Standard 29 CFR Part 1910.146

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Standard 29 CFR Part 1910.146
Permit Required Confined Space Entry
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Agenda

• Permit Required Spaces - Definition
• Hazards and hazard control
• Permit system
• Entry procedure
• Emergency procedures

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Confined spaces What are they?

• Confined Spaces
• Are large enough and so configured that an
  employee can bodily enter and perform assigned
  work and
• Have limited or restricted means of entry or exit
  (for example, tanks, vessels, silos, storage
  bins, hoppers, vaults and pits are spaces that
  may have limited means of entry) and
• Are not designed for human occupancy
• In addition to the above, Permit Required
  Confined Spaces
• Contain, or has the potential to contain, a
  hazardous atmosphere
• Contain a material that has the potential for
  engulfing an entrant
• Have 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

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Atmosphere hazards Oxygen content

• Oxygen deficiency
• Room air contains approximately 20.9 oxygen
• Below 19.5 oxygen we can develop physical
  problems
• Oxygen deficiency can cause light headedness,
  nausea, and loss of coordination and
  concentration, and the ability to think and react
  normally we can hallucinate, depriving us of our
  ability to recognize hazards and to escape from
  them (self rescue)
• Oxygen deficiency can be caused by many things,
  including
• Nitrogen or inert gas piped into the space
• Chemical processes, including rust
• Chemical evaporation or leakage
• Exhaust from internal combustion engines or other
  external sources

NEVER ENTER AN AREA WITH LESS THAN 19.5 OXYGEN
CONTENT
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Atmosphere hazards Oxygen content

• Oxygen Enrichment
• Oxygen concentration above 23.5 is called oxygen
  enrichment
• Oxygen enrichment causes all combustible
  materials to burn with explosive force that makes
  escape from a fire in a confined space doubtful
• NEVER ENTER AN AREA WITH GREATER THAN 23.5
  OXYGEN
• Oxygen enrichment can be caused by many things
  including
• Use of oxygen to ventilate a space (which is
  never allowed)
• Leaking hose on a torch set
• Some chemical processes

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Atmosphere hazards Lower flammable unit

• The lower flammable limit (LFL) is the minimum
  concentration of flammable vapor, mist, gas or
  dust mixed or suspended in air that will ignite.
  Technically, 100 of the LFL must be present to
  allow a fire or explosion.
• There must be 19.5 or greater oxygen content
  present in the area being sampled to get an
  accurate LFL meter reading
• Since there can be some variation in meter
  readings, we set a wide safety margin for
  acceptable LFL readings
• NEVER ENTER AN AREA WITH GREATER THAN 10 LFL
• High LFL can be caused by many things including
• -Flammable chemicals
• -Flammable material brought into the space for
  the project
• -External processes that leak or seep into the
  space

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Atmosphere hazards Toxic and hazardous substances

• Some confined spaces can contain hazardous
  materials such as hydrogen sulfide (in sewers)
• Exposure to chemical vapor and/or gas and/or
  particulate above the Permissible Exposure Level
  (PEL) can cause damage to your health and impair
  your ability to exit the confined space
• To determine what toxic or hazardous chemicals
  might be present we must know what chemicals were
  present in the space
• PEL exposure data is listed in the OSHA Standards
  and on Material Safety Data Sheets
• NEVER ENTER AN AREA WITH AN EXPOSURE FOR A TOXIC
  OR HAZARDOUS CHEMICAL GREATER THAN THE PEL (OR
  OTHER MAXIMUM EXPOSURE NUMBER)
• A high PEL can be caused by many things
  including
• -Chemicals stored or used in the space
• - External processes that leak or seep into the
  space

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Controlling atmosphere hazards

• All atmosphere hazards are detected and
  quantified by using direct reading meters We
  always use a meter to check that the atmosphere
  is safe prior to space entry
• In addition, we continuously monitor the space
  throughout the entry
• We will look at the meter we use for permit
  confined space entry now
• Ventilation is occasionally used to improve the
  atmosphere. Tips on ventilation are
• -Positive pressure ventilation is always more
  effective
• -Deliver the fresh air as close as possible to
  the entrant
• -Be sure the fan intake is located in clean air

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Engulfment hazard

• Engulfment occurs when a person is covered with a
  substance from a pipe, hopper, duct or other
  source of materials being added to a confined
  space
• Engulfment can suffocate a person, cause serious
  injury or make escape from a space impossible
• NEVER ENTER A SPACE WITH ENGULFMENT HAZARDS
  THAT HAVE NOT BEEN RENDERED SAFE
• An engulfment hazard can be caused by many things
  including
• -Connected pipe lines, ducts and hoppers
• Engulfment hazards are controlled by
  disconnecting, blanking or capping connecting
  pipes, ducts and hoppers

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Other hazards

• There are often mechanical, hydraulic, thermal
  and electrical hazards in confined spaces
• These other hazards are generally controlled
  through standard lockout and tagout (LOTO)
  procedures REFER TO OUR FACILITY PROCEDURE ON
  LOTO
• Other hazards can be caused by many things
  including
• -Heating jackets, coils, etc.
• -Mixers and agitators
• -Moving equipment
• -Electrical equipment

NEVER ENTER A SPACE WITH OTHER HAZARDS PRESENT
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Hazard summary

• Hazards present in permit confined spaces are
  extremely dangerous because
• Space entry and exit is difficult and slow, both
  for entrants and for rescuers
• Many of the hazards are difficult to see, feel or
  smell without using instruments
• Ventilation of confined spaces is poor unless
  supplemental mechanical ventilation is used

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Entry permit

• The permit contains
• The names of all involved individuals
• A list of steps taken to render the space safe
• Atmosphere readings
• The time that the permit expires
• Information needed for contacting the rescue team
• Critical steps in permit completion
• Isolate or make safe all hazards
• Use a meter to determine a safe atmosphere
• Provide access into space
• Have all equipment ready
• Notify the Rescue Service
• COMPLETE ALL INFORMATION REQUESTED ON THE PERMIT

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Entry procedure

• A permit is used to control all confined space
  entry
• All personnel who are involved in the entry must
  have current training and be authorized for their
  role
• Three types of responsible positions are involved
  in an entry and each has an equal decision in
  allowing the entry, not allowing the entry or
  cancelling it (if already in progress). These
  positions are
• -The entry supervisor
• -The entrant
• -The attendant

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Duties

• Entry Supervisor
• -Makes all arrangements
• -Begins permit and oversees completion
• -Contacts rescue service to alert them of the
  entry
• -Supervises the entry, frequently visiting the
  site
• -Returns completed permit to program
  administrator
• Entrant
• -Reviews the permit to assure proper completion
  and her/his agreement
• -Follows all directions from the Attendant
• Attendant
• -Functions to assure safety
• -Continuously evaluates external and internal
  hazards
• -Is willing to terminate the entry for safety
  reasons
• -Is ready to perform a non-entry rescue

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Emergency procedures

• Immediately terminate the permit if
• -Any altered level of consciousness is detected
  in the entrant (clumsiness, slurred speech,
  behavior or speech changes)
• -An emergency is detected inside the space
• -An emergency occurs outside the space
• -Communication is lost
• Never enter a space to affect a rescue practice
  non-entry rescue only
• Immediately summon the rescue service and the
  entry supervisor if any emergency condition is
  suspected
• Continue to attempt non-entry rescue and continue
  to provide fresh air until the rescue service
  arrives
• We will now discuss our rescue service

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Conclusion

• Permit required confined spaces present many
  unique hazards NEVER UNDERESTIMATE THEM
• Control all hazards
• -Atmosphere
• -Engulfment
• -Other (mechanical, thermal,. Etc)
• Preparation saves lives follow the permit system
• Every member of the team has a part to play the
  supervisor, entrant and attendant must all agree
  on safety and must all agree on procedures

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For more information

• For more information regarding Permit Required
  Confined Spaces , or other safety issues, please
  contact
• Gregory Appel Insurance
• Mike Salazar, Vice President
• Direct 317-686-6407
• Email msalazar_at_gregoryappel.com