oxygen to remove the flammable potential of the permit-required
confined space atmosphere.
Isolation, Isolating - The process by which a permit-required
confined space is removed from service and completely protected against
releasing material into the space. This process includes such means
as double block and bleeding of all lines, misalignment of all lines,
lockout of all energy sources, blocking of energy sources, or removing
mechanical linkage as described in the UC Irvine Electrical Safety
Line Breaking - The process of physically opening
a line that contains or previously contained a hazardous material or
hazardous pressure. Two physical in-line blocks are required between
the source of hazardous energy and the point where the line is broken.
Refer to the UC Irvine Electrical Safety Program.
Non-Permit Required Confined Space - Also Referred to as a
Low-Hazard Confined Space - A confined space that does
not contain or have the potential to contain any atmospheric or other
hazard capable of causing death or serious physical harm. A low-hazard
permit-required confined space may become a high-hazard confined
space if there are hazardous materials brought into the space or
if hazardous activities are conducted in the space.
Oxygen Concentration of Ambient Air - Normal ambient
air contains 20.946% (+/-0.002%) oxygen by volume.
Oxygen Deficiency - Any measured oxygen concentration
that is less than normal ambient air. For permit-required confined
space entry purposes, any measured oxygen concentration that is less
than that measured in the ambient air outside the permit-required confined
space (i.e., 20.9%) indicates an oxygen deficiency. The cause of this
oxygen deficiency must be known before entry will be allowed and controls
on this potential hazard will be put in place before entry is allowed
. The oxygen deficiency can be caused by:
- An intrusion of an unknown material into the space that
has diluted or displaced the available oxygen; or
- The presence of something that has consumed the oxygen
such as oxidation (rust), chemical reactions (including combustion),
absorption (on wet activated carbon), or biological action.
Oxygen-Deficient Atmosphere - An atmosphere that
has less than 19.5% oxygen by volume. When the oxygen content is below
19.5%, an air-purifying respirator cannot be worn and a supplied air
respirator must be used for entry.
Oxygen Enrichment - Any measured oxygen concentration
that is greater than normal ambient air (20.9%). Any measured concentration
measured greater than 20.9% is indicative that there is an oxygen source
inside the permit-required confined space (leaking welding hose, chemical
reaction). Special precautions must be taken to understand and control
this hazard potential before space entry is allowed.
Oxygen-Rich Atmosphere - An oxygen concentration
in the space of greater than 23.5% oxygen by volume.
Permit-Required Confined Space - A confined space
that has a high hazard potential because:
- It can contain a hazardous atmosphere;
- It contains a material that can engulf a person;
- It has an internal configuration such that a person could
become trapped or asphyxiated due to inwardly converging walls
or floors; or
- It may contain other health or safety hazards.
The overall program for controlling and protecting employees from
permit space (i.e., high-hazard type spaces) hazards and for regulating
employee entry into permit spaces.
Permit-required confined space Monitor : A
person who has responsibility to oversee the status of a particular
permit-required confined space and to ensure that any changes that
affect the space are documented and incorporated into future permit-required
confined space work.
Permit-required confined space Profile : A document
that summarizes the facts about a permit-required confined space that
may have bearing on safe entry, work and egress from that space. The
profile will also document any necessary emergency response actions
or phone numbers unique to the space.
Permit System - The written procedure for obtaining,
preparing, issuing, and retrieving entry permits for entry into permit-required
confined spaces and returning the space to service following termination
Prohibited Condition - Any condition in permit-required
confined space that is not allowed by the permit during the period
when the entry is authorized.
Purging : The method by which gases, vapors,
or other airborne hazards are initially displaced, diluted, or removed
from a permit-required confined space. Purging is the initial step
in controlling atmospheric hazards before entry into the permit-required
confined space. (See VENTILATING).
Rescue Service: See EMERGENCY
Retrieval System: System for conducting non-entry
rescue of persons from permit-required confined spaces. This system
includes retrieval or extraction devices (a rated tripod, davit, or
other anchorage plus winch) and a full body harness. Wristlets may
be used to aid in a difficult extraction; however, wristlets cannot
be used to support a person's weight.
Testing: The process by which the hazards that may
confront entrants of a permit space are identified and evaluated.
Ventilating: The process where clean fresh air is
blown into the permit-required confined space while persons are in
the space. (See also PURGING). In some cases, local exhaust ventilation
may be required to remove contaminants from the space generated at
a point source. An example of this would be if welding is being conducted
in the space, local exhaust ventilation would be used to remove the
welding fumes and noxious gases.
INITIATOR: Sandra Huang Conrrad