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

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.
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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
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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
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 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.
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 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
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 Tanks
 Boilers
 Vats
 Kilns
 Vaults
 Silos
 Pipelines
 Sewers
 Manure
pits
 Storage bins
 Double hulls
 Pumping stations
 Pits, sumps
 Vessels
 Manholes
 Water reservoirs
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
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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
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

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,
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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)
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Calibration
 Sample Locations

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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
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
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.
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


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
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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
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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!!!
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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!