Confined Space FAQs

  1. Q: I need help now and want to talk with a real person who can help me.  Who can I call?  A: Call the Program Manager, Mark Schmidt on mobile (510) 206-8096 or landline (510) 495-2914.  You can also stop by the office at Building 78.
  2. Q: I am not sure if the space we are working at is a confined space or needs a permit.  Who can I ask and have them evaluate it?  A: Mark Schmidt.  mtschmidt@lbl.gov.  
  3. Q: I was told that I need an Entry Supervisor to write the entry permit and conduct atmospheric monitoring.  Who can I call? A: Call one of the EHS Entry Supervisors on their mobile phone:  Mark Schmidt (510) 206-8096, Mike Kincaid (707) 853-3115, Fred Cereno 708-8175, Rob Connelly (510) 520-9043, Matt Rice (510) 708-1113.
  4. Q: The confined space we are working at has fall hazards.  Who do I talk to for support on fall protection and writing a fall protection matrix form?  A: Matt Rice
  5. Q: What equipment do confined space entries generally need to have on site? A: Basic confined space entry equipment includes:  Lowering and retrieval/rescue device such as a tripod with winch, fall protection harnesses, manhole hook, trench/manhole ladder, traffic control, forced air ventilation unit, portable generator, guardrail gate, manhole ring guard, barrier tape and cones, four-gas meters, head protection helmets, head lamps for illumination, communication radios, LOTO tags, personal protective equipment.  LBNLs EHS department does not provide confined space entry equipment to subcontractors.  
  6. Q: Can LBNL provide our subcontractor’s with confined space training. A: No
  7. Q: What confined space training providers are there? A: oshatraining.com  in San Jose, CA.   http://www.oshatraining.com/confined-spaces-in-construction-training.php

OSHA Training Institute Education Centers

Chabot, Los Positas Community College, Dublin, CA.          http://osha4you.com/courses/osha-safety-standards/40-hour-confined-space-rescue-otc-304

Enviro Safetech (Jay Jamali)

http://www.envirosafetech.com/contact.html

2160-B Oakland Rd.

San Jose, CA 95131

tel: 408-943-9090

info@envirosafetech.com

California Health & Rescue Training

If you would like to contact Kent Freeman regarding classes and quotes, please call:

Office Phone - 530-367-3770

Cell Phone - 916-838-9922

Fax Line - 530-367-4548

Or... email us at calrescue@gmail.com

  1. Q: A subcontractor submitted a written program and worker training only on the California standards 5157 and 5158.  Is this adequate for work at a Federal facility such as LBNL.  A: No. The subcontractor’s written program and training must address the elements of the both the Federal OSHA General Industry 29 CFR 1910.146 and Construction 29 CFR 1926.1200 standards.  LBNL does not recognize California regulations as an equivalent to the unique federal regulations.  
  2. Q: What submittals does a subcontractor need to provide in order to get approved to enter permit-required confined spaces at LBNL as an Attendant or Entrant?  A:  In summary the following are required:  1. A reviewed and approved written confined space program outlining the elements of both OSHA 29 CFR 1910.146 and 29 CFR 1926.1200 Subpart AA.  The program must be on company letterhead.  2. Reviewed and approved confined space training certificate from an approved training provider classroom course.  The certificate shall have the name of the training provider company, the name and signature of the instructor, the course date, the name and company of the worker and that the course covered the elements of OSHA 29 CFR 1910.146 and 29 CFR 1926.1200 Subpart AA.  The training course must include a practical, hands-on portion.  Online training and In-house training are not acceptable for initial training.  
  3. Q: What submittals does a subcontractor have to provide in order to use their own Entry Supervisor?  A.  1. A certificate showing proof of formal, classroom training in atmospheric testing principles for confined spaces, preparing entry permits, identifying confined spaces and permit-required confined spaces, identifying hazards, implementing controls and elimination of hazards, as well as revising classification due to changed conditions.  The Entry Supervisor will be interviewed and asked basic questions to determine their competency as a Qualified Person. 2. Documentation for the type of four-gas meter to be used and the serial number of the instrument to be used at LBNL.  Only pump-type meters will be approved.  3. Documentation of monthly and daily calibration. 4. Information on low and high alarm settings.  5. Submit blank copies of the entry permits to be used for review.  
  4. Q: What if the subcontractor does not have an approved Entry Supervisor? A: LBNL EHS will need to provide a Competent Person with EHS 0277 Entry Supervisor training.
  5. Q: Can a lower-tier subcontractor work under the controlling contractor’s confined space program?  A: This practice is discouraged by EHS and used only in the event of an operationally critical need such as an inspection and not an extended duration project with hands on work.  However, if it becomes necessary, a formal, written letter of agreement must be prepared and signed by both the lower-tier sub and the controlling contractor with the understanding that the lower-tier sub will work under, and comply with the program and all applicable regulatory standards.  
  6. Q: Are excavations covered under the new confined spaces in construction standard 1926.1200?  A: No. However, it is LBNL’s policy to treat open top spaces such as trenches, greater than 4’, as confined spaces.   This 4’ rule is also mentioned in 29 CFR 1926.21 (b)(6)(ii).  
  7. Q: Are attics and crawlspaces confined spaces?  A: Yes, they are now addressed in the confined spaces in construction 1926.1200 Subpart AA.   So construction-related work in these spaces is subject to the regulation.  However, they are generally not permit required.  They do require the use of the buddy system (two man job), notice you are entering, training, use of proper PPE, use of safe work procedures and do not introduce hazards.  One of the most common hazards of attics is heat.  
  8. Q: Can manhole guardrail equipment winches also be used as personnell rescue devices?  A:  No. They are not designed and manufactured for personnel hoisting nor, are they to be used as personal retrieval devices.  
  9. Q: Can extension ladders be used in manholes and trenches? A: No.  You need to use specialized, fixed manhole or trench ladders.
  10. Q: I have alot of questions about equipment including harness and rescue requirements.  Can you summarize these requirements”  A: See below bulleted items.  

      Full body harnesses are required for lowering or hoisting personnel from vertical confined spaces.  Harnesses are required for spaces deeper than 5 feet.

      Full body harnesses are also an integral part of a rescue system.  Rescue plans can be of two types.  A self-rescue system can be used whereby the Entry Team provides their own rescue to the Entrant through the use of their own equipment on site.  The second type of plan is where a rescue service provider, such as a fire department, is relied upon for rescuing an Entrant(s).  Both plan types are acceptable under certain circumstances. For either plan used, wearing a full body harness enables emergency rescue

      In general, Entrants must maintain a retrieval line attached to their harness during vertical confined space entry (i.e. manholes and deep vertical spaces such as storm drains) to enable rescue and retrieval.  If there is a demonstrated danger of entanglement or hazardous impediment caused by the retrieval line, such that a greater hazard is created, then this condition may be evaluated on a case-by-case basis and exempted by the designated Entry Supervisor.

      Short duration, inspection-type work, which does not involve MRO work or a subcontractor's construction-related work in the space, may rely on the LBNL Fire Department as the rescue service.  Provided this exception, a tripod is not required to be on the entry site, although many project managers require it on their projects.  Short duration inspection-type operations, without a tripod on-site, must have a rescue plan coordinated with the Fire Department in order to ensure an availability to respond during the time of the entry.  Coordination includes calling the Fire Department (510) 486-6015 to determine their staff's availability to perform rescue during an entry event.

      In general, confined space entry does not require a fall matrix permit form be prepared since there is no working from height. If a fall hazard that is not protected by Passive Fall Protection System (i.e. guardrails, safety nets, warning lines, etc.) does exist, than an engineered fall protection system is required; and a fall protection matrix permit will become necessary.  Wearing a full body harness in a confined space does not imply working from height as the purpose and intent is specifically for lowering or hoisting personnel from a confined space, whether it is a routine entry or for rescue.  Full body harnesses are required to be worn by in-house staff for all vertical confined space entries regardless of the permit type used (i.e. Alternate Entry, Reclassification, Regular Permit).

      For rescue purposes only, Class II rated chest harnesses or wristlets may be worn in lieu of full body harness.  Chest harness and wristlets are not to be used for the routine lowering or hoisting of personnel, as they are designed and allowed for rescue purposes only.  Since chest harnesses and wristlets are not allowable for lowering or hoisting personnel, it is implied that a ladder will be used to enter and exit the space.  This Program does not authorize a requirement, make recommendation or direct subcontractors to downgrade their PPE or controls as required by OSHA or which employees choose to voluntarily wear and use. Class II chest harnesses or for that matter wristlets are not commonly used alone as a rescue harness. It is more common to use a Class II seat harness in conjunction with a chest harness. It is standard industry practice to use a full body rescue harness with either a dorsal or chest D-ring or rescue shoulder D-rings in conjunction with a rescue spreader strap/bar.  

      Self-rescue equipment, including a tripod with winch, must be in place or, at the immediate ready during entry operations for either Facilities MRO work or construction-related work.  

      An Permit-Required Entry Team that includes an Attendant is required for permit-require confined space entry.  In-house staff must have current EHS0276 Fall Protection training to be authorized to work as a member of a Permit-Required Confined Space Entry Team.  This is to ensure the proper use and adjustment of a harness as well as other rescue systems such as the tripod, winch, or davit arm.  Attendants must be competent in the use of the winch for lowering and hoisting personnel.

      Guarding must be used for vertical confined spaces.  Guarding requires the use of a collapsible steel guard gate to warn and prevent pedestrians from falling into an opened confined space.

      Guarding of open manholes from tools and equipment falling into an opened manhole includes the use of a circular, manhole guard ring. Certain manhole configurations may not suitable for using the manhole guard ring.  These conditions may include improper sizing that is not within the diameter range of 28", 30", and 32".  Another condition may be where the guard ring increases the distance to an upper fixed ladder rung where initial step-down distance becomes too great to allow a worker safe entry.  In these situations the use of the guard ring may create hazard and therefore may be exempted by the Entry Supervisor.  An alternative is to use a fixed manhole ladder, which extends at least 2 feet above the manhole guard ring.  This will generally allow safe entry and exit as well as prevent tools and equipment from falling into the opened space.   Another condition where a manhole guard ring may not be a feasible option is when a line of some type must be routed down into the manhole, which prevents proper fit or can crimp off the line.  For example supplied airlines, hydraulic lines, etc. An additional option for control of overhead hazards of confined space be to control access to the confined space area and require all tools and equipment be tethered at all times while inside the controlled access zone.

      Adequate illumination must be provided.  Headlamps are preferred since they provided hands free operation.  Intrinsically safe LED lights are also recommended to provide ambient light.

      Intrinsically safe devices and equipment are required when working in potentially hazardous atmosphere spaces such as sanitary sewer manholes.

      Fixed manhole ladders are to be used when a ladder is required or a portable manhole/trench ladder when an existing fixed ladder is deemed unsafe.  Extension ladders are prohibited unless there is a reason why manhole ladders are not as safe to use.

      Facilities or other in-house staff is responsible for acquiring their own harnesses.  These may be checked out from Stores or purchased, depending.  LBNL EHS does not provide equipment such as harnesses or tripods to subcontractors. Harnesses must be inspected on an annual basis by a competent person and prior to use by the user.

      All entries and Entry Team members must be authorized to perform the entry by the Activity Lead or Project/Construction Manager.