Restricted Access and Limited Communication Program

Background

Tunnel System

The University of Northern Iowa utility distribution tunnel system is not a confined space as defined by OSHA. Significant factors evaluated in reaching this conclusion include:

• The main tunnel system is designed for employees to enter through building equipment room doors, walk through the tunnel passages and perform equipment maintenance.
• Two means of egress exist for all tunnels in the tunnel system.
• Ventilation is provided throughout the main tunnel system.

Data collected on the utility tunnels is routinely reviewed with affected employees.  Employees have participated in the development of the utility tunnel entry procedure.

After carefully considering all factors involved, and soliciting employee input, the University of Northern Iowa has adopted the following plan to protect the health and safety of employees entering the utility distribution tunnel system.

Limited Communications:

The University has several areas on campus that have limited communications capabilities due to their location.  This program is meant to provide guidance on communication strategies to improve worker safety.

Definitions

• Utility Distribution Tunnel System
  • The utility distribution tunnel system (A.K.A. utility tunnels) is a network of tunnels that are used for the distribution of steam, electrical and communication cables throughout the University campus.  It is a controlled access work area. Authorization is required to enter the utility tunnel distribution system.  Signs are posted on utility tunnel access doors stating that the utility tunnel system is a restricted access space.  Specific utility tunnel entry procedures exist within this document.
• Restricted Access Space
  • University of Northern Iowa designates certain areas of the campus and facilities as Restricted Access Space.  The purpose of this designation is to control the entry and use of these areas to only those individuals who are authorized to enter them. 
    • An example of Restricted Access Space would be the utility distribution tunnel system.
• Entry
  • ​​​​​​​The action by which a person passes through an opening into a Restricted Access 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.
• Limited Communication Access Space
  • ​​​​​​​Any area of campus where communication, whether telephone or radio, is limited or impossible (i.e. equipment rooms where radio signals can not get out to reach dispatch).    
• Hot Work
  • ​​​​​​​Hot work includes welding, use of oxygen/acetylene equipment, or other open flame devices.
• Dispatch
  • ​​​​​​​During normal University working hours, dispatch is performed by Facilities Management via 2-way radio or contacting 3-4400 by telephone.  During non-university hours, dispatch is performed by the Public Safety via 2-way radio or contacting 3-4000 by telephone.  Contact for the Power Plant employees is the Power Plant Control Room at 3-2090 before and after hours.
• Emergency
  • ​​​​​​​An event, internal or external to the restricted access space that could endanger the employee(s) during work in a restricted access space.
• Buddy System 
  • Working in two person teams is a requirement when actively working on energized systems whereby communication is never lost between the two employees. Workers may enter utility tunnels alone for the purpose of inspections or general maintenance such as cleaning, light bulb changing, connecting to piping for locating purposes or checking steam traps.

 

Administrative Responsibilities

Plan Administrator

• The University Safety Officer or designated representative is responsible for implementation of the University Restricted Access and Limited Communication Program. 
• Primary responsibilities include but are not limited to:
  • Interaction and communication with regulatory agencies.
  • Developing compliance strategies.
  • Communication with University administrative personnel.
  • Delegation of implementation responsibilities.

University Department / Unit / Division

• University departments / units / divisions designate employee(s) authorized to enter restricted access areas applicable to departmental facility responsibilities.  University departments / units / divisions can develop and implement a departmental Restricted Access Space entry procedure equal to or more stringent than the University program. 
• Alternate entry procedures must be approved by the University Safety Officer or designated representative prior to entry into a University Restricted Access Space.  University departments / units / divisions shall establish and maintain records, information, and employee training required by University policies and procedures.

Public Safety

• Responsible for control of pedestrian and vehicle traffic in the surrounding area as required.  Also responsible for performing dispatch duties during Facilities Management non-operating hours.

Dispatch

• Responsible for logging entry and exit per employee communication during work in restricted access spaces.

Cedar Falls Fire Rescue

• Primary emergency response/rescue agency according to a Memorandum of Understanding, Confined Space: Rescue and Emergency Medical Service with the City of Cedar Falls, Department of Public Safety, Fire Division.  (Exhibits 1 & 2)

Facilities Management

• Personnel responsible for oversight of renovation, remodel, or construction of existing or new facilities on University property.  Responsible for informing contractor(s) about the elements of the University Restricted Access Entry Program. 
• If contractor(s) decide to use their own procedures, it is the responsibility of Facilities Management to determine if the contractor(s) procedures are as stringent if not more stringent than the University Restricted Access and Limited Access Program.

 

Employee Information and Training

• University Restricted Access Spaces are posted “CAUTION - RESTRICTED ACCESS CALL 273-4400”.  (Exhibits 1 & 2) Prevention of unauthorized access to posted restricted access areas is limited to warning signs and employee awareness of potential hazards.
• University Limited Communications Spaces will be posted “LIMITED COMMUNICATIONS AREA CALL 273-4400 UPON ENTRY AND EXIT”. 
• Contract employer(s) are responsible for their employee(s) compliance with local, state, and federal health and safety regulations including training.
• Affected University personnel shall be provided training and education prior to assignment of duties involving entry of a restricted access area.  Refresher training and education shall be completed when new hazards are identified or whenever employee(s) express a safety concern regarding entry of a restricted access area.
• Employee training records consisting of employee name, employee signature, and date of the training shall certify and authorize personnel participation in restricted access entry.  For additional information see Records Section.

 

Emergency Response

• In accordance with the signed Memorandum of Understanding between the University of Northern Iowa, the City of Cedar Falls, and Sartori Emergency Medical Services (Exhibits 1 & 2), Cedar Falls Fire Rescue and Sartori Emergency Medical Services agree to be first responders in emergency situations.
• Cedar Falls Fire Rescue shall be provided access to restricted access areas whenever necessary to develop appropriate rescue plans and practice rescue procedures.
• Emergency rescue equipment shall be maintained according to manufacturer's recommendations and immediately available for rescue.  University rescue equipment shall be supplemented with local agency equipment and devices.  Personal protective equipment shall be the responsibility of the employer of personnel entering the Restricted Access Space.

 

Procedure for Entry into Restricted Access Areas

The following mandatory sequence of steps and events is to be followed when entering a Restricted access area:

1. The appropriate manager/supervisor shall be notified prior to the entry of any individual into a restricted access area.
2. Prior to entering restricted access area, the scope and sequence of the work will be discussed with all personnel involved in the job.
3. Pre-planning shall include a discussion with all affected personnel of all potential hazards, means and methods of hazard control and emergency pre-plans:
   • Identities and locations of energized steam lines,
   • Identities and locations of energized compressed air lines
   • Identities and locations of energized high-voltage electrical conductors
   • Locations of exposed hot surfaces
   • Signs and symptoms of heat exhaustion and heat stroke
   • Lighting
   • Means of communication
   • Means of entry and egress
   • Hazards created by work activity (chemical products and welding/cutting)
   • External hazards (work in roadways, walkways)
   • Identities of any job-site specific hazards
   • Means to control hazards (personal protective equipment, ventilation/local   exhaust, lockout/tagout procedures)
   • Steam line de-energization and lockout procedures
   • Potential emergency situations and pre-plans
   • The locations of entry and egress from potentially dangerous work conditions will be identified to all personnel working in the tunnel
4. The "buddy system" will be used by employees entering the utility tunnel system when working on energized systems.
5. All items of personal protective equipment required to control job-specific hazards shall be identified in job planning and worn by all personnel. Personnel protective equipment shall include but not be limited to:
   • Long pants to protect from burns and cuts
   • Closed toe footwear
   • Portable flashlight
   • Two-way radio or cell phones
   • Work being done may require additional PPE worn pertaining to the job such as safety glasses, goggles, full face shield, hardhat, bump cap, leather gloves, or safety shoes.
6. When affected employees enter restricted access areas they shall do the following:
   • Contact dispatch by two-way radio or telephone
   • Specify tunnel space entering, building location etc.
   • Specify estimated time duration in tunnel
   • Purpose/work to be accomplished while in restricted access area
   • Notify dispatch by two-way radio or telephone once work is completed and area exited.
7. When hot work is performed in a restricted access area, the University Hot Work Program shall be followed.
8. When hot work is performed, forced ventilation shall be provided and the atmosphere shall be monitored for flammable gases, oxygen content and carbon monoxide. Standard size welding gas cylinders shall not be taken into utility tunnels.

 

Procedure for Entry into Limited Communication Access Areas

Entry into limited communication areas require notification to dispatch on entry and exit including anticipated time in area. During non-university hours, dispatch is performed by the Public Safety via 2-way radio or contacting 3-4000 by telephone.

If work is to be performed in a limited communication access area that requires employee(s) to remain in the area for an extended period of time (i.e. 1 hour or more) the buddy system will be used. 

 

Procedure for Emergencies in Restricted Access and Limited Communication Areas

If a threat to safety and health is observed or perceived, all personnel shall immediately exit the tunnel by the nearest means of egress.

• Do not re-enter tunnel until hazard is identified and evaluated
• Secure jobsite
• Contact supervisor/manager

If emergency assistance is required, use either nearest telephone to call 911, 3-4000 or contact dispatch to summon emergency assistance.  Clearly state to the dispatcher this is an emergency and provide the following information:

• Location of the emergency
• Telephone number from where call is being made (if telephone is used)
• What happened
• What assistance is needed
• Help or first aid that is being provided
• If telephone is used, let the person you contact hang-up first.

Station someone at highly visible location along street to flag down and direct the emergency response vehicle to the scene of the emergency.

 

Records

University departments responsible for implementation of the Restricted Access and Limited Communication Program shall maintain training records including employees’ name, signature, date of the training event, and description of training elements applicable to affected personnel training and education. Training and education records shall be available for review on request of affected personnel, employee representatives, or regulatory agencies.

Entry procedures shall be reviewed when there is reason to believe entry procedures are deficient or whenever a near miss or injury occurs.