Feb 19, 2018
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I want to get into confined spaces and permit-required confined spaces. I need to break this topic up into a couple of different episodes, beginning with a general introduction to terms, definitions, emergency response, and some training requirements before getting into specifics around the actual entry permits and entry procedures like monitoring in the next episode.
Ok, so let’s first define the terms for our discussion:
According to 29 CFR 1910.146, a confined space is ANY space that:
* Is large enough and so configured that an employee can bodily
enter and perform assigned work
* Has limited or restricted means for entry or exit (for example, tanks, vessels, silos, storage bins, hoppers, vaults, and pits are spaces that may have limited means of entry.)
* Is not designed for continuous employee occupancy.
Let’s talk about that last part for a moment; OSHA defines continuous human occupancy vaguely, but use the following as a benchmark:
Can the worker safely remain inside the space during operation? Of course, we are talking about not being exposed to a recognized hazard while inside; moving/rotating parts, live electrical components, gases, fumes, or other hazardous atmosphere, things like that.
I have heard all sorts of crazy excuses why a space is NOT a confined space:
- It has a door
- There is a light, they meant for someone to be in there
- There are two ways out
You need to assess and evaluate ALL aspects of the space to determine whether or not it is considered a confined space according to OSHA.
So, confined spaces can include underground vaults, tanks, storage bins, manholes, pits, silos, underground utility vaults and pipelines, etc. It really depends on you being able to assess the space in question.
Now, OSHA states that the employer shall evaluate the workplace to determine if any spaces are PERMIT-required confined spaces.
Well, a ”Permit-required confined space (permit space)" means a confined space that we already defined, has one or more of the following characteristics:
1. Contains or has a potential to contain a hazardous atmosphere
2. Contains a material that has the potential for engulfing an entrant
3. Has an internal configuration such that an entrant could be trapped or asphyxiated by inwardly converging walls or by a floor which slopes downward and tapers to a smaller cross-section OR
4. Contains any other recognized serious safety or health hazard
If the workplace contains any permit spaces, you have to inform exposed employees, by posting danger signs or by any other equally effective means, of the existence and location of and the danger posed by the PERMIT spaces.
I always recommend controlling access further by adding physical locks when possible. Especially if your policy is that no employees are permitted to enter these spaces. This adds another level of security to the postings.
Ok, for me, starting with managing the spaces themselves as well as the activities in and around these spaces is the key to ensuring worker safety. And it all starts with making sure you are PREPARED to respond to ANY emergency in the workplace.
Emergency services (whether you have confined spaces or not) is critical for any workplace. First and foremost, you need to determine whether or not emergency crews are able to reach your facility in what OSHA calls a “reasonable amount of time” for life-threatening situations.
So, according to OSHA, in workplaces where serious accidents such as those involving falls, suffocation, electrocution, or amputation are possible, emergency medical services must be available within 3-4 minutes, if there is no employee on the site who is trained to render first aid.
OSHA recognizes that a somewhat longer response time of up to 15 minutes may be reasonable in workplaces, such as offices, where the possibility of such serious work-related injuries is more remote.
Also, OSHA has interpreted the standard to require a separate (either in-house or outside) rescue and emergency service when permit space entry operations are performed in an immediately dangerous to life and health (IDLH) atmosphere.
This means any condition that poses an immediate or delayed threat to life or that would cause irreversible adverse health effects or that would interfere with an individual's ability to escape unaided from a permit space. An example would be during inerting activities.
Even in permit space entry operations involving non-IDLH atmospheres, more than one rescuer may be required in permit space entry operations depending on the hazards present and the number of authorized entrants that may require rescue.
The minimum number of people required to perform work that is covered by OSHA standards for permit-required confined space entry standards and respiratory protection standards will be driven by facts such as the hazards or potential hazards, the number of entrants who may require rescue and the configuration and size of the space. So planning is critical!
When using outside services that are able to meet the response time, consider the following:
* Have local response crews been out to see your facility?
* Have they done a walkthrough of some high-hazard processes and activities (not just confined spaces)?
* Are they equipped to manage the types of emergencies your site may present? (Many rural departments may lack some of the resources needed)
* Have emergency services crews trained or conducted simulated rescues at your site?
These are just a few examples of best practices you can follow to ensure a higher level of safety.
Also, keeping track of who is entering these spaces at any given time is key. Whether they are contractors or your own employees; knowing when entries are taking place and tracking entrants is a major part of the OSHA requirements.
This gets us into the permit entry system. This is your written procedure for preparing and issuing permits for entry and for returning the permit space to service following the termination of entry.
This is important; for a PERMIT required confined space, NO entry is allowed unless a written entry permit is completed, you have identified the trained attendant, entrants and entry supervisor (we will go through all that in the next episode) and have documented each hazard of the space and how each hazard is mitigated.
Now, since deaths in confined spaces often occur because the atmosphere is oxygen-deficient or toxic, confined spaces need to be tested prior to entry and continually monitored. More than 60% of confined space fatalities occur among would-be rescuers; therefore, a well-designed and properly executed rescue plan is a must.
If spaces are properly evaluated prior to entry and continuously
monitored while the work is being performed and have appropriate
rescue procedures in effect, fewer incidents would occur. OSHA
considers entry to have been made into space whenever ANY part of
the entrant’s body breaks the plane of the space opening.
CAUTION: hazards may still be present right outside the opening, like when a space has undergone nitrogen purging; an oxygen deficiency could exist just feet outside the opening and someone could be bending down to look inside (without breaking the plane) and be overcome, and pass out, fall into the space, etc. And this HAS led to fatalities before.
So just because OSHA says you have to break the plane to have made an entry, don’t forget about the general environmental controls standard that applies just outside the space.
Let’s stop there with entry procedures and save that specific
topic for the next episode. I wanted to give you an overview of
what is involved and what to expect moving forward.
Now that you have an idea of what these spaces are (according to OSHA) and some of the requirements; let’s focus on preparing for confined space operations in general. In a word; TRAINING.
Employees need to be trained BEFORE they are assigned any duties related to confined space work. Let me break these into some categories for you:
1. General safety
For general safety training, all employees, regardless of their role, need to understand the common hazards present or that may be present in any of the spaces that they might work. Especially hazards they may be introducing themselves. Are they cutting or welding? Are they using chemicals? Are they using electrical equipment?
Training also has to include signs and symptoms of exposure to
certain hazards. All workers need to know how to identify whether
or not an entrant is being affected by any of the hazards that may
be present. They also need to understand how hazards are to be
controlled, the monitoring equipment used in spaces, etc.
General training also has to include how to respond in an emergency. If you do rely on 911 (local emergency services, assuming you already verified they are able to perform such rescues as I already discussed) they need to go over the communication system to be used prior to work beginning.
According to the Standard; you have to develop and implement procedures for summoning rescue and emergency services, for rescuing entrants from permit spaces, for providing necessary emergency services to rescued employees, and for preventing unauthorized personnel from attempting a rescue.
Also, if there is any fall protection or retrieval equipment being used, they have to be properly trained on its set up and use. Especially if non-entry rescue is being utilized. This is crucial. You can see that knowing the confined spaces standard is not enough. You will need to know general safety requirements, PPE standards, Fall Protection, Respiratory Protection, Emergency Services, and First Aid, and more!
Attendants need to know all of the general training requirements as well as the need to remain at the space at all times. They cannot perform ANY other duties that interfere with being an attendant. The entrant can’t yell out to the attendant that they need a wrench or something and the attendant runs to the toolbox real quick and grabs it. They can’t be chatting up another site worker about the game last night, nothing like that!
This all has to part of the training. The same goes for the entry supervisor. Now the entry supervisor is responsible for ensuring ALL the sections of the permit have been addressed appropriately. The entry supervisor can also serve as the attendant if they are trained to do both, but I always recommend off you have the ability, use another layer of oversight by having someone else be the entry supervisor.
The permit itself we will go into detail on in the next episode. How to fill it out, terminating the space entry, how long you need to keep these on file, all that stuff. I will have permit templates available, checklists for you so you can get started. But this episode, I wanted to introduce the topic, talk about some of the definitions and training requirements to get us started.
So keep an ear out for the next episode as we go deeper into this topic. Let me know what your thoughts are regarding confined spaces. I would like to cover some FAQs as well and talk about some common letters of interpretation in the next episode that will help you improve your confined space entry program.
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