January 1992 (1st revision)
August 1995 (2nd revision)
November 1996 (3rd revision)
Modified for Web Page September 1998
April 2007 (4th revision)
August 2012 (5th revision)
February 2013 (6th revision)
January 2018 (7th revision)
Office of Safety and Environmental Programs
School of Marine Science
Virginia Institute of Marine Science
College of William and Mary
Gloucester Point, Virginia 23062
- OCCUPATIONAL HEALTH PROGRAM
- GENERAL SAFETY REQUIREMENTS
- Compliance with Safety Regulations
- Safety Training
- Two-Person Rule
- Refrigerators and Freezers
- Slippery Surfaces
- Painting and Spraying
- Compressed Air
- Compressed Gas Cylinders
- Work Clothing
- Portable Tools and Insulation
- Electrical Work
- Lockout/Tagout Procedures
- Working Over, Near, or On the Water
- Confined Space Entry Procedures
- Machinery and Machine Guarding
- Fall Protection
- ASBESTOS MANAGEMENT
- PERSONNEL PROTECTION PROGRAM
- PLAN REVIEW
- Authority and Reference
- Responsibility of Compliance
- Energy Control Procedures
- Equipment for Lockout/Tagout
- Sequence of Lockout
- Group Lockout
- Restoring Equipment to Service
- Abandoned Lock Removal Procedures
- Periodic Inspection
- Outside Personnel (Contractors, Ect.)
- Shift or Personnel Changes
- PERMIT REQUIRED CONFINED SPACE SAFETY PRECAUTIONS
- TRAINING REQUIREMENTS
- CONFINED SPACE ENTRY PERMIT - HAZARDOUS AREA ENTRY PERMIT
The Williams-Steiger Occupational Safety and Health Act of 1970 went into effect April 28, 1971 and was adopted by the Commonwealth of Virginia on March 1, 1974. The purpose of this act is to assure every worker safe and healthful working conditions. All rules, regulations, and standards developed and required by the Occupational Safety and Health Administration (OSHA) and the Virginia Department of Labor and Industry will be observed by personnel assigned to the Virginia Institute of Marine Science/School of Marine Science (VIMS/SMS), contractors, vendors, and visitors within the geographical areas of VIMS/SMS responsibility. Visitors to any construction area, shop, vessel, or other area where injury may be likely due to the nature of the activity in progress, must either provide their own protective equipment or be provided with same by the person authorizing the visit.
State and federal laws provide stiff penalties for both employers and individual supervisors who violate safety and health laws. Penalties for such violations may include personal liability for executives and supervisors punishable by fines and/or imprisonment. Employees are expected to be familiar with the general safety requirements of this plan and specific rules as required and approved by individual departments. Deliberate violations may be subject to disciplinary action.
It is the policy of VIMS/SMS to implement fully the Occupational Safety and Health Program for all faculty, staff, and students.
In order to comply with state and federal requirements, this written plan has been developed for VIMS/SMS. All departments and centers are included in this plan. All VIMS/SMS personnel are required to become familiar with the contents of this plan. This plan is available over the VIMS/SMS computer system.
This plan covers those aspects of safety not addressed in the VIMS/SMS Emergency Response Plan, Fire Prevention Plan, Chemical Hygiene Plan, Hazard Communication Standard Training Plan, Diving Safety Manual, Radiation Safety Plan, Respiratory Protection Plan, and other documents.
C. Responsibility and Authority
1. Dean and Director
The Dean and Director is responsible for the safety and health of all personnel assigned to VIMS/SMS.
2. Director for Safety and Environmental Programs
The Director for Safety and Environmental Programs is directly responsible to the Chief Operations Officer for establishing, coordinating, directing, and evaluating the effectiveness of the Safety and Occupational Health Program for VIMS/SMS. The Director for Safety and Environmental Programs is vested with the authority to inspect all VIMS/SMS operations and activities as well as records and, in addition, to take immediate steps to stop any operation or hazardous practice where there appears to be impending danger of serious injury or death or serious damage to equipment, material, or facilities.
3. All Department/Center Heads and Supervisors
Safety and health are paramount responsibilities at each management level. Each member of the management team has a personal and individual responsibility for the safety and health of all persons who report to them or are assigned to them for special purposes. Supervisors shall ensure that all personnel who report to them are instructed in and carry out applicable safety and health precautions for their work and work areas. In carrying out this responsibility the Office of Safety and Environmental Programs shall be called upon for assistance as required. However, this in no way reduces each manager's prime responsibility for safety or his/her obligation to ensure that safety is incorporated into all activities, processes, equipment, and operating procedures under his/her control.
4. Each Individual
Each individual has an inherent responsibility from which he/she cannot be absolved for his/her own personal safety and health as well as the safety and health of those with whom they are associated in a work environment. Each individual is responsible for knowing, understanding, and observing all safety and health precautions applicable to his/her work area. Failure to comply with the Occupational Safety and Health Plan and with other safety and health practices and procedures may be grounds for disciplinary action. Injuries incurred as a result of such a failure might not be covered by Workers' Compensation.
II. OCCUPATIONAL HEALTH PROGRAM
The purpose of the Occupational Health Program is to create and maintain safe and healthful working conditions for all VIMS/SMS personnel. This section will provide basic information on the recognition, evaluation, and control of occupational health hazards to which employees may be exposed. Environmental factors and stresses in the work place which influence the health of the worker include chemicals in the form of liquids, dusts, fumes, mists, vapors, and gases; physical agents such as ionizing radiation, microwaves, noise, vibration, extremes of temperature and illumination; biological agents such as insects, molds, fungi, and bacteria; and ergonomic factors including monotony, repetitive motion, and fatigue.
B. Health Services
1. Emergency Treatment of Illness/Injury on the Job
The Abingdon Volunteer Rescue Squad, Inc. provides emergency treatment and transport services when available. Transportation by the Rescue Squad will only be to a hospital emergency room. If a worker does not wish to be transported by the rescue squad after the squad has arrived and made an assessment of the illness/injury, the individual will be required to sign a release form stating that treatment/transport is not desired from the Rescue Squad. It then becomes the individual's responsibility to arrange for appropriate transportation if medical treatment is desired or needed. It must be kept in mind that injuries to limbs or an altered level of consciousness/awareness which would impair the proper operation and control of a motor vehicle will prohibit the individual from driving themselves to obtain emergency care. Transportation must then be provided by a state vehicle and driver from the individual's work center or by a fellow worker. Care of minor injuries can be obtained at the Office of Safety and Environmental Programs. Emergency assistance can be obtained in accordance with the tag on or near every VIMS/SMS telephone.
2. Reporting of Injuries
All on the job injuries must be reported as soon as possible to the Workers' Compensation Program representative.
3. Medical Examinations
Medical examinations for personnel who have been exposed to health hazardous conditions are an essential part of the occupational health program. These examinations shall be specific for the type of exposure or operation involved. Persons who know they have been exposed or suspect exposure must notify their supervisor and the Office of Safety and Environmental Programs immediately. It is imperative that persons who have been exposed to a harmful contaminant which presents the possibility of contaminating other persons and/or the work area remain in an isolated area, if at all possible, until proper assistance is obtained.
C. Employment of Pregnant Women
Employees should notify their supervisors as early as possible should they become pregnant in order to facilitate a work assignment suitability survey regarding health and safety factors. Pregnancies shall be referred to Human Resources so specific job limitations can be recommended if necessary after consultation with the individual's physician.
D. Handicapped Employees
Architectural barriers should be eliminated and a 'buddy" system developed to assure that employees can be mobile in an emergency. The Uniform Federal Accessibility Standards developed under the Architectural Barriers Act, 42 U.S.C. 4151-4157 and 36 CFR Part 119, Americans with Disabilities Act (ADA), contain all applicable standards
III. GENERAL SAFETY REQUIREMENTS
Personnel safety shall be paramount in all operating procedures to assure maximum practical protection for personnel and to prevent unnecessary exposure to injury and health hazards. Accordingly, it is the responsibility of all concerned to comply with established safety rules and regulations. Management and supervisory personnel at all levels are responsible for assuring that sound safety precautions are understood and carried out in their work areas. Coverage of items in this section is limited to basic guidance in some of the essential areas of safety and health which are generally applicable to all areas of VIMS/SMS. It is emphasized that these are basic requirements to good safety and health performance and do not represent a comprehensive safety and health program for every area.
A. Compliance with Safety Regulations
All VIMS/SMS personnel will observe all safety and health rules and regulations. All personnel will be responsible for warning others when it is believed that they are endangered by known hazards or by their failure to comply with applicable safety and health precautions. Safety and health precautions must not be subordinated or disregarded because of the urgency of a particular job.
B. Safety Training
Supervisors must ensure that all new or reassigned personnel are instructed in safe methods of performing particular tasks prior to starting and during the early stages of each new job. A general safety briefing will be held in conjunction with the Hazard Communication Standard training for every new person checking in.
C. Two-Person Rule
The two-person rule applies whenever dangerous experiments or other potentially life-threatening operations are being performed. No one shall work alone if there is any reason to believe that a situation may develop where the person could not summon assistance within a reasonable time or where assistance from another person would not be available in case of an accident.
When the distance or physical arrangement separating employees is great enough to prevent visual observation or voice communication for long periods, the activities shall be restricted to those with a low probability of an incapacitating accident of such magnitude that help cannot be summoned in a reasonable period of time.
D. Refrigerators and Freezers
Flammable liquids or chemicals capable of giving off flammable or explosive vapors which require refrigeration will not be placed in domestic-type refrigerators. Such material shall be stored in explosion-proof refrigerators. In such confined spaces a very small quantity of flammable liquid can develop into an explosive atmosphere which could be ignited by the interior light switch or thermostat switch of the refrigerator. Standard refrigerators and freezers shall have a "NO FLAMMABLES" sign/label posted on the door.
At no time will food products for human consumption be stored in any refrigerator or freezer which is being used for storage of chemicals or biological samples.
High standards of housekeeping must be maintained in all shops, offices, laboratories, buildings, work areas, and surrounding grounds.
All work areas, especially laboratory counters or benches which are used by several persons and/or which might contain potentially hazardous materials, must be kept clean and neat.
Floors will be kept free from holes and obstructions, especially where the floors form part of the aisles or walking spaces. It is essential that floors are not littered with small objects, such as scraps of metal, nails, and tools.
Aisles, passageways, stairways, and exits shall be kept clear at all times. All exit signs shall be suitably illuminated by a by a reliable light source.
Restrooms will be kept in a clean and sanitary condition at all times.
All VIMS/SMS provided and personal microwave ovens and refrigerators used for the cooking and storage of food shall be kept clean at all times. Failure to maintain an acceptable degree of sanitation shall be grounds for removal of these appliances.
Broken glass shall not be placed in waste baskets. It should be kept in a separate puncture-resistant container that is marked "Broken Glass Handle Carefully" for the cleaning crew to remove or taken directly to a dumpster for disposal.
Other sharp objects, such as scalpel blades, needles, and razor blades, shall be disposed of in appropriate and labeled containers. When the container is filled, the Office of Safety and Environmental Programs should be contacted to assist with proper disposal.
F. Slippery Surfaces
Surfaces which cause hazardous footing to personnel due to the presence of oil or other slippery substances will be cleaned or treated to provide good footing. Linoleum and other polished floor surfaces shall be treated with a slip resistant preparation.
Ladders will be inspected by the worker prior to each use. Ladders with broken or missing rungs, broken or split side rails, or with other faulty parts shall be removed from use and disposed of immediately. Do not place a ladder in front of a door which opens toward the ladder unless the door is locked or otherwise blocked, barricaded, or guarded. No one shall go up or down a ladder without the free use of both hands. Individuals using ladders must maintain three points of contact at all times. If handling material, a rope shall be used to raise or lower the material.
Portable ladders placed against a wall or other fixed object shall be securely fastened or held by a co-worker to prevent slippage. The ladder's base should be placed at a distance from the vertical wall equal to one-fourth the working length of the ladder in order to assure the proper angle (4:1 ratio). No ladder shall be used to gain access to a roof unless the top of the ladder extends at least three feet above the point of support, at eave, gutter, or roof line. Ladders shall not be placed on boxes, barrels, or similar unstable bases to obtain additional height. When using portable ladders on smooth floors or sloping surfaces they shall be equipped with nonslip bases.
H. Painting and Spraying
Proper preventive measures must be taken for operations involving paints, varnishes, lacquers, cleaners, solvents, plastic coatings, and other finishing materials which readily ignite at relatively low temperatures and which could cause fire and health hazards. Many of the materials used in painting and spraying are volatile and may form vapors which may produce explosive and/or toxic mixtures in the air if not removed by adequate ventilation. Conspicuous "NO SMOKING' signs shall be posted where flammable materials are used or stored. The quantity of flammable or combustible liquid kept in the vicinity of spraying operations shall be kept to the minimum required for daily use. All flammable liquids and similar materials shall be stored in approved safety containers and/or storage cabinets.
The provisions of the VIMS/SMS Respiratory Protection Plan shall be complied with at all times during any painting/spraying procedures. The plan is available in Departmental and work center offices and in the Office of Safety and Environmental Programs and is available for review on the VIMS computer network.
I. Compressed Air
Compressed air must not be used for cleaning purposes when vacuum cleaners or something safer will do the job. If not practicable or possible to use other means, compressed air may be used for cleaning when reduced to less than 30 psi and then only with eye protection and safe guarding of other personnel in the area. The use of compressed air for cleaning clothing or any part of the body at any pressure is prohibited.
J. Compressed Gas Cylinders
Compressed gas cylinders shall be stored in an upright position at all times and secured to prevent toppling. The protective caps shall be installed on all cylinders not in use. Cylinders shall not be handled, shipped, or stored without valve protection caps. Compressed gas cylinders must be kept away from excessive heat (125oF, 51.5oC) and shall not be placed where they can come in contact with an electrical circuit. Cylinders shall not be stored within twenty feet of highly combustible material.
K. Work Clothing
Clothing worn around moving machinery shall be close fitting. Neckties and other loose items shall not be worn. Long sleeves will be worn in operations involving welding or burning and in tasks where the exposure to chemicals or ultraviolet and infrared rays is likely. Long sleeves are recommended for brush cutting.
In industrial operations where there is no hazard to the upper arms, short sleeve shirts and blouses may be worn provided they cover the upper torso. All personnel working in industrial operations shall wear trousers, slacks, or coveralls which cover the lower extremities.
Safety shoes are required for all personnel involved in work which has the potential for crushing or lacerating foot injuries. This includes personnel in shops, outside maintenance/grounds and others as determined. This requirement is more fully addressed in the section on personal protective clothing.
Persons working in laboratories shall wear appropriate clothing. Lab coats or aprons should be worn for the majority of operations especially when there is a possibility of splash or spill. Similarly, footwear that provides protection from splash and spill should be worn at all times in laboratories. Going "bare foot" in any laboratory is forbidden. As open-toed shoes, sandals, and "flip-flops" provide no protection from splash or spill, they also are forbidden. Routine cleaning of lab coats and aprons is the responsibility of the individual user.
Persons working in the water should wear appropriate clothing or equipment. Footwear is especially important for person wading where there is any potential for material on the bottom that might lacerate unprotected feet.
1. Portable Tools and Insulation
All electrically powered portable tools shall be inspected prior to use. Tools with frayed cords, broken ground prongs, etc., shall not be used. All portable electrical powered tools shall have insulation and ground tests done on a regular basis. Conductivity tests shall be performed on all electrical protective equipment at prescribed intervals.
2. Electrical Work
All electrical work shall be performed in accordance with published OSHA standards for Electrical Safety-Related Work Practices. 29 CFR 1910.331 through .335, National Fire Protection Association (NFPA) 70 National Electrical Code, and NFPA 70E Electrical Safety Requirements for Employee Workplaces as amended. It is the responsibility of all electrical/electronic maintenance and repair personnel and their supervisors to become familiar with the procedures in the above publications and to employ the mandated safe work practices.
Working on exposed circuit/parts that are energized will not be permitted unless the workers are qualified and trained to do so. Safety related work practices shall be used to prevent electric shock or other electrically induced injuries. Qualified workers are those who have been trained to work safely on energized circuits and, when appropriate, to use the proper personal protective equipment, insulating and shielding materials, and insulated tools. Two workers, one of whom must be trained in CPR, shall work together any time work must be performed on high voltage energized circuitry or equipment.
All routine electrical/electronic maintenance/repair work will employ mandatory lockout/tagout procedures as specified in paragraph M below.
All electrical/electronic repair personnel shall be trained in CPR and will participate in refresher training every 2 years in accordance with the American Heart Association Standard.
M. Lockout/Tagout Procedures
OSHA Standard 29 CFR 1910.147, the Lockout/Tagout Standard, covers situations where injury could be caused by unexpected startup, energization, or release of stored energy while a machine or piece of equipment is being serviced or repaired. The standard requires that each piece of equipment be examined to determine what energy source needs to be locked out and that an energy control program be developed consisting of documented:
1: energy control procedures
2: periodic inspection
The standard does not apply to work on cord and plug connected electric equipment for which exposure to the hazards of unexpected energization or startup of the equipment is controlled by unplugging the equipment from the energy source and by the plug remaining under the exclusive control of the person performing the servicing or repair.
The VIMS/SMS lockout/tagout program along with specific details and forms are in Appendix A.
N. Working Over, Near, or On the Water
Employees working over or near water, where the danger of drowning exists, shall be provided with U.S. Coast Guard approved personal flotation devices (PFDs). Prior to and after each use, the PFDs shall be inspected for defects which would alter their strength or buoyancy. Defective units shall not be used and shall be returned to Field Operations for repair or replacement.
At least one lifesaving skiff shall be immediately available at locations where employees are working over or adjacent to water.
O. Confined Space Entry Procedures
Confined spaces are among the more dangerous work environments. A "confined space" may be generally defined as any area which has limited means of egress, is subject to an oxygen deficient or enriched atmosphere or to the accumulation of flammable or toxic gases or vapors, and is configured so as to make rescue difficult. OSHA Standard 29 CFR 1910.146 provides definitive guidelines relative to entering/working in a confined space in addition to specific mandates dealing with the required training and emergency equipment required to support this type of work.
Examples of confined space working areas at VIMS/SMS include sewers, pits/sumps, chemical/septic waste tanks, vessel voids/bilges, trenches over 4 feet deep, elevator shafts, ventilation ducts, and man holes.
The VIMS/SMS detailed confined space entry program will be found in Appendix B.
P. Machinery and Machine Guarding
For most applications machine guarding is an engineering control method that is the best of several of available options for protecting personnel working around machinery and equipment. The installation of machinery and machine guards is a governing factor in controlling and preventing accidents and injuries. The selection of a guarding method to be used if the machine does not have a manufacturer's installed guard may depend on a number of things such as space limitations; size of stock, and frequency of use. The following general guidelines are provided to assist in that selection. For detailed information consult OSHA Standard 29 CFR 1910.211.
Design and construction characteristics of machine guards include:
1. The guard must be considered a permanent part of the machine or equipment.
2. The guard must afford positive protection. Personnel should not be able to reach a hazard by reaching into, over, under, or through a properly designed and installed guard.
3. The guard must prevent access to the danger zone during operation of the equipment.
4. The guard must be as convenient as possible and must not interfere with normal operation of the machine or maintenance functions. This may include hinging guards to allow for access, using drift pins, latches, or minimizing the number of cumbersome attachments
5. The guard should be designed for the specific job and specific machine, with provisions for lubricating, inspecting, adjusting, and repairing the machine.
6. The guard must be durable and constructed strongly enough to resist normal wear.
7. The guard must not present a hazard in itself.
8. The guard should not be easily bypassed or defeated. The use of "dead man" controls is the preferred method because if the safety device fails or is bypassed, the machine will not present a hazard to personnel.
Under no circumstance shall any VIMS/SMS machine guard be removed to simplify operator use. Nor, shall any VIMS/SMS machine/machinery be operated without the required guard being in place. If required guards are to be serviced or removed to permit service, lockout/tagout procedures must be followed accordingly.
Q. Fall Protection
When work is performed on elevated surfaces protective measures may need to be utilized to protect employees from injuries by falls. Guard rails are often employed for large projects to prevent falls from one level to another but may not be feasible for all projects. In the case of a maintenance activity, it may be beneficial to employ a Fall Arrest System to safeguard workers.
Fall Arrest Systems typically consist of a Body Harness, a Shock Absorbing Lanyard or Retractable Lifeline and a Tie-off Point. These Systems are designed to arrest a free fall should a worker slip from an elevated work site and they also function to minimize forces imposed on the worker as the Fall Arrest System activates and checks the fall.
The Office of Safety & Environmental Programs offers assistance in identifying and evaluating fall protection issues and training in fall protection. Details on the VIMS/SMS Fall Protection Program in Appendix D.
Asbestos is a general term applied to a variety of naturally occurring mineral silicates which are separable into fibers. There are six forms of asbestos with specific attributes and characteristics of commercial importance. They are chrysotile, amosite, crocidolite, tremolite, anthophyllite, and actinolite. Asbestos generally is a fibrous material which is incombustible and possesses high tensile strength, good thermal and electrical insulating properties, and moderate to good chemical resistance. Because of these characteristics, asbestos has been employed in many uses including roofing and flooring products, friction products (brake and clutch facing), reinforcing material in cement, pipe, and sheet materials, a thickening agent in some paints, surfacing materials, and thermal and acoustical insulations (TSIs).
Asbestos now is recognized as a major health hazard. Latency periods of twenty to forty years between asbestos exposure and the first symptoms is typical. Inhalation of asbestos fibers has been demonstrated to cause three primary respiratory diseases, two of which are distinct to asbestos.
Asbestosis is a progressively restrictive fibrosis of the lung and is recognized as a classic disabling or even fatal occupational disease. Asbestos also has been found to be a cause in the development of carcinoma of the lung, particularly malignant mesothelioma. Mesothelioma, a rare malignant tumor of the lung membrane which lines the chest and abdominal cavity, occurs with increasing frequency in workers with exposure to asbestos. Mesothelioma can also occur to “bystanders”, or individuals exposed to workers with asbestos exposure. When coupled with cigarette smoking, the risk of mesothelioma and lung cancer increases dramatically. In addition to these respiratory diseases, asbestos is suspected of causing cancer of the gastrointestinal tract.
Asbestos and materials containing asbestos shall not be used in any building or maintenance application. In locations where asbestos materials are presently installed and are properly sealed/bonded and maintained, rip-out work shall not be performed for the sole purpose of eliminating asbestos. An appropriate O&M program should be in place for facilities containing asbestos to ensure existing sources are safely maintained.
The Surgeon General of the United States has determined that using tobacco products is a leading cause of illness and death. The Commonwealth of Virginia recognizes the right of individuals working or visiting in state buildings to an environment free of contaminants.
The VIMS/SMS policy is to ensure a healthy working environment for all workers. Since December 1992, smoking has been forbidden in all areas of all buildings, including individual offices, and enclosed spaces (automobiles, trucks, vessel cabins, aircraft, etc.) under the management control of VIMS.
Valid, documented, legitimate complaints by non-smoking and smoking employees are of equal concern and will be dealt with on an individual basis. The Office of Safety and Environmental Programs will serve as the functional point of contact and provide assistance or recommendations to the Dean and Director for any employee complaints or concerns about this policy.
VI. PERSONNEL PROTECTION PROGRAM
Whenever possible, processes, equipment, and environments should be designed and arranged so as to prevent or minimize hazardous exposure to personnel. When this is not feasible, approved personal protective equipment (PPE) will be provided, and individuals will be instructed in its proper use and limitations. Once personal protective equipment is provided, its use must be enforced by supervisory personnel. The importance of determining and selecting the proper protective equipment cannot be overemphasized. Only approved, properly fitted personal protective equipment will be used. The Office of Safety and Environmental Programs will provide assistance in determining the type of personal equipment required in any VIMS/SMS area. Personal protective equipment will not be used in hazardous areas or where hazardous conditions exist until it has been determined that the individual can wear the equipment without endangering his/her health. Personal protective equipment shall be furnished by VIMS/SMS through the respective department or shop and the individual's supervisor without cost to the individual.
The supervisor of each work center shall be responsible for determining the quantity of personal protective equipment required and for control of such equipment issued to its personnel. Supervisory personnel are responsible for training their personnel in the selection, use, inspection, and care of personal protective equipment required for their unique work situations, and for maintaining records of such training. Proper equipment storage must be provided to protect against environmental conditions which might degrade the effectiveness of the equipment or result in contamination during storage.
The Personnel Protection Program consists of the following areas: Respiratory Protection, Protective Headgear, Sight Conservation, Hearing Conservation, Hand Protection, and Foot Protection as outlined in the following sections. In depth information on each program can be obtained from the Office of Safety and Environmental Programs.
A. Respiratory Protection
The Respiratory Protection Program is a system whereby respirators will be properly selected, used, and maintained in a manner which will protect employees from hazardous and oxygen- deficient atmospheres in the workplace. The requirements for an acceptable Respiratory Protection Program are defined in OSHA's Respiratory Protection Standard 29 CFR part 1910.134. The Respiratory Protection Plan provides specific details.
B. Protective Headwear
Approved protective headwear (hard hats) shall be worn by all personnel working where there is danger of head injury from impact, falling or flying objects, or electrical shock and burns. Protective headwear shall also be worn by operators of materials handling equipment, personnel engaged in construction work, warehousing, personnel working in excavations, and all personnel using pickaxes, sledge hammers, and chains.
Hard hats are rigid head gear of varying materials designed to protect the worker's head, not only from impact but from flying objects and electric shock or any combination of the three. All approved hard hats must meet the specifications of the American National Standard requirement for Protective Headwear for Industrial Workers, Z89.1-1981 and shall be so identified on the inside of the head shell with name of the manufacturer, the American Standard designation, and class - for example: Manufacturer's name --- ANSI Z89.1-1981 Class B. Metal or light plastic "bump caps" do not fit in the category of approved hard hats and therefore shall not take the place of such equipment. Head protection worn by personnel exposed to electrical shock and burn hazards shall be specifically approved for electrical work hazards. Work center supervisors must ensure that all personnel who work in "Hard Hat Areas" or in occupations which require protective headwear are issued a properly fitting, nonmetallic safety hard hat in accordance with the provisions of this section. Hard hats must not be worn over caps (except winter liners) or hats.
The hard hat's internal suspension system must be worn in the proper orientation on the worker's head so as not to lessen the effectiveness of the protection. It is the user's responsibility to ensure that the suspension straps are properly installed, and that the hat fits properly and is free of cracks, holes, or other imperfections which will negate its protective qualities. Since the effectiveness of hard hats depends upon their structural strength, no ventilation holes, openings, cutting of brims, or other alterations are to be made to any hard hat.
C. Sight Conservation
Personnel engaged in eye hazardous work or research shall be provided with the appropriate type of eye protective equipment in consonance with the assigned task. Eye hazardous operations are defined as any task, assignment, or operation that presents danger, however remote, to the eyes of the worker or those individuals within ten feet of impact, loose foreign bodies, glare, chemical infiltration, injurious radiation, or any combination of the above. Eye hazardous areas are defined as those in which there are sufficient overlapping eye hazardous operations to present a general risk of injury to personnel entering or working therein. Anyone entering an eye hazardous area must wear approved eye protection at all times.
The type of eye protection for each work center will be determined by the work center supervisor based on the type of protection required. In general, the following types can be considered for use:
1. General use - Spectacles with side shields for operations in which foreign bodies may be expected to come from the side of the worker or where personnel engaged in eye hazardous work are working closely together.
2. Corrective Eyewear - Most work centers would find it cost prohibitive to order safety spectacles with optically corrective lenses. Cover goggles which can be worn over the workers regular spectacles should be considered.
3. Welding, Cutting, and Brazing - These operations require special filtered lenses of varying shades dependent upon the type of work being performed. Specific recommendations can be obtained from the Office of Safety and Environmental Programs.
4. Banding and Unbanding - Eyes can be protected by using approved goggles or safety glasses with full-cup side shields. An approved face shield is also available to provide face protection when used in conjunction with appropriate eyewear.
5. Impact Hazard Goggles and Spectacles - Eyecup goggles with glass lenses or plastic enclosed eye-shields are appropriate for heavy impact and large particles, such as in chipping, caulking, sledging, etc. Spectacle goggles may have leather, plastic, or wire mesh side shields that cannot easily be removed and are appropriate for moderate impact and small particles such as in scaling, grinding, woodworking, machine operation, and general work. One piece plastic eye shields are for moderate impact and sparks.
6. Impact and Chemical Face Shields - Shields, curved to cover the face area, provide general protection from flying particles, sprays, sparks, etc. Goggles worn underneath when the eyes require more positive protection. Nonconductive types are made without metal for use by electrical workers.
7. Harmful Liquids and Fine Dusts - Chemical hazard goggles shall be used for work involving chemicals and for any operation which produces fine dust or hazardous and irritating liquids. In conditions where chemicals are concentrated or where splash hazard are continuous, the goggles should be worn under a face shield for greater protection.
It shall be the responsibility of the individual and the work center supervisor to ensure that personal protective eyewear is maintained in a clean and fully operational condition, and that it is used while performing eye hazardous operations. The Office of Safety and Environmental Programs will assist any work center or individual in selecting the proper type of protective eyewear.
D. Hearing Conservation
Noise is one of the most pervasive occupational health problems. Exposure to high levels of noise causes temporary or permanent hearing loss and may cause other harmful health effects as well. The extent of damage depends primarily on the intensity of the noise and the duration of the exposure. Noise induced hearing loss is an irreversible condition that progresses with increased exposure and is aggravated by the normal aging process. Susceptibility to hearing impairment due to noise varies greatly among individuals.
OSHA standard 1910.95 mandates protection against the effects of noise exposure when sound levels in excess of those shown in table G-16 of the standard. In essence, this means that personnel exposed or to impulse or impact peak levels exceeding 140 dba shall be provided with hearing protection devices. Either circumaural hearing protectors (earmuffs) or aural insert hearing protectors (ear plugs) may be used. Plain cotton is not an acceptable hearing protection device. The Office of Safety and Environmental Programs has the capability to conduct noise level monitoring and will assist in the selection of appropriate hearing protective devices.
E. Hand Protection
Hand protection shall be provided to all personnel working in operations involving heated or frigid materials, petroleum products, acids, caustics, or other chemicals that are hazardous when in contact with the skin, live electrical circuits, abrasive work, or when handling materials with sharp edges. Other hand protection may be supplied at the discretion of the work center supervisor for work involving the handling of contaminants, materials which are splintered or extremely rough surfaced, or for other special work needs. The Office of Safety and Environmental Programs will provide selection assistance as required.
F. Foot Protection
Foot hazardous operations are those which have a high incidence or potential for foot or toe injuries. Examples of work generally associated with a high incidence of foot injuries are construction, material handling, warehousing, maintenance, and grounds work. Laboratory workers are subject to spills and splashes. Safety shoes with built-in protective toe box are primarily intended to provide protection from heavy falling objects and must meet the appropriate American National Standard for Safety Toe Footwear and be labeled accordingly.
The VIMS/SMS policy is that those personnel who require safety shoes shall have them provided. Unless circumstances warrant otherwise, only one pair of safety shoes will be authorized per individual per year. It is anticipated that employees who work in areas where accelerated deterioration occurs may require more frequent replacement. On the other hand, some employees may not require yearly replacement. The individual's supervisor shall make the determination as to the continued service life of an individual's safety shoes. Questionable cases shall be referred to the Office of Safety and Environmental Programs for assistance.
As stated in the General Requirements, section III K, above, laboratory workers must wear footwear which provides protection from splashes, spills, and penetrating objects such as broken glass. Thus going "barefoot," or using open-toed shoes, sandals, or "flip flops" is expressly prohibited in VIMS/SMS laboratories.
The general atmosphere in all occupied work areas shall be ventilated by natural or mechanical ventilation or a combination thereof to ensure a comfortable work atmosphere. Ventilation requirements for hazardous atmospheres, materials, or processes must meet Federal and State Air Quality requirements as specified in current regulations. The amount of ventilation in CFM (cubic feet per minute) shall be in accordance with established guidelines relative to the number of personnel per work area.
Provisions should be made for the entrance of clean, tempered air into the building to replace air removed by exhaust systems. Inlets should be arranged and located so that workers are not subjected to drafts of air having a temperature of more than 10 degrees F. below room temperature. The intake for the air supply shall be located so as to prevent insofar as possible, the intake of contaminants from exhaust systems, process vents, or other pollutant sources. Where artificial ventilation is necessary for the maintenance of comfortable working conditions, ventilation systems shall be installed.
The use and location of supplementary portable heaters must be approved by the Director of Facilities Management.
Good illumination shall be provided in all walking, working, and service areas to ensure the safety of all personnel in or at the work environment. There shall be good direction and uniform distribution of illumination.
IX. PLAN REVIEW
Review of this plan will be conducted by the Office of Safety and Environmental Programs, as required.
APPENDIX A : LOCKOUT/TAGOUT PROGRAM
The purpose of this program is to establish the minimum requirements for the lockout/tagout of energy control devices whenever maintenance or servicing is performed on machines or equipment. It shall be used to ensure that the machine or equipment is de-energized, isolated from all potentially hazardous energy sources and locked out/tagged out before employees perform any servicing or maintenance where the unexpected energizing or start-up of the machine or equipment or release of stored energy could cause injury.
NOTE: This program will be available to all employees for review and a copy will be located in the following areas:
1. Office of Safety and Environmental Programs
2. VIMS' Intranet, Occupational Safety and Health Plan, Appendix A
II. AUTHORITY & REFERENCE
Occupational Safety and Health Administration (OSHA) 29 CFR 1910.147
This standard covers the servicing and maintenance of machines and equipment in which the unexpected energizing or startup of the machines or equipment, or release of stored energy could cause injury to employees. This standard does not cover the following:
- Construction, agriculture and maritime employment.
- Installation under the exclusive control of electric utilities for the purpose of power generation, transmission and distribution, including related equipment for communication or metering.
- Exposure to electrical hazards from work on, near, or with conductors, or equipment in electrical utilization installations.
- Oil and gas well drilling and servicing.
1. An employee is required to remove or bypass a guard or other safety device.
2. An employee is required to place any part of his or her body into an area on a machine or piece of equipment where work is being performed at or upon the point of operation, or when an associated danger zone exists during a machine operating cycle.
EXCEPTION: Minor tool changes and adjustments which take place during normal production operations are not covered by the OSHA standard if they are routine, repetitive, and integral to the use of the equipment for production, provided that the work is performed using alternative measures which provide effective protection.
NOTE: The OSHA Lockout/Tagout Standard (See 29 CFR 1910.147) does not apply to work on cord-and-plug connected electrical equipment when the employee performing the service or maintenance controls energizing by unplugging the equipment from the energy source. The standard also does not apply to hot tap operations involving transmission systems from substances such as gas, steam, water, or petroleum, when they are performed on pressurized pipelines. However, it must be demonstrated that the continuity of service is essential, shut off of the system is impractical, and special equipment is used which provides effective protection.
B. Authorized Employees
Job classifications that have the authority and responsibility to perform lockout/tagout operations:
C. Affected Employees
Job classifications whose work operations are or may be in an area where lockout/tagout procedures may be utilized:
D. Other Employees
Job classifications whose work or path to and from work responsibilities may be in or adjacent to an area where lockout/tagout operations potentially occur:
E. Sources of Energy and Stored Energy Requiring Lockout
1. Electrical: service panels, outlets, transformers, motors, capacitors
2. Mechanical: spring-loaded equipment, tensioning devices
3. Hydraulic: rams, oil-powered equipment
4. Pneumatic: compressed-air equipment
5. Kinetic/Gravity: counterweights, flywheels
6. Fluids/Stream: heating pipes, steam lines
IV. RESPONSIBILITY FOR COMPLIANCE
A. All employees are required to comply with the restrictions and limitations imposed upon them during the use of lockout procedures. Employees authorized to lockout machines/ equipment are required to perform the lockout in accordance with the specific procedures established for each machine or piece of equipment. Upon observing a machine or piece of equipment which is locked out to perform servicing or maintenance, employees shall not attempt to start, energize or use that machine or equipment. Failure to comply with this policy will result in disciplinary action.
B. The Director of Safety and Environmental Programs will be responsible for the following:
1. Development of a facility-specific energy control policy.
2. Definition and designated procurement of authorized lockout and tagout devices.
3. Training of supervisors and employees on facility policy and procedures for hazardous energy control.
4. Implementation of the Energy Control Policy and review of supervisory/employee performance.
5. Assurance that newly acquired equipment or overloaded equipment can accommodate locks.
6. Master file maintenance of specific policies, lockout procedures review and training records.
C. The Director of Safety and Environmental Programs, VIMS' Safety Officer, and work unit supervisors shall:
1. Identify specific hazards and develop hazard isolation procedures within the facility.
2. Assure that the facility's hazardous energy control policy and procedures are communicated to employees in the work unit.
3. Monitor hazard isolation procedures for effectiveness.
4. Enforce hazard isolation procedures within his/her work unit and between work units or employers in the case of outside contractors.
5. Maintain work unit files documenting employee training.
6. Specify controls capable of being locked out when replacing or updating equipment controls.
D. Transfer of Lock/Tagout Responsibility
No employee shall remove a lockout or tagout device affixed by another employee unless authorized. Responsibility for lockout or tagout remains that of the authorized employee who affixes the lockout or tagout device subject to the following exception.
When an incoming authorized employee is to assume lock/tagout responsibilities on a piece of equipment from a departing employee due to shift or personnel changes, the incoming employee shall affix his/her property labeled locks and/or tag devices to the equipment. If it is intended that the equipment remain securely locked out until the departing employee returns, responsibility does not need to be passed onto the incoming employee.
An employee whose job requires him/her to operate or use a machine or equipment on which servicing or maintenance is being performed under lockout or tagout, or whose job requires him/her to work in an area in which servicing or maintenance is being performed.
A person who locks out or tags out machines or equipment in order to perform servicing or maintenance on that machine or equipment. An affected employee becomes an authorized employee when that employee's duties include performing servicing or maintenance covered under this section.
Energy Isolating Device:
A mechanical device that physically prevents the transmission or release of energy, including but not limited to the following: a manually operated electrical circuit breaker, a disconnect switch, a manually operated switch by which the conductors of a circuit can be disconnected from all ungrounded supply conductors and, in addition, no pole can be operated independently; a line valve; a block; and any similar device used to block or isolate energy. Push buttons, selector switches and other control circuit type devices are not energy isolating devices.
Any electrical, mechanical, hydraulic, pneumatic, chemical, nuclear, thermal or other potential energy source that could have potential to endanger personnel.
Entry Point of Power:
The point at which energy enters the system, machine or unit, such as the main electrical disconnect. Changes in power routing at the entry point should be shown on the circuit diagrams for the machines.
The placement of a lockout device on an energy-isolating device, in accordance with an established procedure, ensuring that the energy-isolating device and the equipment being controlled cannot be operated until the lockout device is removed.
Normal Production Operations:
The utilization of a machine or equipment to perform its intended production function.
Employees whose work operations may take them in or adjacent to areas where LOTO procedures potentially occur.
Any type of energy that can operate equipment, cause movement, or cause injury directly from the energy source. Common types of power are electricity, air or gas under pressure, gravity, springs, oil or water under pressure, steam, some chemicals and radiation.
Residual Electrical Power:
Electrical energy which is retained in a system, machine or unit when the supply line disconnect is placed on the "OFF" position. Power capacitors and electric or magnetic fields are examples that may have residual power if not properly dissipated.
The differential pressure remaining within a component after the pressure source is closed off.
The placement of a tagout device on an energy isolating device, in accordance with an established procedure, to indicate that the energy isolating device and the equipment being controlled may not be operated until the tagout device is removed.
A prominent warning device, such as a tag and means of attachment, which can be securely fastened to an energy isolating device in accordance with an established procedure, to indicate that the energy isolating device and the equipment being controlled may not be operated until the tagout device is removed.
VI. ENERGY CONTROL PROCEDURES
Procedures will be developed and documented when employees are engaged in activities that potentially could be hazardous, due to exposure from an energy source. The following exceptions to required documentation include:
1. The machine or equipment has no potential for stored or residual energy or re-accumulation of stored energy after shut down which could endanger employees.
2. The machine or equipment has a single energy source which can be readily identified and isolated.
3. The isolation and locking out of that energy source will completely de-energize and deactivate the machine or equipment
4. The machine or equipment is isolated from that energy source and locked during servicing or maintenance.
5. A single lockout device will achieve a locked-out condition
6. The lockout device is under the exclusive control of the authorized employee performing the servicing or maintenance.
7. The servicing or maintenance does not create hazards for other employees.
8. The employer, in utilizing this exception, has had no accidents involving the
unexpected activation or re-energization of the machine or equipment during servicing or maintenance.
Energy control procedures shall clearly and specifically outline the purpose, rules and techniques to be utilized for the control of hazardous energy. (See Form #1) These procedures must include the following:
1. A specific statement of the intended use of the procedures.
2. Specific procedural steps for shutting down, isolating, blocking and securing machines or equipment to control hazardous energy.
3. Specific procedural steps for the placement, removal and transfer of lockout or tagout devices and the responsibility for them.
4. Specific requirements for testing a machine or equipment to determine and verify the effectiveness of lockout devices, tagout devices, and other energy control measures.
VII. EQUIPMENT FOR LOCKOUT/TAGOUT
A. Appropriate Equipment
For the purpose of achieving lockout/tagout, employees will be provided with appropriate lockout equipment. Equipment shall include, but not be limited to:
2. Lockout tags
3. Lockout hasps
4. Specialty lockout devices required to fully secure all hazardous energy sources, including lockout devices specifically designed for breakers, valves, switches, cords, etc.
One or more padlocks will be issued to each authorized employee. Each employee will have an individual key. Only one key per lock shall be issued. These locks may be used only for lockout purposes. Locks will be identified by a number assigned to each employee and/or by the use of a name tag. Only the authorized person may apply and remove the lock, and the key may never be given to another person.
NOTE: In identified instances, a second or master key for each lock will be issued to designated supervisors to enable them to open and remove a padlock after taking the required precautions.
C. Lockout Hasps
These devices are designed to accommodate more than one lockout padlock when more than one person is working on de-activated equipment (Group Lockout). Each person, to assure his or her safety, will apply a lock and warning tag and remove it only after his or her task is completed.
D. Warning Tags
Authorized employees will be issued warning tags which must be used whenever a padlock cannot be applied. The tag must be affixed as closely as possible to the energy disconnect with a single purpose 50-pound strength plastic tie. Extra caution must be exercised since there is no physical restraint when only a tag is used and energy can be restored without removing a padlock. In addition, where possible, energy source components should be altered, removed, or obstructions should be placed to restrict access to energy disconnects. Electricians may remove fuses but must attach a tag to the panel involved and remove the tag only when the fuse is replaced and the machine is returned to service.
Tag legends may include, but are not limited to:
DANGER Do Not Start
DANGER Do Not Energize
DANGER Do Not Open
DANGER Do Not Operate
DANGER Do Not Close
Warning tags shall bear the name of the authorized person and the date of application. Tags must be durable, weather-proof and not easily damaged.
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E. Lockout Devices
Lockout devices, where used, must be designed and affixed in such a manner that the devices prohibit energy activation and/or release of hazardous energy and maintain “safe” or “off” position for machine/equipment energy isolating devices. Utilization of devices for situations they were not originally intended for is prohibited.
A. The authorized employee shall notify all affected employees that servicing or maintenance is required on a machine or equipment and that the machine or equipment must be shut down and locked out to perform the servicing or maintenance.
B. The authorized employee shall identify the type and magnitude of the energy that the machine or equipment utilizes, understand the hazards of each energy source and shall know the methods to control the energy.
C. When the electrical disconnect is attached/adjacent to the equipment, the motor stop button shall be depressed and the disconnect handle placed in the "OFF" position. The disconnect handle should be operated while standing to one side of the disconnect rather than in front of the switch. This is a safety precaution in case the parts in the switch explode. The authorized employee should attach his/her lock to the handle of the disconnect and remove the key.
D. If a switch or disconnect cannot be locked out for any reason, an electrician must remove the fuses before any work is started.
E. Stored or residual energy such as that in capacitors, springs, rotating flywheels and hydraulic systems, and in air/gas, steam or water pressure lines must be dissipated or restrained by methods such as grounding, repositioning, blocking or venting. If there is a possibility of accumulation of stored energy, isolation must be verified continuously until servicing or maintenance is completed.
F. Equipment using hydraulic pressure shall be locked out by placing the hydraulic pump motor electrical disconnect switch in the "OFF" position, applying a lock to the disconnect and bleeding off residual pressure in the piping system if the energy could potentially endanger personnel.
G. The authorized employee shall ensure that the equipment is completely disconnected from all energy source(s) by operating the push button or other normal operating controls or by otherwise testing to make certain the machine/equipment will not operate.
H. Return operating control(s) to neutral or "OFF" position after verifying the isolation of the equipment.
I. The machine is now locked out and service or repairs can safely begin.
J. If there are any doubts about the above procedure, the authorized employee shall contact his/her supervisor before proceeding.
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IX. PROCEDURES INVOLVING MORE THAN ONE PERSON (GROUP LOCKOUT)
If more than one individual is required to lock an energy-isolating device(s), each employee shall utilize a procedure which affords himself or herself a level of protection equivalent to that provided by the implementation of a personal lockout or tagout device. When an energy-isolating device cannot accept multiple locks, a multiple lockout or tagout device (hasp) must be used. Each authorized employee shall affix a personal lockout or tagout device to the group lockout device (group lockbox, hasp, or comparable mechanism) when he or she begins work, and that device will only be removed once that individual has completed work on the machine/equipment being serviced.
X. RESTORING EQUIPMENT TO SERVICE
When servicing or maintenance is completed and the machine or equipment is ready to return to normal operating condition, the following steps shall be taken by the authorized person:
1. Visually inspect the machine or equipment and the immediate area around the machine or equipment to ensure that nonessential items have been removed and that the machine or equipment components are operationally intact.
2. Visually inspect the work area to ensure that all employees have been safely positioned or removed from the area.
3. Verify that the controls are in neutral.
4. Remove the lockout device(s) and re-energize the machine or equipment.
NOTE: The removal of some forms of blocking may require re-energization of the machine before safe removal.
5. Notify affected employees that the servicing or maintenance is completed and the machine or equipment is ready to use.
XI. ABANDONED LOCK REMOVAL PROCEDURES
If a safety lock has been left in place by an employee who has departed the building, it shall be removed only by adherence to the following procedure:
Before the lock is removed:
1. A thorough inspection of the equipment is to be made by the supervisor responsible for the area.
2. The supervisor must confirm that the authorized employee who applied the lock-out device is not at the facility.
3. The supervisor shall make all reasonable efforts to contact the authorized employee to inform him/her that his/her lockout or tagout device has been removed
4. The supervisor shall remove the lock providing he/she has determined starting up the equipment will not endanger other personnel.
5. Each time it is necessary to remove/cut a safety lock, a written report shall be prepared by the person authorized to remove the lock and a copy will be sent to the Director of Safety and Environmental Programs.
6. The supervisor shall ensure that the authorized employee has knowledge of this release before he/she resumes work at the facility.
A. Each authorized employee will receive training in the recognition of applicable hazardous energy sources, the type and magnitude of the energy available in the workplace, and the methods and means necessary for energy isolation and control. The training will be documented.
B. Each affected employee will be instructed in the purpose and use of the energy control procedure. The training/instruction will be documented.
C. All other employees whose work operations potentially takes them in or near areas where energy control procedures may be utilized, will be instructed about LOTO procedures and about the prohibition relating to attempts to restart or re-energize machines or equipment which are locked out. The instruction will be documented.
D. When employees are assigned to work in or on machines/equipment that could potentially endanger personnel should the machines/equipment be activated, the supervisor assigning employees to such work is responsible for ensuring that these workers are provided with specific equipment and instructions to comply with this power lockout procedure.
E. Authorized and affected employees will be retrained whenever there is a change in their job assignments that could affect their lockout responsibilities, a change in the machines that presents a hazard or when there is a change in energy control procedures.
F. Additional retraining will be conducted whenever the periodic inspection reveals that there are deviations from or inadequacies in the employee's knowledge or use of energy control procedures.
G. The employer shall certify that employee training has been accomplished and is being kept up to date. The certification shall contain each employee's name and dates of training.
XIII. PERIODIC INSPECTION
A comprehensive inspection/audit of the energy control procedures will be conducted by the Director of Safety and Environmental Programs or his designee at least annually to ensure that the facility is in compliance with the OSHA Power Lockout/Tagout Standard 29 CFR 1910.147 and the procedures outlined in this policy. The results of the annual inspection will be documented.
XIV. OUTSIDE PERSONNEL (CONTRACTORS, ETC.)
Whenever outside servicing personnel are to be engaged in activities covered by the scope and application of this standard, the on-site employer and the outside employer shall inform each other of their respective lockout or tagout procedures. The on-site employer shall ensure that his/her employees understand and comply with the restrictions and prohibitions of the outside employer's energy control program. The exchange of this information shall be documented.
Supervisors shall ensure the continuity of lockout or tagout protection by the orderly transfer of lockout or tagout device protection between off-going and on coming employees, to minimize exposure to hazards from the unexpected energization or start-up of the machine or equipment, or the release of stored energy.
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A. Specific Energy Control Procedures
B. Authorized Employee Training Certification
C. Affected Employee Training Certification
D. Other Employee Training Certification
E. Annual Power Lockout/Tagout Certification Worksheet
F. Documentation of LOTO Information Given to Contractors
APPENDIX B: CONFINED SPACE ENTRY PROGRAM
Among the more dangerous operations is working in confined spaces. Every year confined space accidents account for a large number of deaths. Most often these deaths are the result of failure of the person or supervisor to recognize the hazard or failure to take simple yet important safety precautions. A sobering fact about confined space accidents is that over half of the deaths recorded are those of rescuers who respond to the accident or are already there and attempt to rescue someone without proper training or precautions. Accordingly, OSHA Standard 29 CFR 1910.146, Permit Required Confined Spaces, was enacted to establish mandatory requirements for practices and procedures to protect personnel from hazards associated with confined spaces.
A confined space generally may be defined as any space which is (1) large enough and configured such that an employee can bodily enter and perform assigned work, (2) has limited or restricted means for entry or exit, and (3) is a space not designed for continuous employee occupancy. Confined spaces at VIMS/SMS include sewers, pits/sumps, underground chemical waste and septic tanks, deep trenches (over 4 feet deep), voids/bilges on vessels, and elevator shafts.
A permit required confined space (PRCS) is a space which meets the criteria for a confined space with one or more of the following additional hazards associated with it:
- Space contains or potentially contains hazardous materials.
- Space contains or potentially contains a hazardous atmosphere.
- Space contains or potentially contains a material capable of engulfing an entrant.
- Space is configured such that an entrant could potentially become trapped
(inwardly converging walls, sloped/tapered floor, overhead limitations, etc.).
- Space contains or potentially contains hazardous energy
(electrical, mechanical, hydraulic, pneumatic, chemical, thermal, etc.).
- Space contains or potentially contains another hazard that might result in serious energy or death.
The general rule is do not enter any confined space without knowing what is in it, what was in it, and what will be done in the space. One must be properly trained and equipped before entry including rescue.
The Director for Safety and Environmental Programs is responsible for the confined space entry and rescue program at VIMS/SMS. Supervisors are responsible for ensuring the mandatory confined space entry or hazardous area entry permit is completed prior to initiation of any work in these areas. Specific information on the entry permit will be found in paragraph III. All personnel entering a confined or hazardous space shall receive the OSHA mandated re-entry training by either their immediate on-site supervisor or the Director of Safety and Environmental Programs.
There are many potential killers in confined spaces. The most common are hazardous atmospheres, specifically: (A) oxygen deficiency/enrichment; (B) flammable gases, vapors, and mists; (C) toxic gases at levels above the Permissible Exposure Limit (PEL); and (D) airborne combustible dusts.
A. Oxygen Deficiency/Enrichment - A normal atmosphere contains approximately 21% oxygen. Any atmosphere containing less than 19.5% oxygen is considered to be oxygen deficient. Air containing 16% or less oxygen cannot sustain human life. Oxygen enrichment exists at levels above 23.5%. This condition can lead to lowered ignition temperatures and vigorous combustion of clothing, hair, or other combustible material.
B. Flammable Gases, Vapors, and Mists - The presence of these materials at levels above 10% of the Lower Flammable Limit (LFL) is considered hazardous. Most sampling instruments are calibrated to signal an alarm at this level.
D. Airborne Combustible Dust - Concentrations of airborne combustible dusts above the Lower Flammable Limit (LFL) is hazardous.
III. PERMIT REQUIRED CONFINED SPACE SAFETY PRECAUTIONS
The OSHA standard requires that a permit be prepared in a standardized format or be preprinted through which all conditions which must be evaluated to ensure safe entry are identified. The following is a brief outline of the accepted procedures mandated in the standard:
A. Do not enter any confined space without knowing what is in it, what was in it, how long it has been closed, what operations will be conducted, and what materials will be used.
B. Test the atmosphere for oxygen content, combustible atmospheres, and toxics. Continuous monitoring with direct reading instruments is the safest method of monitoring.
C. Close and lockout any supply lines, chutes, pipes, pumps, drains, electrical and mechanical equipment connected with the confined space. It is essential that all potential energy sources be isolated from the space before any entry. Refer to VIMS/SMS Lockout/Tagout Program procedures in Appendix A.
D. Where an explosive or flammable atmosphere is present, avoid all possible sources of ignition and use extreme care in purging the contaminated space. Care should be exercised to avoid venting combustible or toxic atmospheres where personnel or ignition sources are present. Blowers, duct-work, vents, and other equipment used for ventilation should all be bonded together to avoid buildup of static electricity. This also applies when using steam, inert gas, or compressed air to vent a space. When possible blowers should push the atmosphere rather than pulling it through the unit. The blower is more efficient and reduces the risk of ignition.
E. Conduct continuous atmospheric monitoring of the space with appropriate equipment even if the space was "safe" when work began. Any alarm or irregular reading from instruments shall be used as a warning to evacuate the space until the condition is corrected.
F. Before anyone enters a confined space, all of the proper equipment must be available for air sampling, respiratory protection, personal protection, communications, and retrieval or rescue. A properly trained attendant must be available and a properly trained and equipped rescue team must be alerted.
G. A permit system should be used to ensure that all necessary precautions have been taken and the entrants, attendants, and rescuers are ready for their respective duties.
H. If it is necessary to enter a space containing a hazardous atmosphere, all entrants shall be equipped with a supplied-air respirator or self-contained breathing equipment, a safety harness, and a life line. Rescue team members must be similarly equipped and standing by. If a rescue is needed, if at all possible it should be accomplished from outside the space by using mechanical retrieval devices.
I. When welding or cutting is to be done inside an enclosed space, the space should be "certified" gas free by a qualified tester before work is begun and a hot work permit issued. Mechanical ventilation should be provided to remove fumes from the workers' breathing zone and from the space.
Conditions which are merely inconveniences in open areas are far more serious when they occur in confined spaces. Testing, purging, and ventilating spaces when possible promotes safe conditions and ensures that confined spaces remain free of atmospheric hazards. Isolating the space from all potential energy sources and providing for rescue can make an otherwise dangerous task safe.
For a complete discussion of requirements for confined space entry refer to 29 CFR 1910.146.
IV. TRAINING REQUIREMENTS
A. Entrants, Attendants, and Supervisors
Training for the above personnel is job and site-specific and will follow the requirements of 29 CFR 1910.146. A copy of each individual's training needs will be provided by the Office of Safety and Environmental Programs upon request.
Training for rescuers will be in accordance with 29 CFR 1910.146. In addition to maintaining proficiency with required equipment, it is required that practice making permit space rescues be carried out at least once every twelve months. The standard requires that
1. Simulated rescue operations in which dummies, mannequins, or persons are removed through representative openings and portals whose size, configuration, and accessibility closely approximate those of the permit spaces be carried out.
2. At least one member of each rescue team maintain current certification in basic first aid and CPR.
The Office of Safety and Environmental Programs is responsible for scheduling and conducting the training exercise.
OSHA General Industry Standards require that fall protection measures be employed when work is being performed at a height of four feet or greater off the ground or to the next lower level. An exception to this rule would be when work is performed from a properly installed ladder or scaffold. Other exclusions from fall protection include the performance of inspections, investigations, or assessments of existing conditions prior to beginning or after completion of work or a maintenance activity. However, any time work is being performed four feet or greater above the ground or to the next lower level, supervisors and workers should always consider Fall Protection requirements.
- Guard every floor hole into which a worker can accidentally walk, by use of a railing and a toe board or a floor hole cover.
- Provide a guardrail and toe board around every open-sided platform, floor or runway that is 4 feet or higher off the ground or next level.
- Regardless of height, if a worker can fall into or onto dangerous machines, equipment or materials, guardrails and toe boards must be installed to prevent falls and injuries.
- Other means of fall protection that may be required on certain jobs include safety harness and line, safety nets, stair railings and handrails.
- Guardrails and Toe Boards: Consisting of a top rail 42 inches from the floor, a mid-rail at 21 inches height and a toe board (minimum of 4 inches high with no more than 1/2 inch clearance between bottom of board and floor).
- Safety Net System: Includes a net system installed as close as possible under the work area.
- Control Zone System: Consisting of a cable or rope and stanchions installed parallel to and not less than 6 feet from the unprotected edge to warn personnel of the approaching unprotected edge. High visibility flagging shall be installed on the cable/rope at intervals of not more than 6 feet.
- Personal Fall Arrest System: Minimum system consists of a body harness, lanyard, connector and an anchorage point that will support a minimum of 5000 lbs.
- Positioning Device System: Consisting of a full body harness with attachment points or a body harness and additional body belt rigged to support an individual on an elevated vertical or inclined surface to allow work with both hands free.
- Hole Covers: Covers are designed and built to fit holes in working surfaces (ex. floors) and structurally sufficient to allow walking across without failure.
Body harnesses are required to be worn with all personal Fall Arrest Systems. Body belts may be worn in addition to body harnesses to allow for positioning of the worker. Only locking-type snap-hooks may be used as part of a Fall Arrest System.
Fall protection training for VIMS/SMS employees must consist of the following as a minimum:
- The nature of fall hazards in the work area and how to recognize and minimize fall hazards.
- The role of the user in Fall Protection Systems.
- Use, operation and limitations of Fall Protection Systems.
- The procedures for erecting, maintaining, inspecting and disassembling Fall Protection Systems being used.
1. Work cooperatively with the Office of Safety & Environmental Programs to identify areas where fall protection is required for jobs and maintenance evolutions consistent with Departmental responsibilities.
2. Purchase or obtain Fall Protection Systems consistent with typical jobs or maintenance activity.
3. Ensure workers are trained in the proper inspection, assembly, wearing, use and disassembly of Fall Protection Systems.
4. Know when fall protection is required for workers and the job function.
5. Provide workers with proper fall protection.
6. Ensure workers use fall protection as required and in correct manner.
7. Supervisors should set the example!
8. Assist departments in identifying where fall protection is required.
9. Provide fall protection training.
10. Attend training and successfully pass written and practical exam.
11. Know inspection procedures for Fall Protection Systems.
12. Wear and use fall protection in correct manner and at all time when working above 4 feet and not protected by other acceptable equipment (ex. an inspected and correct ladder).
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C. Safety & Environmental Programs
January 1992 (1st revision)
August 1995 (2nd revision)
November 1996 (3rd revision)
May 1998 Modified for Web Page
April 2007 (4th revision)
July 2009 (Reviewed for content)
August 2012 (5th revision)
February 2013 (6th revision)
Office of Safety and Environmental Programs
School of Marine Science
Virginia Institute of Marine Science
College of William and Mary
Gloucester Point, Virginia 23062