Cal/OSHA: Confined Spaces Special Emphasis Program OSHA Interpretations Common Mistakes Resources/Assistance Available
2012 Confined Space Special Emphasis Program: Why? Recent increase in confined space fatalities in California Entirely preventable tragedies
California Confined Space Fatalities 2007-2012 8 7 6 5 4 3 2 1 0 2007 2008 2009 2010 2011 2012
2012 Cal/OSHA Confined Space Emphasis Program : For ALL Inspections: Cal/OSHA will Ask employers if they have any confined spaces Look for Confined Spaces during walk-around Identify hazards Verify that spaces are labeled Ask Employer if anyone enters spaces and how spaces are maintained & cleaned Interview employees entering spaces
2012 Cal/OSHA Confined Space Emphasis Program Review written Confined Space Program, procedures, documentation and records Review alternate entry and/or reclassification procedures if applicable Review rescue training & procedures Audit last 6 months confined space permits Audit certificates of reclassification
Confined Space Citations 2010 2012 Calendar Year # of Inspections with 5157 or 5158 Violations 5157 Violations 5158 Violations Non- Serious Serious Willful Non- Serious Serious Willful 2010 31 34 9 1 13 2 0 2011 27 42 12 4 5 5 3 2012 (To-Date) 75 107 31 0 8 3 0
Common Confined Space Citations Evaluation and Posting of Confined Spaces 5157(c)(1) - - - Written Procedures 5157(c)(4) 5158(c)(1)(A) Atmospheric Testing 5157(d)(5) 5158(d)(3) Ventilation 5157(c)(5)(B)(5) 5158(d)(6) Rescue Procedures 5157(d)(9) 5158(c)(1) Training 5157(g)(1) 5158(c)(2)
Most Common Causes of Confined Space Fatalities Confined Space Rescue Grain Handling Toxic and Asphyxiating (Oxygen Deficient) Atmospheres Lockout-Tagout Fires and Explosions Welding and Cutting
Confined Space Federal OSHA Interpretations Confined Space Regulation has been subject to Federal OSHA Interpretations Knowledge of these interpretations can help employers refine their confined space program.
What is a confined space? Confined Space: 1. Is large enough to enter; and 2. Has limited/restricted means of entry or exit; and 3. Is not designed for continuous EE occupancy
Federal OSHA Directive: Limited Means of Entrance/Exit Does person have to use hands to enter/exit space? Is person in awkward posture when entering or exiting space? Is person s entry into or exit from space slowed down/impeded by physical obstructions (pipes, ductwork, walls, holes in floor, flanges, etc.)? Would rescuers need special equipment in order to reach or retrieve entrant?
Dust Collector
Permit Required Confined Space A confined space that has one or more of following characteristics: 1. Potential for a hazardous atmosphere <19.5% Oxygen > 23.5% Oxygen >10% LFL > LFL (Comb. Dust) ->PEL (Acute) 2. Engulfment 3. Entrapment 4. Any other recognized serious safety or health hazard
Other Serious Safety or Health Hazards The determination of whether resulting exposure to hazard in confined space will impair EE's ability to perform self-rescue is aspect that must be addressed by employer. Fed OSHA Compliance Directive In order for serious safety and health hazard to be recognized as being impairment to escape, its severity potential for resulting physical harm to employee must be considered. Fed OSHA Review Commission
Other Serious S&H Hazards? HEAT STRESS! Unguarded Mechanical Equipment Noise? Biohazards
Options for Confined Space Entry (c)(4) Permit space entry (c)(5) Alternate entry procedures (c)(7) Reclassify permit space to non-permit space
Permit Entry Required... permit spaces into which hazards are introduced during entry need protection afforded by complete permit space program Preamble to Fed OSHA Confined Space Standard Example: Welding, cutting, brazing, soldering, painting, scraping, sanding, degreasing, sealing, bonding, spraying, melting
Use of Lockout/Tagout Correct Lockout/Tagout acceptable for electro-mechanical hazards. Lockout/Tagout does not eliminate hazards from flowable materials such as steam, natural gas, and substances that can cause hazardous atmospheres or engulfment hazards. These hazards can be eliminated only by isolation. Ex: blanking, blinding, misaligning or removing sections of lines or pipes and a double block and bleed system.
Blanking or Blinding
Double Block and Bleed System closed closed open
Common Mistakes in Confined Spaces
Inadequate Atmospheric Testing Methane: 0.55 Ammonia: 0.59 Carbon Monoxide: 0.96 Nitrogen: 0.97 Air: 1.0 Hydrogen Sulfide: 1.2 Carbon Dioxide: 1.5 Gasoline: 3-4 Jet Fuel, JP-8: 4.7 Specific Gravity Sampling Lighter than air gases Heavier than air gases So...Must test at multiple levels within space!
Inadequate Atmospheric Testing Air monitoring at opening only is insufficient Entire space must be evaluated Suction Fans must be off during air monitoring Sampling Order: 1. Oxygen 2. Flammables/Explosives 3. Toxics
Process Industry Fatality Confined Space cleaned of contaminants (water rinse, no nitrogen purging) Ventilation in place Air monitoring conducted Confined Space Permit Issued Employee enters Space wearing half face HEPA respirator Employee dies in Confined Space due to lack of oxygen
Process Industry Fatality Exterior Welding O 2 << 19.5 % O 2 normal
Process Industry Fatality Initial air monitoring done at the entry way only. Outside air is being sucked in through the entry way making air testing meaningless. Ventilation design ineffective Exterior Welding consumed oxygen within space
Failure to Recognize Potential for Hazardous Atmosphere Confined Spaces may appear to be harmless Beware of Hidden Dangers
Manure pit
Rotting organic material can release deadly hydrogen sulfide gas
Suspect O 2 Deficient When: Space has been closed up, sealed or not ventilated before entry. Has contained inerted atmosphere or has been purged. Contains any amount of water or organic material. Metal Oxidation - rusting. Combustion processes. Displacement by other gases. Coatings, sludges, materials with cure and/or absorb oxygen - activated charcoal.
Confined Space Resources Cal/OSHA Consultation www.dir.ca.gov/dosh/consultation.html 800-963-9424 or InfoCons@dir.ca.gov Cal/OSHA Confined Space Emphasis Program www.dir.ca.gov/dosh/confined_space_emphasis_program.html Cal/OSHA Confined Space Hazard Alert 2012
Confined Space Resources Fed-OSHA Confined Space topic page http://www.osha.gov/sltc/confinedspaces/ NIOSH: Confined Space topic page http://www.cdc.gov/niosh/topics/confinedspace/ Canadian Center for Occupational Health & Safety http://www.ccohs.ca/oshanswers/hsprograms/confineds pace_intro.html