Confined Spaces –
Avoiding Unnecessary Hazards
and Hazardous Entry
Agenda
• Objectives
• Confined Spaces - Dangerous workplaces
• What is a “Confined Space” according to OSHA?
• Permit-Required Confined Space (PRCS)
• Confined Space Hazards 101
• Penn State Examples
• Confined Spaces at Penn State – A Real Concern?
• Penn State Confined Spaces (by Organization)
• Penn State Confined Space Program
• OSHA Requirements for Employers and Contractors
• Questions/ Comments
Objectives
• Recognize varied types of Penn State confined spaces.
• Recognize Penn State organizations that “own” or work with confined spaces.
• Understand OSHA definition for “confined space”, and “permit-required
confined space.”
• Recognize life-threatening hazards related to confined space work.
• Recognize proper work requirements for “permit-required” confined spaces.
• Understand OSHA requirements for employers, employees, and Contractors.
• Understand access Penn State’s confined space program, and contacts for
answers and assistance regarding Penn State confined spaces.
Confined Spaces – Dangerous workplaces
January 7, 2015
OSHA cites Agridyne after 2
workers succumb to dangerous
fumes in June 2014.
• A 37-year-old worker entered a rail
car to clean out corn steep residue
and was overcome by hydrogen
sulfide gas. A 29-year-old tank
inspector, entered to attempt
rescue, and succumbed to the gas
exposure. Neither worker made it
out of the car alive.
http://www.pjstar.com/article/20140624/NEWS/140629581
Confined Spaces – Dangerous workplaces
Dec. 9, 2014
Latino worker dies following exposure to nitrogen in
tanker truck at Michael Foods' Big Red Farms facility in
Wakefield, Nebraska.
• The 23-year-old Latino worker was found unresponsive in a
tanker truck at the company's Big Red Farms facility. He
was conducting sampling of the tank, which contained egg
products and nitrogen...
Confined Spaces – Dangerous workplaces
Feb. 12, 2014
Serious workplace safety violations were found in connection
with the September 2013 explosion at the Canastota
Wastewater Treatment Plant that killed one worker and
injured another.
• Joy Process Mechanical Inc. of East Syracuse and M. Hubbard
Construction Inc. of Mottville were hired by the plant to replace piping
inside a methane gas dome, a confined space. The Joy Process
Mechanical worker was welding inside the dome when the explosion
occurred, burning him and a Hubbard Construction worker who was
standing atop a stepladder opening to the confined space.
Confined Spaces – Dangerous workplaces
What were possible causes for these tragedies?
Confined Spaces – Dangerous workplaces
What were possible causes for these tragedies?
• Lack of awareness
Confined Spaces – Dangerous workplaces
What were possible causes for these tragedies?
• Lack of awareness
• Lack of effective education and training
Confined Spaces – Dangerous workplaces
What were possible causes for these tragedies?
• Lack of awareness
• Lack of effective education and training
• Lack of preparation
Confined Spaces – Dangerous workplaces
What were possible causes for these tragedies?
• Lack of awareness
• Lack of effective education and training
• Lack of preparation
• Unknown or changing conditions
Confined Spaces – Dangerous workplaces
What were possible causes for these tragedies?
• Lack of awareness
• Lack of effective education and training
• Lack of preparation
• Unknown or changing conditions
These tragedies were not anticipated!
What is a Confined Space?
OSHA defines a confined space as:
• Any space large enough and configured to permit bodily
entry to perform work, AND
• Limited or restricted means for entry and exit, AND
• Not designed for continuous occupancy
(OSHA Standards - 29 CFR Part 1910.146; Part 1926.1202)
What is a Confined Space?
Any space large enough and configured to permit bodily
entry to perform work:
What is a Confined Space?
Limited or restricted means for entry and exit:
Example conditions:
• May have one way in or out, whether opening is large or small
(16-18” diameter),
• May pose difficulty in getting an unconscious worker out,
• May be difficult to introduce safety or work equipment,
• May necessitate climbing over pipes, equipment or obstacles in
the work space.
What is a Confined Space?
Not designed for continuous occupancy:
(Space is not designed for regular human occupancy /work):
•
•
•
•
Storage area
Process enclosure for a tank, vessel, other..
Conveyor or transport enclosure,
Maintenance hatchway for equipment repair, replacement,
clean-up, service
“Permit-Required” Confined Space
Permit-required confined space has one or more of
the following characteristics:
• Contains/ potential to contain a hazardous atmosphere,
• Contains material with potential to engulf an entrant,
• Internal configuration can cause an entrant to be trapped or
asphyxiated by inwardly converging walls or floor that slopes
downward and tapers to a smaller cross section,
• Contains any other recognized serious safety or health hazards.
PRCS entries require RESCUE preparation, equipment and planning
OSHA 29 CFR 1910.146 OSHA 29 CFR 1926.1202
To permit …or not to permit (OSHA)
Space large enough to enter, AND
Limited or restricted entry or exit, AND
Not designed continuous worker occupancy.
YES
Not a Confined Space
Confined Space
Hazardous Atmosphere?
Permit-
Non-
Or
Required
Confined
NO
YES
Engulfment Hazard?
Or
Space
Configuration Hazard?
(OSHA)
Any other recognized
serious hazard?
Or
PermitNO
Confined
Space
(OSHA)
Penn State Examples
• Crawlspaces, manholes, tanks, silos, boilers, meter pits, aquatic service
pits, elevator pits, manure pits, wastewater treatment facilities, water towers,
transformer and electric vaults, tunnels, trenches, HVAC equipment….
Confined Space Hazards 101
Atmospheric – toxic gases, oxygen displacing gases,
other hazardous atmospheres (i.e. explosive or lifethreatening)
Engulfment – by water, grain, powders, earth/soil,
other substances..
Entrapment – tight or convoluted spaces, …can also
make a worker vulnerable to other hazards!
OTHER Serious Safety or Health Hazards –
electrical, mechanical, steam, fire/explosion
Confined Space Hazards 101
Atmospheric Hazards
– Flammable gas, vapor, mist exceeding 10% lower flammable limit
(LFL)
– Airborne combustible dust at or greater than LFL
(estimated when loss of visibility at 5 feet or less)
– Atmospheric oxygen content less than 19.5% (oxygen-deficient), or
greater than 23.5% (oxygen-enriched)
– Any other atmospheric condition that is “Immediately Dangerous
to Life or Health” (IDLH) – toxic or other hazardous atmosphere1
1 OSHA – “An atmospheric concentration [level] of any toxic, corrosive or asphyxiant
substance that poses an immediate threat to life OR would cause irreversible or
delayed adverse health effects OR would interfere with an individual's ability to escape
from a dangerous atmosphere.” [29 CFR 1910.120]
Confined Space Hazards 101
Atmospheric Hazards
Created by:
• Lack of air movement into and through the space – gases or vapors
can build up.
• Toxic or deadly gases can have a different density than air – forming
a toxic layer, or displacing air in the space.
• Organic materials can decompose to create toxic gases – using up
oxygen from the air in the space.
• Gases, vapors, or fine dusts can become explosive in the right
concentration – become easily ignited.
• Nearby vehicles, emergency generators produce carbon monoxide –
can infiltrate a nearby space.
Confined Space Hazards 101
Atmospheric Hazards
How can we check the atmosphere?
Confined Space Monitoring
• Check air quality throughout the space by instrument test. Tests
based on the expected hazardous conditions:
•
•
•
Flammability (not more than 10% of lower flammable level)
Oxygen content (between 19.5 – 23.5%)
Toxic Gases (Penn State examples)
•
•
•
•
Carbon monoxide (OSHA PEL – 50 ppm; NIOSH IDLH -1200 ppm)
Hydrogen sulfide (OSHA PEL - 10 ppm, 20 ppm -Ceiling; IDLH – 100ppm)
Nitrogen dioxide (OSHA PEL – 5 ppm; NIOSH IDLH – 20 ppm)
Chlorine gas (OSHA PEL – 1 ppm; NIOSH IDLH – 10 ppm)
Confined Space Hazards 101
Engulfment Hazards
Examples?
•
•
•
•
Loose, granular materials stored in bins and hoppers
Crusted over grain stored in agricultural silos or bins
Unstable soil in trenches/excavations
Water, sewage, or liquids under pressure, from valves or sources
of openings in confined spaces that may be worked on
Confined Space Hazards 101
Entrapment Hazards
Examples?
• Pits or sub-basements with convoluted piping or equipment
• Silos, tanks, storage bins with baffles and converging walls to
openings at bottom
• Narrow, or shallow passageways or tunnels, that can make it
difficult or more hazardous to perform work (may or may not
contain obstacles)
Confined Space Hazards 101
Other Serious Safety or Health Hazards
Examples?
•
•
•
•
•
•
•
•
Air temperature extremes (hot, cold)
Steam under pressure
Hot or cold process equipment, pipes
High electrical voltage or amperage/ arc-flash- explosion
Heavy or falling objects inside the confined space
Electromechanical forces from process equipment such as mixer blades,
Hydraulic rams or equipment
Very high noise levels that can damage hearing
Confined space hazards may be combined!
Confined Spaces at Penn State –
A real concern?
Confined Spaces at Penn State –
A real concern?
• Frequent new construction/ renovation
Confined Spaces at Penn State –
A real concern?
• Frequent new construction/ renovation
• Different groups: OPP Tech Services, Housing & Foods,
Campus Housing, Campus Maintenance, Contractors
Confined Spaces at Penn State –
A real concern?
• Frequent new construction/ renovation
• Different groups: OPP Tech Services, Housing & Foods,
Campus Housing, Campus Maintenance, Contractors
• Different types of confined spaces
Confined Spaces at Penn State –
A real concern?
• Frequent new construction/ renovation
• Different groups: OPP Tech Services, Housing & Foods,
Campus Housing, Campus Maintenance, Contractors
• Different types of confined spaces
• Life-threatening hazards
• Electrical, mechanical, engulfment, entrapment, hazardous
gases, ..asphyxiation (lack of oxygen)
Confined Spaces at Penn State –
A real concern?
Other potential impacts to Penn State if
persons are hurt, ...lives are lost?
Confined Spaces at Penn State –
A real concern?
Other potential impacts to Penn State if
persons are hurt, ...lives are lost?
•Regulatory fines (OSHA)
•Increased insurance cost
•Increased inspections
•Reduced employee morale
•Penn State credibility
Confined Spaces at Penn State –
Primary Organizations
•
•
•
•
•
•
Office of Physical Plant
Campuses
College of Agriculture
Transmission & Network Services
Auxiliary & Business Services
Applied Research Laboratory
Contact Facility Coordinators/Safety Officers at U/Park, or
Contact Campus Directors of Business Services, Maintenance Supv’s,
Contact EHS (5-6391) for information or support.
Confined Spaces at Penn State –
A real concern?
What should we do to keep ourselves safe?
Confined Spaces at Penn State –
A real concern?
What should we do to keep ourselves safe?
• Be aware of potential hazards
• Training
• Preparation (for the job, for rescue..)
• Use correct equipment
• Monitor potential dangerous atmospheres
• Do not enter confined spaces without proper training,
preparation, equipment, authorization and supervision.
OSHA C/Space Employer Requirements
(Permit-Required Entries)
1. Prepare/update written program
2. Identify spaces
3. Evaluate space hazards
4. Procedure to issue & cancel permits
5. Procedure for work entry and rescue
6. Eliminate or control hazards
7. Provide necessary safety equipment
8. Ensure at least one attendant (PRCS)
9. Coordinate multi-employer (contractor) entries
10.Plan for confined space rescue
11.Review program annually
12.Procedures where multiple spaces are entered
13.Verify/provide safe entry training; rescue if applicable
What about new OSHA requirements
for Construction/ Contractors?
Multi-Employer Coordination
Host Employer provides information to Controlling
Contractor:
• Permit space locations
• Permit space hazards
• Permit space precautions
What about new OSHA requirements
for Construction/ Contractors?
Multi-Employer Coordination
Controlling Contractor provides information to Entry Employers
(Sub-Contractors), others affected:
• Information from Host Employer
• Any additional hazard information
• Permit space precautions
Controlling Contractor debriefs host and entry employers/
exchanges information
What about new OSHA requirements
for Construction/ Contractors?
Multi-Employer Coordination
Entry Employer (Contractors) must:
• Obtain information from Controlling Contractor
• Inform Controlling Contractor of permit program being
followed, including information on created hazards
OSHA Confined Space in Construction- Frequently Asked Questions
https://www.osha.gov/confinedspaces/faq.html
The rule makes the controlling contractor, rather than the host
employer, the primary point of contact for information about
permit spaces at the work site.
Host employer
• must provide information about work site permit spaces to
controlling contractor, who passes info to other entry
employers (whose employees will enter the spaces).
Entry employers
• Provide controlling contractor information about their entry
program and hazards they encounter (will create) in the
space
Controlling contractor
• passes such information to other entry employers and back
to the host
• responsible for making sure employers outside a space
know not to create hazards in the space, and
• entry employers working in a space at the same time do not
create [unforeseen] hazards for one another’s workers
Penn State Confined Space Program
• Written program document (based on OSHA requirements)
• Inventory of confined spaces (by location)
• Confined Space Permit (permit-required work)
• Checklist to ensure preparation
•
•
•
•
•
•
http://www.ehs.psu.edu/workplace-safety/confinedspace/forms
Confined Space Signs/ Labels
Rescue planning (for hazardous PRCS entry)
“Alternate Entry” standard operating procedures (SOP’s)
Training - Entrant/Attendant/Supervisor, Awareness, Rescue
Air monitoring and testing
Annual review of closed permits (to see what may be learned)
Penn State EHS Website – Confined Space Requirements & Guidelines webpage
http://www.ehs.psu.edu/workplace-safety/confined-space/requirementsguidelines
Penn State Confined Space Program
• Inventory of confined spaces (by location)
Worthington-Scranton Campus
Description of Space
Potential Hazard
Meter Pits
Dangerous Air
Sanitary/Stormwater
Manholes
Dangerous Air
Telecommunications
Manholes
Mechanical/Electrical; Dangerous
Air
Who
# Spaces Frequency Type of Activity Enters
of Entry
In Space
Is Space Control Measures
Labeled
4-gas meter, radio, site control, ladder
or fall protection, ventilation, buddy
1 2/Yr
Pump water out Contractor No
system
Fall protection, 4-gas meter, radio, site
control, ventilation, tripod with winch,
14 As needed Maintenance
Contractor No
buddy system
Fall protection, 4-gas meter, radio, site
control, ventilation, tripod with winch,
2 2/Yr
Pump water out Contractor No
buddy system
Notes
Add any specific spaces noted during ISP self-review?
Does campus have any monitoring equipment?
Does campus have any retrival equipment?
Engineering controls to elminate entry?
Other
What if PSU Employees have to enter for tool which fell inside
space
Updated
9/17/2013
None
No
No
Use pumping equipment to eliminate entry inside manhole.
Gave map on sewer manhole
locations.
PPE*
CS PR
Safety glasses,
gloves
Yes Yes
Safety glasses,
gloves
Yes Yes
Safety glasses,
gloves
Yes Yes
http://www.ehs.psu.edu/workplacesafety/confined-space/forms
CONFINED SPACE EVALUATION FORM PAGE 2 OF 2
1) Crawlspaces
No utility service (electrical, natural gas, oxygen-displacing gas (N2 or inert gas), or explosive fuel source may terminate within the crawlspace.
No hot work may be performed in the space, without prior alternate entry evaluation.
No vapor-causing or volatile compounds may used, without prior, alternate entry evaluation and Safety or EHS authorization. Non-volatile
compounds (pipe dope compounds, caulk or paste lubricants, etc.) may be used, if no restricted hazard is introduced by their use.
No reasonable probability of rupturing utility service within the crawlspace, or, opening of service lines in the crawlspace.
Where feasible, crawl space must be cross-ventilated, or exhaust ventilated, where no ventilation is present.
2)
Pipe Chases
Ventilation must be provided, or designed into, and vented through the space during work.
No utility service, and no explosive fuel source may terminate within the crawlspace; no hot work may be performed w/out prior alternate entry
evaluation per item 1 Crawlspaces.
No interconnection to other pipe chases, tunnels, or potential permit-required confined spaces, OR to spaces with uncontrolled atmospheres
or hazardous atmospheres may be present.
3)
Ductwork/ Air Handlers (HVAC equipment)
HVAC Systems DO NOT include, nor pertain to, fume hood exhaust or other forms of exhaust systems/ ducts.
Must be able to open and to permit air exchange through the equipment/duct.
All other hazardous exposures/ electromechanical sources must be properly controlled (pulleys, drives, fans, etc.) and lock-out/tag-out (LOTO)
must be properly enforced.
4)
Cooling Towers
Side panels must be removed to permit cross-ventilation and complete air exchange, prior to and during cooling tower rebuild or cleaning.
No other maintenance activity permitted, which may involve top entry or potential exposure to moving parts or electro-mechanical hazards.
All other hazardous exposures or electromechanical sources must be properly controlled and (LOTO) must be properly enforced.
5)
Equipment/Pool Service Pits and Sub-Basements
Non OPP/Tech Service Staffs Only:
Non-permit entry restricted to performing inspections, pool chemical additions, filter replacements, and similar non-hazardous tasks
Simultaneous hazardous confined space entry work is prohibited during non-permit entry.
No hot work may be performed in the space, without prior alternate entry evaluation.
Office of Physical Plant Tech Services Staff:
All entry to this type space for work associated with electrical or mechanical service is determined by task, and may be permit-required.
6)
Elevator Service Pits
Elevators must be de-energized, blocked, and all safety controls in place. All energy sources must be disconnected, and/or locked out as
required by LO/TO procedures.
No atmospheric hazards, NOR other hazards, generators, or energy sources may be located within, or introduced into space during work.
Confined Space Type: ________________________________Confined Space ID (where available): ____________________________________
 Single Entry Assessment (Dates: _________________)
 Tentative Permanent Entry Assessment
Authorized Supervisor Name/ Signature:________________________________________________________________ Date: __________________
Department/Region Confined Space Coordinator Name/ Signature __________________________________________ Date: __________________
Penn State Confined Space Program
• Confined Space Signs/ Labels
Non Permit Confined Space Sign
Permit-Required Confined Space Sign
Questions / Comments?
Please direct questions or comments to the Penn State or your organizational
contact regarding confined spaces.
Quiz – Test your Awareness
1. Confined spaces are always small, hard to reach places, but
have two means of entry or exit.
2. Confined space injuries or fatalities are always due to a lack
of awareness.
3. Permit-required confined spaces (PRCS) are those which are
defined by the Occupational Safety & Health Administration
(OSHA), and must have all of the following hazards –
atmospheric, entrapment and engulfment.
4. Permit-required confined spaces (PRCS) may have other
serious safety or health hazards associated with the space or
work tasks in the confined space.
5. Atmospheric hazards may include: oxygen deficiency, oxygen
enrichment, or toxic hazards.
True or False
1.______
2.______
3.______
4.______
5.______
Quiz – Test your Awareness
6. Atmospheric hazards are always associated with gases and must
always be explosive in nature.
7. Atmospheric hazards are those which are defined as life
threatening, in confined spaces.
8. Work that is performed in a PRCS, should include advance rescue
planning.
9. Atmospheric hazards in a confined space can be caused by nearby
vehicle operations or emissions.
10. Other serious safety or health hazards may include: steam pressure,
temperature, high electrical voltage, electromechanical or
hydraulics, or very high noise levels.
True or False
6. _____
7. _____
8. _____
9. _____
10. _____
Quiz – Test your Awareness
Multiple Choice
Circle correct
choice(s)
______________________________________________________________________
11. PRCS hazard examples include:
a. Oxygen content less than 19.5%
b. Standing grain in a silo
c. Convoluted pipe works in a sub-basement or tunnel
d. Natural gas lines with valve terminations in a crawl space
12. Confined spaces at Penn State are a concern because of which primary
considerations:
a. Frequent new construction or renovation
b. Many different groups “own” or operate in confined spaces
c. Wide variety of types of spaces
d. Entry into Penn State confined spaces can be life-threatening
13. Penn State employees can recognize a “permit-required confined space
entry, by the following site conditions: a. Posted/completed permits, b.
An Attendant present at the space at all times it is occupied, c. A Danger
sign indicating that entry is by permit only, d. Protective or rescue
equipment
11. a b c d
12. a b c d
13. a b c d
Quiz – Test your Awareness
14. Confined space incidents have the potential to impact Penn State
beyond regulatory fines.
15. Penn State and Penn State Contractors all have obligations under
the OSHA Permit-Required Confined Spaces standard.
16. A non-permit confined space does not contain or have the potential
to contain atmospheric hazards, causing death or serious physical
harm.
17. Penn State personnel should prepare a specific classification form
used to determine whether a confined spaces may qualify as a nonpermit confined space.
True or False
14. _____
15. _____
16. _____
17. _____
Quiz – Test your Awareness
Multiple Choice
Circle correct
choice(s)
________________________________________________________________
18. Penn State’s written confined space program addresses : a. rescue planning, b.
alternate entry standard operating procedures (SOP’s), c. specialized
Entrant/Attendant/Supervisor and Rescuer training, d. Required review of closed
permits every 3 years.
19. Confined space work preparation, must include:
a. Hazard awareness and proper classification of the confined space
b. Necessary equipment, signs, procedures, and training for PRCS work
c. Designated sharing of information about hazards for contracted work
d. Specific host, controlling contractor , entry contractor responsibilities
20. PRCS entries by contractors at Penn State facilities, require:
a. PS supply information regarding CS locations, hazards, precautions
b. General/ Controlling contractor coordinate Host and Entry Employer
information exchange
c. Entry employers supply permit program used and hazards introduced
18. a b c d
19. a b c d
20. a b c
Penn State Confined Space Program Contacts
• T. Hans Derr, CIH
Penn State EHS (CS Program Lead)
814-865-6391
thd12@psu.edu
Pete Muldoon – Commonwealth Campuses
George Conklin – Central Region
Joe Mazzoni – Eastern Region
Brandi Baros – Western Region
http://www.ehs.psu.edu/workplace-safety/confined-space
• Don Fronk, CSP
Office of Physical Plant
814-865-1661
George Benko - Utilities
Jonathon Risley - Construction
Liz Fisher – Buildings and Grounds
dlf21@psu.edu
http://www.opp.psu.edu/intranet/hr/safety-and-workers-compentsation-information/safety-information
• Contact EHS, Campus Maintenance Supervisors, or Campus Confined Space Coordinators for assistance.