CONFINED SPACES SAFETY & HEALTH ISSUES AND REGULATORY COMPLIANCE Are the emplyees r cntractrs wh wrk in yur facility expsed t cnfined space hazards? Have yu cnducted a thrugh assessment f yur facility t identify ptential cnfined spaces? A wrkplace assessment is the first step t ensure emplyee and cntractr safety and t ensure that yu are in cmpliance with OSHA s cnfined space regulatins fr General Industry (29 CFR 1910.146). While these standards d nt apply t cnstructin, there are specific standards in 1926 that d apply. WHAT IS A CONFINED SPACE? The definitin in the OSHA regulatin says that a cnfined space meets the fllwing three criteria: Is large enugh and s cnfigured that an emplyee can bdily enter and perfrm assigned wrk; Has limited r restricted means fr entry r exit (fr example, tanks, vessels, sils, strage bins, hppers, vaults, and pits are spaces that may have limited means f entry.); Is nt designed fr cntinuus emplyee ccupancy. This definitin is adequate in mst cases, but yu still may have questins abut sme spaces at yur facility. Please send us an email if yu wuld like t review a pssible cnfined space with us. Once yu have made the determinatin that cnfined spaces at yur facility exist, yu must develp a cmplete assessment and assciated prgram regarding the plicies and prcedures that yur cmpany will use fr these spaces. The next steps t take in rder t ensure cmpliance are detailed belw. IDENTIFY ALL CONFINED SPACES First, identify all cnfined spaces in yur facility regardless f whether yu enter them and dcument them n an inventry list fr yur recrds. Cntrl access t these spaces by lcking all entrances if pssible and by prviding signs that indicate: CONFINED SPACE DO NOT ENTER WILL EMPLOYEES OR CONTRACTORS ENTER THESE SPACES? Next, decide whether yur emplyees ever need t enter each space r whether yu have cntractrs wh enter them. If entry is never required, ensure that all emplyees are aware f the ptential hazards and that they are never t enter these spaces. Essentially, yur wrk is dne as lng as yu prperly identify any new spaces and peridically remind emplyees f yur nentry plicy. ARE ANY OF THE CONFINED SPACES IN THE FACILITY CONSIDERED TO BE PERMIT-REQUIRED? Sme cnfined spaces require special entry prcedures due t the ptential fr atmspheric and physical hazards within the space. In these cases, emplyers are required t develp a detailed written prgram that describes hw entry will be accmplished safely and that meets OSHA regulatins and utilize an entry permit system. A Permit-Required Cnfined Space (PRCS) is a cnfined space that has ne r mre f the fllwing characteristics: Cntains r has a ptential t cntain a hazardus atmsphere; Cntains a material that has the ptential fr engulfing an entrant; Has an internal cnfiguratin such that an entrant culd be trapped r asphyxiated by inwardly cnverging walls r by a flr which slpes dwnward and tapers t a smaller crss-sectin; Cntains any ther recgnized serius safety r health hazard.
Hellman & Assciates, Inc. The permit is intended t itemize and identify ptential hazards and hw t cntrl them befre entering the space and fr identifying persnnel and lines f respnsibility befre entering the space. This requires that yu evaluate the ptential hazards and develp a permit system fr entry int the space that serves these purpses. The OSHA standard has a generic permit that is available t use as a template fr develping ne specifically fr yur applicatins. Paragraphs (d), (e) and (f) in the standard discuss and list what yu must cnsider when develping a permit system and hw it is t be used t ensure prper and safe entry int cnfined spaces. OSHA s sample permit can be fund here. PERMIT REQUIRED CONFINED SPACE ENTRY PROCEDURES The written cnfined space prgram shuld address cnfined space entry prcedures that must be fllwed t ensure emplyee safety and cmpliance with regulatins. Similarly, each entry permit shuld be develped fr the ptential hazards that may be encuntered within the specific PRCS. Safe entry and wrk in a cnfined space requires that yu cnsider the fllwing items: Identify and evaluate the hazards f permit spaces befre emplyee entrance; Develp and implement the means, prcedures, and practices necessary fr safe permit space entry peratins, including, but nt limited t, the fllwing: Specifying acceptable entry cnditins; Prviding each authrized entrant r that emplyee's authrized representative with the pprtunity t bserve any mnitring r testing f permit spaces; Islating the permit space; and Purging, flushing, r ventilating the permit space as necessary t eliminate r cntrl atmspheric hazards. 2 Prviding pedestrian, vehicle, r ther barriers as necessary t prtect entrants frm external hazards Verifying that cnditins in the permit space are acceptable fr entry thrughut the duratin f an authrized entry Prvide necessary equipment (specified in paragraphs (d)(4)(i) thrugh (d)(4)(ix) f the standard) at n cst t emplyees, maintain the equipment prperly, and ensure that emplyees use the equipment prperly. Such equipment includes testing and mnitring, ventilatin, cmmunicatins, and persnal prtective equipment when engineering and wrk practice cntrls d nt adequately prtect emplyees frm the recgnized hazards. Additinal equipment that shuld be prvided t enable emplyees t wrk safely in the space include: Adequate lighting t see well enugh t wrk safely and t exit the space quickly in an emergency; Barriers and shields as required by paragraph (d)(3)(iv); Equipment, such as ladders, needed fr safe ingress and egress by authrized entrants; Rescue and emergency equipment, except t the extent that the equipment is prvided by rescue services; and Any ther equipment necessary fr safe entry int and rescue frm permit spaces. Cnditins within the PRCS shuld be evaluated upn each entry as fllws: Test cnditins in the permit space t determine whether acceptable entry cnditins exist befre entry; If islatin f the space is infeasible because the space is large r is part f a cntinuus system (such as a sewer), pre-entry testing
Hellman & Assciates, Inc. shall be perfrmed t the extent feasible befre entry, and, if entry is authrized, entry cnditins shall be cntinuusly mnitred in the areas where authrized entrants are wrking. Test r mnitr the permit space peridically t determine whether acceptable entry cnditins are being maintained while in the space; When testing fr atmspheric hazards, test first fr xygen, then fr cmbustible gases and vaprs, and then fr txic gases and vaprs. Prvide each authrized entrant r that emplyee's authrized representative an pprtunity t bserve the pre-entry and any subsequent testing r mnitring f permit spaces. Reevaluate the permit space in the presence f any authrized entrant r that emplyee's authrized representative wh requests that the emplyer cnduct such reevaluatin because the entrant r representative has reasn t believe that the evaluatin f that space may nt have been adequate and immediately prvide each authrized entrant with the results. Prvide at least ne attendant utside the permit space int which entry is authrized fr the duratin f entry peratins NOTE: Attendants may be assigned t mnitr mre than ne permit space prvided the duty can be effectively perfrmed fr each permit space that is mnitred. If multiple spaces are t be mnitred by a single attendant, include in the permit prgram the means and prcedures t enable the attendant t respnd t an 3 emergency affecting ne r mre f the permit spaces being mnitred withut distractin frm the attendant's respnsibilities fr the ther spaces. Designate the persns wh are t have active rles (as, fr example, authrized entrants, attendants, entry supervisrs, r persns wh test r mnitr the atmsphere in a permit space) in entry peratins, identify the duties f each such emplyee, and prvide each such emplyee with apprpriate training. Develp and implement prcedures fr summning rescue and emergency services, fr rescuing entrants frm permit spaces, fr prviding necessary emergency services t rescued emplyees, and fr preventing unauthrized persnnel frm attempting a rescue. Develp and implement a system fr the preparatin, issuance, use, and cancellatin f entry permits. Develp and implement prcedures t crdinate entry peratins when emplyees f mre than ne emplyer are wrking simultaneusly as authrized entrants in a permit space. Develp and implement prcedures (such as clsing ff a permit space and canceling the permit) necessary fr cncluding the entry after entry peratins have been cmpleted. Review entry peratins when the emplyer has reasn t believe that the measures taken under the permit space prgram may nt prtect emplyees and revise the prgram t crrect deficiencies fund t exist befre subsequent entries are authrized Review the permit space prgram, using the canceled permits within 1 year after each entry and revise the prgram as necessary, t ensure that emplyees participating in entry peratins are prtected frm permit space hazards
Hellman & Assciates, Inc. TRAINING Emplyees wh participate in PRCS entries, including supervisrs, attendants and entrants must all be trained s that they acquire the understanding, knwledge, and skills necessary fr the safe perfrmance f the duties t which they are assigned. Training must be cmpleted befre they are assigned such duties r if their duties change. It must be repeated if yu becme aware f deviatins in established prcedures r if yu becme aware f inadequacies in the emplyee's knwledge r use f yur prcedures. The standard requires that the emplyer certify that the training has been accmplished by dcumenting the training and indicating each emplyee's name, the signatures r initials f the trainers, and the dates f training. The certificatin shall be available fr inspectin by emplyees and their authrized representatives. ASSIGNED DUTIES Emplyees wh are authrized entrants, attendants and/r entry supervisrs must have assigned duties that they clearly understand. Authrized entrants must knw: The hazards that may be faced during entry, including infrmatin n the mde, signs r symptms, and cnsequences f the expsure; Hw t prperly use any necessary equipment; Hw t cmmunicate with the attendant as necessary t enable the attendant t mnitr entrant status and t enable the attendant t alert entrants f the need t evacuate the space; T alert the attendant whenever the entrant: Recgnizes any warning sign r symptm f expsure t a dangerus situatin r Detects a prhibited cnditin. Exit frm the permit space as quickly as pssible whenever: An rder t evacuate is given by the attendant r the entry supervisr, 4 Any warning sign r symptm f expsure t a dangerus situatin is recgnized, A prhibited cnditin is detected, r An evacuatin alarm is activated. Attendants must: Knw the hazards that may be faced during entry, including infrmatin n the mde, signs r symptms, and cnsequences f the expsure; Be aware f pssible behaviral effects f hazard expsure in authrized entrants; Cntinuusly maintain an accurate cunt f authrized entrants in the permit space and ensure that the means used t identify authrized entrants as required by the standard accurately identifies wh is in the permit space; Remain utside the permit space during entry peratins until relieved by anther attendant; Cmmunicate with authrized entrants as necessary t mnitr entrant status and t alert entrants f the need t evacuate the space arises; Mnitr activities inside and utside the space t determine whether it is safe fr entrants t remain in the space and rders the authrized entrants t evacuate the permit space immediately if any f the fllwing cnditins are detected: A prhibited cnditin, Behaviral effects f hazard expsure in an authrized entrant, A situatin utside the space that culd endanger the authrized entrants, and Duties f the attendant cannt be effectively and safely perfrmed. Summn rescue and ther emergency services as sn as the attendant determines that authrized entrants may need assistance t escape frm permit space hazards;
Hellman & Assciates, Inc. Take the fllwing actins when unauthrized persns apprach r enter a permit space while entry is underway: Warn the unauthrized persns that they must stay clear f the space, Advise the unauthrized persns that they must exit immediately if they have entered the permit space, Infrm authrized entrants and the entry supervisr if unauthrized persns have entered the permit space, Perfrms nn-entry rescues as specified by the rescue prcedure. Perfrm n duties that might interfere with the primary duty t mnitr and prtect the authrized entrants. Entry Supervisrs are respnsible fr: Knwing the hazards that may be faced during entry, including infrmatin n the mde, signs r symptms, and cnsequences f the expsure; Verifying, by checking that the apprpriate entries have been made n the permit, that all tests specified by the permit have been cnducted and that all prcedures and equipment specified by the permit are in place befre endrsing the permit and allwing entry t begin; Terminating the entry and cancel the permit as required; Verifying that rescue services are available and that the means fr summning them are perable; Remving unauthrized individuals wh enter r wh attempt t enter the permit space during entry peratins; and Determining, whenever respnsibility fr a permit space entry peratin is transferred and at intervals dictated by the hazards and peratins perfrmed within the space, that entry peratins remain cnsistent with terms f the entry permit and that acceptable entry cnditins are maintained. 5 RECLASSIFYING PERMIT SPACES AS NON PERMIT SPACES A PRCS space can be reclassified as a nn-permit space if the permit space pses n actual r ptential atmspheric hazards and if all hazards within the space are eliminated withut entry int the space. This cnfined space may be classified as a nn-permit space fr as lng as the nnatmspheric hazards remain eliminated. Eliminatin f the hazards must be cmpleted frm utside the space prir t entry. If emplyees must enter the space t eliminate the hazards they must use a permit system. Once the hazards have been eliminated the space may be reclassified. Cntrl f atmspheric hazards using frced air ventilatin is nt cnsidered eliminatin f the hazards. RESCUE AND EMERGENCY SERVICES The OSHA standard allws emplyers t use inhuse r utside rescue services fr PRCS rescues. If yu plan t have yur emplyees cnduct rescue activities in cnfined spaces, there are significant issues t address ahead f time. Unless yu are cmmitted t adequate training, prvisin f equipment, practice drills and a significant amunt f preplanning, yu shuld nt cnsider this ptin, but shuld use an utside service instead. Outside services shuld be prearranged and selected based n their capabilities and knwledge f cnfined space hazards and rescues and n their ability t respnd quickly. It is recmmended that utside services visit yur facility t discuss yur cnfined space entry prcedures and s they can becme familiar with the specific spaces where rescue duties may be needed. PERMIT SPACES WITH ONLY ATMOSPHERIC HAZARDS Yu are nt required t use a permit system r designate a rescue team fr entering cnfined spaces that nly have atmspheric hazards, prvided that: Yu can demnstrate that the nly hazard psed by the permit space is an actual r ptential hazardus atmsphere.
Hellman & Assciates, Inc. Yu can demnstrate that cntinuus frced air ventilatin alne is sufficient t maintain that permit space safe fr entry. Yu develp mnitring and inspectin data that supprts these demnstratins and data is well dcumented and available t each emplyee wh enters the space. If entry f the permit space is necessary t btain this data yu must use a permit system and have a rescue team. Entry int the permit space is perfrmed in accrdance with the fllwing requirements: Any cnditins making it unsafe t remve an entrance cver shall be eliminated befre the cver is remved, When entrance cvers are remved, the pening must be prmptly guarded by a railing, temprary cver, r ther temprary barrier that will prevent an accidental fall thrugh the pening and that will prtect each emplyee wrking in the space frm freign bjects entering the space, Befre an emplyee enters the space, the internal atmsphere must be tested with a calibrated direct-reading instrument fr xygen cntent, flammable gases and vaprs, and ptential txic air cntaminants, in that rder. Any emplyee wh enters the space, r that emplyee's authrized representative, must be prvided an pprtunity t bserve pre-entry testing required by the standard. There may be n hazardus atmsphere within the space whenever any emplyee is inside the space, Cntinuus frced air ventilatin must be used, as fllws: 6 An emplyee may nt enter the space until frced air ventilatin has eliminated any hazardus atmsphere, Frced air ventilatin must be directed t ventilate the immediate areas where an emplyee is r will be present within the space and must cntinue until all emplyees have left the space, The air supply fr the frced air ventilatin shall be frm a clean surce and may nt increase the hazards in the space, The atmsphere within the space must be peridically tested as necessary t ensure that the cntinuus frced air ventilatin is preventing the accumulatin f a hazardus atmsphere. Any emplyee wh enters the space, r that emplyee's authrized representative, must be prvided with an pprtunity t bserve the peridic testing. If a hazardus atmsphere is detected during entry: Each emplyee must leave the space immediately, The space must be evaluated t determine hw the hazardus atmsphere develped, Measures must be implemented t prtect emplyees frm the hazardus atmsphere befre any subsequent entry takes place. Verify that the space is safe fr entry and that the pre-entry measures have been taken, thrugh a written certificatin that cntains the date, the lcatin f the space, and the signature f the persn prviding
Hellman & Assciates, Inc. the certificatin. The certificatin must be made befre entry and made available t each emplyee entering the space r t that emplyee's authrized representative. H&A prvides specialized supprt in a number f technical areas. Our certified safety and health prfessinals wrk with yur rganizatin t design a prgram fr yur site-specific cmpliance issues. Please cntact us at: www.ehscmpliance.cm 7