Mary BauerCompliance Assistance Specialist3rd Annual Safety DayWITC Rice Lake, WI 3-15-2012

Confined Space Entry29 CFR 1910.146

Bios & Contacts

• Mary Bauer – Eau Claire Area OSHA OfficeCompliance Assistance Specialist (CAS)

1310 West Clairemont AveEau Claire, WI 54701

715-832-9019 bauer.mary@dol.gov

• Compliance Officer for 20 Years• CAS for 6 Years• All in Eau Claire Area Office• CIH: Certified Industrial Hygienist• CSP: Certified Safety Professional

DISCLAIMER

• GIVE YOU AN IDEA OF REQUIREMENTS – NOT A COMPLETE TRAINING SESSION

• Discussed having a more extensive session in the future if there is more interest.

Objectives

• Confined Space

• Rescue Requirements

Everyone should be aware of:

CONFINED SPACE STATISTICS

• In All Deaths Last Year (139), There Were No Detectors Nor Ventilation

• 65% Of All Confined Space Fatalities Due To Hazardous Atmosphere

• 33% Of All Deaths Were Supervisors• 60% Were Rescuers• 25% Of Spaces Were Toxic Before Entry*****1995 Statistics*****

How to Identify Confined Spaces

• Limited Openings for Entry and Exit AND

• Large enough and so configured to allow employee to enter and perform work AND

• Not Designed for Continuous Occupancy

A space must meet all three of these criteria in order to be classified as a confined space.

Limited or Restricted Meansfor Entry or Exit - Assessment

Is entry/exit or rescue slowed down or impeded by:

• Use of hands (crawling, climbing)

• Contort body

3. Physical Obstructions

4. Posture

Large enough and so configured to allow employee

to enter and perform work.

IS NOT DESIGNED FOR CONTINUOUS EMPLOYEE

OCCUPANCY

Letter of Interpretation 12/20/1994Mr. Edward A. Donoghue

The intent behind this confined space definition component, "Is not designed for continuous employee occupancy", is to focus on the design of the space, which is the key to whether a human can occupy the space, under normal operating conditions.

Definitions (continued)• Lockout - The placement of a lockout device on

an energy isolating device, in accordance with an established procedure, ensuring that the device and the equipment being controlled cannot be operated until the lockout device is removed

• Lockout device - A device that utilizes a positive means, such as a lock, to hold an energy isolating device in a safe position and prevent energization

1910.147(b)

Permit-Required Confined Space (Permit Space)

• A confined space is a permit space if it has one or more of the four specific characteristics that make the space potentially hazardous

• Any one of these characteristics makes a confined space a permit space

Permit Space Permit Space CharacteristicsCharacteristics

• Hazardous atmosphere• Engulfing materials• Inwardly converging

walls, or• Other serious hazards

Classifying Work Space

* Space large enough to enter &;* Limited or Restricted entry or exit &;* Not designed for continuous worker occupancy.

NONot a confined Space

YES Confined Space

Hazardous Atmosphere

Engulfment Hazard

Configuration Hazard

Any other recognized serious hazard

PRCS

Non

Permit

Required

Space

YES NO

Or

Or

Or

Engulfment Hazards

• Loose, granular materials stored in bins and hoppers - grain, sand, coal, sawdust, etc.

• Crusting and bridging below a worker.

• Flooding of confined space.

• Water or sewage flow.

Force Required to Extract a Victim from Grain

165 pound person

Inwardly Converging Walls

• It’s possible to slide down the sloping walls, become stuck, and die of pressure on the chest that makes breathing impossible

• Examples include: hoppers for air pollution dust collectors (i.e., bag houses, electrostatic precipitators, etc.), bottom-mounted unloading chutes for railcars and trucks, cyclones, and funnels

Entrapment: Cone/TaperedNot covered under flat bin entry

Cause of Death: Positional Asphyxiation

Any Other Recognized Serious Safety or Health Hazards

Electrical equipment

Mechanical equipment

Visibility - lighting

Biohazards

Claustrophobia

Noise

Radiation

Temperature

Options for Entry: No Entry• Before looking at entry

options, first determine if there is a way to avoid entry entirely

• For example, use gauges, flow meters, remote cameras, or binoculars to monitor conditions from outside the space

• This worker is vacuuming out the contents of a tank, rather than entering to shovel out the waste

Options for Entering Options for Entering Permit SpacesPermit Spaces

1. Reclassification – (c)(7)

2. Alternate Entry – (c)(5)Alternate Entry – (c)(5)

3. Permit Space Entry – (c)(4)Permit Space Entry – (c)(4)

Minimizing the amount of regulation that applies to spaces whose hazards have been eliminated encourages employers to actually remove all hazards from permit spaces.

Options for Entering Options for Entering Permit SpacesPermit Spaces

1. Reclassification – (c)(7)Reclassification – (c)(7)

2. Alternate Entry – (c)(5)

3. Permit Space Entry – (c)(4)Permit Space Entry – (c)(4)

Alternate entry procedures are allowed if the employer can demonstrate that the only hazard posed by the permit space is an actual or a potential hazardous atmosphere that can be controlled by continuous forced air ventilation.

Options for EnteringOptions for EnteringPermit SpacesPermit Spaces

1. Reclassification – (c)(7)Reclassification – (c)(7)

2. Alternate Entry – (c)(5)Alternate Entry – (c)(5)

3. Permit Space Entry – (c)(4)

Permit space entry requires a detailed written program.

Elimination• A permit space can be reclassified as a

non-permit space if:– It contains no actual or potential

atmospheric hazards, and– All other hazards can be eliminated

(i.e., no ongoing measures are required to keep the space safe)

• This reclassification is valid only as long as the hazards are eliminated

• If the hazards can be eliminated, the standard allows two categories of reclassification

Categories of Categories of ReclassificationReclassification

• (c)(7)(i), and

• (c)(7)(ii)

(c)(7)(i) Reclassification

• Applies only to permit spaces:– That contain no actual or

potential atmospheric hazards, and

– From which all hazards can be eliminated without entering the space

• In this example, this mixer has been locked out before entering it for service or maintenance– TASK DEPENDENT!!!!

Certification

• Paragraph (c)(7)(iii) requires that if a space is reclassified, the employer must:– certify that all hazards in the

space have been eliminated, and

– provide that certification to all employees entering that space

• The reclassification is valid only as long as the hazards remain eliminated

Multi-Employer Provision• When an employer (host

employer) arranges to have a contractor perform permit space work, both employers must follow the requirements of the standard

• Paragraph (c)(8) lists five duties that the host employer has toward the contractor

Host EmployerHost Employerto Contractorto Contractor

• Inform of permit spaces

• Apprise of hazards

• Apprise of precautions and procedures

• Coordinate entry operations

• Debrief

Entry Permit Requirements

• Name and phone numbers of rescue and emergency services.

• Communication procedures.

• Special equipment and procedures.– Personal protective equipment.– Alarm procedures.– Rescue equipment.– Respirators.

Rescue

Rescue and Emergency Procedures

Types of Rescue

• Self-rescue (escape)

• Non-entry rescue

• Entry rescue

There are three types of rescue:

Rescue Team Employer’s Responsibilities

• Provide rescue teams with PPE and training to conduct rescues safely [(k)(2)(i)]

• Train rescue teams to perform assigned rescue duties and establish rescue teams’ proficiency as authorized entrants [(k)(2)(ii)]

• Train rescue teams in basic first-aid and CPR [(k)(2)(iii)]

• Ensure that rescue teams practice at least once every 12 months [(k)(2)(iv)]

Three options to permit-required confined space rescue

1. Arrange for rescue service from an outside source.

2. Arrange for your own employees to provide rescue

3. Provide for non-entry rescue

Read Appendix F-

For Clarification

Response Vs Rescue Time...

• (1) React Time:

Attendant recognizes that the Entrant has a problem.

• (2) Contact Time:

Attendant contacts the Rescue Service.

• (3) Response Time:

Rescue Service arrives at the scene.

Rescue Vs Response Time...

• (4) Assessment Time:

Size-up and strategy determination.

• (5) Preparation Time:

Rescue equipment set-up.

• (6) Rescue Time:

Reaching, treating, packaging, and evacuation of the victim.

OSHA requires 3-5 minutes For IDLH conditions

Non-Entry Rescue• Rescue must be onsite

• Only if it can be done safely

• Mechanical retrieval over 5 feet

• Not use wristlets unless justified

Timely Response, Training, and

Equipment

• Rescue

• Retrieval

• Ventilation & Atmospheric Monitoring

• Barriers

• Access/Egress (ladders, etc...)

• Lighting

• Communication

Timely Response, Training, and Equipment

• Documented training by each team member via simulated rescues in every type of confined space (Rescue training)

• Authorized Entrant/Attendant

• First Aid & CPR (Blood-borne pathogens)

• Haz Com, PPE, Respiratory, Lockout, PSM

• Equipment training (Fall Protection)

Training and Education

• All workers who must enter confined spaces

• All attendants and rescue team members.

• Prior to initial work assignment.

• Retraining:• Job duties change.• Change in permit-space program.• New hazards are present.• Job performance indicates deficiencies.

QUESTIONS

Disclaimer• This information has been developed by an OSHA Compliance Assistance

Specialist and is intended to assist employers, workers, and others as they strive to improve workplace health and safety. While we attempt to thoroughly address specific topics or hazards, it is not possible to include discussion of everything necessary to ensure a healthy and safe working environment in a presentation of this nature. Thus, this information must be understood as a tool for addressing workplace hazards, rather than an exhaustive statement of an employer’s legal obligations, which are defined by statute, regulations, and standards. Likewise, to the extent that this information references practices or procedures that may enhance health or safety, but which are not required by a statute, regulation, or standard, it cannot, and does not, create additional legal obligations. Finally, over time, OSHA may modify rules and interpretations in light of new technology, information, or circumstances; to keep apprised of such developments, or to review information on a wide range of occupational safety and health topics, you can visit OSHA’s website at www.osha.gov.