Presented by: Allan DeLange, CL Coatings, LLC

• This webinar is being presented to issue guidance addressing the hazards and controls for surface preparation and coating application in confined spaces.

• At the end of this webinar, you will be able to:
– Identify confined space industry standards
– Define a confined space
– Recognize hazards in a Permit
Required Confined Space (PRCS)
– Define methods for control and elimination of hazards in a Permit
Required Confined Space (PRCS)
– Become familiar with the elements of a
Permit-Required Confined Space
Program

• Note: This webinar is not a substitute for:
A confined space safety plan
A confined space training course
A OSHA regulation on confined space

• During the webinar reference will be made to the following industry standards:
– OSHA’s General Industry Standard 29 CFR
1910.146 Permit Required Confined Spaces
– OSHA’s Safety and Health Regulations for
Construction 29 CFR 1926
• OSHA is working on a proposed rule on confined spaces more specific to construction as part of its upcoming revision

• An area being large enough and so configured that an employee can enter and perform assigned work; having limited or restricted means for entry; and not designed for continuous occupancy

• Some examples of PRCSs commonly encountered in industrial and marine coating operation include:
– Interiors of storage tanks
– Silos
– Ship holds
– Boilers
– Penstocks

• Confined Spaces can be Deadly
• Some Confined Spaces are more Hazardous than others
• Confined Space Conditions can change rapidly
• Hazards can often be eliminated or controlled before entry
• Surface Preparation and Coating Application
Hazards usually require a written Permit
System for Entry

• Oxygen Deficiency
• Hazardous Atmospheres
• Abrasive Blasting & Waterjetting
• Toxic Materials (Coatings)
• Moving Parts
• Electricity
• Physical Hazards (Heights)

• A “hazardous atmosphere” in a confined space has one or more of the following:
– Flammable gas, mist or vapor
– Flammable Dust
– Oxygen content below 19.5% or above 23.5%
– Air contaminant concentrations that would cause death, incapacitation or permanent health problems
– IDLH atmosphere

• Flammable gases, vapors or dusts will ignite from a spark or flame if above the
“Lower flammable limit” (LFL)
• Gas or vapor levels higher than 10% of the
LFL are considered hazardous and the confined space cannot be entered until levels are reduced

• Engulfing materials include liquids or loose solids such as grain, sand or other granular material.
• Entrapment can occur in a space configured in a way that can trap a worker, for example, sides sloping towards the center.

•
The most common toxic chemicals in confined space fatalities are hydrogen sulfide and carbon monoxide.
• Other toxic chemicals can include welding fumes, vapors from chemical residues or chemical products used in the confined space.
• Chemicals can quickly reach toxic levels in the air of a confined space, especially gases, solvent vapors or sprayed products.

• Electrical lines, steam lines, or hydraulic lines
• Mechanical hazards (moving parts)
• Hazards caused by work operations
– Welding
– Abrasive Blasting
– Waterjetting
– Spray Painting

• When there is an actual or potential
Hazardous Atmosphere, or
• When the space contains loose material that can engulf a person, or
• When the space is configured in a way that can trap a person, or
• When there is any other recognized serious safety and health hazard

• Whenever a hazard is present in the confined space, it should be considered a permit-required confined space (PRCS)

• Establish and implement a written confined space entry program that is reviewed annually.
• Ensure all field personnel are trained in every aspect of each project-specific confined space safety plan, including the rescue plan and each person’s role in the event that the plan has to be implemented.

• Identify the space
• Identify the hazards
• Eliminate or control the hazards
• Isolate & control the space
• Pre-entry verification

• Permit preparation, authorization & cancellation
• Safe work practices
• Emergency Response / Rescue Services
• Training

• Identity of Space
• Purpose of Entry
• Date and Duration
• Supervisor, Entrants & Attendants
• Hazards of the space
• Means to isolate & control space
• Acceptable entry conditions

• Rescue & emergency services
• Communication methods
• Safety, communication, rescue & PPE equipment required
• Atmospheric test results
• Authorization, release for entry, suspension and cancellation

• Before beginning work, a job safety analysis (JSA) should be performed taking into consideration the equipment and materials to be used

• Proper completion of a JSA, listing planned activities, identifying all potential hazards of a confined space entry and establishing the means to control the hazards and eliminate accidents is an excellent way to prepare for confined space entry and completion of an entry permit.

• Hazardous Atmospheres
– Drain or pump out liquid contents
– Blank off, double block & bleed all in-feeding lines
– Air test and ventilate
– Continue ventilation during entry
– Exit space if conditions deteriorate
– Use non-sparking tools where feasible

• Lock Out / Tag Out
– Identify all potential energy sources
– Comply with client operating procedures
– Lock out / tag out energy isolating devices
– Walk down all isolation points prior to each shift
– Verify “Lock Out” of operating equipment
(witness bump test)

• Post Warning Signs
• Limit access by using entry barriers or locks
• Prevent entry by unauthorized workers
• Holes and openings must be closed or guarded when not attended

• Complete pre-entry briefing for all planned entrants and attendants
• Complete pre-entry testing for air quality
• Verify isolation of the confined space
• Confirm required pre-entry requirements and availability of all permit required materials and equipment

• Engineered Supply & Exhaust
• Cross ventilation – circulation
• Breathing zone issues
• Source of ventilation
• Point of exhaust

• Confined spaces should always be monitored for hazardous atmospheres both prior to entry and continuously in areas where work is being performed

• Required prior to and during confined space entry
• Monitor for O2, LEL, CO, H2S, SO2
• Monitors must have current calibrations
• Results must be documented

• All required PPE per entry permit
• Respiratory protection
• Eye protection, hearing protection
• Protective clothing, gloves & footwear
• Fire retardant clothing - Chemical suits
• Fall protection
• Harness (& lifeline) to facilitate rescue

• Examine the workspace for snags and equipment and tool placement that could make retrieval difficult
• If obstructions render lifelines unusable, require entrants to wear the harnesses regardless to facilitate rescue

• A means of communication must be provided between the attendant and entrants
– 2 way radio systems
– Air Horns
– Audible and/or visual direct contact
– Signaling protocols
– Lifelines
– Alarm systems

• Try to substitute less hazardous materials
• Use paints and solvents with flash points above 100F
• Minimize the total amount of hazardous materials within a confined space at any time

• GFCIs and Assured Grounding Program
• Ground and bond containers when transferring liquids
• Electrically ground coating spray systems
• Electrically ground blowers and duct work
• Explosion proof electrical and lighting systems are required when flammable atmospheres may be present.

• The person (such as a foreman), trained, competent, and responsible for determining if acceptable entry conditions are present at a permit space where entry is planned, for authorizing entry and overseeing entry operations, and for terminating entry.
REVIEW THE JSA!

• The Entry Supervisor has TOTAL Responsibility for the Confined Space and must:
‾ Pre-entry briefing on the confined space
‾ Know the hazards in the confined space
‾ Verify testing and confirm equipment availability before endorsing permits
‾ Terminate entry and cancel permits as needed
‾ Verify that a rescue team is available
‾ Remove unauthorized personnel
‾ Determine that operations are consistent with the terms of the permit and JSA

• An individual stationed outside one or more permit required confined spaces who monitors the authorized entrants and who is trained to perform all attendants duties assigned per the
Confined Space Entry Program.
• Mandatory for PRCS.

• The Attendant must:
‾ Know the hazards in the confined space
‾ Be aware of the behavioral effects of exposure
‾ Maintain an accurate count of entrants
‾ Remain outside until relieved by another attendant
‾ Monitor activities in confined space and order an evacuation if necessary

• The Attendant must:
‾ Monitor activities in confined space and order an evacuation if necessary
‾ Summon rescue team when necessary
‾ Prohibit unauthorized entry
‾ Perform non-entry rescue if necessary
‾ Perform no other duties

• An employee who is authorized and trained by the Company or an approved third party, to enter a permit space.

• The entrant is authorized by the entry permit to enter the confined space.
The entrant must:
• Know the hazards faced during entry
• Properly use the required equipment
• Communicate with the attendant
• Alert attendant of possible exposure or changes in conditions
• Exit the space quickly when conditions warrant

• A means must be provided for both safe normal entry or exit , and emergency extrication. Tripods with hoist, lifeline, and full body harness are often used for emergency extrication. Ladders may be used for ordinary entry and exit.

• Rescue and emergency services must be available for Permit Required Confined Spaces
• The personnel designated to rescue employees from permit spaces, may be employees specifically trained for confined space rescue, client site services, local paid or volunteer fire department, or other trained services

• Require that confined space rescue team be readily available for call out within 5 minutes at the permit spaces

• Visit the closest fire station and provide the Chief with a briefing about the job, including all entries.
• Give the Chief a copy of all
MSDSs.
• Have a site visit with the fire
Chief to review the entry permit and work site.

• Employers are required to certify that all employees, including attendants, entrants and entry supervisors, have been properly trained for permit space operations.
• Rescue and emergency service providers must receive special training and practice permit space rescues annually

• Accepted industry practices and regulatory requirements should be implemented prior to and during all surface preparation and coating application operations in confined space which may create a hazardous atmosphere

• This concludes our webinar for today.
Please join us for our next webinar, April
13 th at 11am EST on Common Legal
Problems in Coating Work and How to
Stay Out of Court