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Confined Space Entry

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Definition of a Confined Space

• Is large enough and so configured that an employee can bodily enter and perform assigned work; and

• 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.); and

• Is not designed for continuous employee occupancy.

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Definition of a Permit Required Confined Space

A confined space that has one or more of the following characteristics:

• Contains or has a potential to contain a hazardous atmosphere;

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

• 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

• Contains any other recognized serious safety or health hazard.

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Vault or Pit?

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Confined Space?

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Pit Versus Vault – AGA Exemption

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Confined Space Exemptions• The Confined Space and PRCS requirements do not apply

to construction activities, including excavations.• Under normal circumstances, work inside a natural gas

system vault or “pit” would seem to fall under the 29 CFR 1910.146.

• However, there is a letter of interpretation written in May of 1994 that seemingly provides an “exemption” from PRCS for work inside “vaults”.

• This exemption references section 4(b)(1) of the OSH Act.

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4(b)(1) Avoiding Duplication of Rules• The Occupational Safety and Health Act (OSH Act) covers every

employer engaged in a business affecting interstate commerce who has one or more employees. This is very broad coverage under the Commerce Clause of the Constitution. However, to avoid duplication in enforcement in the occupational safety and health area, Congress, in section 4(b)(1), took into account the other Federal agencies which in the exercise of their statutory responsibilities may issue regulations or standards which affect occupational safety and health issues. Section 4(b)(1) provides, in pertinent part: Nothing in this Act shall apply to working conditions with respect to which other Federal agencies . . . exercise statutory authority to prescribe or enforce standards or regulations affecting occupational safety and health.

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The Exemption• Basically, the exemption indicates that OSHA will not

enforce PRCS rules for “vaults” UNLESS :

“However, enforcement of the PRCS standard in vaults is not entirely preempted. Because the OPS regulatory scheme primarily relates to the hazards of gas in vaults, the more comprehensive PRCS standard may apply to these spaces to the extent that hazards other than those related to gas are involved.”

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The Conclusion

“Based upon the information A.G.A has provided, OSHA expects that the PRCS standard would apply only in unusual circumstances in which hazards not normally encountered in day-to-day operations are present.”

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Confined Space Atmospheric Testing and Retrieval Equipment

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Atmospheric Testing• The type of Confined Space atmospheric testing

used may be based on the application of the previous information. However, if the PRCS standard is applied, a generally accepted method of testing involved measuring four components:– % O2– CO ppm– % LEL (Lower Explosive Limit)– H2S ppm (standard cell on a 4 gas meter but can be

changed or not used).

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Atmospheric Testing• Limitations of Rangers and Rovers

– Ranger: • Displays LEL and %Gas, but not simultaneously; some units

display CO. A dial has to be turned to each reading individually.

– Rover: • Has option for CO and O2 Sensors; • Will read CO PPM and O2 with optional sensors• Reads %Gas; • Is specific to methane and propane; does not read other

flammable gasses per the manufacturer.

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Atmospheric Testing• Typical Four Gas Meters used for atmospheric

testing for confined space entry:– Simultaneous display of up to four gases.– Typical meter:

• O2 %• CO ppm• H2S ppm• LEL %

– The meter can remain outside the space so all atmospheric readings are visible by the CS Attendant using confined space kit probes.

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Atmospheric Testing

BW Technologies GasAlertMax XT II Gas Detector

• Gives readout of four gases simultaneously• Intrinsically safe• Can be used from a distance• Cover can be removed to work as a personal monitor.• One button operation• %O2, %LEL, CO ppm, H2S ppm• H2S sensor can be changed to read other gases

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Confined Space Retrieval Equipment

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Confined Space Retrieval Equipment

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Questions Before the Live Demonstration?