technical committee on confined space safe …...richard wright principal wright rescue solutions,...

TECHNICAL COMMITTEE ON

Confined Space Safe Work Practices AGENDA

First Draft Meeting (F2015) Quincy, MA

April 7-10, 2014

Continental Breakfast served each Am at 7:30 AM. Lunch provided each day. Day One 8:00 AM-5:00 PM

1. Welcome. Don English, Chair. 2. Introduction of Committee Members and Attendees. 3. Approval of Meeting Minutes (attached-Feb 11th, 2014). 4. Revision Timeline for Fall 2015 documents (attached). 5. Staff presentation, Nancy Pearce-Revision process. 6. Task group reports/Chapter review and review of Public Inputs Day Two 8:00 AM-5:00 PM 7. Comments about NFPA 350 from Terry Krug, ASSE Z117.1 Chair 8. Task group reports/Chapter review and review of Public Inputs 9. Task Group meetings (TBD) Day Three 8:00 AM-5:00 PM 10. Task group reports/Chapter review and review of Public Inputs 11. Task Group meetings (TBD) Day Four 8:00 AM-5:00 PM 12. Task group reports/Chapter review and review of Public Inputs 13. Task Group meetings (TBD) 14. Other Business. 15. Schedule Next Meeting. 16. Adjourn.

Address List No PhoneConfined Space Safe Work Practices CNS-AAA

Nancy Pearce03/14/2014

CNS-AAALeslie D. EnglishChair254 South Jackson StreetGrove Hill, AL 36451

SE 3/1/2011CNS-AAA

Adam C. JonesSecretaryBuechel Fire Protection District4101 Bardstown RoadLouisville, KY 40218

E 10/18/2011

CNS-AAARick ArgudinPrincipalCapital Safety5740 West Little York, Suite 179Houston, TX 77091

M 07/29/2013CNS-AAA

Edward K. BoringPrincipalHilton Head Island Fire Rescue40 Summit DriveHilton Head Island, SC 29926International Association of Fire ChiefsAlternate: Rodney Foster

E 10/20/2010

CNS-AAALouis A. Donsbach, Jr.PrincipalUS Steel CorporationOne North Broadway, 91E2/TS 526Gary, IN 46402-3101

U 10/18/2011CNS-AAA

Aaron D. DuffPrincipalBristol-Myers Squibb Company1 Squibb Drive, Bldg. 102, Office 133New Brunswick, NJ 08903NFPA Industrial Fire Protection Section

U 10/20/2010

CNS-AAATimothy R. FisherPrincipalAmerican Society of Safety EngineersDirector, Practices and Standards1800 East Oast Oakton StreetDes Plaines, IL 60018-2187American Society of Safety Engineers

SE 03/03/2014CNS-AAA

Alfred W. KeissPrincipalMed-Tex Services, Inc.6940 State Road, Building EPhiladelphia, PA 19135-1541Alternate: Robert J. Masonis, Sr.

SE 10/18/2011

CNS-AAASteven E. KoschPrincipal3M Company3M Cottage Grove, Building 143-01Cottage Gove, MN 55016

M 03/07/2013CNS-AAA

Richard S. KrausPrincipalAPI/Petroleum Safety Consultants210 East Fairfax Street, Apt. 600Falls Church, VA 22046-2909American Petroleum Institute

U 3/4/2009

CNS-AAAEdmund L. Lydon, Jr.PrincipalNortheast Hospital Corporation85 Herrick StreetBeverly, MA 01915-1790New England Healthcare Engineers Society

U 08/09/2012CNS-AAA

Glenn E. MatePrincipalGuilford Fire Department, EMT-Local 4177Fairfield Regional Fire School584 Moose Hill RoadMonroe, CT 06468

E 3/4/2009

1



CNS-AAAJoseph R. MathewsPrincipalSprinkler Fitters Local 692 JATC14004 McNulty RoadPhiladelphia, PA 19154United Assn. of Journeymen & Apprentices of thePlumbing & Pipe Fitting IndustryAlternate: Mark R. Ronecker

L 3/4/2009CNS-AAA

Glenn E. McGinley, IIPrincipalOhio Public Employment Risk Reduction Program4448 Prairie Creek LaneMaumee, OH 43537-9020

E 8/5/2009

CNS-AAADavid McLaughlinPrincipalOregon OSHAPO Box 14480Salem, OR 97309-0405Alternate: Stan Thomas

E 03/07/2013CNS-AAA

Jim E. NorrisPrincipalBunge North America11720 Borman DrivePO Box 28500St. Louis, MO 63146-1000National Oilseed Processors Association

U 3/4/2009

CNS-AAAMichael PalmerPrincipalEnSafe Inc.308 North Peters Road, Suite 200Knoxville, TN 37922American Industrial Hygiene Assn/Confined SpacesCommitteeAlternate: Bayless L Kilgore


James T. PorterPrincipalSafety and Fire Consultant1475 North Latson RoadHowell, MI 48843Ford Motor Company

U 3/4/2009

CNS-AAABob A. RusczekPrincipalCertified Safety and Health11 Arbor LaneWilbraham, MA 01095Alternate: Adam J. Goodman


Bob VigdorPrincipalTyco/Scott Safety4320 Goldmine RoadMonroe, NC 28110International Safety Equipment Association

M 03/07/2013

CNS-AAADavid WagnerPrincipalIndustrial Scientific Corporation1001 Oakdale RoadOakdale, PA 15071Alternate: Andrew Saunders

M 10/27/2009CNS-AAA

Laura Hartline WeemsPrincipalCenter for Toxicology and Environmental Health5120 Northshore DriveNorth Little Rock, AR 72118

SE 03/07/2013

CNS-AAAWilliam H. WeemsPrincipalSafe State ProgramUniversity of AlabamaPO Box 870388Tuscaloosa, AL 35487


Richard WrightPrincipalWright Rescue Solutions, Inc.2002 Tupelo CourtPanama City, FL 32405Alternate: Dennis M. O'Connell

SE 3/1/2011

2



CNS-AAALeonard A. Young, Jr.PrincipalMassachusetts Water Resources Authority2 Griffin WayChelsea, MA 02150-3334American Federation of State, County & MunicipalEmployees

L 08/09/2012CNS-AAA

John Zimlich, Jr.PrincipalLouisville Gas & Electric16660 Dixie HighwayLouisville, KY 40272

U 03/05/2012

CNS-AAAChristopher S. BuehlerAlternateExponent, Inc.10850 Richmond Avenue, Suite 175Houston, TX 77042


Rodney FosterAlternateMidwest City Fire Department8201 East RenoMidwest City, OK 73130International Association of Fire ChiefsPrincipal: Edward K. Boring

E 03/07/2013

CNS-AAAAdam J. GoodmanAlternateS-E-A Limited1110 Benfield BoulevardMillersville, MD 21108Principal: Bob A. Rusczek


Bayless L KilgoreAlternateEnsafe Inc.1148 College StreetBowling Green, KY 42101American Industrial Hygiene Assn/Confined SpacesCommitteePrincipal: Michael Palmer

SE 10/23/2013

CNS-AAARobert J. Masonis, Sr.AlternateNewport Beach Fire Department (retired)PO Box 1804Temecula, CA 92593Principal: Alfred W. Keiss


Dennis M. O'ConnellAlternateRoco Rescue Inc.26 Cobalt LaneWestbury, NY 11590Principal: Richard Wright

SE 10/29/2012

CNS-AAAMark R. RoneckerAlternateSprinkler Fitters 268 JATC1544 South 3rd StreetSt. Louis, MO 63104United Assn. of Journeymen & Apprentices of thePlumbing & Pipe Fitting IndustryPrincipal: Joseph R. Mathews

L 07/29/2013CNS-AAA

Andrew SaundersAlternateHoneywell Inc.7004 NW 99th WayTamarac, FL 33321Principal: David Wagner

M 03/07/2013

CNS-AAAStan ThomasAlternateOregon OSHA3075 NE Georgianne CourtBend, OR 97701Principal: David McLaughlin

E 03/07/2013CNS-AAA

Nancy PearceStaff LiaisonNational Fire Protection Association1 Batterymarch ParkQuincy, MA 02169-7471

1/11/2012

3

TECHNICAL COMMITTEE ON

Confined Space Safe Work Practices Pre-FD Meeting Minutes

Conference Call/Adobe Connect Meeting February 11, 2014

10:00AM-11:30PM EST Attendees: Don English, Chair Hal Cohen, HCC Associates Aaron Duff, Bristol-Meyers Squibb Adam Jones, Buechel Fire Protection District Alfred Keiss, Med-Tex Services, Inc. Stephen Kosch, 3 M Company Richard Kraus, API/Petroleum Safety Consultants Ed Lydon, Northeast Hospital Corp. Glenn Mate, Guilford Fire Dept David McLaughlin, Oregon OSHA Glenn McGinley, Ohio Public Employee Risk Reduction Program James Norris, Bunge North America Mike Palmer, Ensafe Inc Robert Rusczek, Certified Safety and Health Bob Vigdor, Tyco/Scott Safety Laura Weems, Center for Toxicology and Environmental Health Bill Weems, Safe State, Univ of Alabama Richey Wright, Wright Rescue Systems John Zimlich, Louisville Gas and Electric Rodney Foster, Midwest City Fire Dept Bayless Kilgore, Ensafe Inc Dennis O’Connell, Roco Rescue Mark Ronecker, Sprinkler Fitters 268 JATC Andrew Saunders, Honeywell, Inc Nancy Pearce, NFPA Staff Liaison

1. Don English, Chair opened the meeting at 10:10 AM welcomed the committee and explained the purpose of the meeting. 2. Introduction of New Committee Members. New members Bayless Kilgore and Mark Ronecker introduced themselves and their affiliations. 3. Meeting Minutes from April 2-4 meeting in Charlotte NC were approved as written. 4. Summary of Public Inputs Received. Nancy Pearce indicated that 1164 public inputs were received and that all had to be addressed at the first draft meeting. Many of the inputs received were editorial in nature however there are a number of substantive issues that need to be considered by the committee. Nancy also explained that the changes made in the first draft meeting would be posted and would go out again for public comment. She explained that additional changes could be made at the second draft meeting but only to sections of the document that had been revised in the first draft. No new material is allowed at the second draft meeting. 5. Next Steps-Task Group Work to be done. Nancy Pearce and Don English discussed the best way to deal with the

many public inputs and have established task groups to deal with chapters 6-16. Chapters 1-5 are general chapters that will be dealt with by the whole committee. Task group chairs have been established for Chapters 6-16 and all committee members are asked to join one or more task groups. The plan is to have each chapter task group review a pdf of all the public inputs and determine which are editorial and which are substantive and need further discussion. The task groups will be provided a word document to revise using tracked changes and will be prepared to discuss the changes made to the chapter in the first draft meeting. The chapter task groups will also be asked to review the chapter content to see if additions or deletions are needed and to review the chapter to see if it correlates well with requirements in other chapters in the document. Nancy will send out the information and instructions in an email to all committee members and task group members by the end of the day. 6. First Draft Meeting Logistics. Nancy indicated that ASSE would have a representative addressing the committee on Day 2 of the meeting. The Committee would also like to have task group meetings on the afternoon of Day 1 so she Will request several rooms for the task group meetings. The task groups should have most of their work completed by the meeting but this will provide additional time for last minute changes that may be best discussed face to face at the meeting. Nancy reminded the committee to let Joanne Goyette know if they are planning to attend and to make reservations if they had not already done so. 7. Other Business. No other business was discussed. 8. Meeting was adjourned at 1135 AM.

2015 FALL REVISION CYCLE *Public Input Dates may vary according to standards and schedules for Revision Cycles may change. Please check the NFPA Website for the most up‐to‐date information on Public Input Closing Dates and schedules at

www.nfpa.org/document# (i.e. www.nfpa.org/101) and click on the Next Edition tab.

Process Stage

Process Step

Dates for

TC

Dates forTC with CC

Public Input Closing Date for Paper Submittal* 11/29/2013 11/29/2013 Public Input Closing Date for Online Submittal (e‐PI)* 1/3/2014 1/3/2014 Final Date for TC First Draft Meeting 6/13/2014 3/14/2014

Public Input Posting of First Draft and TC Ballot 8/1/2014 4/25/2014 Stage Final date for Receipt of TC First Draft ballot 8/22/2014 5/16/2014

(First Draft) Final date for Receipt of TC First Draft ballot ‐ recirc 8/29/2014 5/23/2014 Posting of First Draft for CC Meeting 5/30/2014 Final date for CC First Draft Meeting 7/11/2014 Posting of First Draft and CC Ballot 8/1/2014 Final date for Receipt of CC First Draft ballot 8/22/2014 Final date for Receipt of CC First Draft ballot ‐ recirc 8/29/2014 Post First Draft Report for Public Comment 9/5/2014 9/5/2014

Public Comment Closing Date for Paper Submittal* 10/10/2014 10/10/2014 Public Comment Closing Date for Online Submittal (e‐PC)* 11/14/2014 11/14/2014 Final Date to Publish Notice of Consent Standards (Standards that

received no Comments) 11/28/2014 11/28/2014

Appeal Closing Date for Consent Standards (Standards that received no Comments)

12/12/2014 12/12/2014

Final date for TC Second Draft Meeting 5/1/2015 1/23/2015 Comment Posting of Second Draft and TC Ballot 6/12/2015 3/6/2015 Stage Final date for Receipt of TC Second Draft ballot 7/3/2015 3/27/2015

(Second Final date for receipt of TC Second Draft ballot ‐ recirc 7/10/2015 4/3/2015 Draft) Posting of Second Draft for CC Meeting 4/10/2015

Final date for CC Second Draft Meeting 5/22/2015 Posting of Second Draft for CC Ballot 6/12/2015 Final date for Receipt of CC Second Draft ballot 7/3/2015 Final date for Receipt of CC Second Draft ballot ‐ recirc 7/10/2015 Post Second Draft Report for NITMAM Review 7/17/2015 7/17/2015

Tech Session Notice of Intent to Make a Motion (NITMAM) Closing Date 8/21/2015 8/21/2015 Preparation Posting of Certified Amending Motions (CAMs) and Consent

Standards 10/16/2015 10/16/2015

(& Issuance) Appeal Closing Date for Consent Standards (15 days) 10/31/2015 10/31/2015 SC Issuance Date for Consent Standards (10 days) 11/10/2015 11/10/2015

Tech Session Association Meeting for Standards with CAMs 6/6‐9/2016 6/6‐9/2016 Appeals and Appeal Closing Date for Standards with CAMs 6/29/2016 6/29/2016 Issuance SC Issuance Date for Standards with CAMs 8/4/2016 8/4/2016

Approved___ October 30, 2012 Revised____March 7, 2013____________

Public Input No. 1236-NFPA 350-2014 [ Global Input ]

See the uploaded file.

Additional Proposed Changes

File Name Description ApprovedAugust_2013_NFPA_Comment_From_Tim_Fisher.docx Tim Fisher public input email.pdf Email

Statement of Problem and Substantiation for Public Input

We retain our outstanding objections based upon:

1. Our original correspondence to NFPA in August 2013 notifying the organization of our concerns with conflict and duplication.

2. The published results of the PINS deliberation, which note our overall concerns and objections in regards to conflict and duplication.

We have not seen anything in the draft standard addressing our original concerns with conflict and duplication. To this end, we retain our outstanding objection to this proposed standard based upon our concerns with conflict and duplication and the ANSI Essential Requirements Document.

Also see public input #1237 submitted by Terry Krug.

Submitter Information Verification

Submitter Full Name: TIM FISHEROrganization: AMERICAN SOCIETY OF SFTY ENGRStreet Address:City:State:Zip:Submittal Date: Thu Jan 09 07:28:49 EST 2014

National Fire Protection Association Report http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara...

1 of 1309 3/13/2014 10:15 AM

From: Tim Fisher Sent: Monday, August 26, 2013 2:13 PM To: Tim Fisher Subject: Z117.1 committee response to NFPA 350 draft standard Importance: High Greetings Z117: As you are aware, there has been ongoing concern with the proposed NFPA 350 Standard/Guide for Confined Spaces. The Z117 Committee has discussed this issue in the past and noted its concern with conflict and duplication. Z117 Chair (Terry Krug) has asked that a notification be sent Z117 committee members asking them to review NFPA's draft 350 document/standard and comment back on the impact to Z117.1 either complimentary or detrimental and the reasoning. When we receive the committee's responses, then we will draft a letter to NFPA on our position and our recommendations. We cordially ask that any comments should be submitted to the attention of the Z117 secretariat staffer (Tim Fisher) by October 11, 2013. Nancy Pearce from NFPA spoke last Friday on an AIHA up-date call. Nancy's claim is that the NFPA draft 350 standard's main purpose is to be a how to document and is not meant to compete with Z117.1. Along with this message you will find a comparison chart provided by NFPA. We would note that during your review, Z117 members should not be correcting or word-smithing the NFPA 350 document. We are looking for your specific insights and comments addressing the technical and professional impact on Z117.1. NFPA has also posted the document for public input. www.nfpa.org/350. The closing date is January 3, 2014, but we will contact NFPA staff to see if there is a different submission date for the Z117 Committee. Finally, below is a communication sent to NFPA by Z117 Secretariat Staff after reviewing the draft document. Please review the attached and below. We will look forward to receiving any comments you may have by October 11, 2013. We would ask that that they be submitted as a word document on the attached template. ***Comment from Z117 Secretariat Staff*** I have been on the run for the past several weeks, but appreciate your sending me this document for review. I do have a question - do I have your permission to distribute this document to the Z117 ASC membership? I wanted to check with you on this first before taking any additional

action. I assume NFPA is okay with this, but do want to confirm. I have had the opportunity to review the document and must note that these comments are my own personal views. I believe there is going to be great concern with this proposed document on the part of Z117 due to past correspondence and discussion with Z117 leadership. My first question - when will NFPA propose this standard in Standards Action? Z117 and ASSE have already provided notification to NFPA of concern with this project and noted opposition to the establishment of this document under the ANSI banner. In the past, we have pointed to the ANSI Essential Requirements Document and specifically to the sections on duplication and conflict as support for our argument. It might be prudent for NFPA to hold a meeting in accordance with Section 2.5.1.2 of the ANSI Essential Requirements Document if NFPA does intend to pursue processing this NFPA document as an American National Standard. Please also note that Z117 has reviewed this issue before in the past and authorized ASSE as the committee secretariat to file appeals at the SDO and the ANSI level if/when NFPA attempts to process this document as an American National Standard. From my personal review, it unfortunately appears that the document is rife with conflict and duplication. I did a review of the definitions section and noted significant differences between the NFPA document and the Z117.1 Standard, which has been used and accepted for over thirty years within the private and public sector. Our first example is the scope. Z117.1: Scope. This standard provides minimum safety requirements to be followed while entering, exiting and working in confined spaces at normal atmospheric pressure. NFPA: This guide is intended to protect workers who enter into confined spaces for inspection or testing or to perform associated work from death and from life-threatening and other injuries or illnesses and to protect facilities, equipment, non–confined space personnel, and the public from injuries associated with confined space incidents. Comment: We are not sure what the intent of the NFPA document is, but there is nothing more fundamental than the scope statement of a standard or a guide. We are not sure how the NFPA document can profess to be a best practices document since it appears this standard addresses inspection or testing while Z117.1 covers the entire confined space entrance. From our read of the document the NFPA document does not address the key areas of confined space entry.

Second example – why the need to define a confined space separate from Z117.1? NFPA is on Z117 and has been on the committee for decades. NFPA has approved the standard and definition(s) many times. Why the need to create confusion/duplication in regards to a standard it has helped to write? Z117.1: Confined Space. Enclosed area large enough and configured to allow a person to bodily enter and has the following characteristics: • Its primary function is other than human occupancy. • Has restricted entry and exit. (Restricted entry and exit is a physical configuration, which requires the use of the hands for support or contortion of the body to enter into or exit from a confined space.) NFPA: A space that (1) is large enough and so configured that a person can bodily enter and perform assigned work; (2) has limited or restricted means for entry or exit; and (3) is not designed for continuous employee occupancy. Another issue that caught my attention is this statement from the NFPA document: “NFPA 350 does not distinguish between permit required confined spaces and confined spaces. All confined spaces need permits for entry.” 5.1* HEADING. The terms confined space, non-permit required confined space, and permit required confined space can cause some confusion among employers and workers. To eliminate such confusion, this guide uses only the term confined space and makes provisions for evaluating the hazards of and issuing permits for all confined spaces entries regardless of whether the evaluation shows multiple hazards or no hazards at all.* From a personal perspective, I am not sure that I agree with this approach. Requiring permits for all confined spaces regardless of hazard/exposure is neither efficient or effective. The document appears to place great emphasis on a JHA, but then seems to disregard the analysis and requires permits for all spaces? The Z117.1 Standard has historically been based upon the idea that a risk assessment (Section #3) is required and then appropriate steps are taking utilizing the hierarchy of controls. The NFPA document is not a supplement to Z117.1, but would rather seem to be a complete contradiction. I did copy in Terry Krug (Z117 Chair), Ed Grund (Z117 past chair), and Tim Healey (ASSE-SDC Chair). They will review and then advise on the next steps to take. Thanks and Regards, Tim at ASSE

Copy To: ASSE-SDC (Informational-Purposes)


See the uploaded file.

Additional Proposed Changes

File Name Description ApprovedNFPA_350_comments_from_Terry_Krug_1-2014_.docx Terry Krug public input email.pdf email


We retain our outstanding objections based upon:

1. Our original correspondence to NFPA in August 2013 notifying the organization of our concerns with conflict and duplication.

2. The published results of the PINS deliberation, which note our overall concerns and objections in regards to conflict and duplication.

We have not seen anything in the draft standard addressing our original concerns with conflict and duplication. To this end, we retain our outstanding objection to this proposed standard based upon our concerns with conflict and duplication and the ANSI Essential Requirements Document.

Also see public input #1236 submitted by Tim Fisher.


Submitter Full Name: Terry KrugOrganization: EXOSHAStreet Address:City:State:Zip:Submittal Date: Mon Jan 13 08:41:58 EST 2014


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December31,2013TimFisher,CSP,CHMM,CPEA,ARMDirectorofPracticesandstandardsAmericanSocietyofSafetyEngineers(ASSE)1800EastOaktonStreetDesPlaines,IL60018Tim,IhavereviewedmostofthenewNFPA‐350documentandhavethefollowingtoptencommentstobepassedontotheNFPAcommitteedevelopingthis“GuideforSafeConfinedSpaceEntryandWork”Therearemanymorecomments,thesearejustmytopten.

1. Thepublicalreadyhavetwoormorestandardsaddressingconfinedspacesandpermitspaces;OSHA’s29CFR1910.146generalindustrylegalrequirementstobefollowedbyemployerscoveredbytheOSHActandANSIZ1127.12009editiontobefollowedbyemployerswhowanttodomorethanwhatisminimallyrequiredbylaw.Bothofthesestandardsdefineconfinedspacesandwhatisaspacethatrequiresapermitforentry.NFPAlabelsallconfinedspacesaspermitspaceswhichconfusesthepublicandplacesanextraburdenforcomplianceonemployers.

2. Definitionssection:Definitionseitherarenotneeded(Accidents)or

redundant3.3.7ConfinedSpaceRescueServicev3.3.8ConfinedSpaceRescueTeam,orarecompletelylackingtoclarifythedocumentsuchas;HazardousAtmosphere,Entrant,Attendant,EntrySupervisor,tonameafew.Whydoesn’tthedocumentdefinetermsnotfoundinOSHA’s1910.146andANSIZ117.1andrefertothosedocumentsforproperdefinitions?

3. Section4.4Allconfinedspacesshouldbepostedwithasign,tag,orlabeldenotingthemasaconfinedspace.Thisisoverlyburdensometoemployers,postasignoneveryrailtankcarthatcomesthroughaswitchingyard?Labeleverymanholecover?OSHAstatestoonlyIDpermitspacesbyasignorequallyeffectivemeansthatthespaceisclassifiedasapermitspace.Thiscouldbedonethroughtrainingoftheeffectedemployeesornotifyingcontractorsthatcertaintypesofspacesatthefacilityarepermitspaces.

4. Section6.4.2#(5)AdministrativecontrolsaccordingtoOSHAislimitingthe

timeofexposureorchangingworkpracticesnotpostingsignsandtrainingpersonnelinhowtoidentifyhazardsandevaluateandcontrolhazards.

5. Chapter7Atmosphericmonitoring:Theguidestatedthatatmosphericmonitoringneedstobeconductedpriortoentry,itdiscussestestingfromtheoutsidein7.1.9andalsodiscussesthequalifiedtestershouldunderstandthemonitorandit’slimitations7.1.7.1howeverdoesnotdiscusssensorpoisonsandinterferencesuntillaterin7.2.7.Itshouldbementionedearlyandelaboratedlater.Section7.1,11statesifentryintotheconfinedspaceisrequiredfortesting…theentrantshouldbeprotectedbyafullpermitsafeguardssuchasattendant,PPEandcommunicationdevices.Thispersonisenteringintoanunknownatmosphere(IDLH)andOSHAstatesanSCBAshouldbeusedper1910.134(g)(3).Youalsohavestatedin6.3.1thatavisualinspectionandatmosphericmonitoringneedstobeconductedinallareaswithinthespace.Unlessyouspecifyremotecamerasandremotemonitoringtechniquesbeused,employeewillhavetoenter.Youhavealsosaidin7.1.11ifyouareenteringtotest,theconfinedspaceitshouldbeventilatedaccordingtochapter9.Howareyougoingtodocumentwhattheatmosphereisifyouareventilating?

6. 7.2.6Measuringrange:Sensormeasuringrangesshouldbeeasyto

understand.Oxygenrangeis0to25%byvolumenotgreaterthanorequalto25%foroxygen,thatexpressesapeaknotarange.Thesamegoesforflammablesgasesandvapors,0to100%LFL/LEListherange.ThetoxicsshouldhavealimitlessrangeandalarmattheTLVorPELnottheIDLHor50%IDLH.Takecarbonmonoxide,dowewanttheinstrumenttopeakat600ppm?(IDLH=1200ppm)Thissectionneedswork.

7. 7.2.7Interferences:ThisissoimportantinahowtoguideIthinkthe

commoninterferencesshouldbelistedandwhattheyproduceandhowtheusercanminimizeerror(suchasbackupelectronicreadingswithadetectortubesample)oragasbagsentofftoalab(ifthereistime)etc.Thedetectortubesection7.3.1needsexpansiontoincludeshelflife,whattodoifthestaincoverstheentiretube(otherthanrun),periodicvolumechecksinterferences,andcanatubebeusedagainorsaved?

8. 7.6MonitorCalibration:7.6.1Inthelastsentence,“Priortocompletionof

aspancalibration”Shouldchangecompletiontostarting.Priortostartingofaspancalibration…7.6.1.2typoinmiddlesentencethitseir.7.8BumpTesting:7.8.1.2definitionshouldbefirstunder7.8andtheactualproceduresshouldbespelledoutlikeahowtoguide,soanyonecanreadthissectionandunderstandabumptestandperformitproperly.Section7.8.4and7.8.5istooconfusingi.e.oxygenbumptestislowerthanalarmsetpoint.Surrogategases,ifyouwanttokeepthissection,needtobeexplainedbetterwithexamples.Ihavetoldinstrumentuserstouseexpiredgasesortobreatheintothesensorstobumptesttheoxygensensorasalastresort.Thischapteroncalibrationandbumptestingiswherethehowtodoitwouldbeveryvaluable.

9. Section7.11.3OSHAonlyrequirescontinuousmonitoringunder146(d)(5)(i)onlyifthespacecannotbeisolated.

10. Chapter8HazardeliminationandControl:8.2.1AcceptableEntry

Conditions.Wheredidyougetoxygenlevelsbetween19.5to22%?Anylevelover21%isproblematicduetoincreasedfirehazard.WhataboutToxicmaterials:anylevel?2‐5ppmCOisnotaproblem.H2Sat2ppmisnotanissue.Letssetsomerealvalueshere.8.2.4Inertingneedstobeexplainedbetter.Youneedvaluesgivensuchaspurgewithnitrogenuntiltheoxygenlevelsarebelow6%/volumeifproductcouldbeanoxidizerorbelow8%/volumeifnot.UsethemethodologyinNFPA306followedbythemarinechemist.Tellingsomeonetopurgewithaninertgasorsteamandnotexplainhowtodoitwillleadtopossibleexplosionsordeath.Thissectionneedsmajorrevisionandstep‐by‐stepprocedures.ANSIZ117.1or1910.146donotcoverinertedenvironmentsordoanadequatejobofexplainingit.

Thisguidecouldreallybevaluableifitsupplementedtheexistingstandardsbyexplainingthehowtodoitwhereexistingstandardsdonotcovertopicsordonotdoanadequatejobofexplaining.

ThankyouforallowingmetosubmitthesecommentsontheNFPA–350GuideforSafeConfinedSpaceEntryandWorkSincerely,TerryW.Krug,MS,CIH,CSPPresidentEXOSHA,Inc.ChairZ117.1SafetyRequirementsforConfinedSpaces(630)863‐5359


I represent the wind industry and would like to see more defining criteria around ladder access. Every space in a wind turbine is accessed by a vertical ladder yet the entire wind turbine is not aconfined space. There are many discussions throughout the industry and it's not an easyagreement on what is a confined space. Guidance from NFPA could help improve the decisionmaking.

Additionally, we in the wind industry need more definition around 'normal operation'. Normaloperation for a turbine is running and producing power for the collection system. We typically donot access turbine when operating except to open the door at the bottom platform and put theturbine in the maintenance mode. During this mode, the generator is not generating electricity.

Clarification regarding not intended for continuous human occupancy will be of great benefit. Themachines are designed to be entered once yearly (some are every 6 months) to perform servicingand maintenance. Occassionally the visits can be more frequent based on faults. The doors arelocked not sealed, the machine is not air tight, so the normal confined space definitions just don'tapply.


Better clarification and perhaps increased criteria for wind turbines.


Submitter Full Name: James TylerOrganization: VestasStreet Address:City:State:Zip:Submittal Date: Thu Sep 26 17:53:27 EDT 2013


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Public Input No. 1-NFPA 350-2013 [ Section No. 1.1.1 ]

1.1.1 This guide is intended to protect workers who enter into confined spaces for inspection or testing or toperform associated any other work from death and from life-threatening and other injuries or illnesses andto protect facilities, equipment, non–confined space personnel, and the public from injuries associated withconfined space incidents.


The use of the word "associated" implies work associated with inspection or testing. The standard should apply to ALL work in confined spaces.


Submitter Full Name: Rush BowersOrganization: Terracon ConsultantsStreet Address:City:State:Zip:Submittal Date: Wed Aug 21 14:03:22 EDT 2013


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1.1.1 This guide is intended to protect workers provide information to protect personnel who enter into confinedspaces for inspection or , testing or to perform associated work perform work from death and fromlife-threatening and other injuries or illnesses and to protect facilities, equipment, non–confined spacepersonnel , and the public from injuries harm associated with confined space incidents.


this guide does not protect ..it provides information to help the user protect personnelequipment and facilities cannot be injured..use of harm is most appropriate


Submitter Full Name: Richard KrausOrganization: API/Petroleum Safety ConsultanStreet Address:City:State:Zip:Submittal Date: Sun Oct 13 16:10:00 EDT 2013


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1.1.2 This guide is not intended to replace existing regulations and standards but rather to supplement them byproviding additional guidance for safe confined space entry and work. Existing regulations and standardsare referenced throughout the guide, and the annexes direct the reader to regulations and standards thatmight be applicable.


Harmonize language in para 1.1.2 and 1.4. Reduce conflict with existing regulations and standards, reduce probability of imparting confusion in the minds of impacted persons involved in confined space activities due to this Guide's conflict with existing regulations and standards, the addition of more terminology not widely found in industries where confined space entry activities take place, and the general complication of compliance with yet another presumably credible document. My view stems from my organization's successful participation in over 10,000 confined space entry activities annually for more than a decade in business and industrial locations across the nation and around the world (all General Industry, not Construction).


Submitter Full Name: Timothy HealeyOrganization: The Hartford Steam Boiler Inspection & insurance CompanyAffilliation: n/aStreet Address:City:State:Zip:Submittal Date: Thu Jan 02 14:47:04 EST 2014


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1.1.2 This guide is not intended to replace existing regulations, standards and standards but work practices butrather to supplement them by providing additional guidance for safe confined space entry and work.Existing regulations, standards and standards work practices are referenced throughout the guide, andthe annexes direct the reader to regulations and standards that those that might be applicable.


added work practices and simplified for clarity




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1.1.3 This guide provides both prescriptive and performance-based guidance on how to identify, evaluate,assess, eliminate, and control hazards that occur during entry or work in and around confined spaces.Change "prescriptive" to "instructive". prescriptive has various definitions ranging from mandated toinstructive. Instructive is a better definition for the scope.


Change of wording that would be from mandated to instructive


Submitter Full Name: Dennis O'ConnellOrganization: Roco Rescue Inc.Affilliation: 350 committee memberStreet Address:City:State:Zip:Submittal Date: Thu Dec 26 09:37:43 EST 2013


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1.1.3 This guide provides both prescriptive and performance-based guidance on how to identify in orderto identify , evaluate, assess, eliminate, mitigate and/or control hazards that are present or may occurduring entry or work in and around confined spaces.


changed for correctness




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1.1.4 This guide addresses those fire provides information in order to understand and safeguard prersonnelfrom fire , explosion, safety, and health hazards that are commonly associated with confined space entry.


more correctly identifies the purpose of the guide




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1.1.5 This guide addresses training, guide provides information regarding training, education, qualifications, andcompetencies required for personnel responsible for confined space hazard identification, hazardevaluation , and hazard control as well as for those who are working and for personnel who work in andaround confined spaces.


the guide provides does not address. changed for clarity




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1.1.7 This guide addresses confined provides information concerning confined space hazards and safepractices that are common in applicable to all industries with confined spaces.


provides information. applies to all confined spaces not just industrial




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1.1.8 This guide addresses hazards guide provides information regarding hazards adjacent to confined spacesthat might affect the safe conditions necessary for entry and work in the confined space.


for clarity and correctness




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1.1.9 This guide provides criteria for controls that eliminate or minimize confined space hazards in the designphase.Suggest reword to:

This guide provides criteria for consideration of methods in controlling or eliminating hazards in the confinedspace design phase.


The section leaves out controlling hazards and only talks about eliminating them. Not all hazards can be eliminated.


Submitter Full Name: Dennis O'ConnellOrganization: Roco Rescue Inc.Affilliation: 350 memberStreet Address:City:State:Zip:Submittal Date: Thu Dec 26 09:46:56 EST 2013


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1.1.9 This guide provides criteria for for procedures and controls that in order to eliminate or minimize mininizeconfined space hazards in the design phase.


for clarity. may need procedures instead of or in addition to controls




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1.2.1 The purpose of this guide is to provide the best safe provide safe work practices for those for personsworking in and around confined spaces. The guide goes beyond minimum requirements that have beenestablished by regulations and standards and intends to provide those who strive to achieve a higher highlevel of safety with the best practices for identifying, evaluating, and eliminating, mitigating or controllinghazards in order to manage the risk risks associated with confined space activities. This guide is alsointended to address confined space related work practices and procedures not fully covered or explained inexisting regulations and standards related to confined space entry and work.


revised for clarity


Submitter Full Name: Richard KrausOrganization: API/Petroleum Safety ConsultanStreet Address:City:State:Zip:Submittal Date: Mon Oct 14 13:00:08 EDT 2013


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1.2.2 This guide also serves to refer the reader to provides information regarding other applicable documentsthat relate to particular types of industries or type of work being done in a confined space and occupanciesas well as different types of work performed in confined spaces .


additional information and changed for clarity




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Public Input No. 736-NFPA 350-2013 [ Section No. 1.3 ]

1.3 * Application.This guide is intended to provide guidance for safe entry into confined spaces and associated workregardless of location classification, use or location of the space .


added work associated with confined space entry as well as space classification and use




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Public Input No. 216-NFPA 350-2013 [ Chapter 2 ]

Chapter 2 Referenced Publications (Reserved)29 CFR 1910.146, Permit-Required Confined Spaces29 CFR 1910.147, Control of Hazardous EnergyAIHA, Confined Space Entry, An AIHA Protocol GuideASTM D4276-02, Standard Practice for Confined Space EntryAPI 2015 Requirements for Safe Entry and Cleaning of Petroleum Storage TanksAPI 2016 Guidelines and Procedures for Entering and Cleaning Petroleum Storage TanksAPI 2217A Guidelines for Safe Work in Inert Confined Spaces in the Petroleum and PetrochemicalIndustriesANSI Z117.1, Safety Requirements for Confined SpacesNFPA 306, Standard for the Control of Gas Hazards on VesselsNFPA 326, Standard for the Safeguarding of Tanks and Containers for Entry, Cleaning, or RepairNFPA 1006 - Standard for Technical Rescuer Professional QualificationsNFPA 1670 - Standard on Operations and Training for Technical Search and Rescue IncidentsConfined Space Emergency Response: Assessing Employer and Fire Department Practices, Journal ofOccupational and Environmental Hygiene, 9: 120-128, Michael P. Wilson, Heather N. Madison, andStephen B. Healy.


some suggested references


Submitter Full Name: Alfred KeissOrganization: Committee MemberStreet Address:City:State:Zip:Submittal Date: Tue Sep 10 08:50:14 EDT 2013


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Public Input No. 1232-NFPA 350-2014 [ Chapter 3 ]

Chapter 3 Definitions3.1 General.The definitions contained in this chapter shall apply to the terms used in this guide. Where terms are notdefined in this chapter or within another chapter, they shall be defined using their ordinarily acceptedmeanings within the context in which they are used. Merriam-Webster’s Collegiate Dictionary, 11th edition,shall be the source for the ordinarily accepted meaning.3.2 NFPA Official Definitions.3.2.1 Guide.A document that is advisory or informative in nature and that contains only nonmandatory provisions. Aguide may contain mandatory statements such as when a guide can be used, but the document as a wholeis not suitable for adoption into law.3.3 General Definitions.3.3.1 Accident.An unplanned occurrence, which results in a loss such as unintended injury, illness, death, propertydamage, or damage to the environment. [1521, 2015]3.3.2 Accidents.Unplanned events that result in injuries or damage that interrupts routine operations.3.3.3* Acceptable Entry Conditions.Conditions that have met all entry requirements specified in the confined space program and all entryconditions listed on the permit.3.3.4 Adjacent space.Those spaces in all directions from subject space, including points of contact, internal and external, such asdecks, sumps, floating roofs, secondary containment areas, interstitial spaces, under floors, supports, tanktops, and bulkheads. [326, 2015]3.3.5 Competent Person.Someone who is designated in writing and who is capable of identifying existing and predictable hazards inthe surroundings or working conditions that are unsanitary, hazardous, or dangerous to employees, andwho has authorization to take prompt corrective measures to eliminate them. [1006, 2013]3.3.6* Confined Space.A space that (1) is large enough and so configured that a person can bodily enter and perform assignedwork; (2) has limited or restricted means for entry or exit; and (3) is not designed for continuous employeeoccupancy.3.3.7 Confined Space Rescue Service.The confined space Rescue Team designated by the authority having jurisdiction (AHJ) to rescue victimsfrom within confined spaces, including operational and technical levels of industrial, municipal, and privatesector organizations.3.3.8 Confined Space Rescue Team.A combination of individuals trained, equipped, and available to respond to confined space emergencies.

8. 3. 8+ Enclosure.

The case or housing of apparatus, or the fence or walls surrounding an installation to preventpersonnel from accidentally contacting energized parts or to protect the equipment from physicaldamage.

3.3. 9* Explosionproof.Referring to apparatus enclosed in a case that is capable of withstanding an explosion of a specified gas orvapor that might occur within it and of preventing the ignition of a specified gas or vapor surrounding theenclosure by sparks, flashes, or explosion of the gas or vapor within and that operates at such an externaltemperature that a surrounding flammable atmosphere will not be ignited thereby.


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3.3.10 Hazard.Biological, chemical, mechanical, electrical, atmospheric, environmental, or physical agent that has or canhave the potential to result in injury, illness, property damage, or interruption of a process or an activity inthe absence of a control measure.3.3.11 Hazard Evaluation.A two-step process of identifying hazards or potential hazards and then determining the risk of each hazardidentified.3.3.12 Hazard Identification.The determination of present and potential physical, chemical, atmospheric, mechanical, electrical, andbiological hazards in and around a confined space.3.3.13 Hot Work.Work involving burning, welding, or a similar operation that is capable of initiating fires or explosions. [51B,2013]3.3.14 Intrinsically Safe.Type of protection where any spark or thermal effect is incapable of causing ignition of a mixture offlammable or combustible material in air under prescribed test conditions. [70, 2014].3.3.15* Job Hazard Analysis (JHA).A safety management risk assessment (RA) technique that is used to define and control the hazardsassociated with a process, job, or procedure. Any job that has actual or potential hazards is a candidate fora JHA.3.3.16 Maintenance.The routine recurring work required to keep a facility (plant, building, structure, ground facility, utility system,or other real property) or equipment in such condition that it can be continuously utilized, at its original ordesigned capacity and efficiency, for its intended purpose.3.3.17 Periodic.Occurring or recurring at regular predetermined or specified intervals.3.3.18* Permit Required Confined Space (Permit Space).A confined space that has one or more of the following characteristics: (1) Contains or has the potential tocontain a hazardous atmosphere; (2) Contains a material that has the potential for engulfing an entrant; (3)Has an internal configuration such that an entrant could be trapped or asphyxiated by inwardly convergingwalls or by a floor that slopes downward and tapers to a smaller cross-section; (4) Contains any otherrecognized serious safety or health hazard3.3.19 Qualified Person.A person who, by possession of a recognized degree, certificate, professional standing, or skill, and who,by knowledge, training, and experience, has demonstrated the ability to deal with problems relating to aparticular subject matter, the work, or the project. [326, 2015]3.3.20 Rescue Attendant.A person who is qualified to be stationed outside a confined space to monitor rescue entrants, summonassistance, and perform non-entry rescues.3.3.21 Rescue Entrant.A person entering a confined space for the specific purpose of rescue.3.3.22 Retrieval System.Combinations of rescue equipment used for non-entry (external) rescue of persons from confined spaces.3.3.23 Risk.The probability that a substance or situation will produce harm under specified conditions. Risk is acombination of two factors: (1) the probability that an adverse event will occur and (2) the severity of theconsequences of the adverse event.3.3.24 Risk Assessment.A process for systematically evaluating risk that considers the severity of consequences and the likelihoodthat the adverse event will occur.3.3.25 Ventilation.The changing of air within a compartment by natural or mechanical means. Ventilation can be achieved byintroduction of fresh air to dilute contaminated air or by local exhaust of contaminated air. [302, 2015]



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In electrical and telecommunication systems, for example, the words "enclosure", "enclosed space" are terms of art that are generally understood in context. The proposed definition you see here is a definition that appears in the National Electrical Code and may not be an official NFPA definition but it is submitted to help clarify the vocabulary we need to assure worker safety.


Submitter Full Name: Michael AnthonyOrganization: University of MichiganStreet Address:City:State:Zip:Submittal Date: Fri Jan 03 14:19:00 EST 2014


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3.1 General.The definitions contained in this chapter shall apply to the terms used in this guide. Where terms are notdefined in this chapter or within another chapter, they shall be defined using their ordinarily acceptedmeanings within the context in which they are used. Merriam-Webster’s Collegiate Dictionary, 11th edition,shall be the source for the ordinarily accepted meaning.

There is no definition for purging


Definition


Submitter Full Name: Peter NeufeldOrganization: Winkler Fire and RescueStreet Address:City:State:Zip:Submittal Date: Sat Aug 31 23:53:02 EDT 2013


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3.1 General.The definitions contained in this chapter shall apply to the terms used in this guide. Where terms are notdefined in this chapter or within another chapter, they shall should be defined using their ordinarilyaccepted meanings within the context in which they are used. Merriam-Webster’s Collegiate Dictionary,11th edition, shall be is the source for the ordinarily accepted meaning.


eliminate mandatory "shalls"




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3.3 General Definitions.3.3.1 Accident.An unplanned occurrence, which results in a loss such as unintended injury, illness, death, propertydamage, or damage to the environment. [1521, 2015]3.3.2 Accidents.Unplanned events that result in injuries or damage that interrupts routine operations.3.3.3* Acceptable Entry Conditions.Conditions that have met all entry requirements specified in the confined space program and all entryconditions listed on the permit.3.3.4 Adjacent space.Those spaces in all directions from subject space, including points of contact, internal and external, such asdecks, sumps, floating roofs, secondary containment areas, interstitial spaces, under floors, supports, tanktops, and bulkheads. [326, 2015]3.3.5 Competent Person.Someone who is designated in writing and who is capable of identifying existing and predictable hazards inthe surroundings or working conditions that are unsanitary, hazardous, or dangerous to employees, andwho has authorization to take prompt corrective measures to eliminate them. [1006, 2013]3.3.6* Confined Space.A space that (1) is large enough and so configured that a person can bodily enter and perform assignedwork; (2) has limited or restricted means for entry or exit; and (3) is not designed for continuous employeeoccupancy.3.3.7 Confined Space Rescue Service.The confined space Rescue Team designated by the authority having jurisdiction (AHJ) to rescue victimsfrom within confined spaces, including operational and technical levels of industrial, municipal, and privatesector organizations.3.3.8 Confined Space Rescue Team.A combination of individuals trained, equipped, and available to respond to confined space emergencies.3.3.9* Explosionproof.Referring to apparatus enclosed in a case that is capable of withstanding an explosion of a specified gas orvapor that might occur within it and of preventing the ignition of a specified gas or vapor surrounding theenclosure by sparks, flashes, or explosion of the gas or vapor within and that operates at such an externaltemperature that a surrounding flammable atmosphere will not be ignited thereby.3.3.10 Hazard.Biological, chemical, mechanical, electrical, atmospheric, environmental, or physical agent that has or canhave the potential to result in injury, illness, property damage, or interruption of a process or an activity inthe absence of a control measure.3.3.11 Hazard Evaluation.A two-step process of identifying hazards or potential hazards and then determining the risk of each hazardidentified.3.3.12 Hazard Identification.The determination of present and potential physical, chemical, atmospheric, mechanical, electrical, andbiological hazards in and around a confined space.3.3.13 Hot Work.Work involving burning, welding, or a similar operation that is capable of initiating fires or explosions. [51B,2013]3.3.14 Intrinsically Safe.Type of protection where any spark or thermal effect is incapable of causing ignition of a mixture offlammable or combustible material in air under prescribed test conditions. [70, 2014].


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3.3.15* Job Hazard Analysis (JHA).A safety management risk assessment (RA) technique that is used to define and control the hazardsassociated with a process, job, or procedure. Any job that has actual or potential hazards is a candidate fora JHA.3.3.16 Maintenance.The routine recurring work required to keep a facility (plant, building, structure, ground facility, utility system,or other real property) or equipment in such condition that it can be continuously utilized, at its original ordesigned capacity and efficiency, for its intended purpose.3.3.17 Periodic.Occurring or recurring at regular predetermined or specified intervals.3.3.18* Permit Required Confined Space (Permit Space).A confined space that has one or more of the following characteristics: (1) Contains or has the potential tocontain a hazardous atmosphere; (2) Contains a material that has the potential for engulfing an entrant; (3)Has an internal configuration such that an entrant could be trapped or asphyxiated by inwardly convergingwalls or by a floor that slopes downward and tapers to a smaller cross-section; (4) Contains any otherrecognized serious safety or health hazard

3.3. 18 Plenum.

A compartment or chamber to which one or more air ducts are connected and that forms part ofthe air distribution system.

3.3. 19 Qualified Person.A person who, by possession of a recognized degree, certificate, professional standing, or skill, and who,by knowledge, training, and experience, has demonstrated the ability to deal with problems relating to aparticular subject matter, the work, or the project. [326, 2015]3.3.20 Rescue Attendant.A person who is qualified to be stationed outside a confined space to monitor rescue entrants, summonassistance, and perform non-entry rescues.3.3.21 Rescue Entrant.A person entering a confined space for the specific purpose of rescue.3.3.22 Retrieval System.Combinations of rescue equipment used for non-entry (external) rescue of persons from confined spaces.3.3.23 Risk.The probability that a substance or situation will produce harm under specified conditions. Risk is acombination of two factors: (1) the probability that an adverse event will occur and (2) the severity of theconsequences of the adverse event.3.3.24 Risk Assessment.A process for systematically evaluating risk that considers the severity of consequences and the likelihoodthat the adverse event will occur.3.3.25 Ventilation.The changing of air within a compartment by natural or mechanical means. Ventilation can be achieved byintroduction of fresh air to dilute contaminated air or by local exhaust of contaminated air. [302, 2015]


A great deal of work happens above ceilings on ladders and in large air chambers where duct smoke detectors and fire doors require serving. This class of work and the hazards associated with this work needs to track more explicitly in a best practice document. This definition is taken from the National Electrical Code


Submitter Full Name: Michael AnthonyOrganization: University of MichiganStreet Address:City:State:Zip:


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Submittal Date: Fri Jan 03 14:44:18 EST 2014


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3.3 General Definitions.3.3.1 Accident.

An unplanned occurrence, which results in a loss such as unintended injury, illness, death, propertydamage, or damage to the environment. [1521, 2015]3.3.2 Accidents.

Unplanned events that result in injuries or damage that interrupts routine operations.3.3.3 * Acceptable Entry Conditions.

Conditions that have met all entry requirements specified in the confined space program and all entryconditions listed on the permit.3.3.4 Adjacent space.

Those spaces in all directions from subject space, including points of contact, internal and external, such asdecks, sumps, floating roofs, secondary containment areas, interstitial spaces, under floors, supports, tanktops, and bulkheads. [326, 2015]

3.3.5 Competent Entry Supervisor - (5.4 introduces this term)

3.3.5 Competent Person.Someone who is designated in writing and who is capable of identifying existing and predictable hazards inthe surroundings or working conditions that are unsanitary, hazardous, or dangerous to employees, andwho has authorization to take prompt corrective measures to eliminate them. [1006, 2013]3.3.6 * Confined Space.

A space that (1) is large enough and so configured that a person can bodily enter and perform assignedwork; (2) has limited or restricted means for entry or exit; and (3) is not designed for continuous employeeoccupancy.3.3.7 Confined Space Rescue Service.

The confined space Rescue Team designated by the authority having jurisdiction (AHJ) to rescue victimsfrom within confined spaces, including operational and technical levels of industrial, municipal, and privatesector organizations.3.3.8 Confined Space Rescue Team.

A combination of individuals trained, equipped, and available to respond to confined space emergencies.3.3.9 * Explosionproof.

Referring to apparatus enclosed in a case that is capable of withstanding an explosion of a specified gas orvapor that might occur within it and of preventing the ignition of a specified gas or vapor surrounding theenclosure by sparks, flashes, or explosion of the gas or vapor within and that operates at such an externaltemperature that a surrounding flammable atmosphere will not be ignited thereby.3.3.10 Hazard.

Biological, chemical, mechanical, electrical, atmospheric, environmental, or physical agent that has or canhave the potential to result in injury, illness, property damage, or interruption of a process or an activity inthe absence of a control measure.3.3.11 Hazard Evaluation.

A two-step process of identifying hazards or potential hazards and then determining the risk of each hazardidentified.3.3.12 Hazard Identification.

The determination of present and potential physical, chemical, atmospheric, mechanical, electrical, andbiological hazards in and around a confined space.3.3.13 Hot Work.

Work involving burning, welding, or a similar operation that is capable of initiating fires or explosions. [51B,2013]3.3.14 Intrinsically Safe.

Type of protection where any spark or thermal effect is incapable of causing ignition of a mixture offlammable or combustible material in air under prescribed test conditions. [70, 2014].


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3.3.15 * Job Hazard Analysis (JHA).A safety management risk assessment (RA) technique that is used to define and control the hazardsassociated with a process, job, or procedure. Any job that has actual or potential hazards is a candidate fora JHA.3.3.16 Maintenance.

The routine recurring work required to keep a facility (plant, building, structure, ground facility, utility system,or other real property) or equipment in such condition that it can be continuously utilized, at its original ordesigned capacity and efficiency, for its intended purpose.

3.3.17 Permit Issuer (5.5 introduces this term)

3.3.17 Periodic.Occurring or recurring at regular predetermined or specified intervals.3.3.18 * Permit Required Confined Space (Permit Space).

A confined space that has one or more of the following characteristics: (1) Contains or has the potential tocontain a hazardous atmosphere; (2) Contains a material that has the potential for engulfing an entrant; (3)Has an internal configuration such that an entrant could be trapped or asphyxiated by inwardly convergingwalls or by a floor that slopes downward and tapers to a smaller cross-section; (4) Contains any otherrecognized serious safety or health hazard3.3.19 Qualified Person.

A person who, by possession of a recognized degree, certificate, professional standing, or skill, and who,by knowledge, training, and experience, has demonstrated the ability to deal with problems relating to aparticular subject matter, the work, or the project. [326, 2015]3.3.20 Rescue Attendant.

A person who is qualified to be stationed outside a confined space to monitor rescue entrants, summonassistance, and perform non-entry rescues.3.3.21 Rescue Entrant.

A person entering a confined space for the specific purpose of rescue.3.3.22 Retrieval System.

Combinations of rescue equipment used for non-entry (external) rescue of persons from confined spaces.3.3.23 Risk.

The probability that a substance or situation will produce harm under specified conditions. Risk is acombination of two factors: (1) the probability that an adverse event will occur and (2) the severity of theconsequences of the adverse event.3.3.24 Risk Assessment.

A process for systematically evaluating risk that considers the severity of consequences and the likelihoodthat the adverse event will occur.3.3.25 Ventilation.

The changing of air within a compartment by natural or mechanical means. Ventilation can be achieved byintroduction of fresh air to dilute contaminated air or by local exhaust of contaminated air. [302, 2015]


needs definition and section needs renumbering, terms in 5.6 all need to be defined


Submitter Full Name: Alfred KeissOrganization: Committee MemberStreet Address:City:State:Zip:Submittal Date: Sun Sep 01 10:21:02 EDT 2013


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3.3.1 Accident Incident .An unplanned occurrence, which results in a loss such as unintended injury, illness, death, propertydamage, or damage to the environment. [1521, 2015]


the word accident is being replaced by the word incident that has a more neutral tone




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3.3.2 Accidents. IncidentsUnplanned events that result in injuries or damage that interrupts routine operations.


see 3.3.1. Accident




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delete see 3.3. 2 Accidents.Unplanned events that result in injuries or damage that interrupts routine operations.1


does not have to actually have to interrupt operations. it could happen and not affect work. It could also interrupt non-routine operations




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3.3.3 * Acceptable Entry Conditions.Conditions that have met meet all entry requirements specified in the confined space program and all entryconditions listed on the entry permit.


change "met" to present tense..."meet". add entry to permits so as to not confuse with other types of permits




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3.3.4 Adjacent space.Those spaces in all directions from subject space, including points of contact, internal and external, such asdecks, sumps, floating roofs, secondary containment areas, interstitial spaces, under floors, supports, tanktops, and bulkheads. [326, 2015]Suggest the use of the word “Area”

Area better defines not just adjacent confined spaces but other areas. This should not change the intent buteliminate confusion.


confusing wording


Submitter Full Name: Dennis O'ConnellOrganization: Roco Rescue Inc.Street Address:City:State:Zip:Submittal Date: Thu Dec 26 09:58:12 EST 2013


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3.3.5 Competent Person.Someone who is designated in writing and who is capable of identifying existing and predictable hazards inthe surroundings or working conditions that are unsanitary, hazardous, or dangerous to employees, andwho has authorization to take prompt corrective measures to eliminate them. [ 1006, 2013]

Suggest eliminate or "control them"?


Forgot control hazards




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3.3.5 Competent Person.Someone who is designated in writing and who is capable of identifying existing and predictable hazards inthe surroundings or working conditions that are unsanitary, hazardous, or dangerous to employees, andwho has authorization to take prompt corrective measures to eliminate them. [ 1006, 2013] associated withthe confined space

Note: also see "qualified person"


the competent person may not always have the authority to correct conditions. The competent person can inspect and recognize conditions and may correct conditions only if authorized by (1) the owner/operator or contractor or (2) the confined space entry supervisor or (3) the permit issuer


Submitter Full Name: Richard KrausOrganization: API/Petroleum Safety ConsultanStreet Address:City:State:Zip:Submittal Date: Tue Sep 03 05:36:04 EDT 2013


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3.3.6 * Confined Space.A space that (1) is large enough and so configured that a person can bodily enter and perform assignedwork; (2) has limited or restricted means for entry or exit; and (3) is not designed for continuous employeecontinuous occupancy.


occupancy may not be an employee...for example it could be a contractor or inspector or an intruder...anyone who is not an employee


Submitter Full Name: Richard KrausOrganization: API/Petroleum Safety ConsultanStreet Address:City:State:Zip:Submittal Date: Tue Sep 03 05:31:34 EDT 2013


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3.3.7 Confined Space Rescue Service.The confined space Rescue Team designated by the authority having jurisdiction (AHJ) to rescue victimsfrom within confined spaces, including operational and technical levels of industrial, municipal, and privatesector organizations.Suggest change AHJ to employer or property owner. or give a definition of AHJ;


clarification




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3.3.7 Confined Space Rescue Service.The confined space Rescue Team Team or trained and qualified personnel designated by the authorityhaving jurisdiction (AHJ) to owner/operators or contractors to rescue victims from within confined spaces,including operational and technical levels of industrial facility or contractor, industrial cooperative ,municipal, and private sector organizations.


provides for other rescuers besides rescue service. revised for clarity ie: what is operational and technical levels????




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Public Input No. 82-NFPA 350-2013 [ New Section after 3.3.8 ]

TITLE OF NEW CONTENTType your content here ...

Controlled Access Zone (CAZ): A clearly demarcated area located behind high-viz Danger tape/signage(or eq.), which encompasses (in three dimensions) any/all of the existing and potential hazards and theiradequate control measures which may potentially affect the life and safety of CS Entrants and Entry Teammembers during the CS Entry operation; CAZ shall be initially commissioned as a safe-for-entry conditionand shall not be decommissioned until personnel accountabiity is complete, the CS returned to its originaloperting condition and the CS permit has been signed closed by the Supervisor.


My industrial construction experience (paper, cement, paper, hydroelectric) with PRCS taught me the importance in defining my Project Limit Lines (PLL) and establishing a clear Controlled Access Zone. This provides my direct employees with a visual limit for the term of the contract as well as a warning line of ingress for all others on a multi-employer site. I believe it is critical to emphasize the term CAZ in relation to identifying and controlling CS hazards which may exist or potentially exist outside of the physical CS portal. A CS CAZ is most often structured by the CS Supervisor while conducting a job safety analysis in conjunction with a risk assessment matrix. In any construction job the PLLs are actually 4 dimensional (X, Y, Z & Time) and perpetually changing during critical path work phases. For instance, PRCS work (Vacuuming, dewatering, parging, etc.) in open sewer system requires a constant re-evaluation of controlled access by the competent person. Additionally, there are many instances, particularly in multi-employer shutdown projects, when it may be required to reconfigure the size, shape, design and security of a CS CAZ as previously-non-existant hazardous acts and conditions occur or are abated. Inevitably the project CAZ has a direct correlation to the Rescue Limit Lines (RLL) established by Incident Commander (IC) and Safety Officer (SO) during emergency response event. By including the CAZ in the Definitions it will highlighting its critical importance in the Permit's safe-for-entry criteria and the last task performed before recommissioning the space at substantial completion.


Submitter Full Name: Chip MacdonaldOrganization: Best Safety LLCStreet Address:City:State:Zip:Submittal Date: Thu Sep 05 14:45:59 EDT 2013


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3.3.8 Confined Space Rescue Team.A combination of individuals trained, equipped, and available to respond to confined space emergencies.Suggest more wording… "To respond to and perform entry rescue during confined space emergencies".


clarification of terms




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3.3.8 Confined Space Rescue Team.A combination of individuals trained Two or more individuals who are trained , equipped, and available torespond to confined space emergencies.


a combination of what??? skills??, ethnicity??? a team is two or more (probably could be 1 person also)




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3.3.9 * Explosionproof Explosion Proof .Referring to apparatus enclosed in a case that is capable of withstanding an explosion of a specified gas orvapor that might occur within it and of preventing the ignition of a specified gas or vapor surrounding theenclosure by sparks, flashes, or explosion of the gas or vapor within and that operates at such an externaltemperature that a surrounding flammable atmosphere will not be ignited thereby.


two words




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3.3.9 * Explosionproof.Referring to Equipment or apparatus enclosed in a case that is capable of withstanding of containing anexplosion of a specified gas a gas or vapor that might occur within it the casing and of preventing theignition of a specified flammable gas or vapor surrounding the enclosure by sparks, flashes, or explosionof the gas or vapor within and that operates at such an external temperature that a surrounding flammableatmosphere will not be ignited thereby. atmosphere outside of the casing. .


rewritten for clarity and correctness




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3.3.10 Hazard.Biological, chemical, mechanical, electrical, atmospheric, environmental, or physical agent that has or canhave the potential to result in injury, illness, property damage, or interruption of a process or an activity inthe absence of a control measure.

This should match 6.35


contents matching




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3.3.10 Hazard.Biological, chemical, mechanical, electrical, atmospheric, environmental, or physical agent that has or canor may have the potential to result in injury, illness, property damage, or interruption of a process or anactivity in the absence of a control measure.


"has" and "can" are the same meaning. Use "may" to be correct




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3.3.11 Hazard Evaluation.A two-step The process of identifying hazards or potential hazards and then determining the risk orpotential risk of each hazard identified.


this could be more than a two step process.. identify, evaluate degree of risk, determine what is affected and where it would apply .... for example




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3.3.12 Hazard Identification.The determination of present and potential physical, chemical, atmospheric, mechanical, electrical, andbiological hazards in and around a confined space as well as hazards elsewhere in the facility or vicinitythat may impact upon confined space operations ..


provides for hazards outside the area that could impact operations




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3.3.13

technical committee on confined space safe …...richard wright principal wright rescue solutions,...

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