Confined Space Awareness Rules for Entrance

Version 30 Sep 2015

Agenda

Introduction
Policies and Procedures
General Requirements
Confined Space
Reclassification of Space
Permit Space Entry Procedures
Entry Permit and Termination
Authorized Entrants Duties
Attendant Duties
Entry Supervisor Duties
Rescue and Emergency Services
Atmospheric Testing Procedures

Introduction

Introduction
This course describes the procedures to follow whenever any field
operations installation crew, supervisor, subcontractor or manager must
enter a confined spaced as outlined in OSHA 1910.146, 1926 Subpart AA
and Section 3.10. Confined Space in Construction SOP (SolarCity Safety
Manual).

Policies and Procedures

Policies and Procedures

OSHA definition of confined space
- Is large enough and so configured that an employee can bodily enter
it;
- Has limited or restricted means for entry and exit;
- Is not designed for continuous employee occupancy.

Policies and Procedures (continued)

Protection of the employee from the hazards within confined spaces
- Mandates general and specific requirements for:
- Safe work practices
- Entry procedures
- Training requirements

- Applies to any worksite that has one or more confined spaces that will be
entered by.
- SolarCity employees
- Sub-contractors

Policies and Procedures (continued)

Managers and Supervisors
- Ensure all employees work in proximity or within confined spaces are
protected.
- Supervisors Responsibility obtain the following information.
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Location of confined spaces

Hazards present in space
Permitting requirements
Entry methods

- ALL entry operations shall be coordinated regardless of who is primary

contractor.

General Requirements

General Requirements
COM or PM will obtain information from host employer or owner.
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Specific location
Purposes
Hazards within the space
Criteria used by host to classify the space as permit-required

Supervisors or Crew Leads.

- Inform employees of dangers by
- Posting of signs
- Barriers at existing locations

General Requirements (continued)

Sign shall read as follows: DANGER: PERMIT REQUIRED CONFINED
SPACE DO NOT ENTER
- Signs posted by host employer or owner will fulfill this requirement.
- Managers and supervisors will take measures to prevent SolarCity
employees from entering if not directed to do so.

Confined Space

Confined Space
Equipment required for entry into a Permit-Required Confined Space
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Air testing and monitoring equipment

Ventilation equipment
Communication equipment
Personal Protective Equipment (PPE)
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When engineering and work practice controls cannot adequately protect employee

Lighting
Barriers
Access equipment
Rescue equipment
Site specific equipment for safe entry, exit and rescue

Confined Space (continued)

Entry procedures occurs in six essential steps
- Step 1 Designation of the following:
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Competent person
Authorized entrants
Entry supervisor
Attendants

- Step 2 Evaluation and testing of Space

- Step 3 Continuous monitoring
- Step 4 Completion and use of entry permit process this will include
methods to cancel or suspend permit

Confined Space (continued)

- Step 5 Evaluation and selection of rescue team
- Step 6 Review of entry operations when employees may not be
protected or deficiencies are discovered the following
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Unauthorized entry into permit space

Detection of hazard within a space not covered under existing permit
Condition identification not covered by permit
Occurrence of an injury or near miss during entry
Change in uses or configuration
Employee complains about effectiveness of program

Reclassification of Space

Reclassification of Space
Permit to Non-Permit space can only be done by a SolarCity designated
Competent Person
- The following requirements must be met
- Poses no actual or potential atmospheric hazards
- All hazards within the space are eliminated or isolated without entry into space
- If entry is required to eliminate hazard, then it must comply with all
requirements of the permit-required space
- Testing and inspection demonstrates hazards have been eliminated or isolated

Reclassification of Space (continued)

Permit to Non-Permit space (continued)
- Documentation must be provided for determining the basis that the hazard
has been eliminated or isolated
- Certification must include
- Date
- Exact location
- Signature of person making determination

- Certification must be made available to any employee entering a nonpermitted space

- If hazard arises in the non-permit space, all employees must exit and space
shall be re-classified

Reclassification of Space (continued)

Permit to Non-Permit space (continued)
- Spaces that contain actual or potential atmospheric hazards
- Manholes
- Electrical vaults under total lockout/tagout or de-energized procedures
- Entry must be documented as safe and must be made available per
SolarCitys Confined Space policy sections A.3 and A.4
- Unsafe condition to remove entrance cover must first be eliminated
- Railing, temporary barrier or cover must be provided to prevent accidental fall
into space

Reclassification of Space (continued)

Permit to Non-Permit space (continued)
- Internal atmosphere must be tested prior to entrance in the following
order:
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Oxygen content
Flammable gases
Flammable vapors
Potential toxic contaminants

- This test can be observed by any employee who must enter the space
- No hazardous atmosphere is permitted while employee is in the space

Reclassification of Space (continued)

Permit to Non-Permit space (continued)
- Continuous forced air must be used
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NO entry until hazard is eliminated by forced air

Forced air must be directed at immediate area where employee will be working and
must be present while employee is working
Forced air must be from a clean air source and must NOT increase the hazard

- Continuous monitoring of space

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Use of commercial system to monitor

Use periodic monitoring if no commercial monitoring
If NO alarm is available
- Notify entrants of specific threshold
- Employee will check levels at sufficient frequency to ensure escape time

Reclassification of Space (continued)

Permit to Non-Permit space (continued)
- Hazards detected during entry.
- Require immediate exit of all employees.
- Evaluation of space to determine how levels were reached.
- Implementation of measures to protect employee prior to re-entry.

- Certification document must be completed prior to entry and made

available to employees who enter the space.

Permit Space Entry Procedures

Permit Space Entry Procedures

Entry Procedures to be completed
- Test conditions
- Test in proper order oxygen, combustible gas & vapor, toxic gas & vapor
- Provide entrants opportunity to observe testing both pre-entry and
subsequent
- Provide entrants test results
- Continuously monitor workers area
- Provide early warning system monitor for non-engulfment hazards
- Re-evaluate if authorized attendant request due to indication of inadequate
test

Permit Space Entry Procedures

Entry Procedures to be completed (continued)
- Provide at least one attendant outside the permit space
- Attendant may be assigned to more than one space, provided they can perform
their duties effectively
- Can be stationed at any location provided they can perform their duties
effectively
- Multiple spaces permit must include procedures and means to enable the
attendant to respond to an emergency affecting one or more locations
- It must not distract from responsibilities of other sites

Permit Space Entry Procedures

Entry Procedures to be completed (continued)
- Prior to entry supervisor must:
- Prepare the entry permit
- Sign the entry permit
- Completed permits must be available at the time of entry to all authorized
entrants
- Duration of the permit must not exceed the time required to complete the
assigned task or job identified on permit

Entry Permit and Termination

Entry Permit and Termination

An Entry Permit authorizes entry into a space
- Permit must identify the following:
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Space to be entered and purpose

Date and authorized duration of permit
Tracking system of authorized entrants can be a list of names or roster
Means to detect increase in atmospheric hazards if ventilation system fails
Name of attendant
Name of entry supervisor
Hazards within the space

Entry Permit and Termination (continued)

- Permit must identify the following (continued)
- Measures used to isolate and/or eliminate the hazard within the space (LOTO/
flushing/ventilation)
- Acceptable entry conditions
- Results of testing by name or initials of tester
- Rescue and emergency services that can be called

Entry Permit and Termination (continued)

- Permit must identify the following (continued)
- Communication procedures that will be used by authorized entrants and
attendants
- Equipment PPE, testing and communication equipment, alarm systems and
rescue equipment to be provided
- Any additional permits needed Hot welding or electrical energized work etc.

Entry Permit and Termination (continued)

Termination occurs when any of the following situations are discovered
- When operations covered by permit are complete
- Cancel or suspend and FULLY reassess when condition exist that is not
allowed under the permit
- Either in or near the permit space
- When condition is temporary and does NOT change configuration of the space

- Cancel when condition is not allowed under the current permit

- Entry Supervisor will maintain canceled permit for 1 year
- This will facilitate review of Confined Space Program
- Note any problems encountered to aide in appropriate revisions to program

Authorized Entrant Duties

Authorized Entrant Duties

Familiarity with the following
- During entry:
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Mode of entry
Signs
Symptoms
Consequences of exposure

- Able to use equipment properly

- Communicate with attendant
- assess entrant status
- enable the attendant to alert all incase of evacuation

Authorized Entrant Duties (continued)

- Alert attendant when
- Any warning signs or symptoms of exposure to dangerous situation
- Detects a prohibited condition

Exit space quickly when following conditions arise

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Order to evacuate is given by attendant or entry supervisor

Warning signs or symptoms of exposure to dangerous situation
Detects a prohibited condition
Evacuation alarm is given

Attendant Duties

Attendant Duties
The Entry Supervisor will ensure Attendants are aware of the following:
- Familiarity with and understand the hazards associated with permitted
space. (Signs, Symptoms & Exposure consequences)
- Aware of behavioral effects to exposed hazards
- Continuously maintains accurate count of entrants authorized
- Remains outside unless relieved by another Attendant
- If relived and properly trained the attendant may enter to attempt rescue
- Type of rescue must be designated on the entry permit
- SolarCity will NOT have trained rescue personnel this will be done by onsite
contracted emergency personnel and/or designated rescue company

Attendant Duties (continued)

- Communicate with entrants to include alerting in case of evacuation
- Assess activities both inside and outside the space
- Determine if it is safe
- Order evacuation if required due to following
- Prohibited condition
- Behavioral effects are present due to hazard
- Outside conditions could harm entrants
- Attendant cannot effectively and safely perform the duties required
- Responsible for summoning rescue and other emergency services
- As soon as the entrant is determined to need assistance

Attendant Duties (continued)

- For unauthorized entry attempts the attendant will
- Warn the unauthorized entrant to stay away
- Advise the unauthorized entrant to exit space immediately
- Inform authorized entrants and entry supervisor that an unauthorized person
has entered

- Perform Non-Entry rescue as trained and designated

- NOTE: only authorized rescue teams and emergency personnel will perform
entry rescues

- Perform no duty that will interfere with the attendants primary duty to
protect and assess entrants

Entry Supervisor Duties

Entry Supervisor
Supervisors are responsible for the following:
- Familiar with the hazards of the site during entry
- Familiarity with signs, symptoms and consequences of exposure
- Verify appropriate entries have been made on permit to include
- Testing
- Procedures and Equipment specified are in place prior to allowing entry
- Terminate the entry and cancel or suspend as required
- Verify rescue services are available and operable to complete notification
- Unavailability of services will be confirmed by original service so that an
alternate service can be made available

Entry Supervisor (continued)

- Removal of unauthorized individuals who have
- Entered the space OR
- Attempting to enter the space

- When transferring responsibility or at intervals determined by the hazard

- Ensure entry operations remain consistent with terms of permit
- Acceptable entry conditions are maintained

Rescue and Emergency Service

Rescue and Emergency Services

SolarCity employees will NOT be authorized to preform Entry Rescues
- SC will designate contracted or local emergency services
- Contracted services will remain on site for the duration while authorized
entrants are within the permitted space(s)
- Services will be evaluated on the following:
- Rescue summons in a timely manner
- Proficiency with rescue related task
- Equipment functioning properly while rescuing

- Contracted or local services must contact SolarCity in the event rescue

services become unavailable

Atmospheric Testing Procedures

Atmospheric Testing Procedures

Two distinct purposes of testing
- Evaluation of hazard
- Verification of acceptable conditions

Evaluation of hazard
- Space to be tested using equipment to detect the chemicals that may be
present at levels that are well below the defined exposure limits
- Determines the chemical hazard exists or may become present
- Identify what steps must be followed and what conditions must be met to make
the space safe for workers

Atmospheric Testing Procedures (continued)

Evaluation of hazard (continued)
- Test results and decisions must be done before entry can be granted
- Evaluation or review of results will be done by one of the following
- Certified industrial hygienist
- Registered safety engineer
- Certified safety professional
- All potential hazards must be considered

Atmospheric Testing Procedures (continued)

Evaluation of hazard (continued)
- Permit space is a confined space when it meets one or more of the
following criteria:
- Has or may contain a hazardous atmosphere
- Contains material that can engulf a person
- Has an inside design that can trap or asphyxiate a person (inwardly converging
walls or floor that slopes downward to smaller section)
- Any other serious safety or health hazards

Atmospheric Testing Procedures (continued)

Verification Testing
- Prior to entry of a permit space it must be tested in accordance with the
steps developed during the evaluation test.
- This is done to verify levels are below necessary levels for safe entry
- The conditions are met that have been identified on the permit
- Testing must be done in the following order:
- Oxygen
- Combustible gases
- Toxic gases and vapors

Atmospheric Testing Procedures (continued)

Verification Testing (continued)
- The results of the test must be recorded on the permit near the levels
identified for safe entry

- Definition of duration of test, layered atmospheres and retesting

- Duration of test allow enough time for the air from the space to be drawn into
the equipment and the sensor to react to the chemical if present.
- Layered atmosphere spaces that are deep or have areas leading away from
the entry point may cause the atmosphere to be layered.
- Testing must be done in the area surrounding the worker.
- Test is to be done at 4 feet in the direction of travel and to each side.

Atmospheric Testing Procedures (continued)

Verification Testing (continued)
- Retesting routinely retest permit space to make sure that the
atmosphere continues to be safe.
- Continuous monitoring during entry operations is one of the new changes in
confined space operation.

Summary

Summary
Policies and Procedures
- OSHA 1910.146, 1926 Subpart AA and SolarCity SOP 3.10 Confined Spaces in
Construction

General Requirements
- Obtain information from host employer or owner
- Inform employees of dangers
- Signs posted

Permit Required Entry

- Required equipment air testing, ventilation equipment, barriers etc.
- 6 Steps Designate, Evaluate, Monitor, Complete, Evaluate Rescue and Review

Summary
Reclassification of Space
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From Permit to Non-permit can only be done by SolarCity Competent Person

Hazards in space are eliminated or isolated without entering space
Exit space if Non-permit space has a hazard arise
Internal atmosphere test Oxygen, Flammable gases, Flammable vapors or toxic
contaminants

Permit Space Entry Procedures

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Test conditions and in proper order

Early warning system
Must have at least one attendant outside permitted space
Supervisor must prepare and sign Permit

Summary
Entry Permit and Termination
- Entry Permit must identify

- Space to be entered


- Date & duration of permit

- Means to detect atmospheric change

Name of attendant
Name of entry supervisor
- Hazards within the space

- Entry Termination
- when operations are complete,
- when conditions become present
- Must maintain canceled permit for 1 year

Authorized Entrants Duties

- Familiar with mode of entry, signs and symptoms

- Equipment use
- Communication

Summary
Attendant Duties
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Familiar with signs, symptoms and exposure consequences

Maintains accurate count of entrants
Remains OUTSIDE unless relieved by another attendant
Responsible for summoning rescue and other emergency services
Prevent unauthorized entry attempts
NOTE: Only authorized rescue teams will perform rescue. No one from SolarCity will be
designated as a entry rescue person or team

Entry Supervisor Duties

- Verify entries on Permit
- Terminate, cancel or suspend operation as required
- Remove unauthorized individuals

Summary
Rescue and Emergency Services
- SolarCity employees will NOT be authorized to perform Entry Rescues
- Rescues will be done by contracted or local emergency services
- Contracted or local services must contact SolarCity if services become
unavailable

Atmospheric Testing Procedures

- Two distinct purposes
- Evaluation of hazard space to be tested to identify the steps that will be
followed
- Verification of acceptable conditions through the use of duration testing,
atmosphere layers and retesting.

Questions?