Confined Space Safety

Detailed OSHA Requirements and Nuances:

Written Permit Program:

• • The permit program must include specific procedures for isolating the confined space, testing the atmosphere, and providing rescue services.

  • The permit must be completed and signed by an authorized entrant supervisor before any entry occurs.

  • The permit must be available to all entrants and attendants at the entry location.

Atmospheric Testing Specifics:

• • Testing must be conducted in the following order: oxygen, flammable gases, and toxic substances.

  • Calibration of atmospheric testing equipment is critical and must be performed regularly.

  • Continuous monitoring is required when atmospheric hazards are present or suspected.

  • Understand the PEL (Permissible Exposure Limit) of any gasses, and the LEL (Lower Explosive Limit) of flammable gasses.

Ventilation Techniques:

• • Forced-air ventilation must be directed into the confined space to displace hazardous atmospheres.

  • The ventilation system must be capable of providing adequate airflow.

  • Consider the use of portable ventilation systems with explosion-proof motors in flammable atmospheres.

  • This requires some consideration, as;

    • Negative pressure ventilation can expose a negative air machine motor to flammable gasses.

    • Positive pressure ventilation can push flammable or potentially toxic vapors into unaffected areas.

Lockout/Tagout (LOTO) Details:

• • LOTO procedures must be in accordance with OSHA standard 1910.147.

  • All energy sources that could pose a hazard within the confined space must be locked out and tagged.

  • Verification of isolation is essential before entry.

Rescue Plan Specifics:

• • The rescue plan must be specific to the confined space and the potential hazards.

  • Rescue equipment must be readily available and in good working order.

  • Rescue personnel must be trained in the use of rescue equipment and procedures.

  • Understand the different types of rescue, such as non-entry rescue, and entry rescue.

    • This generally requires employees to be tethered to the exterior by means of a harness. This allowing the attendant to recover the incapacitated entrant from the confined space.

Attendant Responsibilities:

• • The attendant must maintain continuous communication with entrants.

  • The attendant must monitor the atmosphere outside the confined space.

  • The attendant must be able to initiate rescue procedures if necessary.

  • The attendant must never enter the confined space for rescue.

Training Content Details:

• • Training must cover the specific hazards of the confined space.

  • Training must include the proper use of PPE and rescue equipment.

  • Training must include hands-on practice with entry and rescue procedures.

  • Training must include the understanding of the permits.

Equipment Details:

• • Retrieval systems must be used for vertical entries of over 5 feet.

  • Breathing apparatus must be supplied-air respirators or self-contained breathing apparatus (SCBA).

  • Lighting must be explosion-proof in flammable atmospheres.

  • Communication systems must be reliable and effective.

Hot Work Permits:

• • If hot work, such as welding, is to be performed in the confined space, a hot work permit is required.

  • The atmosphere must be tested and verified to be safe before hot work begins.

Contractor Considerations:

• • When contractors are involved, the host employer and the contractor must coordinate entry procedures.

  • The host employer must inform the contractor of the hazards of the confined space.

  • The contractor must ensure that their employees are properly trained and equipped.

Documentation:

• • Maintain records of all permits, atmospheric testing, training, and rescue drills.

  • Documentation is critical for demonstrating compliance with OSHA regulations.

A permit is required when a confined space meets ANY of the following conditions:

1. Contains or has a potential to contain a hazardous atmosphere:

   • This includes oxygen deficiency (less than 19.5% or greater than 23.5%), flammable gases or vapors (above 10% of the lower explosive limit (LEL)), and toxic gases or vapors (above permissible exposure limits (PELs)).

   • Even if the atmosphere is currently safe, if there's a possibility of it becoming hazardous, a permit is required. This "potential" is very important.

2. Contains a material that has the potential for engulfing an entrant:

   • This refers to materials that can flow and bury a worker, such as grain, sand, liquids, or any other free-flowing solid.

   • The mere presence of these materials is enough to trigger the permit requirement, regardless of whether they're currently moving.

3. Contains a configuration that can cause an entrant to be trapped or asphyxiated:

   • This includes spaces with inwardly converging walls or a floor that slopes downward and tapers to a smaller cross-section.

   • It also includes spaces with any other configuration that could cause a worker to become trapped or suffocated.

4. Contains any other recognized serious safety or health hazard:

   • This is a catch-all category that covers a wide range of potential hazards, including:

     • Exposed Electrical hazards (exposed wiring, energized equipment).

     • Exposed Mechanical hazards (moving parts, rotating equipment).  

     • Thermal hazards (extreme heat or cold such as attics in the summer & winter months).

     • Chemical hazards (corrosive or toxic substances).

     • Biological hazards. (mold, biologicials such as bacteria, sewage, blood).

     • Noise hazards. (noise levels that would impede communication with workers & attendant)

These hazards may be mitigated or controlled in some way to isolate the risk from the employees where possible. 

Key Considerations:

Hazard Assessment:

• • A thorough hazard assessment is essential to determine if a space meets any of the criteria for a PRCS.

  • This assessment should be conducted by a competent person.

Potential vs. Actual Hazards:

• • It's important to remember that the potential for a hazard is just as important as the actual presence of a hazard.

  • Even if the atmosphere is currently safe, if there's a possibility of it becoming hazardous, a permit is required.

Reclassification:

• • In some cases, a PRCS can be reclassified as a non-permit confined space if all hazards are eliminated.  

    • Such as; performing attic work at night versus during the day to avoid heat stress or having an electrician protect exposed wiring.

  • However, this reclassification must be done in accordance with OSHA regulations, and must be documented.  

• Continuous Evaluation:

  • Confined spaces should be continuously evaluated, as conditions can change.  

  • A space that was previously safe, can become dangerous very quickly.

• Documentation:

  • All assessments, permits, and reclassifications must be documented.

  • Records must be kept for a specified period of time.

Key Responsibilities of a Confined Space Attendant:

Continuous Monitoring of Entrants:

1. • Maintain constant visual and/or verbal communication with entrants inside the confined space.  

   • Monitor their activities and ensure they are following safe work practices.  

   • Track the number of entrants and their locations within the space.

Monitoring Atmospheric Conditions (Outside the Space):

1. • Observe the area surrounding the confined space for any changes in atmospheric conditions or other potential hazards.

   • Be aware of potential external hazards that could affect the safety of entrants.  

Maintaining Communication:

1. • Ensure effective communication between entrants, the entry supervisor, and rescue personnel.  

   • Use pre-established communication methods (e.g., radios, hand signals).  

   • Relay information about changing conditions or emergencies.

Initiating Rescue Procedures:

1. • Be prepared to activate the rescue plan in case of an emergency.

   • This includes:

     • Alerting rescue personnel.  

     • Using retrieval systems (if applicable).  

     • Never entering the confined space for rescue unless properly trained and equipped.

   • Understanding when a non-entry rescue is possible, and when an entry rescue is required.

Preventing Unauthorized Entry:

1. • Control access to the confined space and prevent unauthorized personnel from entering.  

   • Ensure that only authorized entrants with valid permits are allowed to enter.  

Maintaining an Accurate Count of Entrants:

1. • Keep a precise record of who is in the confined space at all times.  

   • This is essential for ensuring everyone is accounted for in an emergency.

Maintaining Awareness of Hazards:

1. • Stay vigilant for any changes in the environment or the behavior of entrants that could indicate a hazard.  

   • Be aware of the potential for atmospheric hazards, engulfment hazards, and other dangers.

Understanding Permit Requirements:

1. • Be familiar with the requirements of the confined space entry permit.

   • Ensure that all conditions of the permit are being followed.

Never Entering the Confined Space (Unless Properly Trained and Equipped):

1. • The attendant's primary role is to remain outside the space.

   • Entering the space would leave the entrants without monitoring.

   • Only trained and equipped rescue personnel should enter the space in an emergency.

Maintaining a Log:

1. • Document important events, such as entry times, atmospheric readings, and communication checks.  

   • This log can be valuable for post-entry reviews and incident investigations.

Key Qualifications:

• Training: Attendants must be thoroughly trained in confined space entry procedures, hazard recognition, communication methods, and rescue procedures.  

• Competency: They must be able to recognize potential hazards and react appropriately in an emergency.  

• Communication Skills: Effective communication skills are essential for maintaining contact with entrants and other personnel.  

• Alertness: Attendants must remain alert and attentive throughout the entry process.

Encountering Wildlife in a Confined Space 

1. Do Not Approach or Provoke:

The primary rule is to avoid any direct interaction. Animals in confined spaces are often stressed and unpredictable, and they may bite, scratch, or attack if they feel threatened.

Do not attempt to capture, corner, or handle the animal.

2. Immediately Exit the Confined Space (If Safe To Do So):

If possible, and without putting themselves at further risk, employees should safely exit the confined space and close off the entry point to contain the animal.

This removes the immediate threat and allows for a safer assessment of the situation.

3. Report the Encounter:

Immediately report the presence of the animal to the entry supervisor, competent person, or designated safety personnel.

Provide as much detail as possible about the animal's location, size, and behavior.

4. Allow Trained Professionals to Handle the Situation:

Wildlife removal should be handled by trained professionals, such as animal control officers or wildlife removal specialists.

These individuals have the knowledge and equipment to safely capture and relocate the animal.

5. Do Not Re-enter Until the Animal is Removed:

The confined space should not be re-entered until the animal has been safely removed and the space has been assessed for any potential hazards (e.g., droppings, nesting materials).

6. Follow Company-Specific Procedures:

Employees should be aware of and follow their company's specific procedures for encountering wildlife in confined spaces.

These procedures should be included in the confined space entry program and training.

7. Be Aware of Potential Hazards:

Wildlife can carry diseases, parasites, and other biological hazards.

Their droppings and nesting materials can also pose health risks.

Be cautious of any potential injuries, such as bites or scratches, and seek medical attention if necessary.

Injuries to employees may be caused indirectly by the animal encountered. 

• e.g., the animal comes into contact with the employee, the employee panics and strikes their head on something.

8. Consider Environmental Factors:

If the animal is known to be venomous, or aggressive, then extreme caution should be taken.

If the confined space is a sewer, or other location that contains contaminated water, then extra care should be taken to avoid contact with any material that the animal may have contacted.

Prioritize Non-Entry Rescue:

• Whenever possible, attempt to retrieve the trapped employee without entering the confined space. This minimizes risk to rescuers.

• This involves utilizing retrieval systems:

  • Harnesses and Lifelines: The entrant should always wear a full-body harness connected to a retrieval line.

  • Winches and Tripods: These devices provide mechanical advantage for lifting and extracting the employee.  

  • This is the preferred method, and should be the primary method of rescue.

Entry Rescue (If Non-Entry is Impossible):

• If non-entry rescue is not feasible, a trained rescue team must enter the confined space.

• This team must:

  • Be equipped with appropriate personal protective equipment (PPE), including:

    • Respiratory protection (SCBA) for hazardous atmospheres.  

    • Harnesses and lifelines.

    • Atmospheric monitoring devices.

  • Have personnel trained in confined space entry and rescue procedures.

  • Have personnel trained in first aid and CPR.

• Continuous atmospheric monitoring is essential during the rescue.

• The team must safely remove the trapped employee, prioritizing their stability and minimizing further injury.  

Key Safety Considerations:

• Rescue Plan:

  • A detailed, written rescue plan must be in place before any confined space entry.

  • This plan should address potential hazards, rescue procedures, and equipment requirements.

• Training:

  • All personnel involved in confined space entry and rescue must receive comprehensive training.

  • Regular practice drills are crucial to maintain proficiency.  

• Atmospheric Monitoring:

  • Continuously monitor the atmosphere for hazardous conditions.

• Communication:

  • Maintain clear and reliable communication between rescuers, attendants, and other personnel.

• Equipment:

  • Ensure all rescue equipment is properly inspected and maintained.

• Emergency Services:

  • If relying on external emergency services, evaluate their capabilities and response times.

  • 911 may not be able to respond fast enough to save the employee.

OSHA Regulations:

• Adherence to OSHA's 29 CFR 1910.146 (Permit-Required Confined Spaces) is mandatory.

• These regulations outline requirements for:

  • Permit systems.

  • Atmospheric testing.

  • Attendant duties.

  • Rescue services.