Confined Space Entry

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(No Transcript)
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Confined Space Entry

• State Safety Industrial
• Hygiene Unit
• Minnesota Department of
• Employee Relations

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Discussion Objectives

• Differentiate between permit-required and
  non-permit required confined spaces
• Understand acceptable entry conditions
• Identify required elements of a written confined
  space entry program
• Identify elements of a entry permit
• Identify entrant, attendant, and supervisor
  responsibilities

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History of Confined Space Entry Regulations in
Minnesota

• On State Level
• Adopted Feb. 1988
• Included construction agriculture industry
• Private public sector employees

• On Federal Level
• 29 CFR 1910.146
• Adopted April 1993
• Does not cover construction industry

State OSHA programs required to adopt standards
as stringent or more stringent than federal
standards.
Minnesota had to do something.
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What Minnesota did

• Adopted revised federal general industry standard
  29 CFR 1910.146 in May 1999
• covers general industry exposure only
• Maintained state confined space standard
  5207.0300 for construction industry exposure
• construction definition does not include standard
  operations and maintenance activities

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Definitions
Confined Space

• 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 and
• is not designed for continuous employee occupancy

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Definitions
Possible confined spaces

• Sewer Septic tank
• Sewage digester Pumping/lift station
• Storage tank Silo
• Vat Duct
• Utility vault Utility tunnel
• Boiler Pipeline
• Pit Sump
• Trench Reaction vessel

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Definitions
Entry

• The action by which a person passes through an
  opening into a permit-required confined space.
  Entry includes ensuing work activities in that
  space and is considered to have occurred as soon
  as any part of the entrants body breaks the
  plane of an opening into the space.

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Definitions
Hazardous Atmosphere

• (1) Flammable gas, vapor, or mist in excess of 10
  percent of its lower flammable limit (LFL)
• (2) Airborne combustible dust at a concentration
  that meets or exceeds its LFL
• (3) Atmospheric oxygen concentration below 19.5
  percent or above 23.5 percent
• (4) Atmospheric concentration of any substance in
  excess of permissible exposure limit
• (5) Any other atmospheric condition that is
  immediately dangerous to life or health.

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Definitions

• Permit-required confined space means a confined
  space that has one or more of the following
  characteristics
• (1) Contains or has a potential to contain a
  hazardous atmosphere
• (2) Contains a material that has the potential
  for engulfing an entrant
• (3) Has an internal configuration such that an
  entrant could be trapped or asphyxiated by
  inwardly converging walls.
• (4) Contains any other recognized serious safety
  or health hazard.

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Definitions

• Non-permit confined space
• means 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.

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Definitions

• Testing
• means 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.

NOTE Testing enables employers both to devise
and implement adequate control measures for the
protection of authorized entrants and to
determine if acceptable entry conditions are
present immediately prior to, and during, entry
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Employer Responsibilities

• Evaluate work place for confined spaces

• Label spaces

• Decide if spaces will be entered by employees

• Develop written program if entering
  permit-required spaces

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Evaluating Workplaces

• Types of Confined Spaces

• Non-permit
• does not have the potential to contain
  hazard capable of causing death or serious
  physical harm

ANY

• Special (atmospheric only)
• contains only atmospheric hazards that can be
  controlled with forced ventilation

• Permit-required
• potential for a hazardous atmosphere
• potential for engulfing entrant
• inwardly converging configuration
• other recognized serious safety issues

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Evaluating Workplaces

• Tools available to assist in determination of
  space type

• Decision flow chart

• OSHA Confined spaces advisor software

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Non-permit confined space

• Must consider whether other hazards exist in the
  space
• hazardous energy (lock out/tag out)
• temperature
• fall
• Think about situation out of the confined space
  to determine if hazardous
• Examples?

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Non-permit confined space

• Changes to the space
• MUST reevaluate the space to determine
  appropriate classification
• Also provisions for reclassifying a
  permit-required space to non-permit space
• forced air ventilation cant be means of
  eliminating hazard for purposes of reclassifying
  to non-permit

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Special (atmospheric only) confined space

• Continuous forced air ventilation required
• what makes ventilation effective?
• Must test atmosphere prior to entry
• oxygen
• combustible gases
• toxic air contaminants
• CALIBRATED direct reading instrument
• Periodically test atmosphere during entry

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Permit-required confined space

• Requires employer to develop comprehensive
  written confined space entry program

• Must be appropriately labeled

• Must coordinate entry with host employers

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Evaluate the space 1

• Municipal meter and sampling pit
• 6x10 concrete structure with sump pit and water
  piping
• fixed 10 vertical
  ladder
• square 2x3
  entrance hatch

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Evaluate the space 1

• Municipal meter pit
• 6x10 concrete structure with sump pit and water
  piping
• fixed 10 vertical ladder
• square 2x3 entrance hatch

• Confined space with atmospheric only hazards
• What are possible atmospheric hazards?
• Lack of O2
• Combustible gas
• Toxics?

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Evaluate the space 2

• well pit
• concrete block walls with dirt floor
• 12 foot vertical drop
• access by step ladder with with 7 foot drop
  to top of ladder
• square 2x3
  entrance hatch
• exposed electrical wiring

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Evaluate the space 2

• well pit
• concrete block walls with dirt floor
• step ladder
• square 2x3 entrance hatch
• exposed electrical wiring

• Permit-required confined space
• What are the hazards?
• Potential atmospheric
• Fall hazard
• Electrical hazard

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Elements of written permit-require confined space
program

• Measures that prevent unauthorized entry
• Evaluate hazards of permit spaces
• Procedures developed for safe entry
• Evaluate space during entry operations
• Provide attendant
• Provide necessary equipment
• What is necessary equipment???

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Necessary Equipment
Special (atmospheric)

• Gas meter

• Ventilator and flex duct

Permit-required

• Communication system

• Retrieval system

• Full Body harness

• SCBA

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Written permit-require confined space program
(cont.)

• Identify responsibilities of employees
  involved with entry
• Procedure developed to summon rescue and
  emergency procedures
• Develop permit system
• Procedures for coordinating with other employers
• Procedures for review of program

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Permit system requirements

• Permit must be completed prior to entry
• Must be signed by entry supervisor
• Permit should be posted at entry portal
• Duration of the permit identified and must not
  exceed time necessary for task
• Provisions for canceling the permit
• Permits must be retained for 1 year

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Permit Requirements (sample included)

• I.D. of space to be entered
• Purpose of entry
• Date entry authorized
• Authorized entrant
• Attendant
• Supervisor
• Known hazards

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Permit requirements

• Methods to control space
• Acceptable entry conditions
• Initial and periodic test results
• Emergency procedures
• Communication procedures
• Equipment to be used

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Employee training

• Initial training before entry or assistance with
  entry
• When there is a change in procedure
• When employer believes it is necessary
• Employer must certify training was accomplished
  by documenting employees names, training dates,
  and trainers signature

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Duties of Entrant

• Know the hazards
• Use PPE properly
• Communicate with attendant as necessary
• Exit space when there is a problem

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Duties of Attendant

• Know the hazards (be aware of behavioral effects
  of hazards)
• Keep count of entrants
• Remain outside permit-space until relieved
• Communicate with entrant
• Summon rescue squad
• Warn unauthorized persons
• Perform non-entry rescues

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Duties of Entry Supervisors

• Know the hazards
• Verify permit complete
• Sign permit
• Terminate entry and cancel permit when complete
  or a problem
• Verify rescue procedures are in place
• Remove unauthorized individuals
• Ensure consistent and acceptable entry procedures

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Rescue Emergency Services

• Rescuers must be able to respond in a timely
  manner based on hazards
• Notify rescuers of hazards
• Provide advance access to spaces
• If EEs will be doing rescues
• must be trained
• must know first aid and CPR
• must practice at least once every year

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Resources Available to you

• Federal OSHA confined space info page
• http//www.osha-slc.gov/SLTC/confinedspaces/index.
  html
• Copy of the federal standard
• http//www.osha.gov/pls/oshaweb/owadisp.show_docum
  ent?p_tableSTANDARDSp_id9797p_text_versionFAL
  SE
• Federal OSHA interpretations also available at
  above site
• OSHA Advisor software download
• http//www.osha-slc.gov/dts/osta/oshasoft/csa.html
  
• State construction industry standard
• http//www.revisor.leg.state.mn.us/arule/5207/

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Review of Objectives

• Identify one difference between permit-required
  and non-permit required confined spaces
• Define acceptable entry conditions
• Identify 5 required elements of a written
  confined space entry program
• Identify 5 elements of a entry permit
• Identify 3 entrant, attendant, and supervisor
  responsibilities