1 IIPP (Section 3203)(a) “…every employer…” (a) (4) Include procedures for identifying and evaluating work place hazards… ◦ (C) Whenever the employer is made aware of a new or previously unrecognized hazard. 3 Construction 5% Inspection 10% Repair/Maintenance 40% Rescue 36% Retrieve Object 3% Dislodge material 5% Unknown 1% In place February 2012 All Cal-OSHA units ◦ Enforcement ◦ Consultation ◦ Every inspection will include an evaluation of confined spaces Goal: Zero confined space fatalities in 2012 5 For ALL Inspections: Ask ER if they have any confined spaces Look for Confined Spaces during walkaround ◦ Identify hazards ◦ Verify that spaces are labeled Ask ER if anyone enters spaces and how spaces are maintained & cleaned Interview employees entering spaces Review written “Confined Space Program”, or procedures and documentation/records Review alternate entry and/or reclassification procedures if applicable Review rescue procedures Audit last 6 months’ permits for PRCS-entry or certificates of reclassification Confined spaces present very special work requirements and preparations Safety incidents involving confined spaces may result in fatalities; many have multiple serious injuries 8 If confined spaces exist in your workplace ◦ Post the space ◦ Warn employees of the hazard ◦ Prevent employees from entering until an effective and fully implemented confined space program is in place. 9 Large enough and configured so that they can be entered, and Have restricted means for entry or exit, and Are not designed for continuous employee occupancy 10 Tanks Boilers Vats Kilns Vaults Silos Pipelines Sewers Manure pits Storage bins Double hulls Pumping stations Pits, sumps Vessels Manholes Water reservoirs 11 12 13 14 15 Does the person have to use their hands to enter or exit the space? Is the person in an awkward posture when entering or exiting the space? Is a person’s entry into or exit from the space slowed down or impeded by physical obstructions (such as pipes, ductwork, walls, holes in the floor, flanges, etc.)? Would an employee be forced to enter or exit in a posture that might slow selfrescue or make rescue more difficult? Is an acutely hazardous atmosphere or physical hazard present? If it’s not present now, can it become present later? Title 8, CCR Sections 5156, 5157 & 5158 A “performance” standard: Every confined space is unique and must be treated on a case-by-case basis Limited entrance and exit + potential atmospheric hazard or other hazards = “Permit Required Confined Space” Applies to most workplaces such as: ◦ ◦ ◦ ◦ ◦ ◦ Food production Chemical manufacturing Recycling operations Sewer plants Plating shops Amusement parks 19 Limited entrance and exit + hazardous atmosphere = “Confined Space” Applies to: ◦ ◦ ◦ ◦ ◦ ◦ Construction, Agriculture, Marine terminals Telecommunication manholes and unvented vaults Grain handling facilities, Natural gas utility operation within distribution and transmission facility vaults, 20 All Operations or Industries Except: Construction Agriculture Marine Terminals Telecommunication Manholes Grain Handling Facilities Natural Gas Utility Electric Utility 5158 Applies If a confined space has a hazardous atmosphere, or has the potential for a hazardous atmosphere, special confined space procedures must be taken Hazardous atmosphere includes: ◦ Oxygen deficiency or enrichment ◦ Flammable atmosphere ◦ Acutely toxic (Immediately Dangerous to Life or Health, or impairs ability to self-rescue) 22 Calibration Sample Locations 23 Specific Gravity Methane: 0.55 Ammonia: 0.59 Lighter than air gases Carbon Monoxide: 0.96 Nitrogen: 0.97 Air: 1.0 Hydrogen Sulfide: 1.2 Carbon Dioxide: 1.5 Gasoline: 3- 4 Jet Fuel, JP-8: 4.7 Heavier than air gases So...Must test at multiple levels within space! Use direct reading instruments with “real time” information on actual concentrations “Alarm only” devices which do not provide readings, are not considered acceptable direct reading instruments When testing for atmospheric hazards, test in the following order: Oxygen Combustible gases and vapors Toxic gases and vapors OR, test for all simultaneously Aviation fuel Sensor poisoning Calibration Employee medical exposure records Inerting of the space Product stored in a confined space: Gases released when cleaning. Materials absorbed into walls of confined space, even if space has been emptied or cleaned. Rotting organic materials and other decomposition 28 Work performed in a confined space: Welding, cutting, brazing, soldering Painting, scraping, sanding, degreasing Sealing, bonding, melting Connections or pipes to other spaces, or leakage from adjacent areas or soils. 29 Water or other materials in the space, such as sand or sugar, are an “engulfment” hazard A person may be trapped in the space due to sloping floor, converging walls, or piping or other obstacles Any other recognized serious safety hazard such as energy sources, mechanical hazards, steam, or heat 30 One or more of the following: following characteristics: Hazardous atmosphere Energy sources electrical <19.5% Oxygen mechanical > 23.5% Oxygen hydraulic >10% LEL (G/V) pneumatic, etc. =/> 10% LEL (Dust) IDLH Other steam corrosives, etc. >PEL (Acute) Engulfment Entrapment The action by which a person passes through an opening into a permit-required confined space, and includes ensuing work activities in that space Considered to have occurred as soon as any part of the entrant’s body breaks the plane of an opening into the space ◦ Post the space and prevent unauthorized entry ◦ Develop a program ◦ Assess the space prior to and continually during each entry, including atmospheric monitoring ◦ Train employees in required roles – entrant, attendant, supervisor, rescuers ◦ Isolate the space from other energy sources & materials ◦ Have effective rescue procedures 33 34 Non-entry rescue is preferred! You must utilize retrieval systems unless they would not be effective in the space In addition to the attendant, there must be at least one standby person at the site who is trained and immediately available to perform rescue and emergency services. Practice simulated rescue operations at least every 12 months in actual space or representative spaces based on opening size, configuration, and accessibility…. “CALL 911” IS NOT A RESCUE PLAN!!! 35 Evaluate and Posting §5157(c)(1) --- Written Procedures §5157(c)(4) §5158(c)(1)(A) Atmospheric Testing §5157(d)(5) §5158(d)(3) Ventilation §5157(c)(5)(B) §5158(d)(6) Rescue Procedures §5157(d)(9) §5158(c)(1) Training §5157(g)(1) §5158(c)(2) “Confined Spaces: Is it Safe to Enter?” [under revision] OSHA “Advisor” Federal Register Preamble Your Challenge 1)Use the SCORE CARD provided as a guide to the presentation. 2)Make an honest evaluation of your understanding of the topics discussed. 3)Focus your organization’s “improvements” on the issues scored “UNCOMFORTABLE”. The three conditions that define a confined space… 1. Large enough to enter, 2. Limited means of access 3. Not designed for continuous occupancy What must an employer develop as part of their Confined Space Entry program… An inventory of all spaces including the hazards, space classifications, equipment requirements, and rescue procedures Challenge #1 Can your employees identify a Confined Space (CS)? Whenever possible confined spaces should be identified using this method… “Labeling with a sign: “Confined PERMIT REQUIRED Space – Entry by Permit Only – SPACE (or NoCONFINED Unauthorized Personnel similar)” DO NOT ENTER Considered to be the most common and dangerous hazard in a confined space… “Atmosphere” If a confined space has an oxygen atmosphere between _____% and _____ %, it may be safe to enter. “19.5% - 23.5%” Atmospheric monitors display flammability as a percentage of this measurement… “Lower Explosive Limit or LEL” Challenge #2 Are there procedures and supervision in place to test the atmosphere prior to, and during, every Confined Space Entry (CSE)? Lake Hemet Water District CSE Fatality Other than atmosphere, name four other hazards may one face in a confined space….. “Engulfment, internal configuration, or job introduced hazards such as electrical, moving parts, pressure piping, welding, chemicals,….” The frequency with which gas monitors need to be calibrated… “According to the manufacturer’s recommendations” Appendix B of the Cal/OSHA confined space regulation states that the atmosphere should be tested every 4 feet because the potential for… “Stratification” or “Layering” Gas Stratification in Confined Spaces Floats CHECK Drifts ALL LEVELS Sinks The primary means of control used to maintain safe atmospheric conditions… “Mechanical Ventilation” Space Ventilation WIND POSITIVE PRESSURE One opening Lighter than air gases WIND NEGATIVE PRESSURE One opening Heavier than air gases This happens when ventilation air moves directly from the inlet to the exhaust outlet, without reaching the other areas of the space… “ Short-Circuiting” Space Ventilation WIND SHORT CIRCUTING Hose too short Air turns to path of least resistance WIND RECIRCULATING Fan intake in downwind Hazardous air is drawn into fan Challenge #3 Do your employees know how atmospheric control equipment works? The three types of confined space entries that may be performed… “Permit Required Entry” “Alternate Procedure “C(5)” Entry “ “Declassified / Non-Permit Required Entry” Which of the three types of confined spaces require atmospheric testing prior to entry? “ALL OF THEM!” The confined space regulation states that an entry supervisor must complete this document before anyone enters a confined space… “Confined Space Permit” Challenge #4 Can your employees determine the proper classification of a confined space? The four duty positions required by Cal/OSHA for a Permit-Required confined space entry… Entrant, Attendant, Supervisor, Rescue What every confined space position must know prior to an entry being made? The hazards and how to control or eliminate them Confined space entry has occurred when any part of the body… “Breaks the plane of a space” The action that must be taken if the attendant leaves the space… “Personnel must exit the space” The person who has overall responsibility for the entry… “Entry Supervisor” Who has the obligation to inform outside contractors about all known hazards and precautions normally taken when entering a confined space…. “Host Contractor/Host Agency” Challenge #5 Is your staff adequately trained for CSE operations? In the past, 50-60 % of fatalities in confined spaces were these types of persons… “Would be rescuers”? List at least five pieces of rescue equipment you would want to have available… “Tripod, Harness, Winch, Gas Monitor, Ventilator, SCBA, Annual Training….” Rescue teams must conduct a training drill at least once every… “12 months” Challenge #6 Do you, without a doubt, have a rescue capability for every CSE? Thank you for taking the Challenge Rate your organization’s CSE Program! INSTITUTE IMPROVEMENTS NOW!