Confined Space Considerations

Transcription

1 Confined Space Considerations

2 Confined Spaces & In Construction and Industry Dennis M. Dougherty Med-Tex Services, Inc September 14, 2016

3 TRAINING DISCLAIMER These materials are intended to assist employers, workers, and others as they strive to improve workplace health and safety. While we attempt to thoroughly address specific topics, 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, regulators 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 regulatory web sites.

4 Dennis M. Dougherty Med-Tex Services, Inc. SJU, Temple and LaSalle CHST, STS status from BCSP Temple University St. Joseph s University OTI Master Instructor Past President, Mid-Atlantic Construction Safety Council Past President of the ASSE, Philadelphia Chapter PA-EMT, Confined Space/High Angle Rescue Technician

5 New Management

6 Safety Compliance

7 Agenda Definitions Typical Confined Spaces Hazards General Requirements The Written Program Training Requirements Duties of Personnel Alternate Procedures Reclassification Communication and Coordination Rescue and Emergency Services

8 Events November 2005 November 7, Investigators from the U.S. Chemical Safety and Hazard Investigation Board (CSB) are en route to the Valero oil refinery in Delaware City, Delaware, where two contract workers were overcome and killed this weekend by entry into a nitrogen gas-filled process vessel. Source: U.S. Chemical Safety Board CSB November 7, 2005

9 Events June 2015 A man died Tuesday afternoon while working on a septic tank. James Bradley Brown, 20, became unconscious after crawling into a septic tank to work on it. The incident remains under investigation by the Hancock County Coroner s Office and the Occupational Safety and Health Administration, according to the sheriff s office. Source: The Courier, Findlay Hancock Northwestern Ohio June 17, 2015

10 Events June 2015 ATLANTA Two construction workers are still recovering a day after being rescued from a 14 foot hole in Georgia Tech s golf course. Officials say they believe the contractors were tying into an existing sewer line when something went wrong Thursday. They were unconscious, trapped underground for close to 30 minutes before finally being pulled out by Atlanta firefighters. Source: 11 Alive Atlanta, A Tegna Company June 5, 2015

11 Events June 2015 (CONTINUED) Being on the golf course presented another challenge. "We had to bring all the equipment to the scene on foot," said Newell. "The golf course wouldn't support the fire truck. Note: Consider access to job sites for confined space emergency response! Source: 11 Alive Atlanta, A Tegna Company June 5, 2015

12 Events July 2015 DES MOINES, Iowa A father and his son who were so close that they were "like glue" were killed Saturday by noxious fumes from an Iowa hog manure pit - the second father and son in the Midwest to die of poisonous manure pit gases this month. Source: 5 KSDK.com, A Tegna Company June 28, 2015

13 Events July 2015 KANSAS CITY, Mo. Four construction workers were taken to a hospital early Monday after becoming sick from carbon monoxide at a Kansas City home. The workers were in the basement working to repair a leaking pipe. They were operating power tools -- gas-operated -- and they were doing that without proper ventilation, and so the carbon monoxide levels rose in this house to levels of about 600 parts per million when our crews arrived Source: KMBC.com/KMBC-TV; Kansas City June 28, 2015

14 Events August 2016 SAUGATUCK, MI -- A worker who drowned in a molasses tank last week was under the syrup for at least four minutes before the company's owner grabbed an electric saw and cut the container, freeing the worker so he could start CPR. Authorities say a 23-year-old worker was cleaning a 12-foot-tall tank containing molasses in western Michigan when he drowned. Source: S. Martinez; The Grand Rapids Press August 02, 2016

15 Contributing Factors for Confined Space Incidents Lack of hazard recognition Incorrect emergency response

16 Where are the rules?

17 Definition Construction Work: work for construction, alteration, and/or repair, including painting and decorating. 29 CFR

18 What standard should I follow if my workers are doing construction AND general industry work in confined spaces? An employer whose workers are engaged in both construction and general industry work in confined spaces will meet OSHA requirements if that employer meets the requirements of 29 CFR 1926 Subpart AA - Confined Spaces in Construction.

19 Primary Differences in the Standards Information Exchange Competent person to evaluate spaces Continuous atmospheric monitoring Continuous monitoring of engulfment hazards. Allowing for the suspension of a permit

20 Exceptions 29 CFR does not apply to: Construction work regulated by 1926 Subpart P Excavations 1926 Subpart S Underground Construction, Caissons, Cofferdams and Compressed Air 1926 Subpart Y Diving Preamble Note: Direct Work for Subpart P and S is not covered. Work in confined spaces related to that work would be.

21 Telecommunications

22 Telecommunications Exempt from Subpart AA if Work is in accordance with Telecommunications standard AND Hazards are addressed by the telecommunication standard (absent any unusual circumstances) Example: maintenance and repair of telecommunications lines and equipment; testing, locating and inspecting telecommunications lines

23 Telecommunications Not Exempt (or subject to other citation) Work for construction Work on telecommunications equipment where hazards may arise that are not addressed by the telecommunications standard Example: Atmosphere that could not be made safe

24 Definitions Confined Space Permit-required Confined Space Entry Handout for more general definitions

25 Definition Confined space means a space that: Is large enough and so configured that an employee can bodily enter it; Has limited or restricted means for entry and exit; and Is not designed for continuous employee occupancy.

26 Definition Permit-required confined space (permit space) means 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.

27 Entry? The action by which a person passes through an opening into a permitrequired confined space, and includes ensuing work activities in that 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.

28 Typical Permit Required Confined Spaces Underground vaults Boilers Pipelines Pits Excavations Storage Tanks Sewers/Culverts Underground utilities Shafts

29 Typical Permit Required Confined Spaces Silos Man-holes

30 Typical Permit Required Confined Spaces

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61 Some Potential Hazards Engulfment Oxygen deficiency Oxygen enrichment Flammable gases or vapors Combustible dusts Toxic substances IDLH atmospheres Physical hazards Page 13

62 Some Potential Hazards Fall Protection Scaffolding Noise Vibration Illumination Temperature Extremes Hazardous Energy Communications Rodents Slips, Trips, and Falls Biological Page 13

63 General Requirements Before it begins work at a worksite, each employer must ensure that a competent person identifies all confined spaces in which one or more of the employees it directs may work, and identifies each space that is a permit space, through consideration and evaluation of the elements of that space, including testing as necessary ( (a)). Sample of a confined space assessment form identifying hazards Note: Very Similar language is found in (c)(1) The employer shall evaluate the workplace to determine if any spaces are permit-required confined spaces.

64 Space info Hazard Assessment, Evaluation and Rescue Pre-Plan Example

65 General Requirements Post Signage Beyond Signage, inform other employers (controlling contractor) of the permit space Prevent unauthorized employees from entering Written Program

66 General Requirements When entrance covers are removed, the opening must be immediately guarded by a railing, temporary cover, or other temporary barrier that will prevent an accidental fall through the opening

67 Elements of your Written Program Prevent Unauthorized Entry Identify and Evaluate Hazards and the Permit Spaces Develop and Implement Means, Procedures and Practices for Safe Entry Ventilation Considerations Barriers for external hazards to entrants (Vehicle) Verifying acceptable conditions during operations Eliminating dangerous conditions (such as high pressure, heat and atmospheric) for access Page 15

68 Elements of your Written Program Provide Equipment Such As: Atmospheric monitoring Ventilation if needed Communication PPE Lighting Barriers Access/Egress (Ladders) Rescue Equipment (Unless outside service is used) Any other equipment Page 15

69 Elements of your Written Program Evaluate the Space Pre Entry Testing Continuously Monitor the Space *Early Warning for non-isolated engulfment hazards *Continuous monitoring is required unless equipment is not commercially available Share Results Perform anytime there is a request Page 15 Note: Early warning system for engulfment hazards and continuous monitoring are references.

70 Elements of your Written Program Provide Attendants If Attendant has Multiple Spaces, Document Means of Compliance Identify Attendants, Entrants, Etc. Procedures for Rescue Including procedures in a non-entry rescue fails Develop Permit System Page 15

71 Elements of Your Written Program Develop Procedures to Coordinate Entry Operations Develop Procedures to Conclude Entry Review Operations if Non-Acceptable Conditions Exist Review Program Annually Page 15

72 Permit Process Document identification of Program Elements for safe entry Entry Supervisor Must Sign Permit Must Be Available (Post at Site) Duration of the Permit Must Not Exceed Time for Task Terminate,Cancel or Suspend* Permit when complete or nonacceptable condition arises in or near the space Retain for One Year for Review Appendix A *Note: This is a Reference

73 Entry Permit Components

74 Who is involved in Entry? Designate and train each person who is to have an active role such as: Entrants Attendants Entry supervisors Persons who test or monitor the atmosphere Rescue and Emergency Services Note: Knowledge of hazards for non-entry employees is also important. Preamble states that the presence of a confined space on the worksite triggers this standard, not your work.

75 Training is Required Must Provide to Each Employee Whose Work is Regulated by this Standard Language and Literacy Level Prior to Employee Being Assigned Initial Change in Duties Change in Operations Evidence of Deviation or Inadequacies Must Establish Proficiency Records Maintained for Employees Employment

76 Training of Duties/Job Descriptions Authorized Entrant Authorized Attendants Entry Supervisors Pages 17-20

77 Entrant Duties Are familiar with and understand the hazards that may be faced during entry, including information on the mode, signs or symptoms, and consequences of the exposure. Properly use equipment as required. Communicate with the attendant as necessary to enable the attendant to assess entrant status and to enable the attendant to alert entrants of the need to evacuate the space as required. More duties in handout

78 Attendant Duties Understands the hazards that may be faced during entry, including signs or symptoms, and consequences of the exposure. Is aware of possible behavioral effects of hazard exposure in authorized entrants. Continuously maintains an accurate count of authorized entrants. More duties in handout

79 Entry Supervisor Duties Is familiar with and understands the hazards Verifies permit information in accurate Terminates the entry and cancels or suspends the permit as required. Note: Suspension of a permit is unique to the standard. Removes unauthorized individuals More duties in handout

80 Entry Supervisor (Special Note) Verifies that rescue services are available and that the means for summoning them are operable, *and that the employer will be notified as soon as the services become unavailable *Note: Paragraph (d) states: and that the employer will be notified as soon as the services become unavailable verifies language in (j)(4) that the rescue services are available. If you rely on any rescue service, there must be a mechanism in place to suspend work if they become unavailable.

81 Options: Alternate Procedures The use of Alternate Procedures for spaces that an employer can demonstrate that all physical hazards in the space are eliminated or isolated so the only hazard is atmospheric and that can be controlled by continuous forced air. Info Exchange and Training Requirements Apply Must be documented (e) is similar to paragraph in the General Industry Standard, (c)(5)(i), referencing this option. Page 21

82 Options: Reclassification A space classified by an employer as a permit-required confined space may only be reclassified as a non-permit space when no actual or potential atmospheric hazards and if all hazards have been eliminated or isolated Must be documented (g) is similar to the reclassification to a non-permit space outlined in paragraph (c)(7) of the general industry standard Page 22 See Confined Space Handout

83 Options: Reclassification

84 Permit Space Entry Communication and Coordination Host Employer to Controlling Contractor Location of known permit spaces Hazards and Potential Hazards Any Previous Precautions Taken Note: This is based on the (h) requirements and is extremely similar to (C)(8) for Host Employers

85 Permit Space Entry Communication and Coordination Controlling Contractor Responsibilities Obtain Host Employer Information Location of known permit spaces Hazards and Potential Hazards Any Previous Precautions Taken Provide to Entry Employers (*Entity) Host Employer information to Entry Employers Any additional information or knowledge The Previous Precautions taken *Note: Use of the word Entity to address Independent Contractors

86 Permit Space Entry Communication and Coordination Entry Employers Must: Obtain the Controlling Contractor information Inform the controlling contractor of the permit space program and any anticipated hazards existing or that may be created Note, the Controlling Contractor and Entry Employer must coordinate operations when More then one entity makes an entry at the same time Entry may be obtained while any other activity could pose a hazard Note: This may include coordination with non-entry employers.

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88 Permit Space Entry Communication and Coordination After Entry Operations: The Controlling Contractor must debrief each entry entity The Entry employer must inform the controlling contractor of the program and any hazards The Controlling Contractor must then share the information with the host facility Note: If no defined Controlling Contractor is on site, the host facility or other employer that arranges to have another employer s employees enter must fulfil these requirements.

89 A Consideration for employees in or near confined spaces! DON T BE THE SECOND VICTIM

90 Rescue and Emergency Services An Employer Must Evaluate Rescuer s Ability to Respond in a Timely Manner Evaluate Rescuer's Ability Ensure Capability to Reach the Victim Proficient in Performing Rescue Will notify Employer if unavailable Inform Rescuers of Hazards on Site Provide Rescue Teams Access as Necessary example: Preplan Development

91 Rescue Employers Provide and Train with Required PPE Train Employees as Required by the Standard s Training Requirements First Aid/CPR Practice on Like Spaces Performing Rescues at Least Once Every Twelve Months

92 Like Spaces

93 Rescue and Emergency Services Non-Entry Rescue is Default Retrieval line or Mechanical Device Must be attached. Mechanical Device must be attached for vertical-type entries greater then five feet Entanglement Issues must be Negotiated

94 Rescue and Emergency Services Safety Data Sheet SDS or Written Information Must be Made Available to a Medical Facility

95 Rescue Time Frames

96 Prompt Identifies availability of: 1. Trained first aid provider at the worksite Or 2. Ensuring emergency treatment services are within reasonable proximity of the work site

97 Reasonable (Near) Proximity First Aid for serious, life threatening injuries such as accidents involving falls, suffocation, electrocution, or amputation must be available within three to four minutes = 4 Minutes

98 Reasonable (Near) Proximity OSHA recognizes that a somewhat longer response time of up to fifteen minutes may be reasonable in workplaces, such as offices, where the possibility of such serious work-related injuries is more remote Life-Threatening = four minutes Non Life-Threatening = fifteen minutes

99 Recap! Calls for: 1. Trained first aid provider at the worksite 2. Ensuring emergency treatment services are within reasonable proximity of the work site Trained As we discuss rescue, consider training of on-site personnel that may be required well beyond First Aid/CPR!!

100 More Information

101 Questions?