Confined Space Entry

1. Confined Space Entry Jody Jackson, CSP Director Safety, Health, and Environment Montrose Environmental Irvine, Ca. jjackson@Montrose-env.com

2. Permit-Required Confined Spaces29 CFR 1910.146

3. Why Comply? • Confined space entry is one of the leading causes of occupational fatalities in this country. • 1995-1999 BLS: 13 CSE Incidents = 23 Fatalities • Not getting any better - 2015 Census: 136 CSE fatalities (Avg 2 per week)

4. Why Comply? • Biogas Confined Space Incidents (NFPA) • On a farm in Michigan in 1989, five members of the same family, representing three generations, died as one after another entered a manure pit in an attempt to save their relatives. • The incident was repeated in 2012 in Pennsylvania when a father and his two sons died in a manure pit.

5. Close Calls Group Discussion

6. CSE Regulation 29 CFR 1910.146 General Industry Standard

7. CSE Regulatory Statistics • Standard covers 240,000 workplaces and 12.2 million workers • Workers make 4.8 million entries/year • Standard may prevent 85% of fatalities and nearly 11,000 injuries

8. Definition of a Confined Space • Limited means of egress • Can be bodily entered • Not designed for continuous occupancy

9. Definition of Permit-RequiredConfined Spaces • Contains or has potential to contain a hazardous atmosphere • Contains the potential for engulfment • Internal configuration that can trap or asphyxiate entrant • Any other serious safety or health hazards

10. Typical Permit-Required Spaces • Chemical/Other storage tanks • Waste or storage pits • Grain bins • Underground tunnels • Railroad cars under construction • Sumps/Pits • Excavations

11. Typical Non-Permit-Required Spaces • Utility closets • Below-grade trenches (not excavations-discuss) • Storage vaults • Utility sub-basements Take the Occupancy Test!

12. Potential Confined Space Hazards • Engulfment • Oxygen (19.5% - 23.5%) • Flammable gases or vapors (< 10% LEL) • Combustible dusts • Toxic substances (< PEL) • IDLH atmospheres • Physical hazards

13. Atmospheric Testing • Hazards must be tested in this order: 1st Oxygen content (Why first?) 2nd Combustibility/flammability 3rd Toxic atmospheres • Understand your gas detection instrument(s) – READ THE FINE PRINT – BE TRAINED.

14. Reasons for Space Ventilation • Maintain oxygen levels above 19.5% • Maintain toxic gases and vapors at acceptable levels • Temperature

15. Types of Personal Protective Equipment • Harnesses • Retrieval lines • Chemical protective clothing • Welding apron/sleeves • Respirators • Gloves • Safety glasses

16. EmployerResponsibilities • Formulate and manage the confined spaces program • Maintain a space inventory • Maintain a list of “Authorized Personnel” • Maintain copies of space permits (1 year, plus a review within a year) • Direct the confined space training program • Maintain rescue equipment • Coordinate contractor activities

17. Supervisor Responsibilities • Conduct a pre-entry briefing • Ensure that personnel are evacuated when necessary • Ensure that permits are complete and removed when work is finished • Ensure that all necessary equipmentis returned to its proper location • Oversee all necessary confined space activities

18. Attendant Responsibilities • Attend pre-entry briefing • Know the hazards of the space • Control access to the space • Maintain communication with entrants • Not to enter the space for rescue • Summon emergency services • Assist rescue efforts from outside the space • Conduct gas testing as required

19. Attendant Responsibilities (cont.) • Remain at the site while entrants are inside • Order a space evacuation when conditions warrant such an action • Maintain an accurate count of the number of entrants

20. Entrant Responsibilities • Attend the pre-entry briefing • Know the hazards of the space • Use appropriate equipment properly Exit the space if: • An alarm is activated • Communication is lost • Unknown exposures are encountered • Ordered to do so

21. Authorized Person Responsibilities • Familiarize themselves with characteristics of spaces • Verify that all hazards and sources of energy have been controlled in the space • Ensure that confined space permit is posted • Rescind any permit for noncompliance with permit requirements

22. Rescuer Responsibilities • Understand the hazards of the space • Be certified in emergency first aid and CPR • Understand appropriate entry procedures • Know how to use rescue equipment • Practice confined space rescues at least annually Rescue Discussion https://www.osha.gov/laws-regs/standardinterpretations/2008-05-23-0

23. Quiz • A confined space is defined as having limited egress, can be bodily entered, and is not designed for continuous occupancy. TRUE • Some confined spaces may be classified as non-permit-required. TRUE • The three hazards that must be tested for in a confined space are oxygen content, combustibility and flammability, and toxic atmospheres. TRUE

24. Quiz • Entrants must be familiar with all hazards prior to entering a confined space. TRUE • An excavation deeper than 4 feet is a confined space. FALSE • Examples of typical non-permit-required confined spaces are utility closets, below-grade trenches, storage vaults, and utility subbasements. TRUE • Confined space entry is routinely one of the leading causes of occupational fatalities. TRUE

25. Quiz Answers (cont.) • Annual emergency drills are required by the OSHA Confined Space Standard. TRUE • An attendant should never enter a confined. TRUE • An entrant should exit a confined space if ordered to do so, unknown exposures are encountered, communicationis lost, or an alarm is sounded. TRUE

26. Thank You! Questions?