Safety & Environmental Management

Confined Space Entry Program

Program Administration
Program Elements
Outside Contractors
Delegated Responsibilities

UW-Green Bay Permit-Required Confined Spaces
Air Sampling Procedures

UW-Green Bay Confined Space Entry Program
Appendix A: UW-Green Bay Permit-Required Confined Spaces
Appendix B: UW-Green Bay Confined Space Entry Form
Appendix C: Air Sampling Procedures


The purpose of this program is to establish specific procedures to protect UW-Green Bay and subcontractor employees from the hazards of entry into both non-permit and permit-required confined spaces. Procedures for confined space entry are based on the requirements of 29 CFR 1910.146 and Wisconsin Administrative Code Comm 32.29.

Requirements specified in this program will apply to all UW-Green Bay employees and contractors working under the direct supervision of UW-Green Bay.

Program Administration

The UW-Green Bay University Safety Manager, Jill Fermanich, has been designated responsibility for the overall administration of this program and has authority to make necessary decisions to ensure success of this program. Supervisors who have employees covered by this program will have responsibility for ensuring employee compliance with program elements.


Confined Space: A space or work area containing all of the following characteristics:
  • Is large enough and configured so that an employee can bodily enter the space or area and perform assigned task

  • Has limited or restricted means for entry or exit; examples are tanks, silos, vats, degreasers, sewers, tunnels, hoppers, underground utility vaults, and pipelines

  • Is not designed for continuous employee occupancy
Entry: The action by which a person passes through an opening into a permit-required confined space; entry is considered to have occurred as soon as any part of the entrant's body breaks the plane of an opening into the space.

Hazardous Atmosphere: An atmosphere that may expose employees to the risk of death, incapacitation, impairment of ability to self-rescue (escape unaided from a space), injury, or acute illness from one or more of the following:
  • Flammable gas, vapor, or mist in excess of 10 percent of its lower explosive limit (LEL)

  • Airborne combustible dust at a concentration that meets or exceeds its LEL (this condition is met if dust obscures vision at a distance of 5 feet or less)

  • Atmospheric oxygen concentration below 19.5 percent or above 23.5 percent

  • Atmospheric concentration of any substance that could result in employee exposure in excess of the substance's permissible exposure limit

  • Any other atmospheric condition that is immediately dangerous to life or health (IDLH)
Non-permit Required Confined Space: A confined space that does not contain, or, with respect to atmospheric hazards, have the potential to contain any hazard capable of causing death or serious physical harm.

Permit-Required Confined Space: Any space or work area that has one or more of the following characteristics:
  • Contains or has the potential to contain a hazardous atmosphere

  • Contains a material that has the potential for engulfing an entrant

  • Has an internal configuration that can trap or asphyxiate an entrant by inwardly converging walls or by a floor that slopes downward and tapers to a smaller cross-section

  • Contains any other recognized serious safety or health hazard

Program Elements

A list of Campus permit-required confined spaces is found in Appendix A. A sign reading "DANGER -- PERMIT-REQUIRED CONFINED SPACE, DO NOT ENTER" will identify permit spaces on the Campus.

UW-Green Bay employees are not allowed to enter permit-required confined spaces unless:
  • The permit space is evaluated and meets criteria for reclassification to a non-permit space for the duration of the entry

  • Or

  • The permit space is evaluated and meets criteria allowing for use of alternate procedures specified in 29 CFR 1910.145 c(5)(ii). To meet the criteria the only hazard posed by the permit space is an actual or potential hazardous atmosphere and continuous forced air ventilation alone is sufficient to maintain that permit space safe for entry
Outside contractors will be used if a permit space cannot be reclassified or entered using alternate procedures.

A space classified as a permit-required confined space may be reclassified as a non-permit confined space if:
  • The permit space poses no actual or potential atmospheric hazard which has been verified by using procedures in Appendix C "Air Sampling Procedures"

  • All hazards within the space are eliminated without entry into the space

  • Basis for determining that all hazards in the permit space have been eliminated is certified with completion "UW-Green Bay Confined Space Entry Form" found in Appendix B.
A space classified as a permit-required confined space may be entered using alternative procedures if:
  • The only hazard posed by the permit space is an actual or potential hazardous atmosphere, and

  • Continuous forced air ventilation alone is sufficient to maintain that permit space safe for entry

  • Data supporting use of alternative procedures is obtained without entry into the permit space

  • Basis for determining permit space can be entered using alternative procedures is certified with completion of "UW-Green Bay Confined Space Entry Form" found in Appendix B.
The following procedures will be used whenever a Campus employee enters a permit required confined space:
  • All entrants and attendants must be trained on Campus confined space entry policies.

  • The UW-Green Bay Confined Space Entry Form will be completed prior to entry into a permit-required confined space

  • Any conditions making it unsafe to remove an entrance cover will be eliminated before the cover is removed.

  • Once entrance cover is removed, the opening will be guarded to prevent an accidental fall through the opening and to protect employees working in the space from foreign objects entering the space.

  • Before an employee enters the space, the internal atmosphere will be tested for oxygen content, flammable gases and vapors and potential toxic air contaminants.

  • Entrant and/or attendant will have a phone or radio communication readily available during entry to report any emergency that occurs. In case of emergency, call 9-911 or Channel 1 (on radio).

  • Entrant will wear a personal air monitor. If a hazardous atmosphere is detected during entry, all employees must leave the space immediately.

  • Personal protective equipment will be used as needed.

  • An appropriate ladder must be used for safe entry/egress for vertical entries.
The Campus steam tunnels are classified as non-permit confined space. The Power Plant supervisor will document semi-annual atmospheric testing of the steam tunnels to verify absence of any atmospheric hazards. The following procedures must be used when entering Campus steam tunnels:
  • All entrants must be trained on UW-Green Bay confined space entry policies.

  • Supervisor will be notified before entry occurs.

  • Air monitoring, mechanical ventilation and/or respiratory protection will be required when work involves use of hazardous chemicals or welding equipment.

  • Entrants to the tunnel system will immediately evacuate the tunnel system via the closest exit any time they experience symptoms of possible exposure such as headache, dizziness, nausea, drowsiness and difficulty breathing.
In case of an emergency call 9-911 or Channel 1 (on radio). Provide operator with name, location and nature of emergency. Public Safety has provided Brown County emergency responders with a Campus map and directions to all buildings.

The UW-Green Bay Confined Space Entry Form must be completed before entry into any Campus permit space. Entry certification is valid for only one shift and may not be used for any future entries. The form serves as a permanent record of entry activity. Supervisors will maintain the form on file and send a copy to the Campus University Safety Manager.

Entrant will notify supervisor when entry is completed and return the entry form to the supervisor.

Confined space training shall be provided to all UW-Green Bay employees entering, attending or supervising entrance of Campus permit required confined spaces on an annual basis. Supervisors will ensure that all employees under his/her direction who enter a permit space have received the following training:
  • Definition of a confined space and identity of permit spaces on the UW-Green Bay campus.

  • Requirements of the OSHA Confined Space Standard (29 CFR. 1910.146) and UW-Green Bay's Confined Space Entry Program.

  • Recognition, evaluation and control of chemical and physical hazards within a confined space.

  • Use and limitations of atmospheric testing and PPE.

  • Use of "UW-Green Bay Confined Space Entry Form".

  • Steam tunnel entry procedures.

  • Emergency contact procedures.

Outside Contractors

When an outside contractor performs work that includes entry into University permit required confined spaces the Campus will do the following:
  • Inform contractor that the workplace contains permit spaces and that all entries into permit spaces must comply with 29 CFR 1910.146 - OSHA Permit-required Confined Spaces.

  • Provide information to the contractor about the elements and hazards of the space that make the space in question a permit space.

  • Apprise the contractor of any precautions or procedures that the Campus has implemented for the protection of employees in or near permit spaces where the contractor personnel will be working.

  • Have the contractor inform the Campus about any problems encountered during the entry once entry is complete.
An outside contractor will do the following whenever performing work requiring entry into a Campus permit space:
  • Comply with all applicable requirements I 29 CFR 1910.146 - OSHA Permit-required Confined Spaces.

  • Obtain any available information regarding permit space hazards and entry operations from the Campus.

  • Inform Campus of the permit space program the contractor will follow.

  • Inform Campus of any hazards confronted or created in permit spaces.

Delegated Responsibilities

Program Administrator
  • Update UW-Green Bay Confined Space Program as needed.

  • Coordinate required training.

  • Do regular program evaluation with assistance of supervisors.

  • Identify all employees who will enter Campus permit spaces.

  • Ensure all employees who enter Campus permit spaces received required training.

  • Ensure all employees who enter Campus permit spaces complete UW-Green Bay Confined Space Entry Form. Send a copy of completed form to Campus University Safety Manager when entry is completed.

  • Require and enforce additional entry procedures as needed (e.g. require utilization of attendant or communication devices in certain situations).

  • Provide sufficient surveillance of the work area to ensure employee compliance with all program elements.

  • Assist program administrator with regular program evaluations.

Employees covered by Program
  • Attend training as required

  • Follow all required program elements when entering a Campus permit space.

Facilities Management
  • Ensure outside contractors comply with program elements detailed in section V.

Contact Jill Fermanich (ext. 2273) if you have further questions concerning this policy.