When conducting confined space training classes, instructors sometimes tend to gravitate toward using the age old catch phrases: “Don’t look down the hatch with a lighted match,” “Don’t be working fools, comply with confined space rules,” “Smoking has no place in a confined space,” and my favorite, “A grave—the ultimate confined space.” There are literally hundreds of these little quips and they all point out a very important fact: confined spaces can be deadly! All too often a surveyor doesn’t find out until it’s too late that the Occupational Safety and Health Administration (OSHA) has specific regulations for employees to enter confined spaces. Let’s take a look at these regulations.
A confined space is defined as:
- An area that has adequate size and configuration for employee entry.
- An area that has limited means of access or egress.
- An area that is not designed for continuous employee occupancy.
There are many areas we confront on a daily basis that could meet this definition. Attics, crawl spaces, tanks, vats, pits, manholes, sewers, boilers, suspended ceilings and vaults are just a few.
A permit required confined space:
- Must meet the criteria for a confined space.
- Must have the potential for hazardous atmospheric conditions (including toxic, flammable or asphyxiating); engulfment; hazardous configuration; or any other recognized hazards.
It only takes one of the items under the second category to change a confined space to a permit required confined space. If any hazards present can be eliminated without the possibility of returning, the space may revert back to just a confined space.
The hazardous conditions need a little more explanation. Since most of the confined space entries performed by surveying crews are related to underground work, let me address this type of work.
Toxic atmosphere refers to a material like a gas, mist or fume that can do harm to one of the body’s vital systems. A typical toxic gas found in sewers is hydrogen sulfide. Many water treatment and wastewater treatment plants will also have chlorine gas present in large quantities. Carbon monoxide is another example.
Flammable atmospheres could come from methane (natural gas), gasoline, jet fuel, other hydrocarbons or combinations of chemicals that have mixed in the sewer or tank.
Engulfment could come from any liquid or solid that buries or covers the entrant and either blocks off oxygen or keeps the employee from breathing available oxygen. A typical engulfment confined space fatality occurs when farmers walk on the top of a grain storage bin and are trapped when a void below them collapses. A sewer manhole quickly filling with water when a lift station starts is another example.
Hazardous configuration refers to any type of structure or situation that limits the ability of an entrant to escape in the face of danger. This could be due to sloped walls, offset passages, or the lack of ladders or stairways.
Other recognized hazards refers to electrical hazards, mechanical action or anything that could create a dangerous situation for the entrant.
OSHA RegulationsThe central item around which the OSHA Confined Space Regulations revolve is the entry permit. A Permit Required Confined Space (PRCS) requires the employer to issue a permit each time a PRCS is to be entered. Prior to the time a permit is issued, there are many procedures that must take place. OSHA first requires employers to identify the types and locations of confined spaces employees may have to enter. Once it is confirmed that there are confined spaces present in the workplace, the employer must decide if employees will have to enter the confined spaces. If the employer decides confined spaces will not be entered, employees must be informed. If they will be entered, then the real work starts and a Written Confined Space Program must be developed. This program must cover the definitions listed above. Training is required for the entrant, attendant and entry supervisor, required safety equipment, atmospheric monitoring procedures, communication procedures, ventilation procedures and emergency rescue procedures (non-entry and entry). A Confined Space Entry Permit must be developed. OSHA has guidelines for a permit within the regulations. You will have to modify the sample permit to meet your specific conditions.
It is imperative to understand that OSHA is not just looking for compliance in the “cross your T and dot your I” world. They want to make certain that training has been both thorough and comprehended by the employee. Based upon my experience, a two-fold approach is needed. The first training an employee needs is an overall initial training on your Company Written Safety Program. After an employee understands what is expected of him or her and what his or her employer will do to make the workplace safe can he or she get specialized training. Confined space training would fall under this category.
How much time needs to be dedicated to confined space training? For those employees who will be part of the entry team, I recommend no less than a two-day program. This will probably end up at around 11-12 hours of actual classroom time. (Under some situations this may have to be considerably more.) This will include a lot of theory and facts about the dangers of confined spaces as well as demonstrations of equipment and procedures. I personally feel the most important portion of this training is in the employee understanding of the hazards of a confined space and what to do when confronting these hazards. One could spend a week going through actual entries, but if an employee doesn't understand how to make decisions the first time something happens, then a major error could occur. Errors in confined spaces can quickly turn into an IDLH (Immediately Dangerous to Life or Health) situation.
Invest in SafetyYou will need to make an investment in safety equipment for your employees. The cost for confined space equipment can vary, but plan on spending per crew anywhere from $8,000 to $18,000. You will need rescue equipment consisting of some type of tripod, davit, or other configuration, a winch system, fall arrest system, harnesses, plus intrinsically safe lighting, gas monitors and communications. The cost of equipment has a tremendous range so take time in making any purchases. Don't forget that when performing entries in roadways you will need much more than just a few orange cones to isolate the area.
Going InAfter the confined space program has been written, training performed and equipment purchased you are ready for an entry. The safety director or designate must approve each entry permit. When the permit has been approved the actual work may proceed. First, the area must be barricaded or somehow protected for both the safety of workers and members of the public. All entry equipment must be put in place and checked for proper operation. There are three job descriptions for an entry team: entrant, attendant and entry supervisor. The entry supervisor's duties may be performed by either one of the other employees. That means the bare minimum number of employees on an entry team is two. Some entries may require three or more team members. The job titles are self-descriptive. The attendant must always be watching or communicating with the entrant and may have no other duties that would distract him or her from that task. Any member of the entry team may stop an entry at any point a danger becomes evident. Gas monitoring must be performed at several depths before the entry starts and monitoring should be continuous during the entry. Gas concentrations can vary with depth and with horizontal position due to air pocketing. For most entries without a ladder, the entrant must be connected to both a fall protection/retrieval system as well as a hoist system. For entries using a ladder, only a fall protection/retrieval system is needed. A harness is used to suspend the entrant. Powered ventilation will be required for some entries.
An employer must keep all entry permits for at least one year. Yearly evaluations of the Confined Space Program and entry procedures must be performed and documented. When does an employee actually enter a confined space? OSHA has been very clear on this point. When any portion of a person's body breaks the plane of the entry point, an entry has occurred.
Prohibiting entry of confined spaces is certainly the preferred choice. Unfortunately, entries must be made to obtain some information. When entries must occur, make certain you have complied with all OSHA regulations governing Permit Required Confined Spaces. The alternative is quite often a fatal choice.