DAMEWOOD CONSULTING GROUP HEALTH - SAFETY - TRAINING October 30, 2015 City of Seaside Ms Roberta Greathouse Dear Ms Greathouse: On Monday, October 12 th, 2015, I conducted a survey of a number of spaces entered by the City of Seaside Public Works Department. The purpose of this survey was to determine if these spaces are confined spaces and if so what type of space. The following report summarizes the findings of this survey. This report also offers suggestions to reduce employee exposure when entering these spaces. Thank you or the opportunity to work with organization. If you have any questions or need clarification on any matter please don t hesitate to contact me. Steve Damewood Safety Consultant 201 N Deerwood St., ORANGE, CA 92869 (714) 771-4038
Confined Space Survey For The City of Seaside Prepared By Steve Damewood Damewood Consulting Group On Monday, October 12 th, 2015, I conducted a survey of a number of spaces entered by the City of Seaside Public Works Department. The purpose of this survey was to determine if these spaces are confined spaces and if so what type of space. The history of the Public Works Department when working in these spaces has been that no hazardous atmosphere has ever been encountered and no incidents have taken place in these spaces. Regulatory Issues General Industry Safety Orders (GISO) Section 5157 defines a confined space as a space that is large enough for an employee to enter, have limited access or egress and are not designed for continuous occupancy by employees. Further GISO Section 5157 identifies three types of confined spaces: A non-permit confined space is a confined space that contains no atmospheric hazards and has no potential to contain such a hazard. There are no special procedures to enter these spaces. An alternate entry confined space is a confined space where the hazards can be controlled or eliminated by continuous ventilation of the space. Before entry these spaces must be ventilated, tested for combustible gas, oxygen and other toxics and a written CERTIFICATION for entry must be issued. If the ventilation system fails or a hazardous atmosphere is detected or any other serious problem develops, all employees must leave the space. A permit required confined space is a confined space where the hazards cannot be controlled or eliminated by continuous ventilation of the space or an engulfment hazard exists. Before entry these spaces must be isolated, ventilated, tested for combustible gas, oxygen and other toxics and a written PERMIT for entry must be issued. An attendant with rescue equipment is required to be on the site. 2
GISO 5157 requires the employer to determine if the space to be entered is a confined space and if so what type of space. Also to develop and implement a confined space entry program appropriate to the type of confined space being entered. Summary of Findings In general I found that the spaces evaluated are in fact a confined space under GISO 5157. The only spaces that are permit required confined spaces would be the wet wells and live sewer. The wet wells are not entered by City of Seaside employees but by Monterey Regional Water Pollution Control Agency (MRWPCA) employees. I recommend the City of Seaside send the MRWPCA a letter notifying them that the wet wells have been classified as a permit required confined space. City of Seaside may enter live sewer systems. All other confined spaces identified are considered as a non-permit space. I recommend a policy for City of Seaside employees that no employee shall enter a live sewer if a hazardous atmosphere is present and / or shall immediately evacuate if one is detected. In that case the open sewer should be considered an alternate entry space. Note: test results do not include work activities where a hazardous atmosphere may be created (such as epoxy coating, sandblasting or extensive welding or cutting) in that event all non-permit spaces shall be reclassified as an alternate entry space. Test results when listed were conducted with a Scott 4 channel meter (combustible gas, oxygen, H2S and CO) that was calibrated and in good working order. Equipment Listing Police Department Storm Water Vault Non-Permit Confined Space. Concrete vault, entered via manway in parking lot above vault and fixed ladder. Approximately 10 feet deep. City employees / contractors may enter vault to service / replace pump or motor. No apparent potential for a hazardous atmosphere. Meter reading no hazardous atmosphere. Lakeside Park Meter Vault Non-Permit Confined Space. Concrete vault, entered via steel plates above vault and vertical ladder. City employees / contractors may enter vault to service / adjust valves and or meter, repair leaks. No apparent potential for a hazardous atmosphere, vault approximately six feet deep. Meter reading no hazardous atmosphere. 3
Water Tanks Non-Permit Confined Space. Two water tanks (not inspected) entered via top man way on tank. City employees / contractors may enter tank for inspection or cleaning. Tanks entered approximately every five years. No apparent potential for a hazardous atmosphere, no meter readings were obtained. No chemical treatment in tanks. Recommend atmosphere be tested for combustible gas and oxygen prior to entry to confirm classification as a non-permit space. Lakeside Park Storm Water Vault Non-Permit Confined Space. Concrete vault, entered via steel plates above the vault. Plates sealed and I could not visually inspect the vault. No apparent potential for a hazardous atmosphere, vault approximately 20 feet deep. City employees typically clean the vault from outside and do not enter the vault. Should entry be required recommend atmosphere be tested for combustible gas and oxygen prior to entry to confirm classification as a non-permit space. Wet Well Stations Permit Confined Space. The City of Seaside has four sanitation wet wells. City employees do not enter these wet wells but employees of MRWPCA do. Wet wells were not inspected or tested for a hazardous atmosphere. They are classified as a Permit Required Confined Space on the basis of potential exposure to a hazardous atmosphere (open sewer) which cannot be isolated. Sewer Permit Confined Space. City employees may enter live sewers to inspect or repair sewer pipe. The sewer was not inspected or tested for a hazardous atmosphere. It is classified as a Permit Required Confined Space on the basis of potential exposure to a hazardous atmosphere (open sewer) which cannot be isolated. However it could be reclassified as an alternate entry space if continuous forced air ventilation eliminated a hazardous atmosphere. Meter Vault Typical Non-Permit Confined Space. Three concrete vaults, entered via top man way and extension ladder approximately five feet deep. City employees / contractors may enter vault to read meters, service pipe or repair leaks. No apparent potential for a hazardous atmosphere. The City has two vaults approximately two feet deep that are not considered a confined space because access would not be limited. 4
Community Center Pool Surge Pits Non-Permit Confined Space. The City pool has surge pits between six and eight feet deep. Access is from fixed ladder. Employees may enter to repair / replace motor or clean area. No apparent hazard. Entry is with an extension ladder. Meter test indicated no hazardous atmosphere. Community Center Attic Non-Permit Confined Space. Attic above Community Center accessed by a 10 foot fixed ladder. City employees / contractors may enter to service / inspect HVAC equipment. Meter test indicated no hazardous atmosphere. Corporation Yard Attic Non-Permit Confined Space. Attic above Corporation Yard accessed by a fold down ladder. City employees / contractors may enter to service / inspect HVAC, lighting and camera equipment. Meter test indicated no hazardous atmosphere.. 5
CITY OF SEASIDE CONFINED SPACE ENTRY 1.0 Purpose This procedure has been developed to detail the methods, controls, activities and practices for employee entry and work in confined spaces. 2.0 Scope This procedure applies to all City controlled sites. A copy of this procedure will be on file at every jobsite during confined space entry / work. Copies will be available from the Supervisor for employees, subcontractors and representatives of Cal-OSHA. 3.0 Summary Confined spaces are those spaces that are large enough for an employee to enter, have limited access or egress and are not designed for continuous occupancy by employees. Different procedures are required for different types of confined spaces. A non-permit confined space is a confined space that contains no hazards and cannot ever contain a hazard. The detailed procedures for entering these spaces are in Section 8.0. An alternate entry confined space is a confined space where the hazards can be controlled or eliminated by continuous ventilation of the space. Before entry these spaces must be ventilated, tested for combustible gas, oxygen and other toxics and a written CERTIFICATION for entry must be issued. An attendant is required to be on the site. If the ventilation system fails or a hazardous atmosphere is detected or any other serious problem develops, all employees must leave the space. The detailed procedure for entering these spaces is in Section 9.0. A permit required confined space is a confined space where the hazards cannot be controlled or eliminated by continuous ventilation of the space or an engulfment hazard exists. Before entry these spaces must be isolated, ventilated, tested for combustible gas, oxygen and other toxics and a written PERMIT for entry must be issued. An attendant with rescue equipment is required to be on the site. If the ventilation system fails or a hazardous atmosphere is detected or any other serious problem develops, all employees 6
must leave the space. City employees will not enter permit-required confined spaces that cannot be reclassified as an alternate entry space. 4.0 Definitions Acceptable entry conditions - the conditions that must exist in a permit space to allow entry and to ensure that employees involved with a permit-required confined space entry can safely enter into and work within the space. Attendant - an individual stationed outside permit spaces who monitors the authorized entrants and who performs all attendants duties assigned in the employer's permit space program. Authorized entrant - an employee who is authorized by the employer to enter a permit space. Blanking or blinding - the absolute closure of a pipe, line, or duct by the fastening of a solid plate (such as a spectacle blind or a skillet blind) that completely covers the bore and that is capable of withstanding the maximum pressure of the pipe, line, or duct with no leakage beyond the plate. Confined space - a space that 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. Double block and bleed - the closure of a line, duct, or pipe by opening and locking or tagging a drain or vent valve in the line between the two closed valves. Emergency - any occurrence (including any failure of hazard control or monitoring equipment) or event internal or external to the permit space that could endanger entrants. Engulfment - the surrounding and effective capture of a person by a liquid or finely divided (flowable) solid substance that can be aspirated to cause death by filling or plugging the respiratory system or that can exert enough force on the body to cause death by strangulation, constriction, or crushing. Entry - the action by which a person passes through an opening into a permitrequired confined space. Entry includes ensuing 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. 7
Entry permit (permit) - the written or printed document that is provided by the employer to allow and control entry into a permit space and that contains the required information. Hazardous atmosphere - an atmosphere that may expose employees to the risk of death, incapacitation, and impairment of ability to self-rescue (that is, escape unaided from a permit space), injury, or acute illness from one or more of the following causes - flammable gas, vapor, or mist in excess of 5 percent of its lower explosive limit (LEL) - airborne combustible dust at a concentration that meets or exceeds its LEL - atmospheric oxygen concentration below 19.5 percent or above 23.5 percent - atmospheric concentration of any substance for which a Permissible Exposure Limit (PEL) is published in Federal or State OSHA regulations and which could result in employee exposure in excess of its permissible exposure limit - any other atmospheric condition that is immediately dangerous to life or health. Hot work permit - the employer's written authorization to perform operations (for example, riveting, welding, cutting, burning, and heating) capable of providing a source of ignition. Immediately dangerous to life or health (IDLH) - any condition that poses an immediate or delayed threat to life or that would cause irreversible adverse health effects or that would interfere with an individual's ability to escape unaided from a permit space. Inerting - the displacement of the atmosphere in a permit space by a noncombustible gas (such as nitrogen) to such an extent that the resulting atmosphere is noncombustible. Isolation - the process by which a permit space is removed from service and completely protected against the release of energy and material into the space by such means as: blanking or blinding; misaligning or removing sections of lines, pipes, or ducts; a double block and bleed system; lockout or tagout of all sources of energy; or blocking or disconnecting all mechanical linkages. Line breaking - the intentional opening of a pipe, line, or duct that is or has been carrying flammable, corrosive, or toxic material, an inert gas, or any fluid at a volume, pressure or temperature capable of causing injury. Non-permit confined space - a confined space that does not contain or, with respect to atmospheric hazards, have the potential to contain any hazard capable of causing death or serious physical harm. Oxygen deficient atmosphere - an atmosphere containing less than 19.5 percent oxygen by volume. 8
Oxygen enriched atmosphere - an atmosphere containing more than 23.5 percent oxygen by volume. Permit-required confined space (permit 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. Prohibited condition - any condition in a permit space that is not allowed by the permit during the period when entry is authorized. Rescue service - the personnel designated to rescue employees from permit spaces in an emergency. Retrieval system - the equipment (including a retrieval line, full-body harness, and a lifting device or anchor) used for non-entry rescue of persons from permit spaces. Testing - the process by which the hazards that may confront entrants of a permit space are identified and evaluated. Testing includes specifying the tests that are to be performed in the permit space. 5.0 Responsibility The designated entry supervisor is responsible for implementation of this procedure to include: A. Evaluating and classifying potential spaces for confined space status and knowing the hazards that may be faced during entry including information on the mode, signs or symptoms and consequences of the exposure. B. Conducting a pre-entry briefing to review hazards, personal protective equipment, rescue / emergency notification and protocol. C. Issuing certifications (if required). D. Reviewing and ensuring all confined space requirements are complied with and that acceptable entry conditions are maintained throughout the entry. E. Ensuring that the confined space is isolated prior to entry (except sewers). 9
F. Conducting or ensuring that all atmospheric testing is completed and documented on the entry permit prior to entry. G. Ensuring that the required ventilation is properly placed and maintained prior to and during the confined space entry. H. Preventing unauthorized individuals from entering or attempting to enter the permit required confined space during entry operations. I. Terminating the entry and canceling the entry permit when the entry operations covered by the entry permit have been completed or a condition that is not allowed under the entry permit arises in or near the permit space. J. Verifying that rescue services are available and that the means to summon additional help are available and operable. 2. Entrants (employees entering a confined space) are responsible for: A. Knowing the hazards that may be faced during entry, including information on the mode, signs or symptoms, and consequences of the exposure. B. Properly using equipment as required by this procedure. C. Communicating with the stand-by attendant as necessary to enable the attendant to monitor entrant status and to enable the attendant to alert entrants of the need to evacuate the space. D. Alerting the attendant whenever the entrant recognizes any warning sign or symptom of exposure to a dangerous situation, or detects a prohibited condition. E. Exiting from the permit space as quickly as possible whenever an order to evacuate is given or the entrant recognizes any warning sign or symptom of exposure or a prohibited condition. 3. Attendants are responsible for: A. Knowing the hazards that may be faced during entry, including information on the mode, signs or symptoms, and consequences of the exposure, B. Being aware of possible behavioral effects of hazard exposure in entrants. C. Continuously maintains an accurate count of entrants in the permit space and ensures that the entry roster is maintained and accurate. 10
D. Remaining outside the alternate entry space during entry operations unless relieved by another attendant. E. Communicating with authorized entrants as necessary to monitor entrant status and to alert entrants of the need to evacuate the space. F. Monitoring activities inside and outside the space to determine if it is safe for entrants to remain in the space and orders the authorized entrants to evacuate the permit space immediately if the attendant detects a prohibited condition or if the attendant detects the behavioral effects of hazards exposure in an authorized entrant or if the attendant detects a situation outside the space that could endanger the authorized entrants or if the attendant cannot effectively and safely perform all duties. G. Initiating on-site rescue procedures and, if necessary, summon additional rescue and other emergency services as soon as the attendant determines that authorized entrants may need assistance to escape from permit space hazards. H. Warning unauthorized persons that they must stay away from the permit space or advising the unauthorized persons that they must exit immediately if they have entered the permit space. I. Performing non-entry rescues. J. Performing no duties that might interfere with the attendant's primary duty to monitor and protect the authorized entrants. 6.0 Contractor Information When employees of a contractor are required to enter either a permit required or non-permit required confined space controlled by the City, the City shall provide the contractor with the following information: A. Status of the confined space as either permit or non-permit required. B. Any available information regarding permit space hazards and entry operations. C. Procedures to coordinate entry operations with the City when both City personnel and contractor personnel will be working in or near permit spaces. The City shall inform the contractor of the confined space entry program that the contractor will follow and of any hazards confronted or created in permit spaces, either through a briefing or during the entry operation. 11
7.0 Training Prior to assignment for confined space entry work or a change in employee duties or if the City has reason to believe that deviations from procedures have occurred, employees shall be trained in: A. Confined space entry / work procedure. B. Pre-entry and operating procedures. C. Hazards they may encounter. D. Emergency notification and rescue protocol. The City shall document the training. The documentation shall contain each employee's name, the signatures or initials of the trainers, and the dates of training. The certification shall be available for inspection by employees. 8.0 Non-Permit Confined space Entry 1. Prior to entering any non-permit confined space the employee entering the space shall: A. Test the atmosphere with the appropriate meter for oxygen concentration, amount of flammable gas, carbon monoxide and hydrogen sulfide. Test will be continuous while the employee is inside the space. If any reading is obtained that would indicate a hazardous atmosphere the space shall be reclassified as alternate entry and the procedures in Section 9 shall be followed. B. Record test results on the work order or similar document. C. Ensure that automatic lights / ventilation systems are in operation (if equipped). D. Wear a hard hat, safety glasses and an extraction harness. 9.0 Alternate Entry Confined Space Entry 1. The confined space shall be considered an alternate entry confined space if the city can demonstrate: A. That the only hazard posed by the permit space is an actual or potential hazardous atmosphere and B. That continuous forced air ventilation alone is sufficient to maintain that permit space safe for entry and 12
C. Monitoring and inspection data that supports the demonstrations required above. 2. If an initial entry of the permit space is necessary to obtain the data required the confined space shall be treated as a permit required confined space until certified as an alternate entry confined space. 3. The determinations and supporting data required are documented by the city and are made available to each entrant. 4. Entry into the permit space under the terms of an alternate entry confined space is performed in accordance with the following requirements: A. Any conditions making it unsafe to remove an entrance cover shall be eliminated before the cover is removed. B. When entrance covers are removed, the opening shall be promptly guarded by a railing, temporary cover, or other temporary barrier (such as equipment that blocks the entry hole) that will prevent an accidental fall through the opening and that will protect each entrant working in the space from foreign objects entering the space. C. Before an entrant enters the space, the internal atmosphere shall be tested, with a calibrated direct-reading instrument, for the following conditions in the order given Oxygen content, flammable gases and vapors, carbon monoxide and hydrogen sulfide. 5. There must be no hazardous atmosphere within the space whenever any entrant is inside the space. 6. An entrant may not enter the space until the forced air ventilation has eliminated any hazardous atmosphere; 7. The forced air ventilation shall be so directed as to ventilate the immediate areas where an entrant is or will be present within the space and shall continue until all employees have left the space; 8. The air supply for the forced air ventilation shall be from a clean source and may not increase the hazards in the space. 9. The atmosphere within the space shall be continually tested as necessary to ensure that the continuous forced air ventilation is preventing the accumulation of a hazardous atmosphere. 10. If a hazardous atmosphere is detected during entry, entrants shall leave the space immediately and the space shall be evaluated to determine how the 13
hazardous atmosphere developed; and measures shall be implemented to protect entrants from the hazardous atmosphere before any subsequent entry takes place. Employees shall have a 10 minute emergency escape respirator to facilitate exiting the space should a hazardous atmosphere be encountered. 11. Wear a hard hat, safety glasses and an extraction harness. 12. An attendant may be assigned for all alternate entry confined spaces. The attendant s duties are detailed in Section 5.3. 13. The City shall verify that the space is safe for entry and that the pre-entry measures have been taken, through a written certification that contains the date, the location of the space, and the signature of the person providing the certification. The certification shall be made before entry and shall be made available to each entrant entering the space. 13. When there are changes in the use or configuration of an alternate entry confined space that might increase the hazards to entrants, the city will reevaluate that space and, if necessary, reclassify it as a permit-required confined space. 10.0 Rescue 1. Prior to entry, the emergency response protocol will be reviewed with all employees. This protocol includes: A. Confined space identifier and location. B. Site emergency notification (phone number, radio frequency, etc.) and location of nearest phone and or radio. C. Emergency evacuation signal for the area. D. Evacuation routes and assembly area. 2. An extraction device shall be present on the site if entry is below grade. Setup of the rescue device will be a decision of the entry team. 3. If the workers inside the confined space become ill, injured or do not respond to outside communication, the stand-by will make an emergency notification to the designated off site rescue group. (FIRE DEPT) 4. Notifications shall be by on-site radio and/or telephone. In the event no radio or telephone is available on site, then an additional employee will be on site within sight and call and that employee will be dispatched to a pre-determined location to make notification of an emergency. 14
5. When making emergency notification speak clearly and give details about what has happened and where the emergency is. Be sure the information is repeated back correctly and let the emergency operator hang up first. 6. The attendant may attempt to effect a rescue from outside the space and/or begin to prepare to enter the space BUT THEY SHALL NOT ENTER THE SPACE UNTIL ADDITIONAL ASSISTANCE FROM THE RESCUE TEAM IS ON SITE AND IS DIRECTED TO DO SO. 7. In the event of an emergency outside the confined space that requires entrants from inside the space to evacuate the space, the attendant will signal entrants to evacuate with a verbal or mechanical warning. 8. The City Public Works Department shall meet with the Fire Department to coordinate entry rescue. The Public Works Department shall provide a list of confined spaces, access to the space for inspection purposes and will conduct rescue drills with the Fire Department is so requested. The Public Works Department shall document that these activities have been completed requesting that the responding fire department certify (document) that the fire department can respond to an entry rescue. CITY OF SEASIDE ALTERNATE ENTRY 15
CONFINED SPACE CERTIFICATION Confined Space Identifier (Location): Date: Review the following items, complete all items. Work\activity to be performed: Entry Certification Expires: Toxic Contaminants / Test Results LIMIT READING Oxygen deficiency / enrichment 19.5%/23.5% Flammable gas / vapor 5% LEL Hydrogen sulfide 10 PPM Carbon Monoxide 25 PPM Other (list) Yes / No Yes / No Is the confined space isolated / protected (if not, entry cannot proceed, live sewer excepted). Is the confined space air mover/blower running (if not the entry cannot proceed, unless you can demonstrate that air movement is not required). PPE required in space, check all that apply: Hard hat Safety glasses/goggles Face shield Respirator Gloves Body protection Foot protection Harness / lifeline Tripod / winch Emergency Instructions Stand-by attendant: On job / site method of communication: Visual Radio Other (List) Emergency contact method: Cell phone Truck radio Emergency numbers: 911 In-house / administration Fire / Police Dispatch Confined Space Inspected By: Date: CITY OF SEASIDE NON PERMIT CONFINED SPACE ENTRY LOG 16
Confined Space Date LEL Oxygen H2S CO Initials 17