technical committee on confined space safe work practices ......kennyw.oldfield alternate alabama...

Technical Committee on Confined Space Safe Work Practices First Draft Meeting Agenda

Embassy Suites, Fort Lauderdale, FL April 4-6, 2017

Continental Breakfast served each morning at 7:30 AM. Lunch provided on day one.

1. Welcome. Don English, Chair.

2. Introduction of Committee Members and Attendees. See page 3.

3. Approval of Pre-First Draft Meeting Minutes. See page 7.

4. Revision Timeline for Fall 2018 Documents. See page 9.

5. Staff Presentation, First Draft Revision process.

6. Task group reports/Chapter review and review of Public Inputs. See page 10.

General Requirements (Chapter 1, 4 and 5). Laura Weems Chapter 3 Definitions. Bob Rusczek. Chapter 6 Hazard Identification/Evaluation. Mark Ronecker. Chapter 7 Atmospheric Monitoring. Andrew Sanders Chapter 8 Hazard Elimination and Control. Chris Buehler. Chapter 9 Ventilation. Glenn McGinley. Chapter 10 Rescue. Richey Wright. Chapter 11 Training and Competencies. Laura Weems. Chapter 12 and 14 Written Programs and Recording. Al Keiss. Chapter 13 Permits. Mike Palmer. Chapter 15 Management of Change. Jim Haiser. Chapter 16 Prevention of Design. Bill Weems.

of 297

Inerting. Dick Kraus. Hot Work/Welding Task Group. Dennis O’Connell. OSHA Construction Standard comparison of NFPA 350. Al Keiss.

8. Other Business.

Review of NFPA 350 promotion, on line training etc.

9. Schedule Next Meeting.

10. Adjourn.

of 297

Address List No PhoneConfined Space Safe Work Practices CNS-AAA

Nancy Pearce02/22/2017

CNS-AAA

Leslie D. English

Chair254 South Jackson StreetGrove Hill, AL 36451

SE 3/1/2011CNS-AAA

Adam C. Jones

SecretaryBuechel Fire Protection District4101 Bardstown RoadLouisville, KY 40218

E 10/18/2011

CNS-AAA

Rick Argudin

PrincipalCapital Safety5740 West Little York, Suite 179Houston, TX 77091

M 07/29/2013CNS-AAA

Edward K. Boring

PrincipalHilton Head Island Fire Rescue40 Summit DriveHilton Head Island, SC 29926International Association of Fire ChiefsAlternate: Rodney Foster

E 10/20/2010

CNS-AAA

Christopher S. Buehler

PrincipalExponent, Inc.420 Lexington Avenue, Suite 1740New York, NY 10170

SE 03/03/2014CNS-AAA

Aaron D. Duff

PrincipalJohnson & Johnson410 George StreetNew Brunswick, NJ 08901-2016NFPA Industrial Fire Protection Section

U 10/20/2010

CNS-AAA

Timothy R. Fisher

PrincipalAmerican Society of Safety Engineers1800 East Oast Oakton StreetDes Plaines, IL 60018-2187


James R. Haiser, Jr.

PrincipalDow Corning Corporation28899 East Iron Woods PathMidland, MI 48642

M 12/08/2015

CNS-AAA

Daniel Hudson

PrincipalCity of Dalton Fire Department72 Boxer LaneRock Spring, GA 30739


Alfred W. Keiss

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

SE 10/18/2011

CNS-AAA

Steven E. Kosch

Principal3M Company3833 Jola WayRed Wing, MN 55066

M 03/07/2013CNS-AAA

Richard S. Kraus

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

U 3/4/2009

CNS-AAA

Edmund L. Lydon, Jr.

PrincipalNortheast Hospital Corporation85 Herrick StreetBeverly, MA 01915-1790New England Healthcare Engineers SocietyAlternate: Danny J. Collins

U 08/09/2012CNS-AAA

Glenn E. Mate

PrincipalGuilford Fire Department, EMT-Local 4177Fairfield Regional Fire School584 Moose Hill RoadMonroe, CT 06468

E 3/4/2009

1 of 297



CNS-AAA

Joseph R. Mathews

PrincipalSprinkler 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, II

PrincipalOhio Public Employment Risk Reduction Program4448 Prairie Creek LaneMaumee, OH 43537-9020

E 8/5/2009

CNS-AAA

Kevin McKeigue

PrincipalTyco/Scott Safety4320 Goldmine RoadMonroe, NC 28110International Safety Equipment AssociationAlternate: Cristine Z. Fargo

M 04/05/2016CNS-AAA

Terrance L. McKinch

PrincipalMortenson Construction3278 South Duffield RoadLennon, MI 48449-9407

IM 08/03/2016

CNS-AAA

David McLaughlin

PrincipalOregon OSHAPO Box 14480Salem, OR 97309-0405

E 03/07/2013CNS-AAA

David Andrew Noel

PrincipalThe Scoular Company1001 Haxall Point Road, Suite 710Richmond, VA 23219

M 08/03/2016

CNS-AAA

Michael Palmer

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


Bob A. Rusczek

PrincipalCertified Safety and Health11 Arbor LaneWilbraham, MA 01095Alternate: Adam J. Goodman

SE 08/09/2012

CNS-AAA

Rich St. Myers

PrincipalUS Steel Corporation1 North BroadwayGary, IN 46402

U 11/30/2016CNS-AAA

James L. Tyler

PrincipalVestas1417 NW Everett StreetQuad 4.09Portland, OR 97209-2652American Wind Energy AssociationAlternate: Michele Myers Mihelic

U 10/28/2014

CNS-AAA

David Wagner

PrincipalIndustrial Scientific Corporation1 Life WayPittsburgh, PA 15205Alternate: Andrew Saunders

M 10/27/2009CNS-AAA

Laura Hartline Weems

PrincipalArmy Corps Of Engineers, Little Rock District6220 Southwind DriveNorth Little Rock, AR 72118

U 03/07/2013

2 of 297



CNS-AAA

William H. Weems

PrincipalSafe State ProgramUniversity of AlabamaPO Box 870388Tuscaloosa, AL 35487Alternate: Kenny W. Oldfield


Richard Wright

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

SE 3/1/2011

CNS-AAA

Leonard A. Young, Jr.

PrincipalMassachusetts Water Resources Authority90 Tafts AvenueWinthrop, 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-AAA

Todd W. Trefren

Voting AlternateLouis Dreyfus Commodities4800 Main StreetSuite 600Kansas City, MO 64112-2509National Oilseed Processors Association

U 12/08/2015CNS-AAA

Danny J. Collins

AlternateNortheast Fire Safety and ConsultingPO Box 3025Plattsburgh, NY 12901New England Healthcare Engineers SocietyPrincipal: Edmund L. Lydon, Jr.

U 10/28/2014

CNS-AAA

Cristine Z. Fargo

AlternateInternational Safety Equipment Association1901 North Moore Street, Suite 808Arliington, VA 22209Principal: Kevin McKeigue

M 08/03/2016CNS-AAA

Rodney Foster

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

E 03/07/2013

CNS-AAA

Adam J. Goodman

AlternateS-E-A Limited795 Cromwell Park Drive, Suite NGlen Burnie, MD 21061Principal: Bob A. Rusczek


Bayless L Kilgore

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

SE 10/23/2013

CNS-AAA

Robert J. Masonis, Sr.

AlternateNewport Beach Fire Department (retired)1686 Rice Canyon RoadFallbrook, CA 92028-8719Principal: Alfred W. Keiss


Michele Myers Mihelic

AlternateAmerican Wind Energy Association1501 M Street NW, Suite 1000Washington Dc, DC 20005-1769Principal: James L. Tyler

U 10/28/2014

3 of 297



CNS-AAA

Dennis M. O'Connell

AlternateRoco Rescue Inc.26 Cobalt LaneWestbury, NY 11590Principal: Richard Wright


Kenny W. Oldfield

AlternateAlabama Fire College7291 Gadsden HighwayTrussville, AL 35173-1688Principal: William H. Weems

SE 08/11/2014

CNS-AAA

Mark R. Ronecker

AlternateSprinkler 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 Saunders

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

M 03/07/2013

CNS-AAA

Nancy Pearce

Staff LiaisonNational Fire Protection Association1 Batterymarch ParkQuincy, MA 02169-7471

1/11/2012

4 of 297

TECHNICAL COMMITTEE ON

Confined Space Safe Work Practices

AGENDA

Pre-First Draft Minutes

Atlanta, GA

August 9-10, 2016

8 AM-5 PM EDT

Attendees:

Don English Committee Chair AL

Rick Argudin Capital Safety TX

Edward Boring Hilton Head Island Fire Rescue SC

Chris Buehler Exponent, Inc. TX

Aaron Duff Bristol-Myers Squibb Company NJ

Adam Goodman S-E-A Limited MD

James Haiser Dow Corning Corp MI

Adam Jones Buechel Fire Protection District KY

Alfred Keiss * Med-Tex Services, Inc. PA

Steven Kosch 3M Company MN

Richard Kraus API/Petroleum Safety Consultants VA

Edmund Lydon* Northeast Hospital Corporation MA

Glenn McGinley* Ohio Public Employment Risk Reduction OH

Terry McKinch* Mortensen Construction MN

Kenny Oldfield Alabama Fire College AL

Michael Palmer * EnSafe Inc. TN

Mark Ronecker Sprinkler Fitters 268 JATC MO

Bob Rusczek Certified Safety and Health MA

Andrew Saunders Honeywell Inc. FL

James Tyler American Wind Energy Assoc. WA

David Wagner Industrial Scientific Corporation PA

Laura Weems Ctr for Toxicology and Env. Health AR

William Weems Safe State Program AL

Leonard Young Mass Water Resources Authority MA

*Conference call

of 297

NFPA Staff:

Nancy Pearce NFPA Staff Liaison MA

Larry Russell NFPA Staff MA

Rachel Abrams NFPA Meetings Staff MA

Guests

Dan Hudson Dalton Fire Department

1. Don English, Committee Chair welcomed the Committee and explained the

purpose of the meeting was to review the document and determine what

revisions were needed at first draft and to establish task groups.

2. Committee members and attendees introduced themselves and their affiliations.

3. Meeting minutes from the second draft meeting (April 7-9, 2015) were approved.

4. Nancy Pearce provided updates on NFPA 350 revision cycle and reviewed the

revision cycle for NFPA 350. The document is now open for public input until

January 5, 2017 and a First Draft meeting must be held before June 15, 2017.

Nancy also explained that there is now a three part Confined space training

module available on 350 at www.nfpa.org/350 along with a free 5 minute module

on Identification of Confined Spaces. NFPA is rolling out a two day training

program on NFPA 350 as well starting in the Fall. There are two open registration

classes now available in St. Louis and Dallas in October and NFPA is prepared

to bring additional training on site to facilities on request. Information on these

classes is also at www.nfpa.org/350.

5. Task group reports and chapter reviews were provided by task group chairs or

their representatives. The Committee discussed some of the issues raised and

provided feedback to the task group to help them develop public inputs. The task

groups will meet over the next few months to develop public inputs.

6. Other Business/Next Steps-Task groups will have a member submit public inputs

by the January deadline if possible, otherwise they will bring the proposed

revisions to the Committee meeting.

7. The Committee decided on a meeting in New Orleans or Fort Lauderdale in April.

(NFPA’s meeting department has now scheduled the First Draft meeting April

4-6th, 2017 in Fort Lauderdale. Details on booking a room and meeting

information will be sent out this Fall.)

of 297

http://www.nfpa.org/350

http://www.nfpa.org/350

Process Stage

Process Step Dates for TCDates for TC

with CC

Public Input Closing Date 1/5/2017 1/5/2017

Final date for TC First Draft Meeting 6/15/2017 3/16/2017Posting of First Draft and TC Ballot 8/3/2017 4/27/2017Final date for Receipt of TC First Draft ballot 8/24/2017 5/18/2017Final date for Receipt of TC First Draft ballot ‐ recirc 8/31/2017 5/25/2017Posting of First Draft for CC Meeting 6/1/2017Final date for CC First Draft Meeting 7/13/2017Posting of First Draft and CC Ballot 8/3/2017Final date for Receipt of CC First Draft ballot 8/24/2017Final date for Receipt of CC First Draft ballot ‐ recirc 8/31/2017Post First Draft Report for Public Comment 9/7/2017 9/7/2017

Public Comment closing date 11/16/2017 11/16/2017Notice published on Consent Standards (Standards that receive No Comments).

Note: Date varies and determined via TC ballot.Appeal Closing Date for Consent Standards (Standards That Received No

Comments)Final date for TC Second Draft Meeting 5/17/2018 2/8/2018Posting of Second Draft and TC Ballot 6/28/2018 3/22/2018Final date for Receipt of TC Second Draft Ballot 7/19/2018 4/12/2018Final date for receipt of TC Second Draft ballot ‐ recirc 7/26/2018 4/19/2018Posting of Second Draft for CC Mtg 4/26/2018Final date for CC Second Draft Meeting 6/7/2018Posting of Second Draft for CC Ballot 6/28/2018Final date for Receipt of CC Second Draft ballot 7/19/2018Final date for Receipt of CC Second Draft ballot ‐ recirc 7/26/2018Post Second Draft Report for NITMAM Review 8/2/2018 8/2/2018

Notice of Intent to Make a Motion (NITMAM) Closing Date 8/30/2018 8/30/2018Posting of Certified Amending Motions (CAMs) and Consent Standards 10/11/2018 10/11/2018Appeal Closing Date for Consent Standards 10/26/2018 10/26/2018SC Issuance Date for Consent Standards 11/5/2018 11/5/2018

Tech Session Association Meeting for Standards with CAMs June 2019 June 2019

Appeal Closing Date for Standards with CAMs *TBD *TBDCouncil Issuance Date for Standards with CAMs* *TBD *TBD

*When receipt of the confirmed Annual Meeting dates become available.

Approved: 8/4/2016

Comment

Stage (Second

Draft)

Tech Session

Preparation

(& Issuance)

Appeals and

Issuance

2018 FALL REVISION CYCLE

Public Input

Stage

(First Draft)

* Public Input Closing 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 Next Edition tab.

of 297

Public Input No. 2-NFPA 350-2016 [ Chapter 2 ]

Chapter 2 Referenced Publications

2.1 General.

The documents or portions thereof listed in this chapter are referenced within this guide and should beconsidered part of the recommendations of this document.

2.2 NFPA Publications.

National Fire Protection Association, 1 Batterymarch Park, Quincy, MA 02169-7471.

NFPA 10, Standard for Portable Fire Extinguishers, 2013 edition.

NFPA 51B, Standard for Fire Prevention During Welding and Other Hot Work, 2014 edition.

NFPA 70®, National Electrical Code®, 2014 edition.

NFPA 70E®, Standard for Electrical Safety in the Workplace®, 2015 edition.

NFPA 77, Recommended Practice on Static Electricity, 2014 edition.

NFPA 302, Fire Protection Standard for Pleasure and Commercial Motor Craft, 2015 edition.

NFPA 306, Standard for the Control of Gas Hazards on Vessels, 2014 edition.

NFPA 326, Standard for the Safeguarding of Tanks and Containers for Entry, Cleaning, or Repair, 2015edition.

NFPA 704, Standard System for the Identification of the Hazards of Materials for Emergency Response,2012 edition.

NFPA 1500, Standard on Fire Department Occupational Safety and Health Program, 2013 edition.

NFPA 1521, Standard for Fire Department Safety Officer Professional Qualifications, 2015 edition.

NFPA 1561, Standard on Emergency Services Incident Management System and Command Safety, 2014edition.

NFPA 1670, Standard on Operations and Training for Technical Search and Rescue Incidents, 2014edition.

NFPA 1855, Standard for Selection, Care, and Maintenance of Protective Ensembles for Technical RescueIncidents, 2013 edition.

NFPA 1951, Standard on Protective Ensembles for Technical Rescue Incidents, 2013 edition.

NFPA 1981, Standard on Open-Circuit Self-Contained Breathing Apparatus (SCBA) for EmergencyServices, 2013 edition.

NFPA 1983, Standard on Life Safety Rope and Equipment for Emergency Services, 2012 edition.

NFPA 1991, Standard on Vapor-Protective Ensembles for Hazardous Materials Emergencies, 2016edition.

NFPA 1992, Standard on Liquid Splash — Protective Ensembles and Clothing for Hazardous MaterialsEmergencies, 2012 edition.

2.3 Other Publications.

2.3.1 AIHA Publications.

American Industrial Hygiene Association, 3141 Fairview Park Drive, Suite 777, Falls Church, VA 22042.

“Prevention through Design: Eliminating Confined Spaces and Minimizing Hazards.” AIHA Confined SpacesCommittee. https://www.aiha.org/government-affairs/PositionStatements/PtD%20Conf%20Space%20AIHA%20-%20BOD%20Approved.pdf.

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

1 of 282 2/22/2017 2:45 PM

of 297

2.3.2 ANSI Publications.

American National Standards Institute, Inc., 25 West 43rd Street, 4th Floor, New York, NY 10036.

ANSI/AIHA/ASSE Z10, Occupational Health and Safety Management Systems, 2012.

ANSI Z49.1, Safety in Welding, Cutting, and Allied Processes, 2012.

ANSI/ASSE Z117.1, Safety Requirements for Confined Spaces, 2009.

ANSI/ASSE Z590.3, Prevention Through Design: Guidelines for Addressing Occupation Hazards & Risks inthe Design & Redesign Processes, 2011, reaffirmed 2016 .

ANSI/ASSE Z244.1-2003 (R2014) Control of Hazardous Energy - Lockout/Tagout & Alternative Methods

2.3.3 API Publications.

American Petroleum Institute, 1220 L Street, NW, Washington, DC 20005-4070.

API STD 653, Tank Inspection, Repair, Alteration, and Reconstruction, 2009 2014 .

API RP 2009, Safe Welding and Cutting Practices in Refineries, Gasoline Plants, and PetrochemicalPlants, 2002, reaffirmed 2007 .

API STD 2015, Requirement for Safe Entry and Cleaning of Petroleum Tanks, 2001 2014 .

API RP 2016, Guidelines and Procedures for Entering and Cleaning Petroleum Storage Tanks, 2001,reaffirmed 2006 .

API RP 2027, Ignition Hazards and Safe Working Practice for Abrasive Blasting of Atmospheric StorageTanks in Hydrocarbon Service, 2002, reaffirmed 2012 .

API RP 2201, Safe Hot Tapping Practices in the Petroleum & Petrochemical Industries, 2003, reaffirmed2012 .

API 2202, Guidelines for Protecting Against Lead Hazard when Dismantling and Disposing of Steel fromTanks that Have Contained Leaded Gasoline, 1991. (Withdrawn)

API API RP 2207, Preparing Tank Bottoms for Hot Work, 2007, reaffirmed 2012 .

API STD 2217A, Guidelines for Safe Work in Inert Confined Spaces in the Petroleum and PetrochemicalIndustries, 2009.

2.3.4 ASSE Publications.

American Society of Safety Engineers, 1800 E Oakton Street, Des Plaines, IL 60018 520 N. NorthwestHwy , Park Ridge , IL 60068 .

ASSE Z590.3 Tech Brief, September 2011.

2.3.5 CDC Publications.

Center for Disease Control and Prevention, 1600 Clifton Road, Atlanta, GA 30333.

National Institute for Occupational Safety and Health (NIOSH). Prevention through Design: Plan for theNational Initiative, November 2010.

2.3.6 CGA Publications.

Compressed Gas Association, 4221 Walney Road, 5th Floor 14501 George Carter Way , Suite 103 ,Chantilly, VA 20151-2923 1788 .

CGA 7.1, Commodity Specification for Air, October 2011.

2.3.7 ICS Publications.

International Chamber of Shipping, 38 St. Mary Axe, London, UK, EC3A 8BH.

International Safety Guide for Oil Tankers and Terminals (ISGOTT), fifth edition, 2006.


2 of 282 2/22/2017 2:45 PM

of 297

2.3.8 U.S. Government Publications.

U.S. Government Publishing Office, 732 North Capitol Street, NW, Washington, DC 20402 20401-0001 .

Title 29, Code of Federal Regulations, Part 1910, “Occupational Safety and Health Standards.”

Title 29, Code of Federal Regulations, Part 1915, “Occupational Safety and Health Standards for ShipyardEmployment.”

Title 29, Part 1926, “Safety and Health Regulations for Construction.”

U.S. Department of Transportation (DOT). Pipeline and Hazardous Materials Safety Administration,Emergency Response Guidebook http://phmsa.dot.gov/staticfiles/PHMSA/DownloadableFiles/Files/Hazmat/ERG2012.pdf

2.3.9 Other Publications.

Merriam-Webster’s Collegiate Dictionary, 11th edition, Merriam-Webster, Inc., Springfield, MA, 2003.

2.4 References for Extracts in Advisory Sections.

NFPA 51B, Standard for Fire Prevention During Welding, Cutting, and Other Hot Work, 2014 edition.

NFPA 70®, National Electrical Code®, 2014 edition.

NFPA 77, Recommended Practice on Static Electricity, 2014 edition.

NFPA 99, Health Care Facilities Code, 2015 edition.

NFPA 302, Fire Protection Standard for Pleasure and Commercial Motor Craft, 2015 edition.


NFPA 1006, Standard for Technical Rescuer Professional Qualifications, 2013 edition.

NFPA 1026, Standard for Incident Management Personnel Professional Qualifications, 2014 edition.

NFPA 1451, Standard for a Fire and Emergency Service Vehicle Operations Training Program, 2013edition.

NFPA 1521, Standard for Fire Department Safety Officer Professional Qualifications, 2015 edition.

NFPA 1561, Standard on Emergency Services Incident Management System and Command Safety, 2014edition.

NFPA 1670, Standard on Operations and Training for Technical Search and Rescue Incidents, 2014edition.

Statement of Problem and Substantiation for Public Input

Referenced current SDO names, addresses, standard names, numbers, and editions.

Related Public Inputs for This Document

Related Input Relationship

Public Input No. 3-NFPA 350-2016 [Chapter E]

Submitter Information Verification

Submitter Full Name: Aaron Adamczyk

Organization: [ Not Specified ]

Street Address:

City:

State:

Zip:

Submittal Date: Tue May 31 21:43:56 EDT 2016


3 of 282 2/22/2017 2:45 PM

of 297

Public Input No. 157-NFPA 350-2017 [ New Section after 3.3.18 ]

Insert 3.3.18 Controlled Atmosphere Space. A space which, by virtue of its operations, requiresdeliberate and accurate atmospheric modification (whether through pressurizing hardware, filters, ormembranes) and constant monitoring. These spaces include aircraft cabins, clean rooms and spacesprotected by non-inerting modified air fire prevention systems.


Rationale: Given the various methods of deliberate atmospheric control that modify the properties of air without the introduction of hazardous agents or inert gasses, it would be beneficial to reduce ambiguity and create a clear definition of such spaces to assist in assessing and eliminating relevant potential hazards. Without the addition of this proposed definition, controlled atmosphere spaces (e.g. pressurized aircraft cabin, clean room, modified air fire prevention system) cannot be clearly distinguished from spaces that have inherent or introduced atmospheric risks that do not benefit from the deliberate and accurate modification and monitoring of the atmosphere.



Public Input No. 159-NFPA 350-2017 [Section No. 4.3]


Submitter Full Name: JB Frost

Organization: OPSYS LLC

Affilliation: OPSYS LLC

Street Address:

City:

State:

Zip:

Submittal Date: Wed Jan 04 11:25:35 EST 2017


4 of 282 2/22/2017 2:45 PM

of 297

Public Input No. 155-NFPA 350-2017 [ Section No. 4.3 ]

4.3 Determination of Confined Spaces.

Spaces that should be evaluated to determine if they could be confined spaces include those that have allthree of the following characteristics:

(1) Are large enough and so configured that a person can bodily enter and perform assigned work.

(2) Have limited or restricted means for entry and exit. Any space that requires a ladder to access orrequires a worker to crawl or contort his or her body to enter or exit could be considered a confinedspace. Nonstandard staircases such as spiral stairs or ships’ ladders could also be considered to havelimited access or restricted means of egress. Often, these spaces are located below grade or requiredescent into a space. There are also confined spaces, such as water tanks, HVAC systems, and windturbines, that are typically located aboveground. Other spaces, by virtue of the distance a worker wouldhave to travel to exit the space in an emergency, may be considered to have limited means of exit.

(3) Are not designed for continuous human occupancy. These are spaces where employees would notnormally be assigned for work. They are spaces where a desk, computer, or phone would not beplaced but that might need to be entered for nonroutine inspection, maintenance, or repair work. Utilityvaults, crawl spaces, tanks, and below-grade structures are examples of spaces that typically are notdesigned for continuous human occupancy..


Grammar - extra comma at end of sentence


Submitter Full Name: Laura Weems

Organization: Army Corps Of Engineers, Littl

Street Address:

City:

State:

Zip:



5 of 282 2/22/2017 2:45 PM

of 297






(3) Are not designed for continuous human occupancy or a controlled atmosphere space . These arespaces where employees would not normally be assigned for work. They are spaces where a desk,computer, or phone would not be placed but that might need to be entered for nonroutine inspection,maintenance, or repair work. Utility vaults, crawl spaces, tanks, and below-grade structures areexamples of spaces that typically are not designed for continuous human occupancy..


Rationale: Given the increasing prevalence of controlled atmosphere spaces, it would be beneficial to distinguish their inherently unique characteristics when considering the context of the determination of confined spaces.



Public Input No. 157-NFPA 350-2017 [New Section after 3.3.18] Addressing common issue


Submitter Full Name: JB Frost

Organization: OPSYS LLC

Affilliation: OPSYS LLC

Street Address:

City:

State:

Zip:



6 of 282 2/22/2017 2:45 PM

of 297








Grammar - extra period at end of sentence




Street Address:

City:

State:

Zip:



7 of 282 2/22/2017 2:45 PM

of 297







Are not designed for controlled atmosphere that provides life safety in compliance with astandard or risk assessment accepted by the AHJ.


Current text unintentionally seems to put some occupiable spaces with controlled air environment within scope. Such as aircraft training cabins on ground, aircraft cabins in air, clean air rooms, occupiable rooms with fire preventative indoor climate etc. These operate with clean air to high standards and may limit ventilation exchange rates by outdoor air. Some of these spaces, most typical aircraft cabins, apply reduced partial volume of oxygen within safe limits as well. Also, gas extinguishing systems allow for short periods of occupation down to 8 or 12 % oxygen without medical screening of occupants.

These occupancies with controlled air quality all comply with acknowledged standards linked to FAA, UL, NFPA, ISO etc. Some may be subject to life safety assessment case by case to comply. They are obviously not confined spaces by definition of NFPA 350 3.3.13; Still, the limits to outdoor air ventilation exchange rate and oxygen content etc found in NFPA 350 cause confusion. To avoid conflicts and recurring discussions, NFPA 350 should be clear that these are not confined spaces per se if air qualities and exchange rates deviates from limits of NFPA 350, provided the spaces are designed to relevant standard that ensure life safety.

The proposed change attempts to address this.


Submitter Full Name: Geir Jensen

Organization: COWI AS

Street Address:

City:

State:

Zip:



8 of 282 2/22/2017 2:45 PM

of 297


4.4 Signs.

Confined spaces should have posted signs, tags, or labels denoting them as confined spaces andprohibiting unauthorized entry. In facilities with similar , recognizable or multiple , confined spaces , (suchas storage tank facilities or workplaces with multiple manholes), the Owner/Operator may choose to identifysuch spaces with facility signage and/or identify the spaces in their written confined space programs in lieuof individual signs or labels. Signs, tags, or labels should have wording similar to the following:

DANGER — CONFINED SPACE

DO NOT ENTER WITHOUT AUTHORIZATION


grammar of commas being in the wrong place in sentence




Street Address:

City:

State:

Zip:



9 of 282 2/22/2017 2:45 PM

of 297

Public Input No. 163-NFPA 350-2017 [ Section No. 4.6.1 ]

4.6.1

Owner/Operators should inform all individuals working in or around confined spaces of the potentiallyhazardous nature of confined spaces on their property, regardless of whether or not they are employees.All employees should receive awareness level training on confined spaces, specific to their worksite, uponhiring.


Committee recommended that we add this information for all employees. Additional information is in chapter 11.




Street Address:

City:

State:

Zip:



10 of 282 2/22/2017 2:45 PM

of 297


5.1.1

All confined spaces have the potential to be an OSHA-defined permit-required confined space , dependingon the work to be performed and the inherent, potential, or introduced hazards in the space at the time ofentry. While the procedures required to safely enter a confined space vary widely, the same basicevaluation of the hazards within those spaces should be performed prior to and during entry. All confinedspaces should be evaluated in accordance with the guidelines in Chapters 6 and 7, and all hazards foundshould be eliminated, controlled, or mitigated in accordance with the guidelines in Chapters 8 and 9.


Grammar. Extra comma in sentence.




Street Address:

City:

State:

Zip:



11 of 282 2/22/2017 2:45 PM

of 297


5.1.1

All confined spaces have the potential to be an OSHA-defined permit-required confined space, dependingon the work to be performed and the inherent, potential, or introduced hazards introduced, oradjacent hazards in the space at the time of entry. While the procedures required to safely enter a confinedspace vary widely, the same basic evaluation of the hazards within those spaces should be performed priorto and during entry. All confined spaces should be evaluated in accordance with the guidelines in Chapters6 and 7, and all hazards found should be eliminated, controlled, or mitigated in accordance with theguidelines in Chapters 8 and 9.


Committee edit: we use the term "potential" in the list of hazards but only define the other three (inherent, introduced and adjacent).




Street Address:

City:

State:

Zip:



12 of 282 2/22/2017 2:45 PM

of 297


5.1.2

Table 5.1.2 shows the terminology used in commonly referenced confined space entry documents such as29 CFR 1910.146, 29 CFR 1926.1200, ANSI/ASSE Z117.1, API 2015, and API 2016, and how the termsrelate to those given in this guide. Other jurisdictions and countries may have different definitions andrequirements in addition to those provided in the table.

Table 5.1.2 Terminology for Confined Space Entry in Various Standards and Documents

Standardor

Document Term Used

Term Usedin

NFPA 350 Comments

29 CFR1910.146

29 CFR1926.1200

Confined spaceConfinedspace

NFPA 350 uses the same definition asOSHA for a confined space.

29 CFR1910.146

29 CFR1926.1200

Permit required confined spaceConfinedspace

NFPA 350 does not distinguishbetween permit required confinedspaces and confined spaces. Allconfined spaces with hazards needpermits for entry.

ANSI/ASSEZ117.1

Non-permit-confined spaceConfinedspace

All confined spaces need pre-entryevaluation prior to entry. If no hazardsare identified and no hazards will beintroduced, then no permit will berequired.

29 CFR1910.146

29 CFR1926.1200

Reclassification (downgraded) entryConfinedspace entry

Not defined in NFPA 350. A confinedspace with hazards that have beeneliminated after the pre-entryevaluation will not require a permit.

29 CFR1910.146

29 CFR1926.1200

Alternate procedures entryConfinedspace entry

Not defined in NFPA 350. A confinedspace where all hazards have beenevaluated and the only hazard is apotentially hazardous atmosphere thatis being controlled with effectiveventilation would be issued a permitfor entry that contains restrictionsrequiring ventilation and continuousmonitoring.

API 2015and 2016

Nonconfined space (a confined spacethat is no longer a confined space dueto reconfiguration)

None

If a space does not meet all thespecifications for a confined space,then it is not a confined space andNFPA 350 does not apply.

NFPA 326

Nonconfined space (for purposes oftank entry, cleaning, or repair a spacethat previously was a confined spacebut no longer meets any of therequirements for a confined space ora permit required confined space,such as a tank with a large door sheetcut into the side)

None

If a space does not meet all thespecifications for a confined space,then it is not a confined space andNFPA 350 does not apply.


13 of 282 2/22/2017 2:45 PM

of 297


Committee edit: we need to update the table to add in the new construction std info. We can add in a new block (row) with 29 CFR 1926 AA or we can add the cite to the row where it aligns with Gen Ind. Since the definitions in Construction align with Gen Ind. recommend we cite of 1926 AA to existing rows for terms of confined space, permit required conf space, reclassification and alternate procedures.




Street Address:

City:

State:

Zip:



14 of 282 2/22/2017 2:45 PM

of 297


5.1.2

Table 5.1.2 shows the terminology used in commonly referenced confined space entry documents such as29 CFR 1910.146, ANSI/ASSE Z117.1, API 2015, and API 2016, and how the terms relate to those given inthis guide. Other jurisdictions and countries may have different definitions and requirements in addition tothose provided in the table.

Table 5.1.2 Terminology for Confined Space Entry in Various Standards and Documents

Standard orDocument Term Used

Term Used inNFPA 350 Comments

29 CFR1910.146

Confined spaceConfinedspace

NFPA 350 uses the same definition as OSHA for aconfined space.

29 CFR1910.146

Permit requiredconfined space

Confinedspace

NFPA 350 does not distinguish between permitrequired confined spaces and confined spaces. Allconfined spaces with hazards need permits forentry.

ANSI/ASSEZ117.1

Non-permit-confinedspace

Confinedspace

All confined spaces need pre-entry evaluation priorto entry. If no hazards are identified and nohazards will be introduced, then no permit will berequired.

29 CFR1910.146

Reclassification(downgraded) entry

Confinedspace entry

Not defined in NFPA 350.

A confined space with hazards that have been eliminated after the pre-entry evaluation will not require apermit.

29 CFR 1910.146 Alternate procedures entry Confined space entry Not defined in NFPA 350.

A confined space where all hazards have been evaluated and the only hazard is a potentially hazardousatmosphere that is being controlled with effective ventilation would be issued a permit for entry thatcontains restrictions requiring ventilation and continuous monitoring.

API 2015and 2016

Nonconfined space (a confined space that is no longera confined space due to reconfiguration)

None

If a space does not meet allthe specifications for aconfined space, then it is not aconfined space and NFPA 350does not apply.

NFPA 326

Nonconfined space (for purposes of tank entry,cleaning, or repair a space that previously was aconfined space but no longer meets any of therequirements for a confined space or a permit requiredconfined space, such as a tank with a large door sheetcut into the side)

None

If a space does not meet allthe specifications for aconfined space, then it is not aconfined space and NFPA 350does not apply.


Committee edit: committee does not think using reclassification or alternate procedures to be a best practice. Recommend adding information to the appendix to address these two items.



15 of 282 2/22/2017 2:45 PM

of 297



Street Address:

City:

State:

Zip:



16 of 282 2/22/2017 2:45 PM

of 297


5.4 Entry Conditions.

Entry into confined spaces by assigned qualified Entrants should be permitted only after the EntrySupervisor has indicated that acceptable entry conditions (see , Section Sections 5.5 and 5.6 ) havebeen met, and after a pre-entry evaluation has been performed and permit issued, if applicable.


Grammar edit - remove spaces and comma; add "s" to sections




Street Address:

City:

State:

Zip:



17 of 282 2/22/2017 2:45 PM

of 297


5.5 Basic Requirements and Considerations.

Prior to entering a confined space, the following should be identified and evaluated:

(1) All inherent, potential introduced , introduced, and adjacent hazards of the confined space should beanticipated, identified, and evaluated in accordance with a written confined space entry program andguidance provided in Chapters 6 and 7.

(2) All hazards should be eliminated, controlled, or mitigated in accordance with Chapters 8 and 9.

(3) An authorized Entry Supervisor qualified in accordance with Chapter 11 should be assigned tooversee the work.

(4) Only authorized Entrants qualified in accordance with Chapter 11 should be assigned to enter thespace.

(5) An Attendant qualified in accordance with Chapter 11 should be assigned for permit entries.

(6) If atmospheric monitoring is required, a gas tester qualified in accordance with Chapter 11 should beassigned.

(7) If ventilation is required, a Ventilation Specialist qualified in accordance with Chapter 11 should beassigned.

(8) If energy sources are required to be isolated or controlled, an Isolation Specialist qualified inaccordance with Chapter 11 should be assigned.

(9) If required, qualified Rescuers and/or services as well as appropriate rescue equipment should beavailable in accordance with Chapter 10.

(10) Any other required permits, including, but not limited to, hot work are issued.

(11) A pre-entry evaluation and/or confined space entry permit should be issued and signed by the EntrySupervisor in accordance with Chapter 13.

(12) A pre-entry meeting should be held with all personnel entering or working in or adjacent to the spaceto discuss the work to be performed, job requirements and assignments, actual and potential hazards,and methods of eliminating or controlling the hazards as listed in the conditions on the permit, andconditions that require immediate evacuation in accordance with Chapter 11 .

(13) Communication between the Entrant and the Attendant and the Attendant and Rescuer, if required,should be established in accordance with Chapter 8.

(14) Permit entry should not occur until all conditions for entry established on the permit have been met. Ifconditions change the permit should be cancelled, operations ceased, and the Entrant shouldimmediately vacate the space.


5.5(1) Potential hazards is not defined but the other three are - also aligns with 5.1.1 (revised). 5.5(12) committee edit: add "conditions....evacuation ... chapter 11"




Street Address:

City:

State:


18 of 282 2/22/2017 2:45 PM

of 297

Zip:



19 of 282 2/22/2017 2:45 PM

of 297


5.6 Roles and Responsibilities.

Every workplace that has one or more confined spaces that can be entered, as identified in Chapter 4,should have personnel assigned to perform the responsibilities of the following roles as applicableItapplicable. It is acceptable for one person to hold more than one of the following positions as long as theyare trained, qualified, and authorized to fulfill that role and it will not adversely affect the safety of the entry:

(1) Owner/Operator and/or Entrant Employer

(2) Entrant

(3) Attendant

(4) Entry Supervisor

(5) Gas Tester

(6) Ventilation Specialist

(7) Rescuer (could be Attendant for non-entry rescue)

(8) Rescue team or rescue service

(9) Standby Worker

(10) Isolation Specialist


Grammar - did not have period and connected two words




Street Address:

City:

State:

Zip:



20 of 282 2/22/2017 2:45 PM

of 297


5.6 Roles and Responsibilities.

Every workplace that has one or more confined spaces that can be entered, as identified in Chapter 4,should have personnel assigned to perform the responsibilities of the following roles as applicableItapplicable. It is acceptable for one person to hold more than one of the following positions as long as theyare trained, qualified, and authorized to fulfill that role and it will not adversely affect the safety of the entry:

(1) Owner/Operator and/or Entrant Employer

(2) Entrant

(3) Attendant

(4) Entry Supervisor

(5) Gas Tester

(6) Ventilation Specialist

(7) Rescuer (could be Attendant for non-entry rescue)

(8) Rescue team or rescue service

(9) Standby Worker

(10) Isolation Specialist


Typographical error.


Submitter Full Name: James Tyler

Organization: Vestas

Affilliation: American Wind Energy Association (AWEA)

Street Address:

City:

State:

Zip:

Submittal Date: Fri Oct 21 11:10:09 EDT 2016


21 of 282 2/22/2017 2:45 PM

of 297


5.7.2

Owners/Operators and Entrant Employers should ensure that all employees engaged in confined spaceoperations have been educated, trained, and/or qualified as follows:

(1) Before beginning initial work and/or duty assignments

(2) Before assignment to a different type of work or duty other than initially assigned

(3) Whenever a change occurs in operations, equipment, equipment configuration, materials, procedures,guidelines, work assignment, or duties that creates or has the potential to create a hazard for which theemployee has not been previously trained, educated, or qualified

(4) Whenever an Owner/Operator and Entrant Employer has reason to believe an employee requiresretraining or additional education due to inadequacies in the employee’s performance or skill orbecause the employee deviates from the confined space program permit requirements or procedures


Add "equipment configuration" for reasons and employer may need to retrain employees





Street Address:

City:

State:

Zip:



22 of 282 2/22/2017 2:45 PM

of 297

Public Input No. 28-NFPA 350-2016 [ Section No. 6.2.2.2 ]

6.2.2.2 Administrative and Work Practice Controls.

Some common administrative and work practice controls include, but are not limited to, the following:

(1) Assigning qualified personnel for all identified tasks

(2) Developing confined space, respiratory protection, isolation, hot/cold work, and other applicableprograms

(3) Following regulations and industry standards

(4) Performing a job hazard analysis prior to starting work and reassessing as needed

(5) Limiting exposures and exposure times to hazardous and toxicchemicals toxic chemicals

(6) Providing decontamination stations and eye wash stations and showers

(7) Providing hazardous material and waste collection, disposal, and/or containment equipment

(8) Identifying and providing rescue personnel and/or services

(9) Developing entryand entry and hot work permits with restrictions and limitations identified

(10) Following regulatory permit requirements

(11) Providing outside services needed, such as cranes

(12) Providing and using appropriate ladder, tripods, and rescue equipment, including harnesses andlifelines

(13) Designating areas for specific equipment, work, breaks, and nonrelated activities

(14) Providing adequate and appropriate lighting equipment

(15) Using temporary barricades and road blocks

(16) Using any special equipment such as GFCI, emergency generators, non-sparking tools, and testequipment

(17) Utilizing lockout/tagout equipment such as tags, locks, and lock boxes


Typographical errors





Street Address:

City:

State:

Zip:



23 of 282 2/22/2017 2:45 PM

of 297


6.2.2.2 Administrative and Work Practice Controls.

Some common administrative and work practice controls include, but are not limited to, the following:

(1) Assigning qualified personnel for all identified tasks

(2) Developing confined space, respiratory protection, isolation, hot/cold work, and other applicableprograms

(3) Following regulations and industry standards

(4) Performing a job hazard analysis prior to starting work and reassessing as needed

(5) Limiting exposures and exposure times to hazardous and toxicchemicals

(6) Providing decontamination stations and eye wash stations and showers

(7) Providing hazardous material and waste collection, disposal, and/or containment equipment

(8) Identifying and providing rescue personnel and/or services

(9) Developing entryand entry and hot work permits with restrictions and limitations identified

(10) Following regulatory permit requirements

(11) Providing outside services needed, such as cranes

(12) Providing and using appropriate ladder, tripods, and rescue equipment, including harnesses andlifelines

(13) Designating areas for specific equipment, work, breaks, and nonrelated activities

(14) Providing adequate and appropriate lighting equipment

(15) Using temporary barricades and road blocks

(16) Using any special equipment such as GFCI, emergency generators, non-sparking tools, and testequipment

(17) Utilizing lockout/tagout equipment such as tags, locks, and lock boxes


editorial


Submitter Full Name: Richard Kraus

Organization: API/Petroleum Safety Consultan

Street Address:

City:

State:

Zip:

Submittal Date: Mon Dec 26 08:18:20 EST 2016


24 of 282 2/22/2017 2:45 PM

of 297


6.2.2.3 Personal Protective Equipment.

Some common personal protective equipment includes, but is not limited to, the following:

(1) Hazard-specific area and personal atmospheric testing and monitoring equipment

(2) Personal and respiratory protection equipment such as thermal stress or impervious clothing, safetyglasses, protective gloves, safety hard hat, air purifying or ai supplied respirator, and safety boots asdetermined by a Job Hazard Analysis

(3) Breathing-air supply and equipment such as self-contained breathing apparatuses (SCBA)


adds additional commonly required PPE




Street Address:

City:

State:

Zip:



25 of 282 2/22/2017 2:45 PM

of 297

Public Input No. 36-NFPA 350-2016 [ Section No. 6.3.4.1.2 ]

6.3.4.1.2

Inherent hazards to be identified include, but are not limited to, the following:

(1) Limited access into the space. Spaces for which ladders or scaffolding are needed to reach the portal,to enter and exit the space, or to perform work therein are considered to have limited access. Elevatedspaces require different considerations for entry and rescue than those that are at ground level,including fall protection.

(2) Size and shape of the portal. The restrictive nature of some portals makes access with certain types ofPPE difficult or impossible or requires Entrants to contort their bodies while entering or exiting. Anelevated, open, unprotected edge or portal may create a fall hazard.

(3) Size and shape of the space/vessel. Inwardly converging walls or a funnel-shaped discharge canentrap an Entrant; congested or dark spaces can inhibit mobility or create slip, trip, and fall hazards.

(4) Products or processes in the space. Chemicals, thermal stress, noise, steam, pressurization,mechanical equipment, operations, and other activities associated with the use of the space can createhazards. Disturbing product residue during entry or work can release a contaminant that produces ahazard not detected during pre-entry testing.

(5) Fixed equipment within the space. Piping systems, conduits, ducts, machinery, pressurized lines, andfire suppression systems should be evaluated for potential hazards and locked out/tagged out, tested,gas-freed, liquid freed, steam freed or vapor freed and/or inerted if needed to reduce the risk.

(6) Structures. Structural integrity should be evaluated prior to use. Items that are susceptible todegradation and physical damage include, but are not limited to, fixed ladders, floors, pipes, anchorpoints, and supports.


adds additional necessary items to be checked




Street Address:

City:

State:

Zip:



26 of 282 2/22/2017 2:45 PM

of 297


6.3.4.2.2

Examples of introduced hazards include the following:

(1) Atmospheric hazards. Ventilating a space may introduce contaminants from the following:

(2) Sources outside the space via an ill-placed supply-air duct

(3) Contaminated air drawn from internal combustion engine exhaust

(4) Oxygen-deficient air drawn from another space or source or from an inert atmosphere

(5) Product off-gassing captured by forced ventilation and contaminated adjacent areas

(6) Chemical hazards. Products used in cleaning, abating, painting, or coating need to be checked forreactivity with other chemicals that might be present. Chemicals may produce hazardous vapors orgases and/or displace or consume oxygen due to the nature of the confined space.

(7) Application and drying of flammable paints can cause an explosive atmosphere.

(8) Compressed gas hazards. Compressed gas used for welding, cutting, inerting, hot work, or firesuppression systems pose a hazard due to their contents (e.g., toxic or flammable gases), their abilityto displace or enrich the atmospheric oxygen content (e.g., carbon dioxide fire extinguishing systems),and their potential to become a projectile if damaged. Compressed gas hoses, valves, and regulatorsshould be thoroughly inspected, evaluated, and leak checked prior to being brought into a confinedspace. Due to the inherent risks, compressed gas cylinders, except breathing air cylinders, should notnormally be introduced into confined spaces.

(9) Hot work. Hot work such as welding, cutting, grinding, drilling, and burning, can and/orintentional heating of materials which can produce hazardous atmospheres and flammable conditions.Hazards can includewelding include welding fumes, release of gases, depletion or enrichment of thespace’s oxygen content, or the production ignition sources.

(10) Electrical hazards. Electrical equipment that is not low voltage or intrinsically safe, lighting, powertools, and extension cords, can produce electrical shock, trip hazards, and ignition sources. Additionalconsideration should be given to unexpected sources of electrical energy/ignition sources such asstatic electric discharge that may be generated by the use of airlines/pressure lines or even exhaustfans GFCI should be considered when using AC power.

(11) Slip, trip, and fall hazards. Ladders or scaffolding used to reach portals, gain entry, or access insidethe space can produce slip, trip, fall, and entanglement hazards. Equipment, cables, hoses, tools,ventilation ducts, and other items brought into the space may create slip, trip, and entanglementhazards.


Typographical errors. Hot work needs to include the intentional use of heat producing tools to cause a component to expand in order to remove and replace it. (Bearing heaters, for example). Once the heat is removed the component gradually cools and 'shrinks'. Wind energy uses bearing heaters to connect main shaft to a gearbox through what is known as a shrink disk.





Street Address:


27 of 282 2/22/2017 2:45 PM

of 297

City:

State:

Zip:



28 of 282 2/22/2017 2:45 PM

of 297


6.3.4.2.2

Examples of introduced hazards include the following:







(7) Application and drying of flammable paints and chemical cleaners or coatings can cause an explosiveatmosphere.

(8) Compressed gas hazards. Compressed gas used for welding, cutting, inerting, hot work, or firesuppression systems pose a hazard due to their contents (e.g., toxic or flammable gases), their abilityto displace or enrich the atmospheric oxygen content (e.g., carbon dioxide fire extinguishing systems),and their potential to become a projectile if damaged. Compressed gas cylinders, hoses, valves, andregulators should be thoroughly inspected, evaluated, and leak checked prior to being brought into aconfined space. Due to the inherent risks, compressed gas cylinders, except breathing air cylinders,should not normally be introduced into confined spaces.

(9) Hot work. Hot work such as welding, cutting, grinding, drilling, and burning, can produce hazardousatmospheres and flammable conditions. Hazards can includewelding fumes, release of gases,depletion or enrichment of the space’s oxygen content, or the production of ignition sources.




adds additional items that need to be checked and also an editorial correction




Street Address:

City:

State:

Zip:


29 of 282 2/22/2017 2:45 PM

of 297



30 of 282 2/22/2017 2:45 PM

of 297


6.3.4.2.2

Examples of introduced hazards include the , but are not limited to the following:







(7) Application and drying of flammable paints can cause an explosive atmosphere.

(8) Compressed gas hazards. Compressed gas used for welding, cutting, inerting, hot work, or firesuppression systems pose a hazard due to their contents (e.g., toxic or flammable gases), their abilityto displace or enrich the atmospheric oxygen content (e.g., carbon dioxide fire extinguishing systems),and their potential to become a projectile if damaged. Compressed gas hoses, valves, and regulatorsshould be thoroughly inspected, evaluated, and leak checked prior to being brought into a confinedspace. Due to the inherent risks, compressed gas cylinders, except breathing air cylinders, should notnormally be introduced into confined spaces.

(9) Hot work. Hot work such as welding, cutting, grinding, drilling, and burning, can produce hazardousatmospheres and flammable conditions. Hazards can includewelding fumes, release of gases,depletion or enrichment of the space’s oxygen content, or the production ignition sources.




adds qualifier




Street Address:

City:

State:

Zip:



31 of 282 2/22/2017 2:45 PM

of 297


32 of 282 2/22/2017 2:45 PM

of 297

Public Input No. 56-NFPA 350-2016 [ Section No. 6.3.5 [Excluding any Sub-Sections] ]

A pre-entry evaluation should be conducted for all confined spaces to determine if hazards are present. Itshould be assumed that a confined space is not safe for entry until the hazards (present or potential) areidentified, evaluated, and eliminated or , mitigated or controlled. Hazards include, but are not limited to,mechanical, electrical, physical, chemical, atmospheric, biological, and psychological.


mitigated is used throughout the guide




Street Address:

City:

State:

Zip:



33 of 282 2/22/2017 2:45 PM

of 297

Public Input No. 38-NFPA 350-2016 [ Section No. 6.3.5.2 [Excluding any Sub-Sections] ]

Electrical hazards are created by an electrical current, charge, or field capable of causing injury. Allelectrical sources should be treated as a potential hazard, including low-voltage sources. Low voltage doesnot mean low hazard. If electrical hazards are present, they should be evaluated by a qualified electricianas person as to the potential risk and controls in accordance with NFPA 70E. Voltage alone does notdetermine the severity of electrical shock. The three factors that determine the severity of electrical shockare as follows:

(1) The actual quantity of current (amperes) flowing through the body

(2) The path of current through the body

(3) The time the current flows through the body


does not need to be an electrician to perform this task...only qualified




Street Address:

City:

State:

Zip:



34 of 282 2/22/2017 2:45 PM

of 297


6.3.5.3 Physical Hazards.

These hazards include hazards other than mechanical or chemical that would cause harm to the body,including, but not limited to, noise, engulfment, falls, wet/slick surfaces, slip/trip hazards, lighting, radiation,vibration, and extremes of temperature and pressure. Entrapment hazards are where the shape orconfiguration of the vessel itself can exert enough force on the body to cause death by strangulation,constriction, or crushing and may include narrow cross sections, sloping floors, funneling configurations, orother internal configurations that can entrap. Physical hazards include explosion and fire hazards createdby various chemical agents such as flammable liquids, flammable vapors and gases, paints, solvents, andmethane, as well as combustible settled dust in excess of 1⁄32 in., and airborne concentrations that impairvisibility to less than 5 ft are indicators of potential explosive conditions. Concentrations ofexplosive/flammable vapors that have reached their LEL (lower explosive limit) and have not exceededtheir UEL (upper explosive limit) are capable of explosion. There is no effective PPE for an explosiveenvironment; control or elimination is recommended. Generally, atmospheres that have reached 10 percentof their LEL are considered hazardous and should require additional precautions and actions prior toentering a space. LEL is the lowest concentration of gas or vapor in air in which burning will take place.


adds additional flammable hazards




Street Address:

City:

State:

Zip:



35 of 282 2/22/2017 2:45 PM

of 297



36 of 282 2/22/2017 2:45 PM

of 297

6.4.2

The general steps needed to provide acceptable entry conditions include, but are not limited to, thefollowing:

(1) Investigate thoroughly. Using information in this guide, Entry Supervisors should conduct a thoroughinvestigation of existing or potential hazards that could pose a danger to Entrants and confined spaceworkers. Entry Supervisors should then ensure entry requirements are documented on permits andthat Entrants and workers know what the hazards are, where and when they may be located orexpected, and what control measures are appropriate for each hazard.

(2) Conduct a hazard evaluation to determine the risks. Entry Supervisors should develop hazardscenarios that describe the environment, possible exposures, actions, or events that could precipitate ahazard, and the outcome should the hazard occur. Hazard scenarios should determine what can gowrong, how the event may occur, what the consequences may be, and how likely the event is tohappen. Consideration should also be given to the Entry Supervisors and Entrants themselves,because their level of training, experience, and use of PPE can contribute to or create hazards in andaround confined spaces. For example, wearing chemical protective clothing to prevent skin contact foran extended period of time in a hot environment may create heat stress hazards.

(3)

(4) Prioritize the risks. The Entry Supervisor should prioritize and note which of the hazards pose thehighest risk and focus on controlling or eliminating those first.

(5) Determine control measures. Entry Supervisors should know it is always best to eliminate hazardswherever possible regardless of the probability or severity of the hazard. If that is not feasible, the nextbest strategy is to use engineering controls to reduce exposures. Engineering controls include, but arenot limited to, local exhaust ventilation to remove contaminants, general dilution ventilation to supplyfresh air to the space, and substitution of materials so that hazardous chemicals are not introduced orproduced during work in the space. Other types of control measures include administrative controlsand PPE. Administrative controls include such measures as rotating employees or restricting time tocontrol toxic chemical, noise, or heat exposures; and/or posting warning signs and ensuring thatpersonnel are trained how to identify, evaluate, and control hazards; and developing and implementingappropriate confined space, isolation, hot work, and other safety programs. PPE should be used whenengineering and administrative controls are not sufficient to reduce or eliminate the hazards as PPEdoes not reduce or remove the hazard. (See also Chapter 8.)

(6) Verify control measures. Entry Supervisors should ensure that the control measures chosen do notintroduce additional hazards that have a higher level of risk or change the risk. For example, ifventilation ducts block the exit for Entrants, it may be determined that the risk of not having theventilation outweighs the risk posed by the blocked exit.

(7) Determine if the level of risk is acceptable. Entry Supervisors should determine if the risk has beenreduced to an acceptable level, as determined by the organization or the supervisor, with the controlmeasures chosen. For example, the risk assessment might conclude that a complicated, redundantventilation system is required for entry. A facility in-house confined space entry team might concludethey are uncomfortable and unfamiliar with implementing such a system and determine that they willnot complete the entry; instead, they conclude the risk is too great and decide to not conduct entryoperations, choosing instead to hire a professional contractor.

(8) Implement and train. After the controls are implemented, Entry Supervisors should ensure thatpersonnel involved in the entry operations are informed of the hazards, risk assessmentdeterminations, and specific control measures and if those control measures may pose a hazard.

(9) Institute ongoing assessment. Entry Supervisors should ensure that the identification and evaluation ofhazards is an ongoing process as conditions often change in a confined space due to inherent,introduced, and adjacent hazards. Entry Supervisors should conduct regular visual and atmosphericmonitoring of the space to ensure conditions do not change. Personnel should be aware that changingconditions may indicate the need to evacuate the space and re-evaluate it.

* Assess and evaluate risks. Entry Supervisors should conduct a risk assessment to evaluate thehazards. This assessment should be based on the needs of the situation and the identified hazards.Examples include performing atmospheric monitoring in the space (e.g., for oxygen levels, flammability,and toxic chemicals) and performing a visual inspection to determine if there are physical hazards.There are numerous methods for conducting risk assessments; one such method is outlined inANSI/AIHA Z10-2012, Occupational Health and Safety Management Systems.


37 of 282 2/22/2017 2:45 PM

of 297


hazardous chemicals are restricted...not hazardous are OK




Street Address:

City:

State:

Zip:



38 of 282 2/22/2017 2:45 PM

of 297


Safety data sheets (SDS) should be available and reviewed for recent materials that are presently andpreviously have been stored or used in a confined space being entered, have been used to purge aconfined space being entered, or are being brought into the space being entered.


need to also be concerned about what is presently used and stored




Street Address:

City:

State:

Zip:



39 of 282 2/22/2017 2:45 PM

of 297


6.6.3 Placards and Markings.

Warning placards and markings may provide Entrants with warnings for specific hazards, such aselectrocution, toxins, and chemical hazards. NFPA 704 contains a marking system to warn of significanthazards and should be present utilized at most facilities.


editorial...better language




Street Address:

City:

State:

Zip:



40 of 282 2/22/2017 2:45 PM

of 297


7.1 General.

The purpose of this chapter is to outline the steps necessary for testing and evaluating confined spaceatmospheres for gaseous hazards and hazardo/ur vapors and gases and to help determine the equipmentnecessary for this task. This chapter does not cover evaluating or testing for nongaseous hazards such asdusts, particulates, or other potential atmospheric hazards. If potential for other non-gaseous atmospherichazards does exist, a qualified person should be consulted regarding safe work practices in theseenvironments.


vapors are also hazardous and need testing




Street Address:

City:

State:

Zip:



41 of 282 2/22/2017 2:45 PM

of 297


7.1 General.

The purpose of this chapter is to outline the steps necessary for testing and evaluating confined spaceatmospheres for gaseous hazards and to help determine the equipment necessary for this task. Thischapter does not cover evaluating or testing for nongaseous hazards non hazardous vapors and gasessuch as dusts, particulates, or other potential atmospheric hazards. If potential for other non-gaseousatmospheric hazards does exist, a qualified person should be consulted regarding safe work practices inthese environments.


again, gases are not the only hazards to be tested for. Vapors also need testing




Street Address:

City:

State:

Zip:



42 of 282 2/22/2017 2:45 PM

of 297


7.2 Procedures for Atmospheric Monitoring.

Atmospheric monitoring should be performed using the procedures described in this chapter prior to anyconfined space entry to determine if the atmosphere within the space is safe for entry. Atmosphericmonitoring may not be necessary if the documented initial hazard evaluation, as described in Chapter 6,has determined that there is no potential for atmospheric hazards to exist in the space. Atmosphericmonitoring is performed for two distinct purposes:

(1) Pre-entry testing to determine if it is safe to enter under the specific conditions listed in the entrypermit

(2) Continuous or periodic monitoring of the atmosphere within the space to assure safe work conditionsin accordance with the applicable permit ( see Section entry, safe work and cold work) requirements(see 7. 14 13 )


Section 7. 14 not applicable. This should be 7.13. Global change is needed. Added information more specifically delineates the two reasons for monitoring




Street Address:

City:

State:

Zip:



43 of 282 2/22/2017 2:45 PM

of 297

Public Input No. 46-NFPA 350-2016 [ Section No. 7.3 [Excluding any Sub-Sections] ]

The atmosphere of a confined space should be tested for all potential hazardous atmospheric contaminantsas identified in the initial hazard evaluation (see Chapter 6) before each entry by a Gas Tester. Theappropriate testing equipment should be used to determine that the atmospheric concentrations at the timeof entry are within the range of acceptable entry conditions as described in required by the entry permit(see section 8.4.2 ) . The results of the testing (e.g., actual gas concentrations) should be recorded alongwith the stipulated acceptable entry conditions according to the permit recommendations in Chapter 13. Allgas monitors should be equipped with the proper sensors to detect the potential atmospheric hazards beingtested and certified for use in the environment where they are being used. Refer to the gas monitormanufacturer’s specifications and hazardous location and intrinsic safety certifications according to theelectrical code.


the SPECIFIC entry requirements are addressed in the permit. Section 8.4.2 is the broad scope




Street Address:

City:

State:

Zip:



44 of 282 2/22/2017 2:45 PM

of 297


7.3.3

If atmospheric monitoring is done from outside the confined space, initial testing should be performed withall ventilation controls turned off to ensure testing of a static atmosphere and to determine the backgroundgas concentration levels in the event that ventilation fails fails or atmospheric conditions inside the spacechange during entry. However, after initial testing is completed, the atmosphere should be continuouslymonitored with the ventilation controls turned on if ventilation is necessary as a means to mitigate thehazard.


there are 2 reasons to do this monitoring




Street Address:

City:

State:

Zip:



45 of 282 2/22/2017 2:45 PM

of 297


If the confined space has not been opened or the atmosphere is not immediately accessible for testing, theEntry Supervisor should open the confined space just enough to allow insertion of a probe for testing. Anypotential hazard, including, but not limited to, pressure and electric shock should be eliminated, controlled,or mitigated prior to opening the space. Some manhole covers may have a small opening to allow theinsertion of a sampling hose or insertion may be made through an existing fitting or connection . .


provides additional methods




Street Address:

City:

State:

Zip:



46 of 282 2/22/2017 2:45 PM

of 297


7.3.6.2

The purpose of testing before completely opening the confined space is to prevent the creation of animmediately hazardous atmosphere either inside or outside the confined space, or to prevent dilution of theatmosphere inside the space with outside air and to protect the personnel outside the space.


adds additional reason for small opening when testing




Street Address:

City:

State:

Zip:



47 of 282 2/22/2017 2:45 PM

of 297


7.3.9 *

If entry into the confined space is required to test the entire area, a second the Gas Tester, who can bethe intended space Entrant, equipped equipped with all appropriate PPE (i.e., breathing air, harness,lifeline, etc.), can enter the space to complete the test, which would include irregular areas where pocketsof gas could , liquid or vapor could become trapped. An entry permit and an Attendant are required for thisoperation. Once the space has been completely tested it should be ventilated according to Chapter 9 inorder to ensure that any hazards identified in the testing are properly controlled. The gas tester must be trained and qualified as an entrant in order to conduct internal testing


no need for a second gas tester The gas tester must meet entrant requirements to enter.




Street Address:

City:

State:

Zip:



48 of 282 2/22/2017 2:45 PM

of 297


7.3.11

If the confined space requires a horizontal entrythe entry the atmosphere should be tested using a gasmonitor with a sampling pump and rigid sampling probe according to Section 7.7. The atmosphere shouldbe tested at 4 ft (1.2 m) intervals working inward from the opening of the space.


editorial




Street Address:

City:

State:

Zip:



49 of 282 2/22/2017 2:45 PM

of 297


7.3.13

Whereas the pre-entry test determines the initial air quality before the confined space is entered, it isimportant to continuously or periodically monitor for changes in the atmosphere during work operationsinside the space to ensure that a safe atmosphere is maintained. (See Section 7.14 . 13 )


editorial global change allows for periodic monitoring where acceptable




Street Address:

City:

State:

Zip:



50 of 282 2/22/2017 2:45 PM

of 297


7.3.15.1

If any results from atmospheric monitoring exceed the acceptable limits for entry described inSection required by the entry or hot worl permit (see Section 7.17) , all work within the confined spaceshould cease and the space should be evacuated immediately.


the permit determines the specific requirements,,, 7.17 has broad guidance




Street Address:

City:

State:

Zip:



51 of 282 2/22/2017 2:45 PM

of 297


7.4.7.4

Alternative or additional test methods as determined by the entry supervisor and gas tester , including, butnot limited to, colorimetric tubes and grab bag sampling, should be used in conjunction with a gas monitorto identify other contaminants in the space and verify the actual concentration of the targeted hazards. (SeeSection 7.3 5 .)


provides guidance as to who selects alternate methodseditorial for section




Street Address:

City:

State:

Zip:



52 of 282 2/22/2017 2:45 PM

of 297


7.13.1

The atmosphere in and around a confined space should remain safe (ie: within the limits established by theentry permit) during entry operations. Atmospheric conditions can change quickly or gradually over time;and without continuous atmospheric monitoring, air either continuous or internittent as required by thepermit, air contaminants may increase or the oxygen percentage may decrease or increase, creatingdangerous confined space atmospheric conditions. Entrants, Attendants, and other personnel may beunaware of changing conditions if the air quality was only initially monitored and determined to beacceptable. The atmosphere within and outside the confined space should be monitored continuouslyor periodically to ensure continued safe working conditions.


entry into a space that has been declared gas and vapor free and has no capability of additional contamination may only require intermittent monitoring as determined by the applicable program and permits.




Street Address:

City:

State:

Zip:



53 of 282 2/22/2017 2:45 PM

of 297


The hazard identification and risk assessment process as specified in Chapter 6 requires that hazards beeliminated, mitigated, or controlled to a safe level. This chapter addresses common confined spacehazards. Confined spaces, however, may have unique hazards that are not addressed in this best practiceguide. Nonetheless, the hazards need to be either eliminated,mitigated, or controlled using appropriate andeffective methods.


Editorial


Submitter Full Name: Christopher Buehler

Organization: Exponent, Inc.

Street Address:

City:

State:

Zip:

Submittal Date: Thu Jan 05 10:09:02 EST 2017


54 of 282 2/22/2017 2:45 PM

of 297


The hazard identification and risk assessment process as specified in Chapter 6 requires that hazards beeliminated,mitigated, or controlled to a safe level. This chapter addresses common confined space hazards.Confined spaces, however, may have unique hazards that are not addressed in this best practice guide.Nonetheless, the hazards need to be either eliminated,mitigated, or controlled using appropriate andeffective methods. One method for continuous improvement is nearmiss/good catch reporting, resolutionand documentation.

Additional Proposed Changes

File Name Description Approved

Public_Comment_No._266_HELD.pdf NFPA 350 Public Comment No. 266


NOTE: This Public Input appeared as "Rejected but held" in Public comment No. 266 in F2015 Second Draft Report for NFPA 350 and per the Regs. at 4.4.8.3.1.


Submitter Full Name: TC ON CNS-AAA

Organization: NFPA TC ON CONFINED SPACE SAFE WORK PRACTICES

Street Address:

City:

State:

Zip:

Submittal Date: Fri Sep 02 14:26:20 EDT 2016


55 of 282 2/22/2017 2:45 PM

of 297

Public Comment No. 266-NFPA 350-2014 [ Section No. 8.3 [Excluding any

Sub-Sections] ]

The hazard identification and risk assessment process as specified in Chapter 6 requires that hazards beeliminated or controlled to a safe level. This chapter addresses common confined space hazards. Confinedspaces, however, may have unique hazards that are not addressed in this best practice guide. Nonetheless,the hazards need to be either eliminated or controlled using effective control methods.One method forcontinuous improvement is nearmiss/good catch reporting, resolution and documentation.

Statement of Problem and Substantiation for Public Comment

Brian Mckay's paper "Measures of Effects of Near Miss Reporting has been requested and sent to NFPA Standards AdmiinistratorThe concept of near miss applies to NFPA 350 sections 6.5.1., 3.3.5 definitions , and to preplan and permit as well as MOC sections. It is an important part of training and communications and essential to the fabric of NFPA 350

Related Item

Public Input No. 266-NFPA 350-2013 [Section No. 10.6.1 [Excluding any Sub-Sections]]


Submitter Full Name: cait casey

Organization: Aspen Risk Management Group

Street Address:

City:

State:

Zip:

Submittal Date: Wed Nov 12 15:29:22 EST 2014

Committee Statement

CommitteeAction:

Rejected but held

Resolution: The Committee agreed with the submitter that near miss reporting could be important for confinedspace entry. However the submitter has not provided specific information about how near missreporting could be used for confined space entry. The Committee requests that the submitterconsider adding a substantiation for how near miss reporting could be used in the document duringthe next revision cycle. This is also considered to be "new material" and as such should beconsidered at the first draft stage.


143 of 349 6/19/2015 4:03 PM

of 297


8.4.1 Acceptable Entry Conditions.

Where levels are outside the following parameters, entry should be allowed only after the following controlmeasures are taken:

(1) Oxygen content between 19.5 percent and 22.0 percent

(2) Flammable gases and vapors below 10 percent of the lower explosive limit (LEL) of the materialinvolved

(3)


This material is already provided in Section 7.14. As such, Section 8.4.1 is redundant and should be deleted.




Street Address:

City:

State:

Zip:


* Potential toxic air contaminants at or below the occupational exposure limit (OEL) asdetermined by the written confined space program


56 of 282 2/22/2017 2:45 PM

of 297


Prior to entry, Entry Supervisors should ensure that harmful or potentially harmful vapors, gases, toxics, andother residual materials have been removed from the confined space to the greatest extent possible inaccordance with the entry permit requirements. This can be accomplished from outside the space withoutbodily entry by ventilating with fresh air or purging with inert gas, water, or steam. If this is not possible,controls are needed to ensure that removal during entry does not create additional hazards. Caution: Theuse of steam to purge flammable atmospheres without using proper precautionary measures may result infire or explosion and may create an oxygen deficient atmosphere .


Alerting the user to the possibility that air/oxygen may have been displaced such that the atmosphere is oxygen deficient.




Street Address:

City:

State:

Zip:



57 of 282 2/22/2017 2:45 PM

of 297


8.4.2.4.1

Confined space entries of petroleum storage tanks should be in accordance with API 2015, Requirementsfor Safe Entry and Cleaning of Petroleum Storage Tanks, and API 2016, Guidelines and Procedures forEntering and Cleaning Petroleum Storage Tanks. Entry into inerted confined spaces should be inaccordance with API 2017A Safe Work in Inert Confined Spaces in the Petroleum and PetrochemicalIndustries, 2016. . These standards provide detailed safety requirements for aboveground petroleumstorage tanks.


adds additional API Standard covering inert confined spaces




Street Address:

City:

State:

Zip:



58 of 282 2/22/2017 2:45 PM

of 297


8.4.2.4.2

Entry Supervisors should ensure that confined space entry into and work within petroleum storage tanksare conducted in accordance with all applicable Owner/Operator and contractor programs, industrystandards, and regulatory requirements. ANSI/API 2015, Requirements for Safe Entry and Cleaning ofPetroleum Storage Tanks, and API API 2016, Guidelines and Procedures for Entering and CleaningPetroleum Storage Tanks, and API 2017A Safe Work in Inert Confined Spaces in the Petroleum andPetrochemical Industries provide detailed safety requirements for confined space entry to and work withinabove-ground petroleum storage tanks.


adds API 2217A covering inert spaces




Street Address:

City:

State:

Zip:



59 of 282 2/22/2017 2:45 PM

of 297


8.4.3 Combustible Dusts.

Entry Supervisors should ensure that combustible dust residue should be removed using intrinsically safevacuums, manual cleaning methods, or approved water wash-down methods that do not place dust insuspension in spaces where ignition sources could be present. The Entry Supervisor should confirm thatvacuum equipment is grounded and bonded to the space being cleaned and that compressed air is not .Compressed air should not be used to move or clean combustible dust unless vacuuming or manualcleaning creates a safety exposure to the person cleaning due to lack of access . In these situations, safetyprocedures should be followed and equipment shut down in the area to eliminate potential sources ofignition. Additional information on compressed air and water cleaning of combustible dust can be found inNFPA 652.


The edited sentence was broken into two to reduce confusion.




Street Address:

City:

State:

Zip:



60 of 282 2/22/2017 2:45 PM

of 297


Entry Supervisors should be aware that ventilation will not always eliminate all of the atmospheric hazardswithin a confined space. If hot work is to be conducted within a confined space that contains flammable orcombustible vapors or liquids, one method to control the ignition hazard is to displace any oxygen in theatmosphere within the space with an inert gas. Inert gas can also be used to displace oxygen whereflammable materials or atmosphere cannot be removed prior to entry. Entry Supervisors should not permitentry into confined spaces with inert atmospheres except in limited circumstances in accordance with theOwner/Operator or Entrant Employer's confined space program and respiratory protection program .Persons engaged in inert entry operations, including Entry Supervisors, Entrants, Attendants, Rescuers andothers should be trained, experienced, and qualified in this specific of activity.


Remind the Entry Supervisor that entry should also be in accordance with the applicable respiratory protection program. Deletion of "of" in the last sentence was editorial.




Street Address:

City:

State:

Zip:



61 of 282 2/22/2017 2:45 PM

of 297


Entry Supervisors should be aware that ventilation will ventilation may not always eliminate all of theatmospheric hazards within a confined space. If hot work is to be conducted within a confined space thatcontains flammable or combustible vapors or liquids, one method to control the ignition hazard is to displaceany oxygen in the atmosphere within the space with an inert gas. Inert gas can also be used to displaceoxygen where flammable materials or atmosphere cannot be removed prior to entry. Entry Supervisorsshould not permit entry into confined spaces with inert atmospheres except in limited circumstances inaccordance with the Owner/Operator or Entrant Employer's confined space program. Persons engaged ininert entry operations, including Entry Supervisors, Entrants, Attendants, Rescuers and others should betrained, experienced, and qualified in this specific of specific activity.


proper ventilation can remove all vapors. also correct typo




Street Address:

City:

State:

Zip:



62 of 282 2/22/2017 2:45 PM

of 297


8.4.4.5

Whenever inert gases are used to purge a space, the Ventilation Specialist and Entry Supervisor shouldconsider the discharge point for the evacuated atmosphere in relation to personnel and any sources ofignition outside or adjacent to the space. The Entry Supervisor may require atmospheric testing in theadjacent areas and barriers placed at appropriate distances to ensure that exhausted contaminants arewithin acceptable levels as defined in Section 8.4. The Entry Supervisor can use a hot-, warm-, andcold-zone system to delineate areas and degrees of hazard and controls .


Clarification.




Street Address:

City:

State:

Zip:



63 of 282 2/22/2017 2:45 PM

of 297


8.4.4.6

Whenever inerting is performed, the atmosphere within 35 ft (10.7 m) outside of the opening should betested as determined by the Entry Supervisor to be sure it is safe for breathing. In outside environments,the Entry Supervisor should consider humidity, wind direction, and wind speed and extend the testing area,if necessary.


clarification and typo




Street Address:

City:

State:

Zip:



64 of 282 2/22/2017 2:45 PM

of 297


8.4.4.8.1

Where any entry requires supplied breathing air, the Owner/Operator or Entrant Employer should assurethat the respiratory breathing air supplier adheres to practices that eliminate the potential for insufficientoxygen content in an air supply cylinder and the possibility of cross contamination of the cylinder air withother gases. They should assure that only certified compressor sourced breathing air meeting CGA 7.1Grade D quality (or equivalent better quality ) is used for SAR required entries. Air supply cylinders shouldbe dedicated to breathing air service and be secured with sealed valves (and racks) and controlled toprevent cross contamination.


Clarification.




Street Address:

City:

State:

Zip:



65 of 282 2/22/2017 2:45 PM

of 297


8.4.4.8.2

After cylinders and racks are in place at the job site and prior to each day's (or shift's) use, a qualifiedperson should test each breathing air cylinder (to be used) to assure the proper oxygen content and thatthere is no contamination .


provides for contamination check




Street Address:

City:

State:

Zip:



66 of 282 2/22/2017 2:45 PM

of 297


8.4.4.8.4

Owners/Operators and Entrant Employers should develop and implement respiratory protection programsthat include medical evaluation, training, and fit testing s before providing Entrants with respiratoryequipment.


Editorial.




Street Address:

City:

State:

Zip:



67 of 282 2/22/2017 2:45 PM

of 297


8.4.4.8.4

Owners/Operators and Entrant Employers should develop and implement respiratory protection programsthat meet applicable regulatory requirements and include medical evaluation, training, and fit testing sbefore testing before providing Entrants with respiratory equipment.


adds regulatory requirements and corrects error




Street Address:

City:

State:

Zip:



68 of 282 2/22/2017 2:45 PM

of 297


8.5.2 Hot Work Permit.

When hot work is required in or adjacent to a confined space, the Entry Supervisor should issue aseparate hot work permit attached to the confined space permit. The Owner/Operator where the hot workis to occur, or the contractor/subcontractor conducting the hot work, should have a hot work program andhot work permit procedures. The Entry Supervisor should ensure that, in addition to all of the requirementson the entry permit, the hot work permit contains information, including, but not limited to, the following:

(1) Conditions under which hot work permit authorization is to start/ stop or be cancelled

(2) Requirements for ventilation, inerting, or other atmospheric precautions

(3) Requirements for PPE and respiratory protection in addition to that required by the entry permit

(4) Requirements for continuous or periodic atmospheric monitoring within the confined space and, whennecessary, outside of the confined space as determined by the Entry Supervisor in accordance withthe confined space program and hot work program.


Language modified to be consistent with OSHA construction regulation 1926.1203 (e)(2)(vi).




Street Address:

City:

State:

Zip:



69 of 282 2/22/2017 2:45 PM

of 297


8.5.3 Cold Work Options.

Wherever possible, Entry Supervisors should provide alternatives other than hot work in or aroundconfined spaces during a confined space entry. The Entry Supervisor should consider alternative cold workmethods, including, but not limited to, mechanical cutting, cold cutting, scraping, hand grinding, and filingwith equipment that minimizes the potential for sparks and heat. For example, cutting can be done withhand saws, hydraulic shears, pneumatic chisels, or pipe cutters. Mechanical joining methods such as nutsand bolts, screwed fittings, or couplings can be used. Hand filing can be done instead of mechanicalgrinding, and threaded pipe might be used instead of welded or soldered pipe. Personnel should be awarethat sparks can be generated by some of these techniques, but the risk is greatly reduced as the sparksare typically not hot enough to cause ignition.


The cold work section should be moved to before the hot work section because cold work is preferred.




Street Address:

City:

State:

Zip:



70 of 282 2/22/2017 2:45 PM

of 297


8.5.4

Wherever hot work is performed, the Entry Supervisor should evaluate all locations and adjacent spaceswhere flammable or combustible liquids, gases, or materials may be present or occur. If such hazards exist,measures should be taken by the Entry Supervisor to control, remove, or clean them prior to issuing the hotwork permit. Entry Supervisors should ensure that hot work is not conducted in areas adjacent to tanks orlines containing flammable or combustible materials unless there is no other alternative, safety measureshave been implemented, and a hot work permit covering such activity has been approved. When hot workon tanks, vessels, containers, lines, and equipment containing flammable and combustible liquids or gasesis to be performed, Entry Supervisors should refer to API 2201, Safe Hot Tapping in the Petroleum andPetrochemical Industries, and API 2009, Safe Welding and Cutting Practices in Refineries, GasolinePlants and Petrochemical Plants , for guidance.


adds API 2009




Street Address:

City:

State:

Zip:



71 of 282 2/22/2017 2:45 PM

of 297


8.5.10

The Entry Supervisor should ensure that tanks containing oxygen (excluding SCBA tanks breathing aircylinders ), flammable gas, and inert gas remain outside a confined space, if possible. Entry Supervisors,Attendants, and Entrants should be aware that leaking oxygen lines can create an oxygen-enrichedenvironment and leaking acetylene can create a flammable atmosphere, both of which can lead toincreased fire and explosion hazards.


Breathing air cylinders is more general and inclusive of SCBA tanks.




Street Address:

City:

State:

Zip:



72 of 282 2/22/2017 2:45 PM

of 297


8.5.11

Entry Supervisors should ensure that all hoses and torches associated with oxygen and gas cylinders aredisconnected and the gas and oxygen supply shut off at the end of the work period and during unattendedbreaks or extended break periods.


need to do this at end of shifts or day's work




Street Address:

City:

State:

Zip:



73 of 282 2/22/2017 2:45 PM

of 297


8.5.12

Entry Supervisors should ensure that all electrical welding equipment used in flammable and combustibleatmospheres is inspected and approved by prior to use by a qualified person, is intrinsically safe, and isproperly grounded, and, where necessary, bonded to the tank, vessel, equipment, or confined space.


need to say when to inspect




Street Address:

City:

State:

Zip:



74 of 282 2/22/2017 2:45 PM

of 297


8.5.13

Entry Supervisors should sure ensure that ordinary combustible materials are not located within 35 ft ofthe hot work area. If such materials are present and cannot be removed, the Entry Supervisor shouldindicate appropriate preventive measures on the hot work permit and make sure they are implemented tocontrol or mitigate the potential hazards before work begins.


Editorial




Street Address:

City:

State:

Zip:



75 of 282 2/22/2017 2:45 PM

of 297


Entry Supervisors should be aware of, and ensure that all welding and hot work is conducted in accordancewith Owner/Operator or contractor programs and procedures, industry practices, and regulations applicableto the specific industry or operation being performed. Owner/Operators, contractors, and Entry Supervisorsshould be aware of the most current regulations, codes, and practices, including, but not limited to, theAmerican Welding Society’s publications on safe welding practices and procedures. API 2009 SafeWelding and Cutting Practices in Refineries, Gasoline Plants and Petrochemical Plants provides guidancefor work in these facilities.


adds API 2009




Street Address:

City:

State:

Zip:



76 of 282 2/22/2017 2:45 PM

of 297


8.5.14.1.4

NFPA 326 contains minimum procedures that permit repair, hot work, or other operations that couldpotentially create a fire, an explosion, or other hazard wherever hot work is performed on tanks orcontainers containing flammable, combustible, or other hazardous vapors, liquids, or solid residues. TheAmerican Welding Society AWS Fact Sheet Bundle for Chemical Industry Welding also has informationregarding hot work operations.


adds specific AWS document title




Street Address:

City:

State:

Zip:



77 of 282 2/22/2017 2:45 PM

of 297

Public Input No. 67-NFPA 350-2016 [ New Section after 8.5.14.4.8 ]

TITLE OF NEW CONTENT

Type your content here ...

8.5.14.4.9 API 2217A Safe Work in Inert Confined Spaces in the Petroleum and PetrochemicalIndustries.

This publication provides guidance for safely entering and working within confined spaces that have beenintentionally purged with an inert gas until the oxygen level in the space is too low to support combustion

-


adds API 2017A




Street Address:

City:

State:

Zip:



78 of 282 2/22/2017 2:45 PM

of 297


All sources of energy — mechanical, electrical, hydraulic, chemical, or stored energy — in confined spacesthat could impact worker safety should be eliminated using the appropriate isolation or lockout/tagoutprocedures in accordance with regulatory requirements and the Owner/Operator orcontractor/subcontractor's isolation program prior to issuance of an entry permit.


adds regulatiory




Street Address:

City:

State:

Zip:



79 of 282 2/22/2017 2:45 PM

of 297


8.6.2*

The Isolation Specialist or Entry Supervisor should verify that all energy sources that could potentiallyimpact operations within and around the confined space have been isolated, locked out/tagged out, orotherwise safeguarded against prior to the issuance of an entry permit. If there is a need to enter the spaceto verify that sources have de-energized, the entry should be performed by an Isolation Specialist, who alsoqualifies as an Entrant, following the permit process and entry procedures provided in this guide.


Editorial




Street Address:

City:

State:

Zip:



80 of 282 2/22/2017 2:45 PM

of 297


8.8.1.1 Requirements.

Before use, the Entry Supervisor should make sure that a qualified person thoroughly inspects all cleaningequipment, nozzles, hoses, couplings, and accessories that could potentially create an electrical staticcharge to ensure electrical continuity between the parts of the assembly and that they are properly bondedand grounded, if necessary . Inspections should include, but not be limited to, the following:

(1) Vapor and gas freeing, degassing, flushing and ventilation equipment and appurtenances, such asblowers and eductors; inert gas piping and connections; water, fuel, oil, and steam piping, hoses,nozzles, and connections; flame and detonation arrestors; and flexible vapor intake and exhaustducting.

(2)

(3) Hoses and nozzles used to inject product, steam, chemicals, solvents, or water into a tank to dislodgeand flush residue and sludge or wet down pyrophoric deposits. The hoses and nozzles should bebonded to the space and the equipment should be grounded.

(4) Abrasive blasting hoses, nozzles, and equipment, which should be bonded to the space andgrounded.

(5) Mechanized portable and robotic cleaning equipment, which should be bonded to the space andgrounded.

(6) Welding, cutting, grinding, and hot tapping equipment, which should be bonded to the work andgrounded to dissipate stray currents.


provides information to assure equipment is not disconnected and will provide a continuous electrical path to ground or bond




Street Address:

City:

State:

Zip:


* Vacuum trucks used for removing materials, degassing and exhausting vapors from a confinedspace. The vacuum truck suction and discharge hoses should be electrically bonded to both the truckand space and grounded.


81 of 282 2/22/2017 2:45 PM

of 297


8.13* Animals and Insects .

The confined space should be visually inspected by the entry supervisor prior to entry, and any potentiallydangerous animals or insects should be removed or eliminated. If an extermination chemical is used, itmight be necessary to have the environment in and around the space reassessed prior to permitting entry.The Gas Tester should include the pesticide hazard when retesting. The Entry Supervisor should determineif the space needs to be ventilated and if respiratory protection and/or protective clothing and gloves shouldbe worn by the Gas Testers and workers to prevent skin exposure to the chemicals.


Insects are animals, and therefore the paragraph title could be shortened to just Animals, Other options are Fauna or Wildlife.




Street Address:

City:

State:

Zip:



82 of 282 2/22/2017 2:45 PM

of 297


9.1.3 *

Where considering ventilation, the Entry Supervisor and Ventilation Specialist should understand thedifferences between ventilation and purging. These terms are often used interchangeably, but actually applyto different atmospheric hazard control methods. Ventilation provides a means to introduce breathingquality air to enter a space and control contaminants in that space through mixing and dilution. Purging isthe use of air, water or tother safe liquid, steam, or an inert gas to displace air within a hazarousatmosphere within the space. (See Section 9.3.)


the use of a combustible liquid to purge a flammable liquid from a space is common as is the use of water. Also the purging is of the internal atmosphere not necessarily air.




Street Address:

City:

State:

Zip:



83 of 282 2/22/2017 2:45 PM

of 297


9.3.4.1.1

When an inert gas purge is used to displace flammable vapors that exceed or are within the flammablerange, the inert gas should be introduced by the Ventilation Specialist into the space and maintained untilthe flammable vapor concentration has been reduced to a safe level approximately 20% of the LFL value,for the specific contents .



Public_Comment_No._377_HELD.pdf NFPA 350 Public Comment No. 377


NOTE: This Public Input appeared as "Rejected but held" in Public Comment No. 377 of the F2015 Second Draft Report for NFPA 350 and per the Regs. at 4.4.8.3.1.


Submitter Full Name: TC ON CNS-AAA

Organization: NFPA TC ON CONFINED SPACE SAFE WORK PRACTICES

Street Address:

City:

State:

Zip:

Submittal Date: Fri Sep 02 14:11:41 EDT 2016


84 of 282 2/22/2017 2:45 PM

of 297

Public Comment No. 377-NFPA 350-2014 [ Section No. 9.3.4.1.1 ]

9.3.4.1.1

Where an inert gas purge is used to displace flammable vapors that exceed or are within the flammablerange, the inert gas should be introduced by the ventilation specialist into the space and maintained untilthe flammable vapor concentration has been reduced to approximately 1 percent by volume,which is 20%of the LFL for typical petroleum products value, for the specific contents .

Statement of Problem and Substantiation for Public Comment

Modify text as shown

Related Item

First Revision No. 8-NFPA 350-2014 [Chapter 9]


Submitter Full Name: EMERY THOMAS

Organization: CONOCOPHILLIPS

Street Address:

City:

State:

Zip:

Submittal Date: Fri Nov 14 18:01:39 EST 2014

Committee Statement

CommitteeAction:

Rejected but held

Resolution: Committee agrees and has slightly modified the suggested revision but maintained the intent of theproposal. The committee removed any specific levels from the text until they can research theissue further. A task group on inerting will be formed.


200 of 349 6/19/2015 4:03 PM

of 297


9.4.2.1

The Ventilation Specialist should determine if it is necessary to attach flexible ducting to any air-movingdevice to deliver the air to the designated location within the confined space. Flexible ducting may also beused to direct exhaust air flow to a predetermined outside location (such as 12 feet above the surfacelevel) or to a environmental collection system. Flame arresters may be required in exhaust lines whereflammable vapors or gases are being vented.


adds additional requirements




Street Address:

City:

State:

Zip:



85 of 282 2/22/2017 2:45 PM

of 297


9.4.3 * Thermal Oxidizers.

Where ventilating tanks, vessels, and other confined spaces with flammable atmospheres, localenvironmental regulations often restrict ventilation discharge emissions. The Ventilation Specialist shoulddetermine if the system requires a gas-freeing or vapor-freeing tank connected to a thermal oxidizer unit orvapor recovery system to safely use exhaust ventilation. In such cases, the use of an approved flamearrestor in the connecting line is recommended.


provides information on safety device




Street Address:

City:

State:

Zip:

Submittal Date: Wed Dec 28 10:54:11 EST 2016


86 of 282 2/22/2017 2:45 PM

of 297


9.4.4 * Bonding/Grounding.

Static electricity is created when input or exhaust air moves through a fan, blower, or ducting. Whenventilation is used to dilute or exhaust flammable gases or vapors, the Ventilation Specialist should controlall ignition sources, including static electricity. Regulations and best practices require that all air-movingdevices, including ducting and appurtenances attached to the air-moving device, be properly bonded to thespace and grounded to ensure the dissipation of any accumulated static charge within the ventilationsystem. This includes ducting and appurtenances attached to the air-moving device.


notes that static can be created by both input air and exhausted atmosphere. rearranged for clarity




Street Address:

City:

State:

Zip:



87 of 282 2/22/2017 2:45 PM

of 297


9.6 Limitations of Ventilation.

The Entry Supervisor and Ventilation Specialist should consider the following limitations during the hazardevaluation and risk assessment process; during design and selection of ventilation equipment; and duringthe installation and use of ventilation systems for confined spaces:

(1) Permit requirements for entry, including but not limited to explosive atmosphere limits, oxygenlevels, toxic exposure limits, temperature and humidity limits.

(2) Source and quality of supply and makeup air, inert gas and purge materials, if used and their impacton the ventilation requirements. .

(3) Use of approved equipment where required (e.g., the electrical area classification and use ofpneumatic or steam operated ventilation systems in flammable atmospheres)

(4) Bonding and grounding of all air-moving devices and any ducting or attachments

(5) Noise levels associated with air-moving devices

(6) Maintaining access and egress needs while ventilating spaces

(7) Frequent or periodic atmospheric monitoring inside a confined space and outside the space asnecessary to ensure acceptable air quality an acceptable atmosphere in accordance with the permitrequirements

(8) Time required to achieve initial safe conditions and/or for re-entry into a confined space

(9) In addition to ventilation, any respiratory protection and other PPE that might be necessary to ensurethe safety of confined space Entrants and workers in adjacent spaces


adds additional information for consideration in ventilation operations.




Street Address:

City:

State:

Zip:



88 of 282 2/22/2017 2:45 PM

of 297


10.1.2.4

Owner/Operators and Entrant Employers should implement rescue procedures for the following Attendantoperations:

(1) Recognizing the need for confined space search and rescue

(2) Initiating contact and establishing communications with victims where possible

(3)

(4) Advising the responding Rescuers of the situation and potential hazards

(5) Recognizing specific confined spaces, their ingress and egress limitations and internal configuration

(6)

(7)


adds additional information for attendant rescue




Street Address:

City:

State:

Zip:


* Recognizing and identifying the hazards associated with non-entry confined space emergencies

* Identifying the need for and performing a non-entry retrieval, based on the conditions present

* Implementing the emergency response system for confined space emergencies


89 of 282 2/22/2017 2:45 PM

of 297


It is the ultimate responsibility of the Owner/Operator to assure that the rescue service is qualified and readyto perform rescue from spaces within their jurisdiction. In turn, where the Owner/Operator has assigned thisauthority to an Entrant Employer and they have agreed to accept the responsibility to provide the rescueservice, those providing the service should be accountable to be fully prepared for the task. A rescueservice should meet all requirements of NFPA 1670, chapter on confined space rescue, technician level.

agreed to accept the responsibility to provide the rescue service and signed documentation stating as such.


Many times there are company's that are working in confined spaces in our city and the fire department is not notified or consulted. Without our knowledge these company list our fire department as the responding agency for confined space rescue. We do not have the training or equipment to perform these tasks. If these company's were to have to have a signed document from the AHJ / fire department stating that these jurisdictions are going to be the responding agency that will provide confined space rescue it would help make sure that an appropriate agency will be responding if the need arises. It would also help us be aware of any confined space activity being performed in our city. Another potential benefit would be that it helps fire departments recognize their need for training and purchasing confined space rescue equipment so they can provide this service or at least locate the most appropriate mutual aide prior to a confined space rescue situation.


Submitter Full Name: scott lewis

Organization: Lincoln Park Fire Department

Affilliation: Lincoln Park Fire Department

Street Address:

City:

State:

Zip:

Submittal Date: Tue Oct 11 11:52:51 EDT 2016


90 of 282 2/22/2017 2:45 PM

of 297


10.2.3.3.1 Patient Care Components.

Patient care components should include, but not be limited to, the following:

(1) Assessing and addressing critical immediate life-threatening conditions

(2) Assessing and addressing conditions that are not immediately life threatening

(3) Stabilization and packaging of the patient with regard to injuries so as to prevent further harm ifpossible

(4) Identification and means of access to trauma centers relative to specific confined space injuriesincluding, but not limited to, toxic exposures, chemcial and physical burns, asphixiation or lack ofoxygen, cuts, breakage, bruises and other physical or mental trauma.


adds an important patient care component.. what to do afterwards




Street Address:

City:

State:

Zip:



91 of 282 2/22/2017 2:45 PM

of 297


10.9.1 *

The size and composition of a confined space rescue team and the required rescue equipment, should bebased on pre-incident planning and practice of the plan to ensure effective operations. The role of aconfined space rescue team is intended to include entry into the space to perform a rescue. Therefore theteam should be staffed to provide for the following exclusive functions:

(1)

(2)

(3) * Attendant, whose function is to deny unauthorized persons access and to monitor the conditions inthe space and the status of all Entrants

(4) Rescue supervisor to maintain control of the entire operation and who is knowledgeable in all teamfunctions

(5) Safety officer, whose function is to observe operations in and around the emergency scene and callattention to any safety hazards. The safety officer is qualified and authorized to halt operations (ifneeded) when a significant hazard is recognized. Although halting operations ideally should beperformed by a single well-trained individual with no other assignments, any rescue team membershould be able to halt an operation for safety concerns at any time.


adds annex item for clarity




Street Address:

City:

State:

Zip:


* Entrant/entry team of sufficient size to provide immediate assistance to, or rescue of, entry teammembers who become ill or injured and are unable to perform self-rescue

* Backup team of sufficient size to provide immediate assistance to or rescue of entry team memberswho become ill or injured and are unable to perform self-rescue


92 of 282 2/22/2017 2:45 PM

of 297

Public Input No. 206-NFPA 350-2017 [ Chapter 11 ]

Chapter 11 Confined Space Personnel Duties, Responsibilities, and Competencies

11.1 * General.

All persons engaged in confined space activities and operations should be competent and qualified. Thereare numerous entities that may be involved, individually or working together, in confined space entry andrelated activities. These include, but are not limited to, Owners/Operators, contractors/subcontractors,facility personnel, rescue services, and visitors, as well as other persons and operations both within andoutside of the confined space. This chapter covers the duties, responsibilities, qualifications, andcompetencies of these individuals as related to confined space activities. This chapter lists requirements forall persons and tasks that might be required for entry. It is important to recognize that there are at leastthree key positions required for a basic confined space entry that requires permitting: the Entry Supervisor,the entry Attendant, and the Entrant. In addition to these three positions, rescue should be provided asoutlined in Chapter 10. In many applications one or more of these persons (often the Entry Supervisor) canhandle other tasks addressed in this chapter,including, but not limited to, atmospheric testing, issuingpermits, conducting ventilation, and providing standby services.

11.2 Entrants.

11.2.1 General.

11.2.1.1

Entrants should be competent, qualified, and authorized to enter and work within confined spaces.

11.2.1.2

As defined in the applicable confined space program, entry occurs when any part of the Entrant’s bodybreaks the plane of a confined space opening.

11.2.2 Entrant Duties and Responsibilities.

11.2.2.1

Entrants should enter the confined space only when designated by their employer and authorized by theEntry Supervisor and after a confined space pre-entry evaluation has been performed and a permit issuedif necessary.

11.2.2.1.1

Each Entrant should verify in writing, where required, that his or her name is listed on the entry permit.

11.2.2.1.2

Entrants should be aware of the hazards that might be encountered during entry, including the confinedspace hazards and controls noted on the permit.

11.2.2.2

Entrants should conduct assigned work following approved procedures that minimize hazards.

11.2.2.3

Entrants should demonstrate the proper use of approved equipment, materials, tools, and personalprotective equipment (PPE) identified in the permit to the Entry Supervisor.

11.2.2.4

Entrants should remain aware of potential atmospheric and nonatmospheric hazards that might beencountered during confined space entry.

11.2.2.4.1

Entrants should exit the confined space when changing conditions result in hazards that causeunacceptable risks.


93 of 282 2/22/2017 2:45 PM

of 297

11.2.2.4.2

Entrants should immediately exit the space if the entry permit expires or is cancelled.

11.2.2.4.3

Entrants should immediately exit the space when directed by the Attendant or the Entry Supervisor orduring any emergency occurring elsewhere in the vicinity that requires evacuation.

11.2.2.5

Entrants should understand and be able to communicate the hazards inside and outside the confinedspace that may be encountered during entry, including information on the mode, signs or symptoms, andconsequences of exposure and act accordingly depending on the situation.

11.2.2.5.1

Entrants should immediately notify the Attendant of any symptoms of exposure, an emergency, orunacceptable conditions.

11.2.2.5.2

Entrants should exit the confined space immediately if symptoms, warning signs, or unacceptableconditions occur.

11.2.2.6

Entrants should react to emergencies as trained and directed, including, but not limited to, self-rescue orevacuation of the confined space.

11.2.2.7

Entrants may also perform other activities and assigned duties if qualified in accordance with the applicableconfined space program, including, but not limited to, self-rescue, monitoring, hot and cold work inside thespace, and performing non-entry tasks.

11.2.3 Entrant Qualifications.

11.2.3.1

An Entrant should understand and comply with applicable governmental regulations that pertain to theplanned confined space entry and work as explained by the entry supervisor or included in the entry permit.

11.2.3.2

An Entrant should understand and be able to communicate to the Entry Supervisor the use, limitations, andhazards of materials, substances, and equipment approved for use within the specific confined space (e.g.,tools, PPE, energy isolation devices, gas monitors, and chemicals) before entry.

11.2.3.3

An Entrant should understand and be able to communicate to the Entry Supervisor before entry the primaryand secondary means of communication to be used during emergencies.

11.2.3.4

An Entrant should understand and be able to communicate to the Entry Supervisor before entry how tointerpret and respond to gas monitor displays and alarms.

11.2.3.5

An Entrant should understand and be able to communicate to the Entry Supervisor before entry all sectionsof the confined space entry permit that are applicable to the Entrant’s duties.

11.2.3.6

An Entrant should understand and be able to communicate to the Entry Supervisor before entry personalwarning signs and overexposure symptoms, including actions that must be taken in the event of exposure.

11.2.3.7

An Entrant should understand and be able to verbally explain to the Entry Supervisor before entryapplicable emergency procedures to be taken within or around the confined space.

11.2.4 Entrant Demonstrated Competencies.


94 of 282 2/22/2017 2:45 PM

of 297

11.2.4.1

An Entrant should be able to read and understand permit requirements.

11.2.4.2

An Entrant should be able to demonstrate the proper use of required assigned equipment, tools, andmaterials, including, but not limited to PPE, respiratory protection, non-entry rescue devices, instruments,and cleaning and decontamination materials.

11.2.4.3

An Entrant should be able to communicate when evacuation is desired.

11.2.4.4

An Entrant should be able to complete assigned tasks in an approved manner.

11.3 Attendant.

11.3.1 General.

11.3.1.1

Attendants should be competent, qualified, and authorized to oversee the Entrants working inside theconfined space and the activities occurring outside the confined space that might affect confined spaceoperations.

11.3.1.2

Attendants should be stationed outside confined spaces but in close proximity to the entry so that Entrantscan be observed.

11.3.2 Attendant Duties and Responsibilities.

11.3.2.1

Attendants should understand and be able to communicate to the Entry Supervisor the hazards inside andoutside the specific confined space that might occur during entry, including information on the modes, signsor symptoms, and consequences of exposure to Entrants.

11.3.2.1.1

Each Attendant should verify that his or her name is listed on the entry permit. This may require initialing orsignature, as required by the Entry Supervisor.

11.3.2.1.2

Attendants should be constantly observing, monitoring, and evaluating the conditions in and around theconfined space to ensure that compliance with the requirements of the permit are maintained throughoutthe entry.

11.3.2.1.3

Attendants should monitor adjacent areas outside the confined space for changing conditions that mightaffect safe entry work or activities.

11.3.2.2

Attendants should remain outside the confined space opening during entry operations until relieved byanother assigned Attendant.

11.3.2.2.1

Attendants should inform the replacement Attendant of current confined space and Entrant status.

11.3.2.2.2

The replacement Attendant’s name should be listed on the entry permit and acknowledged by replacementAttendant’s initials or signature, as required by the applicable confined space program.

11.3.2.3

Attendants should monitor Entrants status and direct Entrant evacuation as needed.

11.3.2.4

Attendants should continuously maintain an accurate count of Entrants in the confined space.


95 of 282 2/22/2017 2:45 PM

of 297

11.3.2.5

Attendants should take the following actions when unauthorized person(s) approach or enter a confinedspace while entry is underway:

(1) Warn nonauthorized personnel not to enter into the confined space

(2) Inform Entrants and Entry Supervisors when nonauthorized personnel enter or attempt to enter theconfined space

(3) Prevent nonauthorized personnel from interfering with Attendant duties

11.3.2.6

Attendants should summon rescue and other emergency services immediately upon recognizing anEntrant’s distress inside the confined space.

11.3.2.7 *

Attendants should perform non-entry rescue as trained and equipped.

11.3.2.8 *

Attendants may perform other approved assigned duties that do not interfere with the primary duty tomonitor and protect the Entrants. Attendants may also perform other assigned duties, if competent andqualified, in accordance with the applicable confined space program, including, but not limited to, testingexternal atmosphere, summoning Rescuers, and performing non-entry rescue.

11.3.3 Attendant Qualifications.

11.3.3.1

Attendants should be competent, qualified, and authorized in accordance with the applicable confinedspace program and governmental regulations that pertain to the planned confined space work.

11.3.3.2

An Attendant should be competent and qualified to operate and understand the assigned atmosphericmonitor and to be capable of recording readings as required.

11.3.3.3

Attendants should know and be able to communicate to the Entry Supervisor the use, limitations, andhazards of materials, substances, and equipment approved for use outside the specific confined space,including, but not limited to, tools, PPE, energy isolation devices, gas monitors, and chemicals.

11.3.3.4

Attendants should know and be able to communicate to the Entry Supervisor the hazards inside andoutside the specific confined space that might be encountered during entry operations, includinginformation on the modes, signs or symptoms, and consequences of exposure to Entrants.

11.3.4 Attendant Demonstrated Competencies.

11.3.4.1

Attendants should be able to read, understand, and communicate permit requirements to the EntrySupervisor if applicable.

11.3.4.2

Attendants should be educated or trained in the proper use of required assigned equipment, including, butnot limited to, PPE, respiratory protection, non-entry rescue devices, tools, and communication devices,and be able to demonstrate such competency to the Entry Supervisor.

11.3.4.3

Attendants should be able to communicate with Entrants in order to evacuate the confined space whenconditions arise that might endanger the Entrant.

11.3.4.4

Attendants should be able to perform their assigned tasks safely in accordance with the requirements of theapplicable confined space program and/or entry permit.


96 of 282 2/22/2017 2:45 PM

of 297

11.3.4.5

Attendants should be able to recognize Entrant signs and symptoms related to hazardous or toxic chemicalexposures and oxygen deficiency and take appropriate action required to assist Entrant self-evacuation orwith Entrant rescue.

11.4 Entry Supervisor.

11.4.1 General.

11.4.1.1

Entry Supervisors should be qualified and competent to oversee and direct confined space entry andassociated operations in accordance with applicable regulations, entry and work permits, facility operatingpractices, and appropriate confined space program requirements.

11.4.1.2 *

Entry Supervisors can also be designated on the permit(s) as Attendants, Gas Testers, VentilationSpecialists, Isolation Specialists, and Entrants in accordance with the applicable confined space program.Entry Supervisors should be trained and/or qualified in accordance with the respective requirementsprovided in this chapter for alternative activities.

11.4.2 * Entry Supervisor Duties and Responsibilities.

11.4.2.1

Entry Supervisors should verify that the appropriate information has been recorded on the confined spaceentry permit, that other specified permits and all tests specified by the permits have been completed, andthat all requirements, procedures, and equipment specified by the permit have been satisfied or are inplace before issuing the permit to authorize entry.

11.4.2.1.1

Entry Supervisors should be able to determine requirements and implement procedures to identify and theneliminate, control, or mitigate hazards.

11.4.2.1.2

Entry Supervisors should be identified and should sign or initial permits to document acceptance ofresponsibility.

11.4.2.1.3

Where required by the applicable confined space program or regulations, the assigned Entry Supervisorshould remain at the confined space work site to control operations unless relieved by another competent,qualified, and authorized Entry Supervisor. The relieving Entry Supervisor should initial or sign the permit(s)to document the change of responsibility if applicable.

11.4.2.1.4

Entry Supervisors should ensure that personnel involved with the confined space operations are informedwhen another person assumes the Entry Supervisor role.

11.4.2.1.5

Entry Supervisors should be trained and qualified as an Entrant if duties require entry into confined spaces.

11.4.2.1.6

Entry Supervisors should be trained and qualified as Gas Testers if duties require maintaining, testing, andoperating gas monitors, including interpreting and analyzing test results.

11.4.2.1.7

Entry Supervisors should be trained and qualified as Ventilation Specialists if duties require ventilation ofthe space. Entry Supervisors should be knowledgeable of the requirements for ventilation to ensure that theproper method is used for the hazards present, the confined space configuration, and the work to be done.

11.4.2. 2 7

Entry Supervisors should conduct a pre-entry safety meeting with all persons involved prior to the start ofconfined space operations in accordance with the applicable confined space program (see Section 5.5).


97 of 282 2/22/2017 2:45 PM

of 297

11.4.2. 3 8

Entry Supervisor should coordinate activities where multiple Owners/Operators are working on the samejob or on nearby jobs that might affect the confined space operations.

11.4.2. 4 9 *

Entry Supervisors should terminate the entry and cancel the permit if permit requirements are no longermet.

11.4.2. 4 9 .1

Entry Supervisors should cancel the permit and/or take appropriate action to effect the removal of anyunauthorized individuals who enter or attempt to enter a permit space during entry operations or whenunauthorized equipment is brought into a space.

11.4.2. 4 9 .2

Entry Supervisors should cancel the permit if conditions arise inside or outside the confined space thatwere not anticipated on the permit and have the potential to adversely affect operations.

11.4.2. 4 9 .3

Entry Supervisors should cancel and reissue the permit with the new entry and control requirements if theconfined space is reclassified.

11.4.2. 5 10

Entry Supervisors should identify methods of alerting Rescuers and ensure that Rescuers are available fora timely response, as required by the confined space program.

11.4.2. 6 11

Entry Supervisors should determine that acceptable entry conditions are met and that they remainconsistent with requirements of the entry permit, including whenever changes occur inside or outside theconfined space.

11.4.2. 7 12

Entry Supervisors should ensure that all energy sources, including, but not limited to, electrical, steam,hydraulic, and mechanical, and all tank equipment and appurtenances, including, but not limited to, tankmixers, heaters, sensors, piping or ducting into or from the space, and other instrumentation, have beencontrolled, disconnected, or isolated before the permit is issued.

11.4.2. 8 13

Entry Supervisors should ensure that the Gas Tester, Entrants, Attendants, and other confined spacepersonnel properly wear and use approved PPE and appropriate respiratory protection as identified on andrequired by the permit.

11.4.2. 9 14

Entry Supervisors should ensure that access to confined spaces is prohibited when work is not in progressand there are no Attendants present. Access should also be prohibited if required emergency response isnot available.

11.4.2. 10 15

Entry Supervisors should ensure that areas are barricaded, cordoned off, or otherwise protected to preventexposure to hazardous atmospheres where toxic and flammable gases, vapors, or inert gas is vented.Entry Supervisors should ensure that there are no ignition sources present in areas susceptible toflammable or combustible vapors, gases, or combustible dust exhausted from the space.

11.4.2. 11 16 *

Entry Supervisors should ensure that all ignition sources in the area are eliminated or controlled beforepermitting work to be conducted that might involve the actual or potential release of flammable orcombustible vapor, gas, or dust into the atmosphere around or inside the confined space.

11.4.3 Entry Supervisor Qualifications.

11.4.3.1 *

Entry Supervisors should be certified as a confined space entry (safety) supervisor where certification isavailable, and required or applicable.


98 of 282 2/22/2017 2:45 PM

of 297

11.4.3.2

Entry Supervisors should know and be able to apply the applicable regulatory and confined space programrequirements and be able to explain them to assigned personnel.

11.4.3.3

Entry Supervisors should know the proper use of gas monitors and be able to understand, analyze, andinterpret gas monitor readings in order to provide for safe entry and work in confined spaces.

11.4.4 Demonstrated Competencies.

11.4.4.1

Entry Supervisors should be able to identify, recognize, and assess hazards associated with the specificconfined space and operations and the methods to be used for elimination, mitigation or control of suchhazards in accordance with Chapters 6, 7, and 8.

11.4.4.2

Entry Supervisors should know and be able to identify and evaluate the need for required equipment.

11.4.4.3

Entry Supervisors should know the requirements applicable to the specific space and work to be done andbe able to prepare, issue, and understand permits.

11.4.4.4

Entry Supervisors should know the available communications methods and equipment and be able tocommunicate with all personnel, including facility and emergency responders, as required.

11.4.4.5

Entry Supervisors should be able to perform their assigned tasks in a competent and approved manner andensure that personnel for whom they are responsible do the same.

11.5 Rescuer.

Rescuers should be competent, trained, and equipped as required by applicable regulations and confinedspace entry and rescue programs. Rescuers should be designated by the appropriate authority (i.e., theOwner/Operator or the Entrant Employer) and be able to respond to emergencies requiring the rescue ofEntrants from outside or from within confined spaces in accordance with the provisions of Chapter 10. ARescue Service should meet all requirements of NFPA 1670, chapter on confined space rescue, technicianlevel.

11.6 Gas Tester.

11.6.1 General.

Gas Testers should be qualified in the appropriate selection, inspection, calibration, testing, adjustment, anduse of monitoring equipment and applicable monitoring and testing procedures needed to assess andevaluate atmospheres in and around confined spaces, in accordance with Chapter 7.

11.6.2 Gas Tester Duties and Responsibilities.

11.6.2.1

Gas Testers should determine proper selection of gas monitors based on the atmospheric hazards that arepresent or that could be encountered during confined space operations.

11.6.2.2

Gas Testers should inspect, calibrate, test, and adjust gas monitors prior to use.

11.6.2.3

Gas Testers should first test, sample, and monitor the atmosphere around the outside of the confinedspace prior to entry and then test the atmosphere within the space from the outside (without bodily entry)through an opening, using a probe or similar equipment.

11.6.2.3.1

A Gas Tester should verify that his or her name is listed on the entry permit as tester if applicable.


99 of 282 2/22/2017 2:45 PM

of 297

11.6.2.3.2

Gas Testers should be qualified as Entrants and be aware of all confined space hazards, entryrequirements, PPE, and other controls prior to entry for testing.

11.6.2.4

Gas Testers should sample, analyze, interpret, and monitor the atmosphere inside the confined space inthe following order:

(1) Oxygen levels

(2) Flammable gases and vapors

(3) Toxic/hazardous atmospheric contaminants

11.6.2.5

Gas Testers should record test results on the permit and verify by signing the permit, indicating the time(s)and the result(s) of the testing, if applicable.

11.6.2.6

Gas Testers should allow Entry Supervisors, Attendants, Entrants, and workers (or their authorizedrepresentatives) to observe the monitoring process and the results.

11.6.2.7

Gas Testers should re-evaluate conditions by testing, sampling, and monitoring the atmosphere botharound and inside the confined space as often as necessary as determined by the Entry Supervisor.

11.6.3 Gas Tester Qualifications.

11.6.3.1

Gas Testers should be familiar with and be able to apply the confined space program and entry permitrequirements and governmental regulations that pertain to the planned confined space work.

11.6.3.2

Gas Testers should be trained and qualified in the appropriate selection, inspection, calibration, adjustment,and use of gas monitors.

11.6.3.3

Gas Testers should understand and be able to communicate to the Entry Supervisor how to assess,interpret, and apply material safety data information and limitations pertinent to the hazards associated withthe confined space and surrounding area and operations.

11.6.3.4

Gas Testers should understand and be able to communicate to the Entry Supervisor the monitoring ofatmospheres in and around confined spaces and know how to apply the appropriate testing proceduresassociated with monitoring.

11.6.3.5

Gas Testers should be trained and meet the qualifications for an Entrant in order to test within confinedspaces.

11.6.3.6

Gas Testers should know how to determine, select, and use required and approved PPE and respiratoryprotection based on hazards associated with the confined space operations in accordance with theconfined space permit.

11.6.3.7

Gas Testers should know and be able to communicate to the Entry Supervisor how to monitor, analyze, andinterpret results of the atmospheric hazards test readings.

11.6.4 Gas Tester Demonstrated Competencies.


100 of 282 2/22/2017 2:45 PM

of 297

11.6.4.1

Gas Testers should be able to demonstrate the competencies required for a Gas Tester and an Entrant andunderstand permit requirements for entering confined spaces, conducting monitoring, and recordingmonitoring results.

11.6.4.2

Gas Testers should be able to select, inspect, adjust, calibrate, bump test, and properly use required gasmonitors.

11.6.4.3

Gas Testers should be able to conduct monitoring and testing in an approved manner in accordance withthe entry permit requirements and applicable regulatory requirements.

11.6.4.4

Gas Testers should be able to compare results with recognized and applicable government, industry, andcompany occupational exposure limits to determine the degree of hazard that is present in the space forsafe entry and work with or without PPE.

11.7 Owner/Operator.

11.7.1 General.

Owners/Operators should have control, ownership or authority over the confined space and should ensurethat confined space operations are conducted in accordance with regulatory and industry practices, theOwner/Operator’s confined space program, and Chapter 12.

11.7.2 Owner/Operator Duties and Responsibilities.

11.7.2.1

Owners/Operators should evaluate and re-evaluate confined spaces and identify and designate those thatshould be classified as confined spaces in accordance with Chapter 4. This responsibility may bedelegated by the owner when the space is under the control of a third party [such as when a building orportion thereof (a space) is leased or contracted to a third party] and the Owner/Operator has no obligationto the building, the space, or the operations therein.

11.7.2.2

Where applicable, Owners/Operators should obtain required jurisdictional permits and authorizations.

11.7.2.3

Owners/Operators should identify and designate those individuals (facility personnel, contractors, andcontract personnel under facility supervision) who are educated, trained, competent, and/or qualified toperform specific confined space–related duties, including, but not limited to, supervising operations, issuingpermits, entering into confined spaces, conducting atmospheric monitoring, providing rescue, performingAttendant duties, overseeing ventilation, and conducting hot or cold work operations within or associatedwith confined spaces. Owners/Operators should designate and identify the individuals and their duties inthe written confined space program in accordance with Chapter 12.

11.7.2.4

Owners/Operators should develop and implement a confined space program in accordance withChapter 12, which should be available for review by the employees and their authorized representatives.The confined space program applicable to the operations may be that of the Owner/Operator.

11.7.2.5

Prior to entry, Owners/Operators should conduct a confined space entry safety meeting in accordance withChapter 5 to ensure that assigned Entry Supervisors, Gas Testers, Entrants, Attendants, ventilation andIsolation Specialists, Rescuers, and workers are apprised of and understand the hazards associated withthe confined space activity.

11.7.2.6

If Owners/Operators arrange for a contractor to perform work that involves confined space entry, theOwners/Operators should ensure that the contractor is aware that entry into a confined space requirescompliance with an applicable confined space program.

11.7.2.7


101 of 282 2/22/2017 2:45 PM

of 297

Owners/Operators should ensure that any contractors/subcontractors are aware of precautions orprocedures that the host employer has implemented for the protection of employees in or near the confinedspace where the contractor/subcontractor personnel will be working.

11.7.2.7.1

Owners/Operators should coordinate entry operations with the contractor when both host employerpersonnel and contractor personnel will be working in or near confined spaces.

11.7.2.7.2

Owners/Operators should debrief contractors at the conclusion of entry operations regarding the confinedspace program that was followed and regarding any hazards confronted or created in confined spacesduring entry operations. Where the debriefing indicates a need to change program requirements,Owners/Operators and contractors should revise confined space programs accordingly.

11.7.2.7.3

Owners/Operators should coordinate activities between multiple employers (Owner/Operator, contractor,and subcontractor) working on the same job or on other nearby jobs that could affect the confined spaceoperations.

11.7.2.8

Owners/Operators should implement effective measures to prevent unauthorized personnel from enteringconfined spaces or impeding upon confined space operations.

11.7.2.9

If changes occur in the hazards, use, or configuration of a confined space or in nearby operations thataffect the confined space, Owners/Operators should ensure that Entry Supervisors cancel the entry and hotand cold work permits, Entrants leave the space, and operations are discontinued until the confined spaceis re-evaluated and, if necessary, reclassified.Owners/Operators should then ensure that Entry Supervisorsestablish revised entry criteria, if needed, and reissue permits or issue new permits for continuing work, ifapplicable.

11.7.2.10 *

Owners/Operators should provide required equipment appropriate for employee entry and work in andaround the confined space and ensure that it is properly inspected, tested, maintained, and used inaccordance with the confined space program and permit requirements.

11.7.2.11

Owners/Operators should identify, evaluate, qualify, and designate rescue services or facility Rescuers anddevelop and implement procedures for communicating with and summoning rescues and emergencyservices.

11.7.2.12

Owners/Operators should develop and implement procedures to review planned confined space operationsprior to entry when there is reason to believe that the requirement of the applicable confined space programmight not protect employees. The Owner/Operator should revise the program to correct identifieddeficiencies before entries are authorized.

11.7.2.13 *

Owners/Operators should review the confined space program annually, utilizing cancelled permits andother information, and revise the program accordingly to ensure continued protection from hazards duringentry operations.

11.7.2.14

Owners/Operators should consult with employees and their authorized representatives on the developmentand implementation of all aspects of the confined space program and make information available to allaffected employees and their authorized representatives.


102 of 282 2/22/2017 2:45 PM

of 297

11.7.2.15

Owners/Operators should provide training or education, as needed, regarding existing, new, and revisedprocedures and work practices so that all employees involved in confined space operations and activitiesacquire the understanding, knowledge, and proficiency necessary for the safe performance of assignedduties. Training or education should be provided as follows:

(1) Before the employee is first assigned to perform confined space related duties

(2) Whenever there is a change in assigned duties

(3) Whenever there is a change in confined space–related contents, configuration, use, or operations thatpresents a hazard

(4) Whenever the employer has reason to believe that there are deviations from the confined space entryprocedures, operations, or program requirements or that there are inadequacies in the employee’sknowledge of those procedures and requirements

11.7.2.16

Owners/Operators should certify that required training or education has been accomplished. Thecertification should contain the training or education provided, the employee’s name, the signatures orinitials of the trainers or educators, and the dates of training or education. Owners/Operators should providefor the certification to be available for inspection by employees, employees’ authorized representatives, orother authorized entities, including, but not limited to, regulatory inspectors and investigators.

11.7.3 Owner/Operator Qualifications.

11.7.3.1

Owners/Operators should be able to identify and classify confined spaces within their facility.

11.7.3.1.1

Where the Owners/Operators are absent parties, the requirement for identification and classification ofspaces may be designated, by contract or agreement, to another responsible entity. Such spaces include,but are not limited to, the following:

(1) Spaces within portion of a facility owned by, leased to, or controlled by another entity

(2) Spaces within an entire facility leased by or controlled by another entity

11.7.3.2

Owners/Operators should know and understand the regulatory requirements associated with confinedspace operations and ensure these are identified in the facility confined space program and properlyapplied by employees working in and around confined spaces.

11.7.3.3

Owners/Operators should develop and implement an appropriate confined space program.

11.7.3.4

Owners/Operators should train or educate, qualify, and designate employee personnel who are assigned toperform confined space operations.

11.7.3.5

Owners/Operators should be able to identify, evaluate, and select contractors, subcontractors, and rescueservices.

11.7.4 Demonstrated Competencies.

11.7.4.1

Owners/Operators should know and be able to communicate permit requirement to contractors and EntrySupervisors and be able to evaluate permits upon completion of operations to determine if any deficienciesin the facility confined space or permit programs need to be corrected.

11.7.4.2

Owners/Operators should be able to evaluate the need for, identify, and provide equipment required forconfined space operations.


103 of 282 2/22/2017 2:45 PM

of 297

11.7.4.3

Owners/Operators should provide a means of communication and be able to communicate with andcoordinate activities among facility personnel, contractors, and subcontractors associated with confinedspace operations.

11.7.4.4

Owners/Operators should understand the requirements and be able to assign tasks in accordance with theapplicable confined space and permit programs, employee qualifications, and operational requirements.

11.7.4.5

Owners/Operators should be able to recognize, evaluate and classify confined spaces in accordance withthe applicable confined space program and regulatory requirements.

11.8 Contractor/Subcontractor.

11.8.1 General.

Contractors are employers who perform work under contract to an Owner/Operator at the Owner/Operator’sconfined space work site. Contractors may employ subcontractors who perform work under contract to theprimary contractor.

11.8.2 Contractor and Subcontractor Duties and Responsibilities.

11.8.2.1

Contractors should identify and designate those individuals (either contractor personnel or subcontractors)who are educated, trained, competent, and/or qualified to perform specific confined space–related duties,including, but not limited to, supervising operations, issuing permits, entering into confined spaces,conducting atmospheric monitoring, providing for rescue, performing Attendant duties, overseeingventilation, and conducting hot or cold work operations. Contractors and subcontractors should designateand identify the individuals and their duties in the entry and work permits as required by applicableregulations, standards, and the written confined space program, in accordance with Chapter 12.

11.8.2.2

Contractors should participate in a pre-job safety meeting with the Owner/Operator to establishassignments and responsibilities associated with the confined space entry. Subcontractors should attendeither this meeting or a separate meeting conducted by the contractor.

11.8.2.3

Contractors and Owners/Operators should review the applicable confined space program and determinewhat is needed to conduct entry and work operations in compliance with program requirements. Theconfined space program applicable to the operations may be that of the Owner/Operator, the contractor, orboth.

11.8.2.4

If contractors do not agree to use the Owner/Operator’s confined space program, they should develop andimplement their own confined space program in accordance with regulatory requirements, industrystandards, applicable safe work practices and procedures, and Chapter 12 of this guide. The contractor’sconfined space program should not conflict with and may be used to supplement the Owner/Operator’sconfined space program.

11.8.2.5

Contractors should provide for the applicable confined space program to be available for inspection bycontractor, the subcontractor, and facility employees and their authorized representatives.

11.8.2.6 *

During pre-plan operations, contractors should review and evaluate the confined space to be entered,identify actual and potential hazards, and determine appropriate measures to be taken to eliminate, control,or mitigate the hazards.

11.8.2.7 *

When contractors/subcontractors perform work that involves confined space entry, they should be awarethat entry into a confined space requires compliance with an applicable confined space program. The samerequirements apply between a contractor and a subcontractor.


104 of 282 2/22/2017 2:45 PM

of 297

11.8.2.8

Contractors should make sure that they are aware of the hazards associated with the confined space andapprise subcontractors, as necessary, of such hazards.

11.8.2.9

Contractors/subcontractors should be aware of any precautions or procedures that the Owner/Operator hasimplemented for the protection of employees in or near the confined space where thecontractor’s/subcontractor’s personnel will be working.

11.8.2.10

Contractors and subcontractors should coordinate entry operations with each other and with theOwner/Operator when both Owner/Operator personnel and contractor personnel are working in or nearconfined spaces.

11.8.2.11

Contractors/subcontractors should implement effective measures to prevent personnel from enteringconfined spaces unless they are designated as Entrants.

11.8.2.12

If changes occur in the use or configuration within a confined space or external to the confined space thataffect the hazards, contractors/subcontractors should ensure that the entry permit is cancelled, Entrantsimmediately vacate the space, the confined space is re-evaluated and, as necessary, reclassified, and newor renewed permits are issued establishing revised entry criteria, as necessary.

11.8.2.13 *

Contractors/subcontractors should provide the required equipment and ensure that it is properly inspected,tested, maintained, and used in accordance with the confined space program and entry and work permitrequirements.

11.8.2.14

If rescue service is provided by the contractors/subcontractors, contractors should identify, evaluate, andqualify assigned Rescuers or rescue and emergency services and develop and implement procedures forsummoning Rescuers and emergency services.

11.8.2.15

Contractors/subcontractors should develop and implement procedures to review entry operations whenthere is reason to believe that the measures taken under the confined space program might not protectemployees. Contractors/subcontractors should revise their program to correct identified deficiencies beforesubsequent entries are authorized.

11.8.2.16 *

Contractors should review and evaluate their confined space programs annually, utilizing cancelled permitsand other information, and revise the programs to ensure continued protection from hazards during entryoperations. Contractors also should provide to Owners/Operators copies of permits they have issued for theOwners’/Operators’ review and evaluation.

11.8.2.17 *

Contractors should consult with and make information available to contractor employees and theirauthorized representatives regarding the development and implementation of all aspects of the contractors’confined space program. Contractors should ensure that the applicable confined space program is alsoavailable to subcontractor employees and their authorized representatives.

11.8.2.18

Contractors/subcontractors should provide training covering existing, new, and revised procedures andwork practices so that all contractor/subcontractor employees involved in confined space operations andactivities acquire the understanding, knowledge, and proficiency necessary for the safe performance ofassigned duties in accordance with confined space program and permit program requirements.


105 of 282 2/22/2017 2:45 PM

of 297

11.8.2.18.1

Contractors/subcontractors should ensure that employees are trained, educated, and/or qualified asfollows:

(1) Before the employee is first assigned duties associated with confined space operations


(3) Whenever there is a change in permit space classification, hazards, or operations that presents ahazard

(4) Whenever the contractors/subcontractors have reason to believe that employees are deviating fromthe confined space entry procedures, operations, or program requirements or that there areinadequacies in the employees’ knowledge and application of procedures and requirements

11.8.2.18.2

Contractors/subcontractors should certify that employee training, education, or qualification has beenaccomplished. The certification should contain the employee’s training, education, or qualifications; theemployee’s name; the signatures or initials of the trainers or qualifiers; and the dates of training, education,or qualification. The certification should be available for inspection by regulating agencies,Owners/Operators, and contractors/subcontractor employees or their authorized representatives, asapplicable.

11.8.2.19

After completion of the work, contractors should meet with subcontractors and with Owners/Operators toreview safety issues that occurred during the confined space operations.

11.8.2.19.1

Contractors/subcontractors should debrief Owners/Operators at the conclusion of the entry operationsregarding the confined space program followed and any hazards confronted or created in confined spacesduring entry operations.

11.8.3 Contractor/Subcontractor Qualifications.

11.8.3.1

Contractors/subcontractors should be able to recognize and understand confined space operations,including, but not limited to, hazard evaluation, entry, and work program and permit requirements.

11.8.3.2

Contractors/subcontractors should recognize and understand the existing and potential hazards that maybe encountered during entry into confined spaces and necessary controls and protective measures to betaken to prevent or mitigate hazards and exposure.

11.8.3.3

Contractors/subcontractors should know, understand, and comply with applicable regulatory requirements.

11.8.3.4

Contractors/subcontractors should be able to develop and implement an appropriate confined spaceprogram in compliance with the Owner/Operator program.

11.8.3.5

Contractors/subcontractors should designate trained, educated, and/or qualified personnel for confinedspace operations.

11.8.3.6

Contractors/subcontractors should be able to identify, evaluate, and select qualified subcontractors andrescue services.

11.8.4 Contractor/Subcontractor Demonstrated Competencies.

11.8.4.1

Contractors/subcontractors should be able to understand and safely conduct confined space entry andwork requirements and evaluate or issue permits accordingly.


106 of 282 2/22/2017 2:45 PM

of 297

11.8.4.2

Contractors/subcontractors should be able to evaluate equipment needs and then identify, select, inspect,maintain, and provide required equipment.

11.8.4.3

Contractors/subcontractors should provide for a means of communication and be able to coordinateactivities associated with confined space operations.

11.8.4.4

Contractors/subcontractors should be able to assign tasks in accordance with the confined space programand permit requirements applicable to the proposed operations.

11.8.4.5

Contractors/subcontractors should be able to predict, recognize, and understand hazards associated withthe specific space and operations.

11.8.4.6

Contractors/subcontractors should be able to evaluate, qualify, and select contractor personnel andsubcontractors. Subcontractors should be able to evaluate, qualify, and select subcontractor personnel.

11.9 Ventilation Specialist.

11.9.1 * General.

Ventilation Specialists should be familiar with, educated, trained, and/or qualified in the various methodsand requirements for removing hazardous and/or contaminated atmospheres from confined spaces.Ventilation Specialists might also perform other activities if they are competent or qualified and areassigned in accordance with the applicable confined space program and Chapter 9.

11.9.2 Ventilation Specialist Duties and Responsibilities.

11.9.2.1

Ventilation Specialists should be familiar with acceptable ventilation methods and procedures and ensurethat the specific procedures or methods to be used have been reviewed and approved in accordance withChapter 9.

11.9.2.2

At the confined space planning meeting or prior to permit issuance, Ventilation Specialists should reviewand understand the potential hazards associated with the use of ventilation methods, including dilution,inerting, and purging, in order to determine the appropriate method to be used to provide a safeatmosphere within the space for entry and work.

11.9.2.3 *

Ventilation Specialists should be aware of the hazards associated with infrequently used ventilationprocedures and the risks of using inert gases, pure oxygen, chemicals, or steam and that such use shouldbe approved by the Entry Supervisor and comply with applicable regulatory requirements and industrypractices.

11.9.2.4

Ventilation Specialists should ensure that if the exhausted atmosphere might be combustible or flammable,ignition sources in and around confined spaces have been eliminated or controlled prior to ventilation.

11.9.2.5

Ventilation Specialists should ensure that adequately sized openings are provided for both clean air intakeand contaminated atmosphere exhaust and that the air supply and exhaust points are separated as farapart as possible.

11.9.2.6

Ventilation Specialists should ensure that air introduced into a confined space is from a clean(uncontaminated) source.


107 of 282 2/22/2017 2:45 PM

of 297

11.9.2.7 *

Ventilation Specialists should ensure that the hazardous atmosphere is properly exhausted and does notenter or accumulate in unapproved areas. Hazardous atmospheres can also be captured and treated whererequired by the Owner/Operator or applicable regulations. Ventilation Specialists should ensure thatventilation is conducted in accordance with the applicable confined space program, permits, industrystandards, and regulatory requirements.

11.9.2.8

Ventilation Specialists should modify ventilation procedures or use appropriate alternatives as necessary tomaintain acceptable atmospheric exposure levels in accordance with permit requirements during entry orhot or cold work.

11.9.2.9

Ventilation Specialists should be familiar with potential atmospheric contaminants, including, but not limitedto, liquids, sludge and residue, vapors, gases, welding fumes, and dusts and with those areas withinconfined spaces where contaminants may collect, including, but not limited to, sumps, piping, underflooring, between walls, in high or low places (depending on the characteristics of the materials), and lessvisible or less accessible areas where contaminants are at risk of remaining following cleaning or otherroutine confined space activities. Where there is a need for a Ventilation Specialist to enter the confinedspace to determine the existence of any contaminants, he/she should have an entry permit and meet thesame requirements as and be qualified as an Entrant.

11.9.2.10 *

Ventilation Specialists should ensure that ventilation air streams do not compromise the accuracy ofcontinuous or periodic air test results.

11.9.2.11

Ventilation Specialists should provide ventilation in accordance with the entry permit and for as long asdeemed necessary by the Entry Supervisor, Gas Tester, or Entrants.

11.9.2.12

Ventilation Specialists should be able to coordinate and communicate ventilation and atmospheric testingactivities with the Gas Tester as directed by the Entry Supervisor.

11.9.3 Ventilation Specialist Qualifications.

11.9.3.1

Ventilation Specialists should be familiar with the confined space program and industry practices andgovernmental regulations that pertain to ventilation operations including, but not limited to, oxygen levels,flammable and toxic atmospheric levels, and required air changes per hour.

11.9.3.2

Ventilation Specialists should be familiar with the use, limitations and hazards of materials, substances, andequipment approved for use both inside and outside the specific confined space, including, but not limitedto, fans, eductors, tubing, hoses, vapor collection equipment, PPE, Gas Testers, inert gases, flue gas,steam, water, fuel oil, and chemicals.

11.9.3.3

Ventilation Specialists should know and understand the hazards inside and outside the specific confinedspace associated with ventilation operations.

11.9.3.4

Ventilation Specialists should know and understand the applicable confined space and permit program,industry practices, and regulatory requirements applicable to ventilation and be able to apply ventilationtechniques appropriate to the specific hazards and confined space.

11.9.4 Ventilation Specialist Demonstrated Competencies.

11.9.4.1

Ventilation Specialists should be able to read, understand, and communicate permit requirements to theEntry Supervisor.


108 of 282 2/22/2017 2:45 PM

of 297

11.9.4.2

Ventilation Specialists should be able to appropriately select, inspect, maintain, test, and use requiredventilation equipment and PPE.

11.9.4.3

Ventilation Specialists should be able to understand and identify, assess, interpret, and apply informationprovided by gas monitors in order to provide appropriate ventilation of the space.

11.9.4.4

Ventilation Specialists should be able to communicate and take appropriate action, including, but not limitedto, stopping or maintaining ventilation as directed by the Entry Supervisor when evacuation is required.

11.9.4.5

Ventilation Specialists should be able to complete assigned tasks in an approved manner in accordancewith the confined space program and permit requirements, the Entry Supervisor’s directions, facility andregulatory requirements, and industry practices.

11.9.4.6

Ventilation Specialists should understand the requirements for and be able to determine appropriateventilation flow rates in accordance with the entry permit and regulatory requirements.

11.10 Isolation Specialist.

11.10.1 * General.

Isolation is the process of removing a confined space from service and completely protecting the spacefrom the unwanted release of energy, liquids, gases, chemicals, and other materials into the space throughfixed or temporary connections to the space, as well as disconnecting and de-energizing potentiallyhazardous machinery and equipment within or attached to the space. Isolation may be permanent ortemporary. Isolation operations should be performed by Isolation Specialists who should be trained,educated, or qualified and competent to perform required isolation duties. Isolation Specialists should beassigned and authorized by the Owner/Operator or contractors, as appropriate, in accordance with therequirements of the applicable permits, isolation, or the lockout/tagout program and the confined spaceprogram. At the conclusion of confined space operations, Isolation Specialists should restore the space topre-isolation conditions.

11.10.2 Isolation Specialist Duties and Responsibilities.

11.10.2.1

Isolation Specialists should comply with the applicable lockout/tagout/isolation program and be authorizedby the Owners/Operators or contractors to operate, install, and apply the applicable energy control devicesor other isolation equipment, materials, and procedures.

11.10.2.2

Isolation Specialists should inspect and determine that equipment or devices to be used for isolation areapproved, in acceptable condition, and appropriate for the task prior to their use.

11.10.2.3

Isolation Specialists should notify authorized personnel, including, but not limited to, Owners/Operators,contractors, and Entry Supervisors, when the isolation control measures are either applied or removed asrequired by the applicable isolation program and permits.

11.10.2.4

Isolation Specialists should determine if stored energy is a potential issue and, if so, eliminate or control thehazard.

11.10.2.5

Isolation Specialists should know and be able to properly apply and sequence isolation and energy controlprocedures, both when isolating and when de-isolating the confined space.


109 of 282 2/22/2017 2:45 PM

of 297

11.10.2.6

Isolation Specialists should notify and verify to the Owner/Operator, contractor, or Entry Supervisor thatrelevant energy and other hazardous sources have been properly isolated prior to the issuance of permitsfor work in or around equipment or spaces that need to be isolated.

11.10.2.7

Isolation Specialists should develop an isolation checklist relevant to the confined space and ensure that itis available to Owners/Operators, contractors, and Entry Supervisors.

11.10.2.8

Isolation Specialists, as well as other authorized individuals, should use methods and procedures approvedby the applicable confined space or isolation program when temporarily removing lockout/tagout devices.

11.10.2.9

At the conclusion of the work, Isolation Specialists should take appropriate safeguards, using the isolationchecklist for verification purposes, when de-isolating the space in preparation for returning the space toservice.

11.10.3 Isolation Specialist Qualifications.

11.10.3.1

Isolation Specialists should understand and comply with the requirements of confined space, isolation(lockout/tagout) and permit programs, industry procedures and practices, and governmental regulationsthat pertain to isolation.

11.10.3.2

Isolation Specialists should know and be able to communicate to Owners/Operators and contractors theoperation, limitations, and hazards associated with the methods and materials, substances, and equipmentapproved for use for isolating the specific confined space.

11.10.3.3

Isolation Specialists should know and be able to communicate to Owners/Operators, contractors, and EntrySupervisors the hazards inside and outside the specific confined space associated with isolationoperations.

11.10.3.4

Isolation Specialists should know and be able to communicate to Owners/Operators, contractors, and EntrySupervisors the isolation techniques appropriate to the specific hazards and confined space, includingaccepted industry practices and procedures and applicable regulatory requirements.

11.10.3.5

Isolation Specialists should understand the application or operation of and be authorized to work with theapplicable energy control and other isolation equipment and devices and be able to comply with isolationprogram procedures and requirements.

11.10.4 Isolation Specialist Demonstrated Competencies.

11.10.4.1

Isolation Specialists should understand all applicable requirements of the confined space entry permits andwork permits.

11.10.4.2

Isolation Specialists should be able to identify and evaluate specific isolation needs associated with theconfined space entry and proposed work and be able to select approved equipment and methods requiredto properly isolate the space.

11.10.4.3

Isolation Specialists should be able to communicate with Owners/Operators, contractors, and EntrySupervisors as required and appropriate. Communication may take place during planning sessions orpre-entry safety meetings and should include reviewing and verifying the isolation checklist.


110 of 282 2/22/2017 2:45 PM

of 297

11.10.4.4

Isolation Specialists should be trained or educated and qualified to perform assigned tasks in an approvedmanner.

11.10.4.5

Isolation Specialists should have the knowledge and experience to understand isolation needs and be ableto select and apply appropriate, approved isolation devices, equipment, and methods in accordance withthe applicable isolation program and other requirements.

11.11 Standby Worker.

11.11.1 * General.

Standby Workers are individuals assigned to stay outside the confined space and conduct confined space–related operations, as assigned by the Entry Supervisor, that do not involve duties assigned specifically toEntrants, Gas Testers, Rescuers, supervisors, Attendants, Isolation Specialists, or Ventilation Specialists.Standby Workers may be assigned other duties, such as relief for Attendants, only if they are appropriatelytrained and qualified.

11.11.2 Standby Worker Duties and Responsibilities.

11.11.2.1

Standby Workers should have an understanding of the work required and the knowledge and skills toperform the work in a safe manner around the confined space area.

11.11.2.2

Standby Workers should be familiar with the hazards in and around the confined space and use appropriateprotective clothing and equipment as appropriate for assigned duties and exposures or as required by awork permit.

11.11.2.3

Standby Workers should receive direction from the confined space Entry Supervisor regarding tasks to beperformed.

11.11.2.4

Standby Workers assigned to monitor supplied air systems should not have any other duties that distractfrom the monitoring and should adhere to the guidelines given in 11.11.2.4.1 through 11.11.2.4.4.

11.11.2.4.1

Standby Workers should maintain air supply cylinders in a secured, upright position, properly switchcylinders as required to provide a constant air supply, and ensure that the cylinders are protected againstdamage. If cylinders are to be changed and a quick bypass to another cylinder is not available, the Entranton the air supply will vacate the space until the breathing air cylinder is changed.

11.11.2.4.2

Standby Workers should ensure that breathing air supply lines, hoses, and couplings are maintained in asafe, uninterrupted manner so as to not interfere with air supply and are not used for supplying anythingother than breathing air.

11.11.2.4.3

Standby Workers should ensure that the compressors and/or air pumps (used in lieu of cylinders) arelocated in an area where the intake air supply is suitable for breathing and is free of contaminants and thatif the intake air does become or has the potential to become contaminated, Attendants are immediatelynotified to have Entrants vacate the space, and Entry Supervisors are notified so they can cancel the entrypermit.

11.11.2.4.4

Standby Workers should immediately notify Attendants and the Entry Supervisor in the event of air supplyfailure, contamination, or disruption so that Entrants can be directed to switch to emergency bottled air andleave the space. Where Standby Workers also are assigned or acting as Attendants, they shouldcommunicate this information to the Entrants.


111 of 282 2/22/2017 2:45 PM

of 297

11.11.2.5

Standby Workers should have an understanding of the emergency response plans established by theOwner/Operator or contractor and know what to do during an emergency.

11.11.2.6

Standby Workers conducting cleaning, disposal, or hot and/or cold work operations in and around theconfined space should be able to perform these activities in accordance with the confined space programand issued permit requirements.

11.11.3 Standby Worker Qualifications.

11.11.3.1

Standby Workers should know and comply with the requirements of the specific confined space program;hot work program; applicable permits; Owner/Operator, contractor, and industry safe work practices; andprocedures and governmental regulations that pertain to work assignments.

11.11.3.2

Standby Workers should be able to communicate to the entry supervisor the use, limitations, and hazardsof materials, substances, and equipment approved for use in assigned duties.

11.11.3.3

Standby Workers should know and be able to communicate to the Entry Supervisor the hazards inside andoutside the specific confined space associated with Standby Workers’ assigned operations.

11.11.3.4

Standby Workers should know and be able to communicate to the Entry Supervisor the safe workprocedures and practices appropriate to the specific internal and external confined space hazards and theStandby Workers’ assigned duties.

11.11.4 Standby Worker Demonstrated Competencies.

11.11.4.1

Standby Workers should be able to read, understand and comply with the requirements of applicablepermits, including, but not limited to, permits covering entry, hot and cold work, and any other activityassigned to Standby Workers.

11.11.4.2

Standby Workers should be able to properly use required equipment.

11.11.4.3

Standby Workers should be able to communicate with all personnel engaged in confined space operations.

11.11.4.4

Standby Workers should be qualified and able to perform assigned tasks.

11.12 Training.

11.12.1 General.

All confined space personnel should be trained, educated, and/or qualified as required by the applicablewritten confined space program and regulatory requirements to include, but not limited to, the following:

(1) General and specific duties and responsibilities for assigned work

(2) Equipment, tools, PPE, respiratory protection, and monitoring instruments to be used for assignedwork

(3) Type of confined space to be entered, configuration, structure, obstruction, means of entry and exit,and materials or substances within, around, or introduced into the space

(4) Atmospheric, physical, and chemical (toxic) hazard awareness, including, but not limited to, theidentification, elimination, protection, and control measures applicable to the proposed entry and work

(5) Certification, registration, or licensing where required

(6) The physiological and psychological stresses associated with the specific tasks


112 of 282 2/22/2017 2:45 PM

of 297

11.12.1.1

Sources of training or education include, but are not limited to, the following:

(1) On-the-job (apprentice) training or experience

(2) Company sponsored training or education (internal or external)

(3) Job-required regulatory training or education, including, but not limited to, respiratory protection, hotwork, and lockout/tagout, as applicable to duties and assignments

(4) Government, regulatory, private, and labor organization training or education programs, such as NFPAEntry Supervisor Training Program and OSHA on-line courses

11.12.1.2 Retraining.

11.12.1.2.1

All confined space personnel should be retrained, re-educated, or requalified as required by the confinedspace program or regulations.

11.12.1.2.2

All confined space personnel should be retrained, re-educated, or requalified when new duties andresponsibilities are assigned.

11.12.1.2.3

All confined space personnel should be retrained, re-educated, or requalified when new equipment, typesof space, or materials are introduced.

11.12.1.2.4

All confined space personnel should be retrained, re-educated, or requalified when work deficiencies areobserved.

11.12.1.2.5

All confined space personnel should be retrained, re-educated, or requalified when certification requiresrenewal.

11.12.1.2.6

All confined space personnel should be retrained, re-educated, or requalified when regulatory requirementschange or the confined space program is revised.

11.12.1.2.7

All confined space personnel should be retrained, re-educated, or requalified in the proper use of tools andequipment, including, but not limited to, PPE, respiratory protection, and monitoring instruments, accordingto the manufacturers’ recommendations and industry practices, whenever new tools or equipment areintroduced or when changes occur in existing tools or equipment.


Renumbered sections to follow the previous edits




Street Address:

City:

State:

Zip:



113 of 282 2/22/2017 2:45 PM

of 297

Public Input No. 173-NFPA 350-2017 [ Chapter 11 [Title Only] ]

Confined Space Personnel Duties, Responsibilities, Qualifications, and Competencies


Committee edit: Qualifications is a large component of this chapter.




Street Address:

City:

State:

Zip:



114 of 282 2/22/2017 2:45 PM

of 297


11.1 * General.

All persons engaged in confined space activities and operations should be competent and qualified. Thereare numerous entities that may be involved, individually or working together, in confined space entry andrelated activities. These include, but are not limited to, Owners/Operators, contractors/subcontractors,facility personnel, rescue services, and visitors, as well as other persons and operations both within andoutside of the confined space. This chapter covers the duties, responsibilities, qualifications, andcompetencies of these individuals as related to confined space activities. This chapter lists requirements forall persons and tasks that might be required for entry. It is important to recognize that there are at leastthree key positions required for a basic confined a confined space entry that requires permitting: the EntrySupervisor, the entry Attendant, and the Entrant. In addition to these three positions, rescue should beprovided as outlined in Chapter 10. In many applications one or more of these persons (often the EntrySupervisor) can handle other tasks addressed in this chapter, including, but not limited to, atmospherictesting, issuing permits, conducting ventilation, and providing standby services.


Committee edit: there isn't a definition for a basic entry. Added space between 2 words.The word "entry" before attendant is redundant and not used elsewhere.




Street Address:

City:

State:

Zip:



115 of 282 2/22/2017 2:45 PM

of 297


11.2 Entrants.

11.2.1 General.

11.2.1.1

Entrants should be competent, qualified, and authorized to enter and work within confined spaces.

11.2.1.2

As defined in the applicable confined space program, entry occurs when any part of the Entrant’s bodybreaks the plane of a confined space opening.

11.2.2 Entrant Duties and Responsibilities.

11.2.2.1

Entrants should enter the confined space only when designated by their employer and authorized by theEntry Supervisor and after a confined space pre-entry evaluation has been performed and a permit issuedif necessary.

11.2.2.1.1

Each Entrant should verify in writing, where required, that his or her name is listed on the entry permitwhere required .

11.2.2.1.2

Entrants should be aware of the hazards that might be encountered during entry, including the confinedspace hazards and controls noted on the permit.

11.2.2.2

Entrants should conduct assigned work following approved procedures that minimize hazards.

11.2.2.3

Entrants should demonstrate the proper use of approved equipment, materials, tools, and personalprotective equipment (PPE) identified in the permit to the Entry Supervisor.

11.2.2.4

Entrants should remain aware of potential atmospheric and nonatmospheric hazards that might beencountered during confined space entry.

11.2.2.4.1

Entrants should exit the confined space when changing conditions result in hazards that causeunacceptable risks.

11.2.2.4.2

Entrants should immediately exit the space if the entry permit expires or is cancelled.

11.2.2.4.3

Entrants should immediately exit the space when directed by the Attendant or the Entry Supervisor orduring any emergency occurring elsewhere in the vicinity that requires evacuation.

11.2.2.5

Entrants should understand and be able to communicate the hazards inside and outside the confinedspace that may be encountered during entry, including information on the mode, signs or symptoms, andconsequences of exposure and act accordingly depending on the situation.

11.2.2.5.1

Entrants should immediately notify the Attendant of any symptoms of exposure, an emergency, orunacceptable conditions.


116 of 282 2/22/2017 2:45 PM

of 297

11.2.2.5.2

Entrants should exit the confined space immediately if symptoms, warning signs, or unacceptableconditions occur.

11.2.2.6

Entrants should react to emergencies as trained and directed, including, but not limited to, self-rescue orevacuation of the confined space.

11.2.2.7

Entrants may also perform other activities and assigned duties if qualified in accordance with the applicableconfined space program, including, but not limited to, self-rescue, monitoring, hot and cold work inside thespace, and performing non-entry tasks.

11.2.3 Entrant Qualifications.

11.2.3.1

An Entrant should understand and comply with applicable governmental regulations that pertain to theplanned confined space entry and work as explained by the entry supervisor or included in the entry permit.

11.2.3.2

An Entrant should understand and be able to communicate to the Entry Supervisor the use, limitations, andhazards of materials, substances, and equipment approved for use within the specific confined space (e.g.,tools, PPE, energy isolation devices, gas monitors, and chemicals) before entry.

11.2.3.3

An Entrant should understand and be able to communicate to the Entry Supervisor before entry the primaryand secondary means of communication to be used during emergencies.

11.2.3.4

An Entrant should understand and be able to communicate to the Entry Supervisor before entry how tointerpret and respond to gas monitor displays and alarms.

11.2.3.5

An Entrant should understand and be able to communicate to the Entry Supervisor before entry all sectionsof the confined space entry permit that are applicable to the Entrant’s duties.

11.2.3.6

An Entrant should understand and be able to communicate to the Entry Supervisor before entry personalwarning signs and overexposure symptoms, including actions that must be taken in the event of exposure.

11.2.3.7

An Entrant should understand and be able to verbally explain to the Entry Supervisor before entryapplicable emergency procedures to be taken within or around the confined space.

11.2.4 Entrant Demonstrated Competencies.

11.2.4.1


11.2.4.2

An Entrant should be able to demonstrate the proper use of required assigned equipment, tools, andmaterials, including, but not limited to PPE, respiratory protection, non-entry rescue devices, instruments,and cleaning and decontamination materials.

11.2.4.3

An Entrant should be able to communicate when evacuation is desired.

11.2.4.4

An Entrant should be able to complete assigned tasks in an approved manner.



117 of 282 2/22/2017 2:45 PM

of 297

Committee edit: wording was awkward and not clear.



Organization: Army Corp Engrs Little Rock

Street Address:

City:

State:

Zip:



118 of 282 2/22/2017 2:45 PM

of 297


11.2.2.1.1

Each Entrant should verify in writing, where required, that verify that his or her name is listed on the entrypermit, where required .


The "verify in writing" indicates that the entrant needs to sign it. The other wording is from the Attendant Duties section.




Street Address:

City:

State:

Zip:



119 of 282 2/22/2017 2:45 PM

of 297


11.2.2.2

Entrants should conduct assigned work following approved procedures that emphasize safety andminimize hazards.


provides an important qualifier




Street Address:

City:

State:

Zip:



120 of 282 2/22/2017 2:45 PM

of 297


11.2.2.4.1

Entrants should exit the confined space when changing conditions result in hazards that causeunacceptable risks or exceed the permit requirements .


adds another important reason to stop work




Street Address:

City:

State:

Zip:



121 of 282 2/22/2017 2:45 PM

of 297


11.2.2.5.1 or indications

Entrants should immediately notify the Attendant of any symptoms of exposure, warning signs orindications of illness, an emergency, or unacceptable conditions occuring while working in the confinedspace .


qualifies where these occur. combines with 11.2.5.5.2 which is then not needed




Street Address:

City:

State:

Zip:



122 of 282 2/22/2017 2:45 PM

of 297


delete and renumber see proposed ch ang e to 11. 2 5 .2. 5. 2 Entrants should exit the confined spaceimmediately if symptoms, warning signs, or unacceptable conditions occur. .1


basically same as previous item




Street Address:

City:

State:

Zip:



123 of 282 2/22/2017 2:45 PM

of 297


11.2.2.7

Entrants may also perform other activities and assigned duties if qualified in accordance with the applicableconfined space program, including, but not limited to, self-rescue, atmospheric monitoring, hot and coldwork inside the space, and performing non-entry tasks.


qualifies type of monitoring




Street Address:

City:

State:

Zip:



124 of 282 2/22/2017 2:45 PM

of 297


11.2.3.1

An Entrant should understand and comply with applicable governmental regulations that pertain to theplanned confined space entry and work as explained by the entry supervisor Entry Supervisor or includedin the entry permit.


Consistency - capitalize job titles




Street Address:

City:

State:

Zip:



125 of 282 2/22/2017 2:45 PM

of 297


11.2.3.3

An Entrant should understand and be able to communicate to the Entry Supervisor before entry the primaryand secondary means of communication to be used during emergencies while working in the confinedspace and in the event of emergencies .


provides for communication while working




Street Address:

City:

State:

Zip:



126 of 282 2/22/2017 2:45 PM

of 297


11.2.4.1



Committee edit: illiteracy in English language should not be a requirement for some roles and not others. Likewise, if directions are understood and followed, the ability to read English is not necessary. Nor is it a regulatory requirement.




Street Address:

City:

State:

Zip:



127 of 282 2/22/2017 2:45 PM

of 297


11.3.1.2

Attendants should be stationed outside confined spaces but in close proximity to the entry so that Entrantsconstant communication or visual observation can be observed maintained with Entrants .


Committee edit: previous wording indicated that other forms of communication are not permitted. Also, some spaces are configured so that visual observation is not possible from outside of the space (e.g., baffles in a ship's fuel tank). Other options have be made available.




Street Address:

City:

State:

Zip:



128 of 282 2/22/2017 2:45 PM

of 297

Public Input No. 179-NFPA 350-2017 [ Section No. 11.3.2.1 [Excluding any

Sub-Sections] ]

Attendants should understand and be able to communicate to the Entry Supervisor the hazards inside andoutside the specific confined space that might occur during entry, including information on the modes, signsor symptoms, and consequences of exposure to Entrants.


Committee edit: The term "understand" indicates that this is a competency when it's a duty.




Street Address:

City:

State:

Zip:



129 of 282 2/22/2017 2:45 PM

of 297


11.3.2. 1.1 2

Each Attendant should verify that his or her name is listed on the entry permit. This may require initialing orsignature, as required by the Entry Supervisor.


This paragraph does not fit under 11.3.2.1




Street Address:

City:

State:

Zip:



130 of 282 2/22/2017 2:45 PM

of 297


11.3.2.1.1

Each Attendant should verify that his or her name is listed on the entry permit. This may require initialing orsignature, as required by the Entry Supervisor, the applicable confined space program or by regulations .


adds additional reasons for signing in




Street Address:

City:

State:

Zip:



131 of 282 2/22/2017 2:45 PM

of 297


11.3.2. 1.2 3

Attendants should be constantly observing, monitoring, and evaluating the conditions in and around theconfined space to ensure that compliance with the requirements of the permit are maintained throughoutthe entry.


Section is not a subsection of 11.3.2.1




Street Address:

City:

State:

Zip:



132 of 282 2/22/2017 2:45 PM

of 297


11.3.2. 1.3 4

Attendants should monitor adjacent areas outside the confined space for changing conditions that mightaffect safe entry work or activities.


This is not a subsection of 11.3.2.1




Street Address:

City:

State:

Zip:



133 of 282 2/22/2017 2:45 PM

of 297


11.3.2. 2 5

Attendants should remain outside the confined space opening during entry operations until relieved byanother assigned Attendant.

11.3.2. 2 5 .1

Attendants should inform the replacement Attendant of current confined space and Entrant status.

11.3.2. 2 5 .2

The replacement Attendant’s name should be listed on the entry permit and acknowledged by replacementAttendant’s initials or signature, as required by the applicable confined space program.


Formatting of numbers




Street Address:

City:

State:

Zip:



134 of 282 2/22/2017 2:45 PM

of 297

Public Input No. 87-NFPA 350-2016 [ Section No. 11.3.2.2 [Excluding any Sub-Sections]

]

Attendants should remain outside the confined space opening during entry operations and perform theirassigned duties until relieved by another assigned Attendant.


important to performed assigned duties




Street Address:

City:

State:

Zip:



135 of 282 2/22/2017 2:45 PM

of 297


11.3.2.2.1

Attendants should inform the replacement Attendant of current confined space permit requirements andany deviations and the Entrant status.


adds additional requirements




Street Address:

City:

State:

Zip:



136 of 282 2/22/2017 2:45 PM

of 297


11.3.2. 3 6

Attendants should monitor Entrants Entrant's status and direct Entrant evacuation as needed.


Format of number to follow the other revisions and correction of grammar - it's a possessive.




Street Address:

City:

State:

Zip:



137 of 282 2/22/2017 2:45 PM

of 297


11.3.2. 4 7

Attendants should continuously maintain an accurate count of Entrants in the confined space.


Reformat numbers




Street Address:

City:

State:

Zip:



138 of 282 2/22/2017 2:45 PM

of 297


11.3.2. 5 8


(1) Warn nonauthorized unauthorized personnel not to enter into the confined space

(2) Inform Entrants and Entry Supervisors when nonauthorized unauthorized personnel enter or attemptto enter the confined space

(3) Prevent nonauthorized unauthorized personnel from interfering with Attendant duties


Format number. Use consistent term -unauthorized and not nonauthorized




Street Address:

City:

State:

Zip:



139 of 282 2/22/2017 2:45 PM

of 297


11.3.2.5


(1) Warn nonauthorized personnel not to enter into the confined space

(2) Inform Entrants and Entry Supervisors when nonauthorized personnel enter or attempt to enter theconfined space

(3) Prevent nonauthorized personnel from interfering with Attendant or other personnel duties or anyconfined space activities


adds additional reasons to stop unauthorized persons




Street Address:

City:

State:

Zip:



140 of 282 2/22/2017 2:45 PM

of 297

Public Input No. 188-NFPA 350-2017 [ Sections 11.3.2.6, 11.3.2.7, 11.3.2.8 ]

Sections 11.3.2.6, 11.3.2.7, 11.3.2.8

11.3.2. 6 9

Attendants should summon rescue and other emergency services immediately upon recognizing anEntrant’s distress inside the confined space.

11.3.2. 7 10 *

Attendants should perform non-entry rescue as trained and equipped.

11.3.2. 8 11 *

Attendants may perform other approved assigned duties that do not interfere with the primary duty tomonitor and protect the Entrants. Attendants may also perform other assigned duties, if competent andqualified, in accordance with the applicable confined space program, including, but not limited to, testingexternal atmosphere, summoning Rescuers, and performing non-entry rescue performing atmosphericmonitoring .


Reformat numbers.Last bullet was redundant with first two so it was simplified. It also addresses the possibility that the Attendant will perform air monitoring (from outside the space) as knowing how to do air monitoring is a qualification.




Street Address:

City:

State:

Zip:



141 of 282 2/22/2017 2:45 PM

of 297


11.3.3.1

Attendants should be competent, qualified, and authorized in accordance with the applicable confinedspace program and understand and comply with applicable governmental regulations that pertain to theplanned confined space entry and work as explained by the Entry Supervisor or included in the entrypermit .


Current paragraph is a near duplicate of earlier para. 11.3.1.1. I changed it to match what committee has for first para. under the Entrant Quals in order to mirror sections better.




Street Address:

City:

State:

Zip:



142 of 282 2/22/2017 2:45 PM

of 297


11.3.3.2

An Attendant Attendants should be competent and qualified to operate and understand the assignedatmospheric monitor and to be capable of recording readings as required.


Making this more parallel with other paragraphs in section where they start with "Attendants should"...




Street Address:

City:

State:

Zip:



143 of 282 2/22/2017 2:45 PM

of 297


11.3.4.1

Attendants should be able to read, understand , and communicate permit requirements to the EntrySupervisor if applicable .


Committee edit: Reads oddly at end when it says attendants should be able to … communicate permit requirements to the Entry Supervisor if applicable. Does this mean that there are times when there isn't an Entry Supv or does it intend on saying that there may not be a permit. Either way, Attendant needs to be able to understand and communicate entry requirements even if there isn't a permit.




Street Address:

City:

State:

Zip:



144 of 282 2/22/2017 2:45 PM

of 297


11.3.4.5

Attendants should be able to recognize Entrant signs and symptoms related to hazardous or toxic chemicalexposures and oxygen deficiency and take appropriate action required to assist Entrant self-evacuation orwith Entrant rescue.


Shorten and clarify




Street Address:

City:

State:

Zip:



145 of 282 2/22/2017 2:45 PM

of 297


11.4.1.1

Entry Supervisors should be qualified and competent to oversee and direct confined space entry andassociated operations in accordance with applicable regulations, entry and work permits, facility operatingpractices, and appropriate confined space program requirements and other programs and procedures,including but not limited to isolation, ventilation and inerting, hot work and respiratory protection asapplicable to the specific entry . .


entry supervisors need knowledge of a broad range of programs and procedures applicable to confined space entry.




Street Address:

City:

State:

Zip:



146 of 282 2/22/2017 2:45 PM

of 297


11.4.1.2 *

Entry Supervisors can also be designated on the permit(s) as Attendants, Gas Testers, VentilationSpecialists, Isolation Specialists, and Entrants in accordance with the applicable confined space program .Entry Supervisors should be trained provided tht they are trained and/or qualified in accordance with therespective requirements provided in this chapter for alternative activities.


as written states entry supervisors should be trained in all. as changed, only requires they be trained in those activities they will be doing




Street Address:

City:

State:

Zip:



147 of 282 2/22/2017 2:45 PM

of 297


11.4.2.1.1

Entry Supervisors should be able to determine the requirements and implement procedures to identify andthen eliminate, control, or mitigate hazards.


Wording sounds like a competency versus a duty.




Street Address:

City:

State:

Zip:



148 of 282 2/22/2017 2:45 PM

of 297


11.4.2.1.2

Entry Supervisors should be identified and should sign or initial permits to document acceptance ofresponsibility . as required by the applicable confined space and other programs or by regulations


qualifies why need to sign (same as for other personnel in Chap 11)




Street Address:

City:

State:

Zip:



149 of 282 2/22/2017 2:45 PM

of 297


11.4.2.1.3

Where required by the applicable confined space program or regulations, the assigned Entry Supervisorshould remain at the confined space work site to control operations unless relieved by another competent,qualified, and authorized Entry Supervisor. The relieving Entry Supervisor should initial or sign the permit(s)to document the change of responsibility if applicable .


Recommend removing language as all actions are only as applicable and because the previous text stated that supervisors should sign the permit. Therefore, a change in supervisor should require a new signature.




Street Address:

City:

State:

Zip:



150 of 282 2/22/2017 2:45 PM

of 297

Public Input No. 205-NFPA 350-2017 [ Sections 11.4.2.1.3, 11.4.2.1.4, 11.4.2.1.5,

11.4.2.1.6, 11... ]

Sections 11.4.2.1.3, 11.4.2.1.4, 11.4.2.1.5, 11.4.2.1.6, 11.4.2.1.7

11.4.2. 1.3 2

Where required by the applicable confined space program or regulations, the assigned Entry Supervisorshould remain at the confined space work site to control operations unless relieved by another competent,qualified, and authorized Entry Supervisor. The relieving Entry Supervisor should initial or sign the permit(s)to document the change of responsibility if applicable.

11.4.2. 1.4 3

Entry Supervisors should ensure that personnel involved with the confined space operations are informedwhen another person assumes the Entry Supervisor role.

11.4.2. 1.5 4

Entry Supervisors should be trained and qualified as an Entrant if duties require entry into confined spaces.

11.4.2. 1.6 5

Entry Supervisors should be trained and qualified as Gas Testers if duties require maintaining, testing, andoperating gas monitors, including interpreting and analyzing test results.

11.4.2. 1.7 6

Entry Supervisors should be trained and qualified as Ventilation Specialists if duties require ventilation ofthe space. Entry Supervisors should be knowledgeable of the requirements for ventilation to ensure that theproper method is used for the hazards present, the confined space configuration, and the work to be done.


These are not subparagraphs of 11.4.2.1.




Street Address:

City:

State:

Zip:



151 of 282 2/22/2017 2:45 PM

of 297


11.4.2.4.3

Entry Supervisors should cancel and reissue the permit with the new entry and control requirements if theconfined space is reclassified conditions change .


350 does not use the term reclassify as noted at beginning of the document.




Street Address:

City:

State:

Zip:



152 of 282 2/22/2017 2:45 PM

of 297


11.4.2.4.3

Entry Supervisors should cancel and reissue the permit with the new entry and control requirements if theconfined space is reclassified or if conditions change .


conditions could change requiring reissuance without reclassification




Street Address:

City:

State:

Zip:



153 of 282 2/22/2017 2:45 PM

of 297


11.4.2.6

Entry Supervisors should determine that acceptable entry conditions are met and that they remainconsistent with requirements of the entry permit, including whenever changes occur inside or outside theconfined space. If such changes affect the permit requirements, the entry supervisoe shoud cancel thepermit, determine new requirements and reissiue the perrnit oce the new requirements are met.


adds what to do after changes occur




Street Address:

City:

State:

Zip:



154 of 282 2/22/2017 2:45 PM

of 297


11.4.2.9

Entry Supervisors should ensure that access to confined spaces is barricaded or prohibited when work isnot in progress and there are no Attendants present. Access should Entry should also be prohibited by notissuing or cancelling entry permits if required emergency response is not available.


provides clarification and adds specific requirements when emergence response not available




Street Address:

City:

State:

Zip:



155 of 282 2/22/2017 2:45 PM

of 297


11.4.3.1 *

Entry Supervisors should be certified as a confined space entry (safety) supervisor where certification isavailable , and required or applicable .


Grammar and removal of extra word. All of these statements are only as applicable.




Street Address:

City:

State:

Zip:



156 of 282 2/22/2017 2:45 PM

of 297


11.4.4 Entry Supervisor Demonstrated Competencies.

11.4.4.1

Entry Supervisors should be able to identify, recognize, and assess hazards associated with the specificconfined space and operations and the methods to be used for elimination, mitigation or control of suchhazards in accordance with Chapters 6, 7, and 8.

11.4.4.2


11.4.4.3

Entry Supervisors should know the requirements applicable to the specific space and work to be done andbe able to prepare, issue, and understand permits.

11.4.4.4

Entry Supervisors should know the available communications methods and equipment and be able tocommunicate with all personnel, including facility and emergency responders, as required.

11.4.4.5

Entry Supervisors should be able to perform their assigned tasks in a competent and approved manner andensure that personnel for whom they are responsible do the same.


To make the header consistent with other headers.




Street Address:

City:

State:

Zip:



157 of 282 2/22/2017 2:45 PM

of 297


11.4.4.2



This sentence combined a qual and competency. Committee recommended verifying the information for each role is in the correct section.




Street Address:

City:

State:

Zip:



158 of 282 2/22/2017 2:45 PM

of 297


11.4.4.3

Entry Supervisors should know be able to prepare and issue permits using the requirements applicable tofor the specific space and work to be done and be able to prepare, issue, and understandpermits performed .


This sentence combined quals and competencies together. Committee recommended we separate them out.




Street Address:

City:

State:

Zip:



159 of 282 2/22/2017 2:45 PM

of 297


11.4.4.4

Entry Supervisors should know the available communications methods and equipment and be able tocommunicate with all personnel, including facility and emergency responders, as required using availablecommunication methods and equipment .


This sentence combined quals and competencies. Committee recommended we separate them out.




Street Address:

City:

State:

Zip:



160 of 282 2/22/2017 2:45 PM

of 297


11.6.2.2

Gas Testers should inspect, calibrate, bump test, and/or adjust gas monitors prior to use in accordancewith manufacturer's instructions .


Committee Edit: committee recommended we state that meters should be used in accordance with manufacturer's instructions.Added "bump' to be consistent with 11.6.4.2




Street Address:

City:

State:

Zip:



161 of 282 2/22/2017 2:45 PM

of 297


11.6.2.2

Gas Testers should inspect, calibrate, test, and adjust gas monitors in accordance with manufacturer'sinstructions prior to use.


Committee edit to ensure that manuf. instructions are used.




Street Address:

City:

State:

Zip:



162 of 282 2/22/2017 2:45 PM

of 297

Public Input No. 96-NFPA 350-2016 [ Section No. 11.6.2.3 [Excluding any Sub-Sections]

]

Gas Testers should first test, sample, and monitor the atmosphere around the outside of the confined spaceprior to entry and then test the atmosphere within the space from the outside (without bodily entry) throughan opening, using a probe or similar equipment prior to entering the space for additional monitoring .


adds a needed qualifier and warning




Street Address:

City:

State:

Zip:

Submittal Date: Fri Dec 30 13:13:46 EST 2016


163 of 282 2/22/2017 2:45 PM

of 297


11.6.2.3.1

A Gas Tester should verify that his or her name is listed on the entry permit as tester if applicable .


All of the text is only as applicable. Furthermore, this was not clear as what was applicable - the permit or the need to perform testing.




Street Address:

City:

State:

Zip:



164 of 282 2/22/2017 2:45 PM

of 297

Public Input No. 198-NFPA 350-2017 [ Sections 11.6.2.3.1, 11.6.2.3.2 ]

Sections 11.6.2.3.1, 11.6.2.3.2

11.6.2. 3.1 4

A Gas Tester should verify that his or her name is listed on the entry permit as tester if applicable .

11.6.2. 3.2 5

Gas Testers should be qualified as Entrants and be aware of all confined space hazards, entryrequirements, PPE, and other controls prior to entry for testing.


Committee edits: the two subparagraphs are not subparagraphs to 11.6.2.3 and should stand alone.The "if applicable' language is not clear. Committee recommended removal.




Street Address:

City:

State:

Zip:



165 of 282 2/22/2017 2:45 PM

of 297

Public Input No. 209-NFPA 350-2017 [ Sections 11.6.2.4, 11.6.2.5, 11.6.2.6, 11.6.2.7 ]

Sections 11.6.2.4, 11.6.2.5, 11.6.2.6, 11.6.2.7

11.6.2. 4 6

Gas Testers should sample, analyze, interpret, and monitor the atmosphere inside the confined space inthe following order:

(1) Oxygen levels

(2) Flammable gases and vapors

(3) Toxic/hazardous atmospheric contaminants

11.6.2. 5 7

Gas Testers should record test results on the permit and verify by signing the permit, indicating the time(s)and the result(s) of the testing, if applicable .

11.6.2. 6 8

Gas Testers should allow Entry Supervisors, Attendants, Entrants, and workers (or their authorizedrepresentatives) to observe the monitoring process and the results.

11.6.2. 7 9

Gas Testers should re-evaluate conditions by testing, sampling, and monitoring the atmosphere botharound and inside the confined space as often as necessary as determined by the Entry Supervisor.


Reformatted numbers to match earlier changes. Removed "if applicable" as it's unclear and unnecessary.




Street Address:

City:

State:

Zip:



166 of 282 2/22/2017 2:45 PM

of 297


11.6.2.7

Gas Testers should re-evaluate conditions by testing, sampling, and monitoring the atmosphere botharound and inside the confined space as often as necessary as determined by the Entry Supervisor and asindicated on the entry permit .


the entry supervisors indicate the parameters on the entry permit




Street Address:

City:

State:

Zip:



167 of 282 2/22/2017 2:45 PM

of 297


11.6.3.1

Gas Testers should be familiar with and be able to apply the confined space program and entry permitrequirements and governmental regulations that covering atmospheric monitoring that pertain to theplanned confined space work.


no need to be familiar with other regulations that those needed to conduct testing




Street Address:

City:

State:

Zip:



168 of 282 2/22/2017 2:45 PM

of 297


11.6.3.3

Gas Testers should understand and be able to communicate to the Entry Supervisor how to assess,interpret, and apply material safety data sheet information and limitations pertinent to the hazardsassociated with the confined space and surrounding area and operations.


updated term to match new OSHA Hazcom GHS stnd




Street Address:

City:

State:

Zip:



169 of 282 2/22/2017 2:45 PM

of 297


11.6.3.5

Gas Testers should be trained and trained to meet the qualifications for an Entrant in order to test withinconfined spaces.


Committee edit - grammatical.




Street Address:

City:

State:

Zip:



170 of 282 2/22/2017 2:45 PM

of 297


11.6.3.6

Gas Testers should know how to determine, select, and use required and approved PPE and respiratoryprotection based on hazards associated with the confined space operations in accordance with theconfined space permit.


Committee edit- the PPE selection is not always selected by the gas tester. The supervisor is responsible.




Street Address:

City:

State:

Zip:



171 of 282 2/22/2017 2:45 PM

of 297


11.6.4.2

Gas Testers should be able to select, inspect, adjust, calibrate, bump test, and properly use required gasmonitors in accordance with manufacturer's instructions .


Committee wanted to add the language "in accordance with manufacturer's instructions" to 11.6.2.2 - this is to make that language consistent.




Street Address:

City:

State:

Zip:



172 of 282 2/22/2017 2:45 PM

of 297


11.6.4.4

Gas Testers should be able to compare results with recognized and applicable government, industry, andcompany occupational exposure limits to determine the degree of hazard that is present in the space forassess the risk to safe entry with and work with or without PPE without control measures in place .


Committee edit to clarify confusing language.




Street Address:

City:

State:

Zip:



173 of 282 2/22/2017 2:45 PM

of 297


11.7.2.1

Owners/Operators should evaluate and re-evaluate confined spaces and identify and designate spaces inorder to identify those that should be classified as confined spaces in accordance with Chapter 4. Thisresponsibility may be delegated by the owner when the space is under the control of a third party [such aswhen a building or portion thereof (a space) is leased or contracted to a third party] and theOwner/Operator has no obligation to the building, the space, or the operations therein.


Committee edit: language was confusing; streamlined it.




Street Address:

City:

State:

Zip:



174 of 282 2/22/2017 2:45 PM

of 297


11.7.2.3 *

Owners/Operators should identify and designate those individuals (facility personnel, contractors, andcontract personnel under facility supervision) who are educated, trained, competent, and/or qualified toperform specific confined space–related duties, including, but not limited to, supervising operations, issuingpermits, entering into confined spaces, conducting atmospheric monitoring, providing rescue, performingAttendant duties, overseeing ventilation, and conducting hot or cold work operations within or associatedwith confined spaces. Owners/Operators should designate and identify the individuals and their duties inthe written confined space program in accordance with Chapter 12.


Taking information that was misplaced in 11.7.3.4 (it is a responsibility and not a qual) and adding as an appendix item to this paragraph. Information will be "O/O should train or educate, qualify, and designate employee personnel who are assigned to perform confined space operations."




Street Address:

City:

State:

Zip:



175 of 282 2/22/2017 2:45 PM

of 297


11.7.2.3

Owners/Operators should identify and designate those individuals (facility personnel, contractors, andcontract personnel under facility supervision) who are educated, trained, competent, and /or qualified toperform specific confined space–related duties, including, but not limited to, supervising operations, issuingpermits, entering into confined spaces, conducting atmospheric monitoring, providing rescue, performingAttendant duties, overseeing ventilation, and conducting hot or cold work operations within or associatedwith confined spaces. Owners/Operators should designate and identify the individuals and their duties inthe written confined space program in accordance with Chapter 12.


Removed "or" as it made the sentence inconsistent.




Street Address:

City:

State:

Zip:



176 of 282 2/22/2017 2:45 PM

of 297


11.7.2.4

Owners/Operators should develop and implement a confined space program in accordance withChapter 12, which should be available for review by the employees and their authorized representatives.The confined space program applicable to the operations may be that of the Owner/Operator, the EntrantEmployer or both . .


see 11.8..3, 4 & 5 The guide provides for this in many places




Street Address:

City:

State:

Zip:



177 of 282 2/22/2017 2:45 PM

of 297


11.7.2.5

Prior to entry, Owners/Operators should conduct a confined space entry safety meeting in accordance withChapter 5 to ensure that assigned Entry Supervisors, Gas Testers, Entrants, Attendants, ventilationVentilation and Isolation Specialists, Rescuers, and workers are apprised of and understand the hazardsassociated with the confined space activity.


Grammatical correction since all roles are capitalized.




Street Address:

City:

State:

Zip:



178 of 282 2/22/2017 2:45 PM

of 297


11.7.2.5 *

Prior to entry, Owners/Operators should conduct a confined Operators should ensure a confined spaceentry safety meeting in accordance with Chapter 5 to ensure is performed. The meeting should e nsurethat assigned Entry Supervisors, Gas Testers, Entrants, Attendants, ventilation and Isolation Specialists,Rescuers, and workers are apprised of and understand the hazards associated with the confined spaceactivity.


The requirement to conduct a pre-entry safety meeting is confusing as the Entry Supervisor has already been tasked with a similar duty in 11.4.2.2Adding appendix material to explain that the Entry Supv is usually responsible for this duty.




Street Address:

City:

State:

Zip:



179 of 282 2/22/2017 2:45 PM

of 297


11.7.2.9

If changes occur in the hazards, use, or configuration of a confined space or in nearby operations thataffect the confined space, Owners/Operators should ensure that Entry Supervisors cancel the entry and hotand cold work permits, Entrants leave the space, and operations are discontinued until the confined spaceis re-evaluated and, if necessary, reclassified . Owners/Operators should then ensure that EntrySupervisors establish revised entry criteria, if needed, and reissue permits or issue new permits forcontinuing work, if applicable if work is continuing .


350 committee decided not use reclassification as an option. This revision removes it and clears up language.




Street Address:

City:

State:

Zip:



180 of 282 2/22/2017 2:45 PM

of 297


11.7.2.10 *

Owners/Operators should provide should ensure required equipment appropriate for employee entry andwork in and around the confined space and ensure that it is available for use. Owner/Operator shouldensure that equipment is properly inspected, tested, maintained, and used in accordance with the confinedspace program and permit requirements.


O/O does not always provide the equipment (e.g., self employed workers).




Street Address:

City:

State:

Zip:



181 of 282 2/22/2017 2:45 PM

of 297


11.7.2.11

Owners/Operators should identify, evaluate, qualify, and designate rescue services or facility Rescuers anddevelop and implement procedures for communicating with and summoning rescues rescue andemergency services.


editorial




Street Address:

City:

State:

Zip:



182 of 282 2/22/2017 2:45 PM

of 297


11.7.2.11

Owners/Operators should identify, evaluate, qualify, and designate rescue services or facility Rescuers anddevelop and implement procedures for communicating with and summoning rescues and emergencyservices.


Committee edit: Unsure how an O/O is to "qualify" an outside rescue service. It should be their job to qualify their own employees, but it seems it should be the job of the rescue service employer to qualify his/her own. Edited to remove need to qualify an outside entity.




Street Address:

City:

State:

Zip:



183 of 282 2/22/2017 2:45 PM

of 297


11.7.2.13 *

Owners/Operators should review the confined space program annually or sooner , if a management ofchange occurs that affects the confined space program, utilizing cancelled permits and other information,and revise the program accordingly to ensure continued protection from hazards during entry operations.


need to revise program if changes occur




Street Address:

City:

State:

Zip:



184 of 282 2/22/2017 2:45 PM

of 297


11.7.3.3

Owners/Operators should develop and implement an appropriate confined space program.


This is a Responsibility and it was already in the document: 11.7.2.4.




Street Address:

City:

State:

Zip:



185 of 282 2/22/2017 2:45 PM

of 297


11.7.3.4

Owners/Operators should train or educate, qualify, and designate employee personnel who are assigned toperform confined space operations.


This is not a qualification and should be added to responsibility section. That change has been added too.




Street Address:

City:

State:

Zip:



186 of 282 2/22/2017 2:45 PM

of 297


11.7.3. 5 3

Owners/Operators should be able to identify, evaluate, and select contractors, subcontractors, and rescueservices.


Reformatted numbers to account for removed para.




Street Address:

City:

State:

Zip:



187 of 282 2/22/2017 2:45 PM

of 297


11.7.4 Owner/Operator Demonstrated Competencies.

11.7.4.1


11.7.4.2


11.7.4.3


11.7.4.4


11.7.4.5



revised title of section to mirror other, similar sections.




Street Address:

City:

State:

Zip:



188 of 282 2/22/2017 2:45 PM

of 297


11.7.4 Owner/Operator Demonstrated Competencies.

11.7.4.1


11.7.4.2


11.7.4.3


11.7.4.4


11.7.4.5



Edited header to be in line with other headers for this section.




Street Address:

City:

State:

Zip:



189 of 282 2/22/2017 2:45 PM

of 297


11.7.4.1

Owners/Operators should know and be able to communicate permit requirement requirements tocontractors and Entry Supervisors and be able to evaluate permits upon completion of operations todetermine if any deficiencies in the facility confined space or permit programs need to be corrected.


editorial




Street Address:

City:

State:

Zip:



190 of 282 2/22/2017 2:45 PM

of 297


11.7.4.1

Owners/Operators should know and be able to communicate permit requirement requirements tocontractors and Entry Supervisors and be able to evaluate permits upon completion of operations todetermine if any deficiencies in the facility confined space or permit programs need to be corrected.


Corrected typographical error.




Street Address:

City:

State:

Zip:



191 of 282 2/22/2017 2:45 PM

of 297


11.7.4.2

Owners/Operators should be able to evaluate the need for, identify, and provide equipment required forconfined space operations or assure that the contractor/subcontractor meet this requirement .


contractors are often responsible for equipment




Street Address:

City:

State:

Zip:



192 of 282 2/22/2017 2:45 PM

of 297


11.7.4.3

Owners/Operators should provide a means of communication and be able to communicate with andcoordinate activities among facility personnel, contractors, and subcontractors associated with confinedspace operations and with nearby activities that may impact upon confined space operations .


also need to communicate with nearby workers




Street Address:

City:

State:

Zip:



193 of 282 2/22/2017 2:45 PM

of 297


11.7.4.4

Owners/Operators should understand the requirements and be should be able to assign tasks inaccordance with the applicable confined space and permit programs, employee qualifications, andoperational requirements.


This combined a qual with a competency. The qual (understand the regulations) is already covered in 11.7.3.2.




Street Address:

City:

State:

Zip:



194 of 282 2/22/2017 2:45 PM

of 297


11.7.4.5

Owners/Operators should be able to recognize, evaluate, and classify confined spaces in accordance withthe applicable confined space program and regulatory requirements.


Grammatical - consistency with use of Oxford comma




Street Address:

City:

State:

Zip:



195 of 282 2/22/2017 2:45 PM

of 297


11.8.2.4

If contractors do not agree to use the Owner/Operator’s confined space program, they should develop andimplement their own confined space program in accordance with regulatory requirements, industrystandards, applicable safe work practices and procedures, and Chapter 12 of this guide . The contractor’scontractor's confined space program should not conflict with and may be used to supplement theOwner/Operator’s Operator's confined space program, but it may not conflict with it .


Committee edit and cleaning up of language. This change clarifies the intent of paragraph.




Street Address:

City:

State:

Zip:



196 of 282 2/22/2017 2:45 PM

of 297


11.8.2.12

If changes occur in the use or configuration within a confined space or external to the confined space thataffect the hazards, contractors/subcontractors should ensure that the entry permit is cancelled, Entrantsimmediately vacate the space, the confined space is re-evaluated and, as necessary, reclassified, and newor renewed permits are issued establishing revised entry criteria, as necessary. Contractors/subcontractorsshould immediately advise owners.operators of changes that affect the confined space or may affectoperations.


Notification is needed as the changes may require an MOC on the part of the owner/operator




Street Address:

City:

State:

Zip:



197 of 282 2/22/2017 2:45 PM

of 297


11.8.2.12

If changes occur in the use or configuration within a confined space or external to the confined space thataffect the hazards, contractors/subcontractors should ensure that the entry permit is cancelled, Entrantsimmediately vacate the space, the confined space is re-evaluated and , as necessary, reclassified, andnew or renewed permits are issued establishing revised entry criteria, as necessary.


Committee is not using term "reclassify"




Street Address:

City:

State:

Zip:



198 of 282 2/22/2017 2:45 PM

of 297


11.8.2.17 *

Contractors should consult with and make information available to contractor employees and theirauthorized representatives regarding the development and implementation of all aspects of the contractors’contractor's confined space program. Contractors should ensure that the applicable confined spaceprogram is also available to subcontractor employees and their authorized representatives.


Typographical correction of apostrophe.




Street Address:

City:

State:

Zip:



199 of 282 2/22/2017 2:45 PM

of 297


11.8.2.18

Contractors/subcontractors should provide training covering existing, new, and revised procedures andwork practices so that all contractor/subcontractor employees involved in confined space operations andactivities acquire the understanding, knowledge, and proficiency necessary for the safe performance ofassigned duties in accordance with confined space program and permit program requirements.

11.8.2.18.1

Contractors/subcontractors should ensure that employees are trained, educated, and /or qualified asfollows:





11.8.2.18.2

Contractors/subcontractors should certify that employee training, education, or and qualification has beenaccomplished. The certification should contain the employee’s training, education, or and qualifications;the employee’s name; the signatures or initials of the trainers or trainers and qualifiers; and the dates oftraining, education, or and qualification. The certification should be available for inspection by regulatingagencies, Owners/Operators, and contractors/subcontractor employees or their authorized representatives,as applicable.


Committee edit: personnel are not trained, or educated or qualified. They receive training and education to obtain a qualification; therefore, there should be an "and" and not an "or". Recommend consistency throughout 350.




Street Address:

City:

State:

Zip:



200 of 282 2/22/2017 2:45 PM

of 297


11.8.2.18.1

Contractors/subcontractors should ensure that their employees are trained, educated, and/or qualified asfollows:






contractors not responsible for other's employees




Street Address:

City:

State:

Zip:



201 of 282 2/22/2017 2:45 PM

of 297


11.8.2.19.1

Contractors/subcontractors should debrief Owners/Operators at the conclusion of the entry operationsregarding the confined space program followed and any hazards confronted or created or any changescreated in confined spaces during entry operations.


need to advise mgt of changes as reclassification or MOC may be needed




Street Address:

City:

State:

Zip:



202 of 282 2/22/2017 2:45 PM

of 297

Public Input No. 252-NFPA 350-2017 [ Sections 11.8.3.5, 11.8.3.6 ]

Sections 11.8.3.5, 11.8.3.6

11.8.3.5

Contractors/subcontractors should designate trained, educated, and/or qualified personnel for confinedspace operations.

11.8.3.6

Contractors/subcontractors should be able to identify, evaluate, and select qualified subcontractors andrescue services.


11.8.3.5 is a responsibility and is already covered in the general section (11.8.2.1).Reformatted next para number to reflect change.




Street Address:

City:

State:

Zip:



203 of 282 2/22/2017 2:45 PM

of 297


11.8.4.6

Contractors/subcontractors should be able to evaluate, qualify, and select contractor personnel andsubcontractors. Subcontractors should be able to evaluate, qualify, and select subcontractor personnel.


Cleaning up language to clarify and simplify.




Street Address:

City:

State:

Zip:



204 of 282 2/22/2017 2:45 PM

of 297


11.9.1 * General.

Ventilation Specialists should be familiar with, educated, trained, and/or and qualified in the variousmethods and requirements for removing hazardous and/or contaminated atmospheres from confinedspaces. Ventilation Specialists might also perform other activities if they are competent or qualified and areassigned in accordance with the applicable confined space program and Chapter 9.


Committee edit: training, educ. and qualifications are needed.




Street Address:

City:

State:

Zip:



205 of 282 2/22/2017 2:45 PM

of 297


11.9.3.1

Ventilation Specialists should be familiar with the confined space program and , industry practices, andgovernmental regulations that pertain to ventilation operations including, but not limited to, oxygen levels,flammable and toxic atmospheric levels, and required air changes per hour.


Grammatical - language. Cleaned up wording.




Street Address:

City:

State:

Zip:



206 of 282 2/22/2017 2:45 PM

of 297


11.9.3.2

Ventilation Specialists should be familiar with the use, limitations and hazards of materials, substances, andequipment approved for use both inside and outside the specific confined space, including, but not limitedto, fans, eductors, tubing, hoses, vapor collection equipment, PPE, Gas Testers gas monitors , inert gases,flue gas, steam, water, fuel oil, and chemicals.


Edited to clarify. The sentence is listing materials, substances and equipment but then had Gas Tester, which is a person. I think they meant to have gas monitors (the equipment) and not the person performing the tests.




Street Address:

City:

State:

Zip:



207 of 282 2/22/2017 2:45 PM

of 297


11.9.4.6

Ventilation Specialists should understand the requirements for and be able to determine appropriateventilation flow rates in accordance with the entry permit and regulatory requirements including theappropriate number of air changes needed per hour, where applicable .


some jurisdictions have requirements for specified number of air changes per hour in spaces.




Street Address:

City:

State:

Zip:



208 of 282 2/22/2017 2:45 PM

of 297


11.9.4.6

Ventilation Specialists should understand the requirements for and be able to determine appropriateventilation flow rates in accordance with the entry permit and regulatory requirements.


The sentence had both a qual and competency in it. Edited to just have a competency.




Street Address:

City:

State:

Zip:



209 of 282 2/22/2017 2:45 PM

of 297


11.10.1 * General.

Isolation is the process of removing a confined space from service and completely protecting the spacefrom the unwanted release of energy, liquids, gases, chemicals, and other materials into the space throughfixed or temporary connections to the space, as well as disconnecting and de-energizing potentiallyhazardous machinery and equipment within or attached to the space. Isolation may be permanent ortemporary. Isolation operations should be performed by Isolation Specialists who should be trained,educated, or qualified and competent to perform required isolation duties. Isolation Specialists should beassigned and authorized by the Owner/Operator or contractors, as appropriate, in accordance with therequirements of the applicable permits, isolation, or the lockout/tagout program and the confined spaceprogram. At the conclusion of confined space operations, Isolation Specialists should be able to restore thespace to pre-isolation conditions.


this should be a qualification. as written it is a directive




Street Address:

City:

State:

Zip:



210 of 282 2/22/2017 2:45 PM

of 297


11.10.1 * General.

Isolation is the process of removing a confined space from service and completely protecting the spacefrom the unwanted release of energy, liquids, gases, chemicals, and other materials into the space throughfixed or temporary connections to the space, as well as disconnecting and de-energizing potentiallyhazardous machinery and equipment within or attached to the space. Isolation may be permanent ortemporary. Isolation operations should be performed by Isolation Specialists who should be trained,educated, or qualified, and competent to perform required isolation duties. Isolation Specialists should beassigned and authorized by the Owner/Operator or contractors, as appropriate, in accordance with therequirements of the applicable permits, isolation, or the lockout/tagout program and the confined spaceprogram. At the conclusion of confined space operations, Isolation Specialists should restore the space topre-isolation conditions.


Committee edit: training, educ. and qual recommended.




Street Address:

City:

State:

Zip:



211 of 282 2/22/2017 2:45 PM

of 297


11.10.1 * General.

11.10.1.1 Isolation is the process of removing a confined space from service and completely protecting thespace from the unwanted release of energy, liquids, gases, chemicals, and other materials into the spacethrough fixed or temporary connections to the space, as well as disconnecting and de-energizing potentiallyhazardous machinery and equipment within or attached to the space. Isolation may be permanent ortemporary.

11.10.1.2 Isolation operations should be performed by Isolation Specialists who should be trained,educated, or qualified and competent to perform required isolation duties.

11.10.1.3 Isolation Specialists should be assigned and authorized by the Owner/Operator or contractors,as appropriate, in accordance with the requirements of the applicable permits, isolation, or thelockout/tagout program and the confined space program. At the conclusion of confined space operations,Isolation Specialists should restore the space to pre-isolation conditions.


Formatting. There is a lot of information in the General Section. Broke it up to make it consistent with how committee did the Entrant and Attendant General Sections.




Street Address:

City:

State:

Zip:



212 of 282 2/22/2017 2:45 PM

of 297


11.10.2.5

Isolation Specialists should know and be able to properly apply and sequence isolation and energy controlprocedures, both when isolating and when de-isolating the confined space.


Sentence had both quals and responsibilities in it. Removed qual.




Street Address:

City:

State:

Zip:



213 of 282 2/22/2017 2:45 PM

of 297


11.10.4.4

Isolation Specialists should be trained or educated and qualified to perform assigned tasks in an approvedmanner.


This sentence is a qualification and is already in the General section 11.10.1.




Street Address:

City:

State:

Zip:



214 of 282 2/22/2017 2:45 PM

of 297


11.10.4. 5 4

Isolation Specialists should have the knowledge and experience to understand isolation needs and be ableto select and apply appropriate, approved isolation devices, equipment, and methods in accordance withthe applicable isolation program and other requirements.


Reformatted number to account for removed section. Removed part of sentence that was a qual and not a competency.




Street Address:

City:

State:

Zip:



215 of 282 2/22/2017 2:45 PM

of 297


11.11.1 * General.

Standby Workers are individuals assigned to stay outside the confined space and conduct confined space–related operations, as assigned by the Entry Supervisor, that do not involve duties assigned specifically toEntrants, Gas Testers, Rescuers, supervisors Entry Supervisors , Attendants, Isolation Specialists, orVentilation Specialists. Standby Workers may be assigned other duties, such as relief for Attendants, only ifthey are appropriately trained and qualified.


Grammatical - made role upper case and used the correct name for it.




Street Address:

City:

State:

Zip:



216 of 282 2/22/2017 2:45 PM

of 297


11.11.2.1

Standby Workers should have an understanding of the work required and the knowledge and skills toperform the work in a safe manner around the confined space area.


Sentence had qualifications in it when this is a responsibility list.




Street Address:

City:

State:

Zip:



217 of 282 2/22/2017 2:45 PM

of 297


11.11.2.2

Standby Workers should be familiar with the hazards in and around the confined space and use appropriateprotective clothing and equipment as appropriate as needed for assigned duties and exposures or asrequired by a work permit.


better wroding




Street Address:

City:

State:

Zip:



218 of 282 2/22/2017 2:45 PM

of 297


11.11.2.3

Standby Workers should receive direction should follow directions from the confined space EntrySupervisor regarding tasks to be performed.


Word choice. The Standby Worker's duty is to follow the directions. The duty of the Entry Supv is to give them. Not sure that receiving is a duty.




Street Address:

City:

State:

Zip:



219 of 282 2/22/2017 2:45 PM

of 297


11.11.2.6

Standby Workers conducting cleaning, disposal, or hot and/or cold work operations in and around theconfined space should be able to perform these activities in accordance with the confined space programand issued permit requirements. Unless the space has been reclassified as NOT a confined space,standby workers conducting hot or cold work operations or other duties inside the space should be trained,qualified and equipped as entrants


provides for meeting entrant requirements if worki.ng in a confined space




Street Address:

City:

State:

Zip:



220 of 282 2/22/2017 2:45 PM

of 297


11.11.2.6

Standby Workers conducting cleaning, disposal, or hot and/or cold work operations in and aroundoperations around the confined space should be able to perform these activities in accordance with theconfined space program and issued permit requirements.


Committee edit: 11.11.1 states that Standby Workers do not perform duties of Entrants, etc. but this section states that "Standby Workers conducting cleaning …. work operations in and around the confined space should be able to perform these activities in accordance with confined space program and issued permit requirements. Removed the word "in"




Street Address:

City:

State:

Zip:



221 of 282 2/22/2017 2:45 PM

of 297


11.11.3.2

Standby Workers should should understand and be able to communicate to the entry supervisor EntrySupervisor the use, limitations, and hazards of materials, substances, and equipment approved for use inassigned duties.


Sentence lacked a qualification. The ability to communicate is more of a competency. Added the need to understand to make this a qual.Grammatical - made role upper case.




Street Address:

City:

State:

Zip:



222 of 282 2/22/2017 2:45 PM

of 297


11.11.3.3

Standby Workers should know and be able to communicate to the Entry Supervisor the hazards inside andoutside the specific confined space associated with Standby Workers’ assigned operations duties .


"duties" is the correct term and is used elsewhere




Street Address:

City:

State:

Zip:



223 of 282 2/22/2017 2:45 PM

of 297


11.11.4.1

Standby Workers should be able to read, understand and comply with the requirements of applicablepermits, including, but not limited to, permits covering entry, hot and cold work, and any other activityassigned to Standby Workers.


Committee edit: removing the need to read.




Street Address:

City:

State:

Zip:



224 of 282 2/22/2017 2:45 PM

of 297


11.11.4.2

Standby Workers should be able to properly use required PPE and equipment needed to pwrform theirduties .


specifies exact equipment used




Street Address:

City:

State:

Zip:



225 of 282 2/22/2017 2:45 PM

of 297


11.12 Training.

11.12.1 General.

All confined space personnel should be trained, educated, and /or qualified as required by the applicablewritten confined space program and regulatory requirements to include, but not limited to, the following:



(3) Type of confined space to be entered, configuration, structure, obstruction, means of entry and exit,and materials or substances within, around, or introduced into the space

(4) Atmospheric, physical, and chemical (toxic) hazard awareness, including, but not limited to, theidentification, elimination, protection, and control measures applicable to the proposed entry and work


(6) The physiological and psychological stresses associated with the specific tasks

11.12.1.1

Sources of training or education include, but are not limited to, the following:

(1) On-the-job (apprentice) training or experience

(2) Company sponsored training or education (internal or external)

(3) Job-required regulatory training or education, including, but not limited to, respiratory protection, hotwork, and lockout/tagout, as applicable to duties and assignments

(4) Government, regulatory, private, and labor organization training or education programs, such as NFPAEntry Supervisor Training Program and OSHA on-line courses

11.12.1.2 Retraining.

11.12.1.2.1

All confined space personnel should be retrained, re-educated, or and requalified as required by theconfined space program or regulations.

11.12.1.2.2

All confined space personnel should be retrained, re-educated, or requalified and requalified when newduties and responsibilities are assigned.

11.12.1.2.3

All confined space personnel should be retrained, re-educated, or and requalified when new equipment,types of space, or materials are introduced.

11.12.1.2.4

All confined space personnel should be retrained, re-educated, or and requalified when work deficienciesare observed.

11.12.1.2.5

All confined space personnel should be retrained, re-educated, or and requalified when certificationrequires renewal.

11.12.1.2.6

All confined space personnel should be retrained, re-educated, or and requalified when regulatoryrequirements change or the confined space program is revised.


226 of 282 2/22/2017 2:45 PM

of 297

11.12.1.2.7

All confined space personnel should be retrained, re-educated, or and requalified in the proper use oftools and equipment, including, but not limited to, PPE, respiratory protection, and monitoring instruments,according to the manufacturers’ recommendations manufacturers’ instructions and industry practices,whenever new tools or equipment are introduced or when changes occur in existing tools or equipment.


Maintaining consistency throughout document that training, education, and qualification are cumulative, not exclusive, of one another. Changed the word from "recommendations" to "instructions" to be consistent with other times the manuf.'s instructions are noted (e.g., gas monitors). I do not think that manufacturers' send out recommendations with their equipment as much as they send out instructions.




Street Address:

City:

State:

Zip:



227 of 282 2/22/2017 2:45 PM

of 297

Public Input No. 114-NFPA 350-2016 [ Section No. 11.12.1 [Excluding any Sub-Sections]

]

All confined space personnel should be trained, educated, and/or qualified as required by the applicablewritten confined space program and regulatory requirements to include, but not limited to, the following:



(3) Type and identification of confined space to be entered, configuration, structure,obstruction obstructions , means of entry and exit, and materials or substances within, around, orintroduced into the space

(4) Atmospheric, physical, and chemical (toxic) hazard awareness, including, but not limited to, theidentification, elimination, mitigation, protection, and control measures applicable to the proposed entryand , exposure and work


(6) The physiological and psychological stresses associated with the specific tasks confined space, theanticipated hazard exposures abd the assigned tasks


provides qualifiers and additional information. One editorial




Street Address:

City:

State:

Zip:



228 of 282 2/22/2017 2:45 PM

of 297


11.12. 1. 2 Retraining.

11.12.1.2.1

All confined space personnel should be retrained, re-educated,

or

and requalified as required by the applicable confined space program

or regulations.

11.12.1.2.2

All confined space personnel should be retrained, re-educated, or requalified when

, industry practices, and regulatory requirements to include, but not limited to, the following:

(1) W hen new duties and responsibilities are assigned.

11.12.1.2.3


(2) W hen new equipment, types of space, or materials are introduced.

11.12.1.2.4


(3) When work deficiencies are observed.

11.12.1.2.5


(4) When certification requires renewal.

11.12.1.2.6


(5) When regulatory requirements change or the confined space program is revised.

11.12.1.2.7

All confined space personnel should be retrained, re-educated, or requalified in

(6) When new tools or equipment are introducted or when changes occur in existing tools or equipment.

(7) As needed to review the proper use of tools and equipment, including, but not limited to

,

PPE

, respiratory protection,

and air monitoring instruments

, according to the manufacturers’ recommendations and industry practices, whenever new tools orequipment are introduced or when changes occur in existing tools or equipment

.


Committee recommended edit to mirror this section with 11.12.1 and make list.


229 of 282 2/22/2017 2:45 PM

of 297




Street Address:

City:

State:

Zip:



230 of 282 2/22/2017 2:45 PM

of 297


11.12.1.2.3

All confined space personnel should be retrained, re-educated, or requalified when new equipment, newtypes, classifications or configurations of space spaces , or products and materials are introduced into theworkplace .


adds a number of items affecting retraining




Street Address:

City:

State:

Zip:



231 of 282 2/22/2017 2:45 PM

of 297


12.1.1 General.

Before confined space operations begin and workers enter the confined space for any reason, theOwner/Operator or Entrant Employer should develop and implement a written confined space program. Thewritten program should be made available to all employees and/or their representatives and should include,but not be limited to, the following:

(1) Program responsibilities

(2) Identification and classification/reclassification of confined spaces

(3) Identification of personnel involved in the confined space entry and supporting operations includingrescue

(4) Standard operating procedures, such as isolation, control of ignition sources, atmospheric monitoringand ventilation

(5) Entry permits and other entry work related permits and work orders

(6) Other facility safety permits and procedures

(7) Emergency communications and rescue procedures

(8) Training

(9) Resources

(10) Program auditing and program changes

(11) Medical qualifications

(12) Regulatory and , industry and best practices

(13) A separate written confined space policy for those facilities where only qualified contractors will enterthe confined space that explains the following:

(a) How the Owner/Operator or employer determines contractors are qualified

(b) How confined space hazards are communicated to contractors

(c) How relevant facility safety information is communicated to contractors

(d) How contractors are debriefed after entry is completed


adds additional information and qualifiers. More specific as to contractor program




Street Address:

City:

State:

Zip:



232 of 282 2/22/2017 2:45 PM

of 297


There should be one person assigned as the program administrator for the company’s or facility’s confinedor contractors's confined space entry program. This person can be the Owner/Operator, employer EntrantEmployer , or other qualified individual assigned by the Owner/Operator or employer Entrant Employer .This individual should be identified in the written confined space program. The program should alsoestablish the roles and responsibilities of all individual positions involved in confined space operations andentries. As a minimum, the name of the program administrator should be listed along with a list ofauthorized Entrants, Attendants, and Entry Supervisors in a separate document, which should be reviewedand updated as needed. Roles such as Gas Tester, Ventilation Specialist, Isolation Specialist, standbyperson, and hot/cold work should Standby Person, as well as applicable programs, including, but notlimited to ,Hot/Cold Work, Isolation (Lockout/Tagout), PPE, Rescue and Respiratory Protection should alsobe identified in the program. Other individuals, if needed, can be assigned by the Entry Supervisor on an AdHoc basis . Chapter 11 provides a list of roles and required training.


provides for contractor programs and adds other programs and procedures usually affecting confined space work




Street Address:

City:

State:

Zip:



233 of 282 2/22/2017 2:45 PM

of 297


12.2.1

A written confined space entry program should be developed and maintained by the Owner/Operator orEntrant Employer for every workplace in which confined space entries will occur. The program shouldcomply with all applicable regulatory requirements, and industry standards and practices.Where a conflictmay exist between and Owner/Operator program and and Entrant Employer program, the prejob evaluation should identify which requirement shall apply and if this is not done, the stricter or morerestrictive of the requirements would be applicable.


provide for when there is a disagreement between programs




Street Address:

City:

State:

Zip:



234 of 282 2/22/2017 2:45 PM

of 297


12.2.3 Written Program Access.

It is recommended that employers ensure that employees who perform confined space operations, and/ortheir authorized representatives, are involved in the development and implementation of the writtenconfined space entry program.


redundant with previous section remove and renumber




Street Address:

City:

State:

Zip:



235 of 282 2/22/2017 2:45 PM

of 297


, The written confined space program should be reviewed at least annually by the Owner/Operator orEntrant Employer and the workers involved in the confined space operations to determine if the program iseffective in providing safe operations for confined space entries. Additionally, if a change occurs that affectsthe confined space, including but not limited to reclassification, a

change in configuration, contents or operations, the program should be reviewed and revised as needed.


providesfor program review due to changes in the space




Street Address:

City:

State:

Zip:



236 of 282 2/22/2017 2:45 PM

of 297


12.7.1 *

The written confined space program should also specify atmospheric conditions that prohibit entry undernormal conditions. The program should indicate that if acceptable atmospheric quality criteria are not met,or if a hazardous atmosphere develops during occupancy , all the entry permit should be cancelled and allEntrants must immediately exit immediately the space . For example, entry should be allowed if any of thefollowing conditions exists only when the proper protective measures as delineated in this document (suchas wearing of PPE) are taken:

(1) Oxygen is lower than 19.5 percent or higher than 22.0 percent.

(2) Hydrogen sulfide is greater than the accepted exposure limits.

(3) LEL is greater than 10 percent.

(4) Carbon monoxide is greater than accepted exposure limits.

(5) Any other hazardous or toxic substance exceeds exposure limits


provides for other substabces




Street Address:

City:

State:

Zip:



237 of 282 2/22/2017 2:45 PM

of 297


12.7.2

The written confined space program should specify when and how atmospheric monitoring is conducted.For example, the program should specify if workers must wear monitoring devices during the entire entry, orif stand-alone monitoring devices will be placed in the space or if the Attendant will be performingatmospheric monitoring from outside the space , or both. either or all of these. methods are to be sed.


provides for monitors that are not personal to be used and qualifies attendant monitors from outside the space




Street Address:

City:

State:

Zip:



238 of 282 2/22/2017 2:45 PM

of 297


12.7.4

The written confined space program should specify who is responsible for maintaining atmospheric monitorinstructions and manuals, and where instrument history and calibration records are maintained. and wherethese are to be maintained, for how long and who has access to them


specific to responsibility for maintaining everything and provides for access




Street Address:

City:

State:

Zip:



239 of 282 2/22/2017 2:45 PM

of 297


The written confined space program should contain information about the selection, use and maintenanceof mechanical ventilation equipment for confined space entry and who is responsible for determiningventilation requirements. The work plan for a specific confined space entry should delineate the type andsize of ventilation equipment to be used, its placement, and intake and exhaust criteria.


provides for selection and additional criteria




Street Address:

City:

State:

Zip:



240 of 282 2/22/2017 2:45 PM

of 297


12.8.1

The written confined space program should specify when and how mechanical ventilation will be used inconfined spaces. For example, some confined spaces may require continuous ventilation during confinedspace entry operations. The program should identify applicable regulatory requirements regarding airchanges during operations with in a confined space .


provides for regulatory considerations applicable to ventilation




Street Address:

City:

State:

Zip:



241 of 282 2/22/2017 2:45 PM

of 297


12.18 * General Fitness for Duty Evaluation.

Owner/Operators or Entrant Employers should ensure that the written confined space program includesevaluation procedures for the physical and mental capabilities of personnel assigned to work in confinedspace operations. The program should consider all actual and potential hazards and operations, and canreference industry and regulatory medical evaluation procedures, including, but not limited to, respiratoryprotection capability, toxic exposure determinations, and physiological and psychological stresses thatmight be present during confined space entries, such as climbing, ladders, heat stress, and claustrophobia.Where required by company policy or regulation, the program should indicate what medical records arerequired, for whom and for what exposures they are required, how long records are to be maintained andwho is responsible for their maintenance.


adds medical record requirements




Street Address:

City:

State:

Zip:



242 of 282 2/22/2017 2:45 PM

of 297


13.1.1

The permit should be displayed at the confined space location. Permits should be marked as cancelledafter the time allowed on the permit has expired, the work is completed, or a change in conditions requirescancellation and a new permit or reissued permit .


mores specific as to cancelled permits




Street Address:

City:

State:

Zip:



243 of 282 2/22/2017 2:45 PM

of 297


13.1.2

Canceled permits should be retained for at least 1 year in accordance with owner/operator policy andshould be made available for Entry Supervisors to review during pre-entry planning and prior to entering aconfined space.


provides for review in pre entry planning




Street Address:

City:

State:

Zip:



244 of 282 2/22/2017 2:45 PM

of 297


13.1.3

Permits should be limited to one shift. If work activity exceeds one shift the permit should be reissued. Inaddition, permits should be considered cancelled if personnel or conditions change.


adds conditions




Street Address:

City:

State:

Zip:



245 of 282 2/22/2017 2:45 PM

of 297


13.2.4.4.2 Atmospheric Ventilation. , Purging and Inerting

The Entry Supervisor should understand ventilation methods , purging and inerting methods andrequirements. The Entry Supervisor should verify that ventilating a confined space with fresh air before andduring confined space work can reduce or remove atmospheric contaminants. Ventilation, especially duringwarmer months, can also provide relief from thermal stress. The permit should outline what ventilationshould be used prior to and during entry. If ventilation will block In situations where ventilation is not afeasible means of making a space safe for entry, purging or inerting may be used. If ventilation, inerting orpurging equipment blocks access into or out of the space, the permit should outline procedures to ensureworker safety during operations.


adds inerting and purging to ventilation




Street Address:

City:

State:

Zip:



246 of 282 2/22/2017 2:45 PM

of 297


13.2.4.4.3 Personal Protective Equipment (PPE).

The permit should address Entrant and Attendant PPE requirements. Also, if workers need to carry escapedevices or additional PPE for specific work, such as entry into inert atmospheres, cleaning or painting, thatthose equipment requirements should also be addressed.


adds other needs and editorial




Street Address:

City:

State:

Zip:



247 of 282 2/22/2017 2:45 PM

of 297


13.2.4.4.4 Other Permits.

All additional permits needed for the confined space should be listed on the entry permit (e.g., hot work,line break, electrical cold work, isolation, etc.).


line work and electrical work are examples of isolation




Street Address:

City:

State:

Zip:



248 of 282 2/22/2017 2:45 PM

of 297


13.2.4.4.5 Grounding and Bonding.

If the confined space or the ventilation or equipment brought into the space need othe equipment used inthe confined space operations needs to be grounded or bonded, then that information should be indicatedas a control ittem on the permit as a control.


basically editorial for clarity




Street Address:

City:

State:

Zip:



249 of 282 2/22/2017 2:45 PM

of 297


13.2.5 Communications.

The Entry Supervisor should select and indicate on the permit the appropriate methods of communication ,and in accordance with the applicable policy for intrinsically safe devices, and should document howcommunication will be maintained, as follows:

(1) Verbal. Acceptable if line of sight is maintained

(2) Radio. Permit to indicate test intervals

(3) Rescue request. Permits indicate how rescue team will be notified


provides for facility acceptable devices




Street Address:

City:

State:

Zip:



250 of 282 2/22/2017 2:45 PM

of 297


13.2.10 Cancel Permit.

Each permit should have an area on the permit to mark the permit as canceled. A permit can be canceledat the end of the work activity by the Attendant or Entrant, or at anytime by the Attendant, Entrant,supervisor, or safety professional because of hazards. The , changing weather conditions, outsideoperations, equipment fasilure, etc. The reason the permit was cancelled should be documented on thepermit, for example, work was completed or conditions changed.


adds additional reasons for cancellation




Street Address:

City:

State:

Zip:



251 of 282 2/22/2017 2:45 PM

of 297


14.1.1 General.

All records for a records required by or associated with a confined space program, including but not linitedto pre-entry evaluations, all entry permits, other associated permits, atmospheric monitoring instrumentcalibration, employee exposure test results, and any additional documents deemed necessary by theconfined space program, should be maintained by the Owner/Operator or employer for a minimum of oneyear to allow for an annual review of the program. Where required by regulations or employer policy,records shall be maintained for the established period.


provides for a broad spectrum of recordkeeping as well as compliance with regulations




Street Address:

City:

State:

Zip:

Submittal Date: Sat Dec 31 09:36:06 EST 2016


252 of 282 2/22/2017 2:45 PM

of 297


14.2.1

Documented evaluation and classification , classification and reclassification records for each confinedspace should be maintained for the duration of occupancy or until permanently the space's existance oruntil the space is permanently changed to a non confined space or eliminated.


more specifically clarifies requirements for this retention




Street Address:

City:

State:

Zip:



253 of 282 2/22/2017 2:45 PM

of 297


14.2.2

Owners/Operators or Entrant Employers should conduct annual reviews of programs, permits, and otherrequired records other records maintenance and retention requirements for continued compoliance andeffectiveness and update each as needed. Worker performance reviews and corrective action imposedand taken should be documented and maintained for a period of one year from the date of the review orlonger, as required by company policy or regulations.


provides clarification and is more specific as to requirements




Street Address:

City:

State:

Zip:



254 of 282 2/22/2017 2:45 PM

of 297


14.2.3

Owners/Operators or Entrant Employers should inspect, test, and maintain confined space monitoring andcalibration equipment, PPE and respiratory protection equipment, breathing air supply and ventilationequipment as required by their respective programs, industry practices, and applicable regulations.Inspection and , testing and maintenance records should be maintained for a minimum of one yearfollowing the activity, or longer if required by company policy or regulations.


adds air supply and respiratory also adds test in second sentence to agree with first sentence




Street Address:

City:

State:

Zip:



255 of 282 2/22/2017 2:45 PM

of 297


14.3.1

Owners/Operators or Entrant Employers should implement programs to retain and maintain employeetraining and retraining , education education , certification, competency, and qualification documentationfor the duration of employment or longer, per company as required by company policy, industry practices,or regulations.


more specific. adds requirements to have a program




Street Address:

City:

State:

Zip:



256 of 282 2/22/2017 2:45 PM

of 297


15.1 Purpose.

This chapter provides information for establishing a management of change (MOC) system for confinedspace operations. Its purpose is to establish and implement procedures needed to provide for continuoussafe operating conditions and work practices whenever change or modifications, other than changes inkind, occur in confined space classification, configuration, equipment, materials, content, scope of work,operating procedures, processes, and personnel, as well as changes to Owner/Operator and contractorconfined space and other applicable programs, industry practices, and regulatory requirements.Owners/Operators should conduct MOC reviews whenever permanent or temporary changes impact uponconfined spaces in their facilities. Such changes may require classification of previous non-classifiedspaces as confined spaces or reclassification of identified confined spaces as non-condfined spaces.


adds information on reclassification




Street Address:

City:

State:

Zip:



257 of 282 2/22/2017 2:45 PM

of 297


15.2 Responsibilities and Communication for Implementing MOC.

For an MOC system to function effectively, confined space Owners/Operators or employers, Entrants,Entrant Employers and their personned, including but not limited to Operations Personnel, Entrants,Attendants, Entry Supervisor Supervisors , and Rescuers should be able to recognize confined spacerelated deviations and changes that are significant enough to trigger an MOC review. Once a deviation orchange triggers an MOC review, facility Owners/Operators or employers Entrant Employers should assignqualified personnel and resources to determine what changes, if any, are needed in the confined spaceprogram and hazard control measures. Owners/Operators and contractors/subcontractors should EntrantEmployers should then implement the changes in their programs and procedures to ensure confined spaceoperations are conducted safely.


uses term entrant employer, adds operation personnel who also affect changes




Street Address:

City:

State:

Zip:



258 of 282 2/22/2017 2:45 PM

of 297


The MOC process should be developed, implemented, communicated, and documented to ensure thechanges and deviations affecting confined spaces are spaces have been reviewed and authorized. TheMOC process should ensure that changes to equipment, processes, personnel, procedures, or materialsaffecting confined spaces are properly reviewed against the original confined space hazard assessmentdata assessment and that hazard elimination, mitigation and control measures applicable to the specificconfined space are reevaluated and changed if needed . The MOC process, if well implemented, can helpprevent or minimize confined space incidents and accidents associated with changes or modifications toconfined space work.


need to tell what should be done after MOC review




Street Address:

City:

State:

Zip:



259 of 282 2/22/2017 2:45 PM

of 297


15.3.1

Owners/Operators and contractors/subcontractors should assign qualified persons familiar with both theconfined space requirements and the applicable equipment, processes, materials, and operations to reviewthe MOC form. These qualified persons should identify potential MOC issues affecting the facilities'confined spaces , develop preventive and protective measures, and propose changes to the confined spaceprogram, as well as other applicable programs, for approval and implementation by the Owners/Operatorsor contractors/subcontractors.


need to also know confined space requirements




Street Address:

City:

State:

Zip:



260 of 282 2/22/2017 2:45 PM

of 297


15.3.2

Upon completion of the MOC review, the person(s) conducting the review should originate and submit anMOC form to the Owner/Operator or contractor/subcontractor for authorization prior to implementing anychange affecting a the applicable confined space program or any specific confined space(s) . An exampleof an MOC form is shown in Figure D.1.


see 15.3.3 Need to apply to the program also




Street Address:

City:

State:

Zip:



261 of 282 2/22/2017 2:45 PM

of 297


15.4.1 Equipment Changes Affecting Confined Space.

Owners/Operators and contractors/subcontractors should initiate an MOC process whenever the addition,modification, or removal of equipment might require new or revised processes, procedures, documentation,or training for the confined space work. Examples of changes to confined space equipment include, but arenot limited to, the following:

(1) Physical configuration of the space (e.g., external or internal dimensions of space, constructionmaterials, physical condition)

(2) Entry or internal access portals and paths, including the number, size, and configurations that canaffect ingress/egress routes)

(3) Internal equipment (e.g., agitators, dampers, piping, obstructions, safety critical equipment, systemparts)

(4) Instrumentation and monitoring (e.g., monitors, electrical controls, program/control logic or set/alarmpoints, calibration, testing, process controls)

(5) Electrical, hydraulic, pneumatic, or mechanical equipment, or change of electrical classification ofequipment

(6) Reclassification of Classification of a space that previously was not a confined space orreclassification of the space so it is no longer a confined space


need to cover new confined spaces created by the MOC process




Street Address:

City:

State:

Zip:



262 of 282 2/22/2017 2:45 PM

of 297

Public Input No. 162-NFPA 350-2017 [ New Section after A.4.1 ]

A.4.3(2)

Additional examples include: tunnels, tubes, ventilation ducts, and water pipes. Entry Supervisor ensures allexit paths are free of hazards and that entrants can evacuate safely. Alternate evacation routes should bedeveloped if hazards may impede main exit path.


Committee member commented that we needed to be clearer on why we have this document and how in previous confined space disasters the space was neither recognized as a PRCS and exit routes were not available for entrants when fire broke out.




Street Address:

City:

State:

Zip:



263 of 282 2/22/2017 2:45 PM

of 297

Public Input No. 161-NFPA 350-2017 [ Section No. A.4.6.2 ]

A.4.6.2

Examples of this type of job include, but are not limited to, a contractor who is sent to various sites to docontract repair work in confined spaces or a pest control specialist who might enter crawl spaces to applypesticides. See also Chapter 6.3.4.2 on Introduced Hazards.


Clarifying where to retrieve more information on that particular topic.




Street Address:

City:

State:

Zip:



264 of 282 2/22/2017 2:45 PM

of 297


A.5.1.2

Reclassified spaces and spaces that may use alternate procedures remain confined spaces. They mayhave no recognized hazards (i.e., reclassified spaces) or have only an atmospheric hazard that can becontrolled with ventilation (i.e., use of alternate procedures). However, best practice is to include thesespaces in the written program (see 12.1.1) and develop safe work procedures.


Committee edit: committee did not intend on saying that confined spaces with no existing hazards do not need to be included in the written program. We want readers to know how 350 is a best work practice - not the minimum requirements of the regulation.




Street Address:

City:

State:

Zip:



265 of 282 2/22/2017 2:45 PM

of 297


A.5.6

The written program should address the circumstances under which one person may be allowed to performmultiple roles during an entry, and procedures should be developed. Not all roles may held by the sameperson during an entry(e.g., the Attendant may not also be an Entrant).


Committee edit: we needed to clarify that the same person may not be able to hold multiple roles during an entry if they conflict. Best practice is to delineate how and when this may be done in written program.




Street Address:

City:

State:

Zip:



266 of 282 2/22/2017 2:45 PM

of 297

Public Input No. 31-NFPA 350-2016 [ New Section after A.7.3.9 ]

Common Gas Threats by Industry





Common_Gas_Threats_by_Industry.doc


What gases are most common for various industries?



Public Input No. 32-NFPA 350-2016 [New Section after A.7.3.9]


Submitter Full Name: Andrew Saunders

Organization: Honeywell Inc.

Street Address:

City:

State:

Zip:

Submittal Date: Tue Dec 20 10:34:24 EST 2016


267 of 282 2/22/2017 2:45 PM

of 297


of 297

Public Input No. 32-NFPA 350-2016 [ New Section after A.7.3.9 ]

Sensor Technologies




Sensor_Technologies_in_Portable_Safety_Gas_Monitors.docx


What are the advantages and limitations of sensor technologies used in Portable Safety Gas Monitors?



Public Input No. 31-NFPA 350-2016 [New Section after A.7.3.9]


Submitter Full Name: Andrew Saunders

Organization: Honeywell Inc.

Street Address:

City:

State:

Zip:

Submittal Date: Tue Dec 20 15:14:42 EST 2016


268 of 282 2/22/2017 2:45 PM

of 297

Electrochemical Consumable Anode Oxygen Sensor: For oxygen deficiency and enrichment use an electrolyte and electrodes to

produce an electrochemical reaction to generate a current proportional to the gas concentration. Gas reading displays as % by volume. Advantages

True percent by volume sensor Ability to adapt to changes in pressure and temperature Stable signal output up to end of operating life Sensor can be calibrated in ambient “fresh air” Can be stored for up to 6 months - store in sealed shipping container Oxygen specificity

Factors that lead to sensor failure: All available surface area of Pb anode converted to PbO Electrolyte contaminated by exposure to: High concentrations of acid gases - SO2 and CO2 Solvents Electrolyte leakage Desiccation Excessive heat Excessive humidity Blockage of capillary pore

Electrochemical Oxygen Pump Long Life Sensor: For oxygen deficiency and enrichment use an electrolyte and electrodes to

produce an electrochemical reaction to generate a current proportional to the gas concentration. Gas reading displays as % by volume. Advantages

Designed using field proven oxygen pump technology Extends sensor life by eliminating the consumable anode This is a lead free O2 sensing technology RoHS compliant Expected operating life of 5 years in air Exceptional performance in changing temperature and humidity Operating temperature range: -40ºC to 60ºC

Limitations Avoid exposure to high concentrations of solvent vapors during storage

and use. Avoid close proximity exposure to alcohol containing antiseptic

products such as wipes, sanitizing gels and liquids. Avoid handling after recent exposure to these products. Alcohols can generate an exaggerated sensor output and prolonged recovery times.

High concentrations of CO2 will affect accuracy and recovery time Requires a constant biased voltage to maintain stability. If detector

battery has been allowed to completely discharge, or when replacing sensors allow 30 to 60 minutes for sensor to stabilize.

of 297

Electrochemical Toxic Gas Sensor: Use an electrolyte and active electrodes to produce an electrochemical

reaction to generate current proportional to the present gas concentration. Gas reading display as parts per million. Advantages

Relatively low cost Sensitive to ppm concentration Accurate and linear over sensor detection range Relatively good target gas specificity Typically fail safe operation

Limitations Cross sensitivities – response to gases other than the target gas can be

confusing Electrolyte contamination by substances such as alcohols and citrus

oils Some sensors very sensitive to humidity and temperature transients,

e.g. NO, ETO Catalytic Bead Combustible Gas Sensor: Also known as pellistors, oxidize combustible gas. Heated catalyst-coated

wire coil burns (catalyzes) the gas of interest; wire temperature increases along with its electrical resistance. Wheatstone Bridge circuitry employs two elements, one for detection and one for compensation. The first element converts the resistance change into a corresponding, measurable signal. The second detector compensates for temperature, pressure and humidity. Gas readings display as % LEL (Lower Explosive Limit). Advantages

Relatively low cost Accurate and linear over sensor detection range relative to calibration

gas Broad band sensor Long history, proven technology

Limitations Unable to identify species of gas detected Requires sufficient O2 to support operating principle High power consumption Fail unsafe operation

NDIR Combustible Gas Sensor: (AKA non-dispersive infrared or NDIR) measure hydrocarbon gases and

carbon dioxide. Detectors are sensitive to varied infrared wavelength ranges. The gas of interest and inert reference gas are exposed to infrared light; amount of light transmitted through each sample is compared to determine gas of interest concentration. A micro-processor monitors signals ratio and correlates results to a readable signal. Advantages

of 297

Does not require presence of O2 Not affected by poisons or inhibitors Lower power consumption than catalytic bead sensor very stable Normally fails safe Sensor available for100% v/v CH4 5 year MTBF - lower cost of ownership over lifespan

Limitations Cannot detect hydrogen, acetylene, carbon disulfide Higher Upfront Cost (4X) Affected more by changes in temperature and pressure. Response is linear to methane but non-linear to other hydrocarbons

PID (Photo-Ionization Detection) Volatile Organic Compound Sensor: PID provides broad range detection for multiple applications:

Rapid screening technique for initial area hazard assessment HAZMAT Response teams Monitoring and data acquisition of human exposures in the workplace Environmental consulting/assessment – soil remediation Aircraft wing tank entry Detection of aviation fuel vapors Detection of diesel fuel vapors Additional level of broad band detection of VOCs that may be encountered

in confined space entry Building management companies for screening “bad” air complaints from

tenants Advantages

Relatively low cost detection of a wide range of toxic VOCs to PPM levels – be aware of the lowest detectable limit capability Accurate and linear over sensor detection range; but readings are

relative to the gas used for calibration Does not require presence of O2

Limitations VOCs usually detected by means of broad range sensors Broad range sensors provide overall reading for general class or group

of chemically related contaminants Unable to identify species of gas being detected Sensor maintenance may be required Response is linear to methane but non-linear to other hydrocarbons

of 297

Public Input No. 148-NFPA 350-2016 [ Section No. A.8.4.2.2 ]

A.8.4.2.2

Where flammable vapors or gases might be present, fans, blowers, and eductors are usually air or steampowered. If electrically driven equipment is used it should be intrinsically safe (explosion proof) inspectedand approved for use by a qualified person.


need to have explosion proof if electrical equipment is allowed for use




Street Address:

City:

State:

Zip:



269 of 282 2/22/2017 2:45 PM

of 297


A.8.4.2.5

Examples of harmful chemical residues include, but are not limited to, corrosive materials such as causticpotash, caustic soda, hydrofluoric acid and hydrochloric acid; pesticides such as chlordane and Aldrin;heavy metals such as lead and arsenic; flammable or explosive materials such as flammable liquids, fueloil or solvents; and pyrophoric materials and biological hazards such as bacteria, viruses, and parasites.


adds additional indformation




Street Address:

City:

State:

Zip:



270 of 282 2/22/2017 2:45 PM

of 297


A.8.6.2

Within the United States, 29 CFR 1910.147 provides requirements for preventing accidental startup ofequipment and machinery or the release of stored electrical, mechanical, pneumatic, or other energy.29 CFR 1910.333 has specific requirements for de-energizing and locking out electrical equipment. Withinthe U.S. and in other areas, NFPA 70E provides comprehensive electrical safety information to preventshock, arc, and other electrical safety hazards. In addition, API 2016, Guidelines and Procedures forEntering and Cleaning Petroleum Storage Tanks, and API 2217A Guidelines for Safe Work In InertConfined Spaces in the Petroleum and Petrochemical Industries provides information for isolating tanks,vessels, and equipment in the petroleum and petrochemical industry for safe entry and work.


adds 2217A for inert spaces




Street Address:

City:

State:

Zip:



271 of 282 2/22/2017 2:45 PM

of 297


A.9.1.3

The Entry Supervisor and qualified Ventilation Specialist should understand the differences betweenventilation, purging, and inerting. They should be able to select the appropriate hazard control methodnecessary for removing or controlling a hazardous atmosphere within the confined space. While the termsare frequently used interchangeably, they are distinct hazard control methods. Ventilation generallyintroduces fresh, uncontaminated air into a space and controls atmospheric contaminants in that the spacethrough mixing and dilution. Purging uses steam, or inert gas to create a safe or nonexplosive atmospherein the space by dispersion, mixing, or dilution. Inerting is the use of an inert gas or flue gas to displace orexpunge the atmosphere within the space. Purging typically uses water, fuel oil, steam, or nonreactivechemicals to physically displace the atmosphere within the space. (See Section 9.3 for guidance onappropriate methods of ventilation.)


redundant and misleading. purging is explained in last e=sentence




Street Address:

City:

State:

Zip:



272 of 282 2/22/2017 2:45 PM

of 297

Public Input No. 152-NFPA 350-2016 [ Section No. A.9.2.2.1.2.1 ]

A.9.2.2.1.2.1

The Entry Supervisor or permit issuer should evaluate and determine safe locations for dispersement ofexhausted atmosphere, depending on the hazard. For example, flammable and combustible vapors thatare permitted to be exhaudted to the atmosphere should be discharged at least 12 ft above the surfacelevel so that they can disperse before reaching any sources of ignition at ground level.


adds qualifier




Street Address:

City:

State:

Zip:



273 of 282 2/22/2017 2:45 PM

of 297


A.9.5.9

Purging can Inerting can be used to displace high concentrations of flammable vapors from a space duringthe cleaning and gas-freeing stage of the process. The objective is to introduce the inert gas so that itdisplaces the flammable vapors to approximately the LEL for the material before introducing fresh air intothe space to bring the oxygen level up to fresh-air levels. Typically, the inert gas is used to displace theflammable vapor concentration to about 1 percent by volume in air. At this point, where air is introduced toremove the remaining vapor concentration and raise the oxygen concentration level, the flammable vaporand air mixture will not be within the flammable range — it will be at a concentration below the LEL — sothere will be no danger of a fire or explosion. Typical inert gases used are carbon dioxide, nitrogen, andargon. Proper application for this process requires knowledge of the space configuration and openings andthe gas selection. Carbon dioxide and argon are both heavier-than-air gases, while nitrogen is slightlylighter-than-air. Selection of the inert gas might depend on what openings are used for introducing the inertgas and how the flammable vapors are vented from the space or captured and treated if environmentalrequirements prohibit emissions. The source of the inert gas can also impact the implementation of thepurging process. As also noted in 9.3.4.3, purging inerting can be used to prepare an area within aconfined space (e.g., piping or other hollow structure) or a confined space for hot work where cleaningcannot be effectively accomplished. In this application, the inert gas is used to displace the oxygenconcentration to a level below that which will support combustion. It is necessary to reduce the oxygen levelto below the limiting oxidant concentration (LOC), which for many petroleum-based materials isapproximately 14 to 16 percent by volume. NFPA 306 and NFPA 326 establish a factor of safety below theLOC by requiring that the oxygen concentration be below 8 percent by volume or 50 percent of the LOC,whichever is least.


this procedure is inerting not purging. purging uses steam, water, etc see A 9.1.3




Street Address:

City:

State:

Zip:



274 of 282 2/22/2017 2:45 PM

of 297

Public Input No. 79-NFPA 350-2016 [ New Section after A.10.9.1(2) ]

TITLE OF NEW CONTENT A 10.9.1 (3)

Type your content here ...A 10.9.1.(3) The attendant may be the assigned attendant identified onthe confined space entry permit.


there is no need for an additional attendant if the original attendant is available and capable




Street Address:

City:

State:

Zip:



275 of 282 2/22/2017 2:45 PM

of 297


A.11.4.2

It is common practice in industry that the permit issuer and the Entry Supervisor are often different persons,especially where contractors are doing the entry work in a manned facility. In such cases, the permit issuermay be a facility employee who initiates the permit according to facility confined space programrequirements. Once the permit requirements are met, the issuer and the Entry Supervisor (and tester) thensign off on the permit. The Entry Supervisor controls the entry and operations in accordance with thepermit requirements and can cancel the permit if the conditions change. Where a single entity has totalresponsibility for the entry and work, the permit issuer and Entry Supervisor may be the same person.


Committee recommended edit to remove this information as it may confuse readers. Also, if we introduce the Permit Issuer, we need to cover those roles / responsibilities, etc.




Street Address:

City:

State:

Zip:



276 of 282 2/22/2017 2:45 PM

of 297

Public Input No. 232-NFPA 350-2017 [ New Section after A.11.7.2.10 ]

A.11.7.2.3

Owner/Operators should train or educate and qualify employee personnel who are assigned to performconfined space operations.


Moved misplaced information from main body to supplement the information in this section




Street Address:

City:

State:

Zip:



277 of 282 2/22/2017 2:45 PM

of 297

Public Input No. 243-NFPA 350-2017 [ New Section after A.11.7.2.10 ]

A.11.7.2.5

The Entry Supervisor is typically assigned this responsibility (see Section 11.4.2.7).


This duty is normally done by Supv. Information is for clarification and connecting the responsibilities together between O/O and Supv.




Street Address:

City:

State:

Zip:



278 of 282 2/22/2017 2:45 PM

of 297


A.11.7.2.10

Equipment may include, but is not limited to the following:

(1) Testing and monitoring equipment and calibration materials

(2) Ventilating equipment

(3) Communications equipment

(4) PPE and respiratory protection

(5) Air suppplied breathing appratur and air supply cylinders or approved air supply compressors

(6) Lighting equipment

(7) Barriers, guards, warning signs, and shields

(8) Equipment, such as ladders, needed for ingress and egress

(9) Rescue and emergency equipment needed to comply with the confined space program requirements(except the equipment provided by rescue services)

(10) Any other equipment necessary for authorized work in and around the confined space


adds air supply




Street Address:

City:

State:

Zip:



279 of 282 2/22/2017 2:45 PM

of 297

Public Input No. 3-NFPA 350-2016 [ Chapter E ]

Annex E Informational References

E.1 Referenced Publications.

The documents or portions thereof listed in this annex are referenced within the informational sections ofthis guide and are not advisory in nature unless also listed in Chapter 2 for other reasons.

E.1.1 NFPA Publications.

National Fire Protection Association, 1 Batterymarch Park, Quincy, MA 02169-7471.

NFPA 30, Flammable and Combustible Liquids Code, 2015 edition.

NFPA 70, National Electrical Code, 2014 edition.

NFPA 70E, Standard for Electrical Safety in the Workplace, 2015 edition.

NFPA 306, Standard for the Control of Gas Hazards on Vessels, 2014 edition.


NFPA 497, Recommended Practice for the Classification of Flammable Liquids, Gases, or Vapors and ofHazardous (Classified) Locations for Electrical Installations in Chemical Process Areas, 2012 edition.

NFPA 499, Recommended Practice for the Classification of Combustible Dusts and of Hazardous(Classified) Locations for Electrical Installations in Chemical Process Areas, 2013 edition.

E.1.2 Other Publications.

E.1.2.1 ACGIH Publications.

American Conference of Governmental Industrial Hygienists, 1330 Kemper Meadow Drive, Cincinnati, OH45240-1634.

Threshold Limit Values for Chemical Substances and Physical Agents, 2006.


280 of 282 2/22/2017 2:45 PM

of 297

E.1.2.2 ANSI Publications.

American National Standards Institute, Inc., 25 West 43rd Street, 4th Floor, New York, NY 10036.

ANSI/CGA 7.1, Commodity Specification for Air , 1989.

E.1.2.3 API Publications.

American Petroleum Institute, 1220 L Street, NW, Washington, DC 20005-4070.

API RP 500, Classification of Locations for Electrical Installations at Petroleum Facilities Classified asClass I, Division 1 & Division 2 ,

1998

2012 with 2014 errata .

API RP 2003, Protection Against Ignitions Arising Out of Static, Lightning, and Stray Currents ,

2008

2015 .

ANSI/API

API STD 2015, Requirements for Safe Entry and Cleaning of Petroleum Storage Tanks ,

2001

2014 .

ANSI/API

API RP 2016, Guidelines and Procedures for Entering and Cleaning Petroleum Storage Tanks , 2001 ,reaffirmed 2006 .

API RP 2027, Ignition Hazards Involved in Abrasive Blasting of Atmospheric Storage Tanks inHydrocarbon Service, 2002 , reaffirmed 2012 .

API

API STD 2217A, Guidelines for Safe Work in Inert Confined Spaces in the Petroleum and PetrochemicalIndustries, 2009.

API 2219, Safe Operation of Vacuum Trucks in Petroleum Service , 2005 , reaffirmed 2012

E . 1.2.3 CGA Publications.

Compressed Gas Association, 14501 George Carter Way, Suite 103, Chantilly, VA 20151-1788.

CGA G- 7.1, Commodity Specification for Air , 2011 .

E.1.2.4 CSA Publications.

Canadian Standards Association CSA Group , 178 Rexdale Blvd., Toronto, ON, M9W 1R3, Canada.

CSA Z1006-10, Management of Work in Confined Spaces, 2015.

E.1.2.5 U.S. Government Publications.

U.S. Government Publishing Office, 732 North Capitol Street, NW, Washington, DC 20402 20401-0001 .

Title 29, Code of Federal Regulations, Part 1910, "Occupational Safety and Health Standards."

E.1.3 Other Publications.

CDC, NIOSH, Fatality Assessment and Control Evaluation (FACE) reports.

International Chamber of Shipping, International Safety Guide for Oil Tankers and Terminals, 2006.

E.2 Informational References. (Reserved)

E.3 References for Extracts in Informational Sections. (Reserved)


281 of 282 2/22/2017 2:45 PM

of 297


Referenced current SDO names, addresses, standard names, numbers, and editions.



Public Input No. 2-NFPA 350-2016[Chapter 2]

Referenced current SDO names, numbers, standard names,numbers, and editions.


Submitter Full Name: Aaron Adamczyk

Organization: [ Not Specified ]

Street Address:

City:

State:

Zip:

Submittal Date: Tue May 31 23:37:28 EDT 2016


282 of 282 2/22/2017 2:45 PM

of 297