CONFINED SPACES. American Galvanizers Association Phone: (720) Fax: (720) Scope

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1 Phone: (720) Fax: (720) CONFINED SPACES 1. Scope 1.1 This guideline covers practices and procedures to protect employees in the galvanizing industry from the hazards of entry into s. 1.2 This guideline covers the Occupational Health and Safety Administration (OSHA) final rule and amendment in 29 CFR concerning requirements for Confined Space Entry (CSE). 1.3 This guideline for s follows the CSE standard and applies to all of general industry, including galvanizers. The CSE standard requires employers to prepare a written program and implement a entry permit system. 2. Referenced Documents BNA Communications Inc. Confined Spaces, Deadly Places Employee s Manual. Edited by: Judy Knight, 1992 BNA Communications Inc. Survival by Permit Employee s Manual J.J. Keller Associates, OSHA Compliance Manual 29 CFR 1910 Plant Safety. Updated October J.J. Keller Associates, Confined Space Final Rule Your New Requirements Under OSHA Section March 1993, Volume 3, Number 3 J.J. Keller Associates, Industrial Safety Report Special Report Permit-Required Confined Spaces. October 1996, Volume 6, Number 10 Roughton, James. Hazardous Materials Control. Confined Space Entry: The Standard. May/June 1993, p Terminology 3.1 Definitions The following terms and definitions are specific to the guideline for s. 3.2 Definitions of Terms Specific to the Guideline acceptable entry conditions conditions that must exist in a permit space to allow entry and to ensure that employees involved with a permitrequired entry can safely enter into and work within the space attendant an individual stationed outside one or more permit-required s who monitors the authorized entrants and who performs all attendant s duties assigned in the employer s program. Disclaimer The material contained herein has been developed to provide accurate and authoritative information about the practices and procedures to protect employees in the galvanizing industry from the hazards of entry into s. This material provides general information only and is not intended as a substitute for competent professional examination and verification as to suitability and applicability. The publication of the material herein is not intended as a representation or warranty on the part of the, Inc. Anyone making use of this information assumes all liability arising from such use. 1

2 3.2.3 authorized entrant individual who is authorized by the employer to enter a permit-required authorized entry an entry that is has been authorized by the entrant supervisor and is restricted to authorized personnel, such as, authorized entrant, and attendant a space that is: (1) large enough and configured so that an employee can bodily enter and perform assigned work; and (2) has limited or restricted means for entry or exit (ex. Tanks, vessels, silos, storage bins, hoppers, vaults, and pits are spaces that may have limited means of entry); and (3) not designed for continuous employee occupancy entry action by which a person passes through an opening into a. Entry includes performing work activities in that space and is considered to have occurred as soon as any part of the entrant s body breaks the plane of an opening into the space entry permit written or printed document that is provided by the employer to allow and control entry into a permit-required and that contains the information specified in section and of this guideline entrant supervisor individual (such as an employer, foreman, or plant manager) responsible for: (1) determining if acceptable entry conditions are present at a permit-required where entry is planned, (2) authorizing entry and overseeing entry operations, (3) terminating entry as required program administrator individual responsible for issuing and administrating the program and making sure that the program satisfies all applicable Federal, State, and local requirements 4. Definition of a Confined and Permit-Required Confined Space 4.1 The OSHA standard defines a Confined Space as an enclosed area that is large enough that an employee can completely enter the space to perform an assigned task, has limited or restricted means for entrance and exit, and is not designed for continuous employee occupancy. 4.2 A Permit-Required Confined Space is defined as a that exhibits one or more of the following characteristics: Contains or has the potential to contain a hazardous atmosphere (toxic, flammable, asphyxiating). Contains a material which may engulf the entrant. Is configured such that an entrant could be trapped or asphyxiated by inwardly converging walls; or has a downward sloping floor that tapers to a smaller crosssectional area. Contains any other recognized serious safety or health hazards If one or more permit-required confined spaces are present at a facility, the employer must develop a entry permit system to restrict and regulate entry into those spaces Employees are allowed to participate in developing a entry permit system and to have access to permit-required program information Employee participation ensures employee involvement in developing and implementing the entry permit system. 4.3 A sample of a permit-required decision flow chart and an example of a typical permit are included as appendices. 4.4 A space classified by an employer as a permitrequired may be reclassified as a nonpermit under the following process: i.) If the space poses no actual or potential atmospheric hazards and if all hazards within the space are eliminated without entry into the space, the permit-required may be reclassified as a non-permit for as long as the non-atmospheric hazards remain eliminated. ii.) The employer shall document the basis for determining that all hazards in a permitrequired have been eliminated through a certification that contains the date, location of the space, and signature of the person making the determination. 2

3 iii.) The certification shall be made available to each employee entering the space and be retained by the employer for one year. 5. Types of Confined Spaces 5.1 Confined spaces can be categorized as areas with open tops that restrict the natural movement of air or enclosed spaces with a limited number of openings for entry or exit. In both cases, the space may contain mechanical equipment with moving parts, that compound the hazards present within the Galvanizing kettles, pickling and caustic tanks, and the access pits around these vessels may be classified as open topped s that usually contain no moving parts. 5.2 Open topped water tanks that appear harmless may develop toxic atmospheres such as hydrogen sulfide from the vaporization of contaminated water. When an entry into a is being planned, gases heavier than air are a primary concern. 5.3 Confined spaces such as sewers, manholes, storage tanks, baghouses, and furnaces usually have limited access. The potential problems arising in these areas are similar to the hazards that occur in open topped s; however, the limited access increases the risk of injury. 5.4 Under certain conditions, excavations, trenches or natural depressions may be considered s because they trap potentially hazardous vapor and restrict the flow of oxygen. 5.5 Activities associated with storage tanks that may involve entry include tank lining, trench digging for access to piping associated with tanks, excavating or repairing beneath tanks, and entering manways to access instrumentation. 5.6 Examples of areas common to the galvanizing industry that can be considered s include: access pits baghouses (dust collectors) caustic tanks chemical storage tanks containment pits galvanizing kettles hazardous and non-hazardous waste tanks kettle pits manholes pickling tanks quench tanks rinse tanks spent acid tanks sumps 6. Hazards of a Confined Space 6.1 Hazards may also develop due to the work being performed in a. For example, welding can generate toxic gases or use up the available oxygen and change the status of a confined space from safe to hazardous. 6.2 Gases that are heavier than air may lie in a for hours or even days after the area has been opened. The hazard may be overlooked with fatal results because some gases are odorless. Gases that are lighter than air may also be trapped within an enclosed type of, especially those with access from the bottom or side. 7. Entry Permit 7.1 Before entering any permit-required confined space, acceptable entry conditions must be verified through testing and an entry permit must be completed and signed by an entry supervisor to authorize entry. 7.2 An entry permit, in addition to an authorized entry, serves as a source of critical safety and hazard information for entrants, attendants, and emergency responders. 7.2 An entry permit acts as a check that all hazards have been controlled, and equipment and safety procedures are in place prior to authorization by an entry supervisor The permit must identify all conditions to be evaluated to ensure safe entry into a permit-required, and should include the following information in the checklist portion of the permit: Hazards (potential and actual) of the confined space Measures for isolation (i.e. lockout/tagout) of the Equipment and procedures used for purging, inerting, ventilating and flushing the in order to remove or control potential hazards Acceptable environmental conditions which must be maintained during entry (i.e. temperature, atmosphere, etc.) 3

4 Testing procedures and monitoring equipment used by the employer to verify that acceptable environmental conditions are being maintained during entry Rescue and other emergency services to be summoned in case of an emergency, including the appropriate means of communicating with those services On-site rescue equipment which will be provided; if necessary Communication procedures and equipment used by authorized entrants and attendants in order to maintain contact during the entry Personal protective equipment, such as respirators, clothing and retrieval lines, necessary to ensure employee safety Any other pertinent information dependent upon the circumstances and conditions of the Specific measures taken to remove or control permit hazards Initial and/or periodic test results corresponding to entry conditions with name(s) or initial(s) of tester(s) and when tests were performed A list of all equipment used to comply with entry requirements Any additional permits issued to authorize work in the permit space In addition to the checklist items required above, the standardized permit form must also include the following information: Identity of the Purpose of the entry Date and authorized duration of the entry A list of authorized entrants A list of eligible attendants A list of individuals eligible to supervise the entry Signature and printed name of the person authorizing the entry, verifying that all actions and conditions necessary for safe entry have been performed 8. Duties of Permit-Required Confined Space Entry Personnel 8.1 Authorized entrants Authorized entrants must know the hazards they may face, be able to recognize signs or symptoms of exposure, and understand the consequences of exposure to the hazards Authorized entrants must know how to use necessary equipment and communicate with the attendants Authorized entrants must be aware of the emergency plan, how to warn other entrants of the existence of a hazardous condition, and summon help if someone is in distress Authorized entrants must be familiar with the tasks they are expected to perform in the permitrequired. The authorized entrants should complete additional training in procedures that are not routine, as well as any potential hazards and how to control them Authorized entrants or their authorized representative have an opportunity to observe any testing or monitoring of permit-required confined spaces conducted prior to entry and subsequent to entry By observing the testing or monitoring of a permit-required, the authorized entrants or their authorized representative help to ensure that the testing has been done properly, respirators and other personal protective equipment being worn are appropriate. 8.2 Attendant - An attendant must be assigned to every permit-required entry An attendant can monitor multiple spaces if the permit program incorporates procedures to enable the attendant to respond to an emergency in one or more of the spaces without compromising the attendant s overall responsibilities An attendant cannot perform other duties that interfere with the primary duties of monitoring and protecting the safety of authorized entrants The attendant must know the hazards of the and be aware of the warning signs and physical symptoms of toxic gases Some of the other responsibilities for attendants include: maintain a continuous count and identification of authorized entrants prevent unauthorized entry by remaining stationed outside until the space is relieved communicate with the entrants to monitor status and activities inside and outside the space and order an emergency exit if required summon rescuers if necessary and begin to perform a non-entry rescue if it can be done 4

5 safely An attendant may also be responsible for continuously monitoring the air, recognizing hazardous atmospheric changes, and ordering evacuation of the space as warranted. An attendant must also be aware of any special work practices that need to be done in the space before an entry begins. If auxiliary ventilation is used, the attendant should be sure that the source of air intake does not draw carbon monoxide or other contaminants into the space. 8.3 Entrant supervisors An entrant supervisor must know the hazards that may be faced during entry, including information on the mode, signs or symptoms, and consequences of exposure An entrant supervisor needs to verify that all tests specified by the permit have been conducted and that all procedures and equipment specified by the permit are in place before endorsing the permit and allowing entry to begin Other responsibilities of an entrant supervisor include: terminating the entry and canceling the permit verifying that rescue services are available and that the means for summoning them are operable removing unauthorized individuals who enter or who attempt to enter the permit-required during entry operations determining that entry operations remain consistent with the terms of the entry permit and that acceptable entry conditions are maintained 9. Preparation of Permit-Required Confined Space 9.1 All material (for example, liquid) will be transferred into a holding container(s). 9.2 Once this procedure is completed, all transfer piping will be properly locked-out/tagged-out according to the lockout/tagout procedure. 9.3 All heat and energy sources will be properly locked-out/tagged-out according to the lockout/tagout procedure. 9.4 The necessary supervisors will then be notified that the permit-required is free of material and the material and heat sources are locked-out/tagged- out. 10. Hazard Testing before Entry into Permit- Required Confined Space 10.1 Prior to entry, the permit-required confined space shall be tested for lingering hazards The atmospheric testing of the permitrequired should include oxygen, flammability (LEL Lower Explosive Limit) and toxics (i.e. carbon monoxide, hydrogen sulfide). Testing should be conducted in the following order: First test for oxygen content, secondly test for flammability (LEL), then test for toxic hazards. If oxygen, flammability and toxic atmospheric testing are acceptable, proceed with preparing the equipment for the permit-required entry. The acceptable levels of oxygen are between 19.5% and 23.5% by volume. Flammable gases shall not contain flammable gas, vapor, or mist in excess of 10 % the LEL. The acceptable toxic levels will depend on the permissible exposure levels (PELs) of the type of gas If the testing indicates unacceptable levels, the next step is to utilize forced air ventilation to provide oxygen to the space and/or remove toxic or flammable atmospheres. The permit-required should be monitored while the space is being ventilated. When the permit-required atmosphere is acceptable, proceed with preparing equipment for the permit-required entry The permit-required area will be continuously monitored while the repairs or work is being done on the permit-required confined space The permit-required entry evaluation log will be maintained at all times from the initial testing until all personnel and equipment are out of the area Authorized entrants have an opportunity to observe the testing or monitoring of the permitrequired to ensure that testing has been done properly prior to entry or subsequent to entry. 11. Preparing the Equipment 11.1 All necessary equipment will be gathered and inspected prior to entry into the permit-required. 5

6 The equipment should include items necessary to perform the activity in the permitrequired The equipment should also include any personal protective devices that are needed. The equipment should be checked to make sure that it is working correctly and fitted properly to the authorized entrant. 12. Topics to Discuss Before Entering the Permit- Required Confined Space 12.1 Before entering the permit-required confined space, a meeting should take place to discuss issues that may occur during the procedure These issues would involve potential situations that may occur while attending to tasks while in the permit-required and information on various personal assignments Topics for Discussion 1. Potential slippery floor surface 2. Overhead crane activity 3. Proper use of personal protective equipment 4. Individuals who will be in permit-required 5. Safety observer assignment 6. Ensure safety observers understand their duty and responsibility 7. Use of safety harnesses, and rescue procedure 8. Length of time expected to be in permitrequired 9. Individuals going into permit-required personally check lockout/tagout locations 10. Procedure for evacuation if atmosphere turns hazardous while in permit-required 13. Rescue Procedures 13.1 A procedure is set up in case of an emergency situation and a rescue is necessary The following is a list of procedures when an authorized entrant is in a. 1. Entrant supervisor will be monitoring atmospheric conditions for a change in oxygen level at all times. 2. If there is a change in the condition of the atmosphere in the permit-required confined space, the authorized entrant shall immediately leave the space. 3. If the authorized entrant is overcome by vapors, the entrant supervisor will immediately radio for emergency backup, and then retrieve the authorized entrant with the retrieval system. 4. When radioing for backup, the entrant supervisor will instruct the main office to dial 911 and have an emergency response. 5. When the authorized entrant is rescued from the permit-required, the entry supervisor or the attendant should immediately provide first aid as needed, until the emergency response department arrive. 14. Rescue and Emergency Services 14.1 OSHA permits employers to rely on outside rescue and emergency services If an employer chooses this strategy, the company must provide outside responders with information about their permit-required confined spaces and make their facilities available for permitrequired rescue practice An employer must select a rescue service that is trained, equipped and available to respond to emergencies that occur during permit-required entries OSHA has added a non-mandatory Appendix F to the 29 CFR that provides guidance to employers in choosing appropriate rescue services for permit-required s Employers may elect to have their own employees enter permit-required s to perform rescue services Employers must ensure that each member of the rescue team is: Provided with and trained to properly use the personal protective equipment and rescue equipment necessary for making rescues from permit-required s Trained to perform the assigned rescue duties Practice making permit-required confined space rescues at least once every twelve months by means of simulated rescue operations in which they remove dummies, 6

7 mannequins, or persons from the actual permit-required s or from representative permit-required confined spaces. Representative permit-required s shall with respect to opening size, configuration, and accessibility, simulate the types of permit-required s that rescue is to be performed Trained in basic first aid and in CPR 15. Nonpermit-Required Confined Spaces 15.1 Confined spaces can also be nonpermit required s. Nonpermit-required s do not have the same stringent procedures as a permit-required Nonpermit-required s do not require an entry permitting system with authorized personnel A nonpermit-required is a that does not contain any characteristics of a permit-required Procedures for a nonpermit-required The first step is to set up rescue procedures in case an emergency occurs in the nonpermitrequired. The procedures should include: 1. The location of the emergency equipment that is easily accessible to the location of a nonpermit-required. 2. Emergency equipment should be checked to make sure it is working properly and is not damaged. 3. Employees should be trained in the proper use and care of the emergency equipment. 4. Emergency contacts should be readily available and posted 5. General training in hazards should be done for any employee that will be working in or around the nonpermit-required. Before entering any type of, testing of the atmosphere in the confined space may be necessary. 1. Testing should involve making sure that the nonpermit-required is safe for entry. 2. Under certain circumstances, the atmosphere in the nonpermit-required may change. Working in a nonpermit-required may decrease the level of oxygen and ventilation may be needed. 3. If the atmosphere changes in a nonpermit-required, necessary precautions should take place. The precautions should entail the proper procedures in ventilating the nonpermitrequired. General safety precautions and common sense should be used while working in or around a nonpermit-required. 7