Permit-Required Confined Space Entry

1. Permit-Required ConfinedSpace Entry 29 CFR 1910.146

2. Objectives • Understand Legislation Developed by Government Agencies • Identify and Use Those Regulations • Identify a Potentially Hazardous Confined Space

3. Organizations • ANSI • American National Standards Institute • Consensus Standards for Atmospheric Hazards • NIOSH • National Institute for Occupational Safety and Health • Documents Incidents • Develops Guidelines for Safe Work

4. Organizations(continued) • OSHA • Occupational Safety and Health Administration • Began Looking at Confined Spaces in 1975 • Cited Under General Duty Clause • Proposed Standard Released June 1989

5. Permit-Required Confined Spaces29 CFR 1910.146 • Became Law April 15, 1993 • Employers MUST • Characterize the Confined Space • Provide a Permit Allowing Entry • Supply Personal Protective Equipment When Required • Excludes Agriculture, Construction, and Shipyards

6. Permit-Required Confined Spaces29 CFR 1910.146 A Confined Space is... • Large Enough and Configured Such That an Employee Can Enter and Perform Assigned Work • Has Limited or Restricted Means for Entry or Exit (e.g., Tanks, Vessels, Silos, Storage Bins, Hoppers, Vaults, and Pits) • Is Not Designated for Continuous Employee Occupancy

8. Permit-Required Confined Spaces29 CFR 1910.146 A Permit-Required Confined Space... • Contains or Has Potential to Contain a Hazardous Atmosphere • Contains a Material That Has the Potential for Engulfment • Internal Configuration of Inwardly Converging Walls or Sloping and Tapering Floor • Contains Any Other Recognized Serious Safety or Health Hazard

9. Permit-Required Confined Spaces29 CFR 1910.146 Engulfment... • Surrounding and Capture of a Person • Liquid or Finely Divided (Flowable) Solid • Can Cause Filling or Plugging of Respiratory System Via Aspiration • Can Exert Enough Force on Body to Cause Death by Strangulation, Constriction, or Crushing

10. Permit-Required Confined Spaces29 CFR 1910.146 Immediately Dangerous to Life or Health (IDLH)... • Immediate or Delayed Threat to Life • Causes Irreversible Adverse Health Effects • Interferes With the Ability to Escape from a Permit Space

11. Permit-Required Confined Spaces29 CFR 1910.146 IDLH Conditions... • Flammable Gas, Vapor, or Mist >10% of LFL (LEL) • Airborne Combustible Dust > LFL Dust Obscures Vision at a Distance of 5 ft. or less • Oxygen < 19.5 % or > 23.5% • Exposures in Excess of OSHA’s PELs

12. Employer’s Responsibilities • Determines Whether Permit-Required Confined Spaces Exist (Appendix A - Flow Chart) • Informs Employees and Posts Warning Signs • Prevents Entry If Employees are Not to Work in PRCS

13. Employer’s Responsibilities(continued) • Develop and Implement a Written Permit Entry Program • May Use Alternate Procedures • If a Non-Permit Space is Reconfigured, Re-evaluation of the Space is Required • Must Inform Contractors and Use Permitting Program

14. DANGER CONFINED SPACE ENTER BY PERMIT ONLY!

16. Permit-Required Confined SpaceELEMENTS OF THE PROGRAM • Prevent Unauthorized Entry • Identify and Evaluate the Hazards Prior to Entry (Appendix B- Who Can Do This, & How) • Develop Safe Entry Procedures • Acceptable Entry Conditions • Isolating the Permit Space • Purging, Inerting, Flushing, or Ventilating • Barriers to Protect from External Hazards

17. Permit-Required Confined Space(PRCS) Equipment • Testing and Monitoring Equipment • Ventilating Equipment • Communications Equipment • Personal Protective Equipment

18. Permit-Required Confined Space(PRCS) Equipment (continued) • Lighting • Barriers and Shields • Ladders and Other Entry/Egress Equipment • Rescue and Emergency Equipment

19. Permit-Required Confined SpaceELEMENTS OF THE PROGRAM (continued) • Evaluate Space Before and During Work • Provide at Least One Attendant Outside for the Duration of Entry Operations • Multiple Space Response Procedures • Designate Active Roles • Rescue and Emergency Response Procedures

20. Permit-Required Confined SpaceELEMENTS OF THE PROGRAM (continued) • System for Preparation, Issuance, Use and Cancellation of Permits • Procedures for Multiple Employer Worksites • Procedures for Closing Space • Review of Entry Operations • Review of Program

21. Permit-Required Confined Space(PRCS) • Permit System • Entry Permit • Training • Other Appendices • Appendix C: Example Situations • Appendix D: Example Check List & Permit • Appendix E: Sewer System Entry

22. Permit-Required Confined SpaceThe Permit 1. DATE:____ TIME:____ A.M../P.M. 2. VESSEL # 3. JOB # 4. LOCATION: 5.DESCRIPTION OF WORK: 6.PHYSICAL HAZARD ASSESSMENT: Engulfment, Electrical, Steam, Augers, Chain Drives etc.. 7. CORRECTIVE MEASURES: Physical Disconnects, Lockout / Tagout etc.. 8. ATMOSPHERIC ASSESSMENT: Oxygen, LEL, CO, H2S (Other) 9. Instrument # 10. Calibration Date: 11. Name of Operator: 12. Substance 13. P.E.L. 14. Actual 15. Oxygen 16. < 19.5% or > 23.5% 17. Other 18. LEL > 10% 20. 21. Carbon Monoxide (CO) 22. 50 ppm 23. Other 24. Hydrogen Sulphide (H2S) 25. 10 ppm 26. Other 27. PPE 28. Respirators 29.Rescue Equipment 30. Other 31. Other 32. Other 33. Names of entrants, Attendants, and Entry Supervisors: 34. Time work / shift completed: (35.) Problems / concerns 36. Emergency contact:

23. Hazard Communication 29 CFR 1926.59 MSDS Training Labeling Written Program Control of Hazardous Energy Sources 29 CFR 1926.417 & 1910.147 “Lock Out/Tag Out” De-Energize ALL Sources of Energy Written Program Other OSHA Regulations

24. Permit-Required Confined Spaces Administrative Controls

25. Permit Space Entry Program Learning Objectives • Describe the Guidelines for a Permit-Required Confined Space Program • Identify Conditions Which Allow the Use of Alternate Procedures

26. General Requirements • A Written Permit Space Program • Authorized Personnel • Confined Space Evaluation Procedures • Acceptable Entry Conditions and Procedures

27. PRCS Program The Entry Permit Shall Identify: 1) The Permit Space to be Entered. 2) The Purpose of the Entry. 3) The Date and Duration. 4) The Authorized Entrants. 5) The Attendants. 6) The Entry Supervisor. 7) The Hazards of the Space to be Entered. 8) Measures to Isolate and Eliminate the Hazards Before Entry. 9) The Acceptable Entry Conditions. 10) The results of Initial and Periodic Tests with Initials of Testers.

28. PRCS Program The Entry Permit Shall Identify: 11) The Rescue and Emergency Services That Can Be Summoned. 12) The Communication Procedures Used By Entrants and Attendants. 13) Equipment such as Testing, Communication and Emergency Equipment. 14) Any Other Information Necessary, In Order To Ensure Employee Safety. 15) Any Additional Permits Such As a Hot Work Permit.

29. Authorized Entrant Duties • Knows Hazards, Symptoms, and Consequences • Proper Use of Equipment • Communicate With Attendant • Exit Promptly From PRCS When Necessary

30. Attendant Duties • Knows Hazards, Symptoms, and Consequences • Awareness of Behavioral Effects of Exposure • Continuously Identifies Number and Identity of Entrants • Remains Outside of PRCS • Communicates With Entrants

31. Attendant Duties • Monitors Entrant & Surrounding Activity • Summons Rescue If Needed • Keeps Unauthorized Persons Away From PRCS • Performs Non-Entry Rescues • Performs Only Attendant Duties

32. Entry Supervisor Duties • Knows Hazards, Symptoms, and Consequences • Verifies Performance of Permit Testing, Procedures and Equipment • Terminates PRCS Entry and Permit

33. Entry Supervisor Duties • Verifies Availability and Communication With Rescue Services • Removes Unauthorized Personnel • Determines Compliance With the Entry Permit

34. Rescue and Emergency Services Using Employer’s Personnel... • Trained in PPE and Rescue Equipment • Trained in Rescue and Authorized Entrant Duties • Practice Rescues Once Every 12 Months • Simulated With Mannequins or People • In Actual PRCS • Trained in CPR and Basic First Aid • At Least 1 Member of Rescue Service Holding Current Certification

35. Rescue and Emergency Services Outside Rescue Service... • Must Be Informed of Hazards Prior to Arrival • Must Have Access to All Spaces to Assess and Allow for Practice of Rescues

36. Rescue and Emergency Services Non-Entry Rescue... “Retrieval Systems or Methods Shall Be Used Whenever an Authorized Entrant Enters a PRCS” • Unless Equipment Increases Risk or WouldNot Assist Rescue • Chest or Full Body Harness, Center of Back Near Shoulder or Above Head; Wristlets ONLY if Harness is Infeasible or Greater Hazard • Attached to Mechanical Device or Fixed Point Outside Space • MSDS Must Be at Worksite and Furnished to Medical Facility Treating Exposed Entrants

37. Testing and MonitoringAppendix B • Evaluation Testing • Any Hazards • Prior to Entry • Technically Qualified Professional • OSHA Consultation Service • CIH • Registered Safety Engineer • CSP • Verification Testing

38. Testing and MonitoringAppendix B • Duration of Testing • Testing Stratified Atmospheres • Atmospheric Envelope of 4 ft. in Direction of Travel and to All Sides • Rate of Progress of Entrant Slowed to Accommodate Instrument Sampling Speed and Response Time

39. Hot Work Permits Defined As: Written Authorization to Perform Operations Capable of Providing a Source of Ignition (Such As Welding, Cutting, or Brazing) Required for: Hot Work in Grain Handling Facilities and Any Other Combustible/ Explosive Areas

40. Hot Work PermitsGeneral Provisions • Remove Fire Hazards & Combustibles • Guard the Work • Guard Openings to Other Areas • Maintain Fire Extinguishers

41. Hot Work PermitsGeneral Provisions • Maintain Fire Watch • Written Permit Authorization • Protect Floors & Walls • Protect Drains, Dusts, and Pipes

42. Alternate Procedures Can be used if... • ONLYHazard is an Actual or Potential Hazardous Atmosphere And • Can Demonstrate That Continuous Forced Air is Sufficient to Maintain the Space as Safe • Data is Developed to Support the Above • A Permit Program is Followed During Data Collection

43. Alternate Procedures(continued) • Hazard from Removing Entrance Cover is Eliminated • Entrance is Made Safe to Prevent Accidental Falls • Atmospheric Testing for • Oxygen • Flammability • Toxic Contaminants

44. Alternate Procedures(continued) • No Hazardous Atmospheres Develop While Employee is In Space • Continuous Forced Air Ventilation is Used • No Entry Until Safe • Remains Until Everyone Has Left Space • Air is From a Clean, Safe Source • Periodic Testing

45. Alternate Procedures(continued) • If A Hazard Develops • Evacuation of Space • Evaluation as to the Source • Protection of Employees Prior to Re-entry • Documentation • Date, Location, Signature of Person Certifying • Certification Made Prior to Entry and Available to each Employee

46. PRCS Program • Permit System • Entry Permit • Personnel Duties • Rescue • Emergency Services Alternate Procedures(continued) At Issue -“Elimination” of Hazards • If the Stated Conditions Are Met, the Employer Does Not Have to Implement • OSHA Compliance Letter (10/12/95) Interprets the Elimination Provision: “… If the Non-Atmospheric Hazards Were Permanently Eliminated, the Alternate Procedures Could Subsequently Be Applied…”

47. Hazards are usually dictated by... • The material stored in the confined space. • The activity carried out in the confined space. (a particular chemical reaction) • The external environment. (a tank located near rising waters)

48. OSHA Estimates • 224,000 establishments have permit required confined space. • 2.1 million workers enter these spaces annually. • 60% of the deaths that occur in confined spaces are the rescuers who go in after the victim.

49. Confined Space Hazards • Chemical Hazards • Physical Hazards • Biological Hazards • Ergonomic Hazards

50. Engulfment • The surrounding or covering of a person by a liquid or flowable solid. Death may result by suffocation, strangulation, constriction, or crushing. • Concrete • Asphalt