Confined Space Entry
29 CFR 1910.146
Mary Bauer
Compliance Assistance Specialist
3rd Annual Safety Day
WITC Rice Lake, WI
3-15-2012
Bios & Contacts
• Mary Bauer – Eau Claire Area OSHA Office
Compliance Assistance Specialist (CAS)
1310 West Clairemont Ave
Eau Claire, WI 54701
715-832-9019
bauer.mary@dol.gov
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Compliance Officer for 20 Years
CAS for 6 Years
All in Eau Claire Area Office
CIH: Certified Industrial Hygienist
CSP: Certified Safety Professional
DISCLAIMER
• GIVE YOU AN IDEA OF
REQUIREMENTS – NOT A COMPLETE
TRAINING SESSION
• Discussed having a more extensive
session in the future if there is more
interest.
Objectives
Everyone should be aware of:
• Confined Space
• Rescue Requirements
CONFINED SPACE STATISTICS
• In All Deaths Last Year (139), There Were
No Detectors Nor Ventilation
• 65% Of All Confined Space Fatalities Due
To Hazardous Atmosphere
• 33% Of All Deaths Were Supervisors
• 60% Were Rescuers
• 25% Of Spaces Were Toxic Before Entry
*****1995 Statistics*****
How to Identify Confined
Spaces
• Limited Openings for Entry and Exit
AND
• Large enough and so configured to allow
employee to enter and perform work AND
• Not Designed for Continuous Occupancy
A space must meet all three of these criteria
in order to be classified as a confined space.
Limited or Restricted Means
for Entry or Exit - Assessment
Is entry/exit or rescue slowed down or impeded by:
• Use of hands (crawling, climbing)
• Contort body
3. Physical Obstructions
4. Posture
Large enough and so
configured to allow employee
to enter and perform work.
IS NOT DESIGNED FOR
CONTINUOUS EMPLOYEE
OCCUPANCY
Letter of Interpretation 12/20/1994
Mr. Edward A. Donoghue
The intent behind this
confined space definition
component, "Is not
designed for continuous
employee occupancy", is
to focus on the design of
the space, which is the
key to whether a human
can occupy the space,
under normal operating
conditions.
Definitions (continued)
• Lockout - The placement of a lockout device
on an energy isolating device, in accordance
with an established procedure, ensuring that
the device and the equipment being
controlled cannot be operated until the
lockout device is removed
• Lockout device - A device that utilizes a
positive means, such as a lock, to hold an
energy isolating device in a safe position and
prevent energization
1910.147(b)
Permit-Required Confined Space
(Permit Space)
• A confined space is a
permit space if it has
one or more of the four
specific characteristics
that make the space
potentially hazardous
• Any one of these
characteristics makes a
confined space a permit
space
Permit Space
Characteristics
• Hazardous atmosphere
• Engulfing materials
• Inwardly converging
walls, or
• Other serious hazards
Classifying Work Space
* Space large enough to enter &;
* Limited or Restricted entry or exit &;
* Not designed for continuous worker
occupancy.
YES
NO
Not a confined Space
Confined Space
Hazardous Atmosphere
PRCS
YES
Or
Engulfment Hazard
Or
Configuration Hazard
Or
Any other recognized
serious hazard
Non
NO
Permit
Required
Space
Engulfment Hazards
• Loose, granular materials stored in bins
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and hoppers - grain, sand, coal, sawdust,
etc.
Crusting and bridging below a worker.
Flooding of confined space.
Water or sewage flow.
Force Required to Extract a
Victim from Grain
165 pound person
Inwardly Converging Walls
• It’s possible to slide down the
sloping walls, become stuck,
and die of pressure on the
chest that makes breathing
impossible
• Examples include: hoppers for
air pollution dust collectors
(i.e., bag houses, electrostatic
precipitators, etc.), bottommounted unloading chutes for
railcars and trucks, cyclones,
and funnels
Entrapment: Cone/Tapered
Not covered under flat bin entry
Cause of Death: Positional Asphyxiation
Any Other Recognized Serious
Safety or Health Hazards
Electrical equipment
Mechanical equipment
Visibility - lighting
Biohazards
Claustrophobia
Noise
Radiation
Temperature
Options for Entry: No Entry
• Before looking at entry
options, first determine if
there is a way to avoid entry
entirely
• For example, use gauges,
flow meters, remote
cameras, or binoculars to
monitor conditions from
outside the space
• This worker is vacuuming out
the contents of a tank, rather
than entering to shovel out
the waste
Options for Entering
Permit Spaces
1. Reclassification – (c)(7)
2. Alternate Entry – (c)(5)
3. Permit Space Entry – (c)(4)
Minimizing the amount of regulation that
applies to spaces whose hazards have been
eliminated encourages employers to actually
remove all hazards from permit spaces.
Options for Entering
Permit Spaces
1. Reclassification – (c)(7)
2. Alternate Entry – (c)(5)
3. Permit Space Entry – (c)(4)
Alternate entry procedures are allowed if the
employer can demonstrate that the only hazard
posed by the permit space is an actual or a
potential hazardous atmosphere that can be
controlled by continuous forced air ventilation.
Options for Entering
Permit Spaces
1. Reclassification – (c)(7)
2. Alternate Entry – (c)(5)
3. Permit Space Entry – (c)(4)
Permit space entry requires a detailed
written program.
Elimination
• A permit space can be reclassified as a
non-permit space if:
Categories of
Reclassification
– It contains no actual or potential
atmospheric hazards, and
• (c)(7)(i), and
– All other hazards can be eliminated
• (c)(7)(ii)
(i.e., no ongoing measures are
required to keep the space safe)
• This reclassification is valid only as long
as the hazards are eliminated
• If the hazards can be eliminated, the
standard allows two categories of
reclassification
(c)(7)(i) Reclassification
• Applies only to permit spaces:
– That contain no actual or
potential atmospheric hazards,
and
– From which all hazards can be
eliminated without entering the
space
• In this example, this mixer has
been locked out before entering it
for service or maintenance
– TASK DEPENDENT!!!!
Certification
• Paragraph (c)(7)(iii) requires that
if a space is reclassified, the
employer must:
– certify that all hazards in the
space have been eliminated,
and
– provide that certification to all
employees entering that space
• The reclassification is valid only
as long as the hazards remain
eliminated
Multi-Employer Provision
• When an employer (host
employer) arranges to
have a contractor perform
permit space work, both
employers must follow the
requirements of the
standard
• Paragraph (c)(8) lists five
duties that the host
employer has toward the
contractor
Host Employer
to Contractor
• Inform of permit spaces
• Apprise of hazards
• Apprise of precautions
and procedures
• Coordinate entry
operations
• Debrief
Entry Permit Requirements
• Name and phone numbers of rescue and
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emergency services.
Communication procedures.
Special equipment and procedures.
– Personal protective equipment.
– Alarm procedures.
– Rescue equipment.
– Respirators.
Rescue
Rescue and Emergency Procedures
Types of Rescue
There are three types
of rescue:
• Self-rescue (escape)
• Non-entry rescue
• Entry rescue
Rescue Team Employer’s
Responsibilities
• Provide rescue teams with PPE and
training to conduct rescues safely
[(k)(2)(i)]
• Train rescue teams to perform
assigned rescue duties and establish
rescue teams’ proficiency as
authorized entrants [(k)(2)(ii)]
• Train rescue teams in basic first-aid
and CPR [(k)(2)(iii)]
• Ensure that rescue teams practice at
least once every 12 months [(k)(2)(iv)]
Three options to permit-required confined
space rescue
Read Appendix FFor Clarification
1. Arrange for rescue service
from an outside source.
2. Arrange for your own
employees to provide rescue
3. Provide for non-entry
rescue
Response Vs Rescue Time...
• (1) React Time:
Attendant recognizes that the Entrant
has a problem.
• (2) Contact Time:
Attendant contacts the Rescue Service.
• (3) Response Time:
Rescue Service arrives at the scene.
Rescue Vs Response Time...
• (4) Assessment Time:
Size-up and strategy determination.
• (5) Preparation Time:
Rescue equipment set-up.
• (6) Rescue Time:
Reaching, treating, packaging, and
evacuation of the victim.
OSHA requires 3-5 minutes
For IDLH conditions
Non-Entry Rescue
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Rescue must be onsite
Only if it can be done safely
Mechanical retrieval over 5 feet
Not use wristlets unless justified
Timely Response, Training, and
Equipment
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Rescue
Retrieval
Ventilation & Atmospheric Monitoring
Barriers
Access/Egress (ladders, etc...)
Lighting
Communication
Timely Response, Training, and
Equipment
• Documented training by each team
member via simulated rescues in every
type of confined space (Rescue training)
• Authorized Entrant/Attendant
• First Aid & CPR (Blood-borne pathogens)
• Haz Com, PPE, Respiratory, Lockout, PSM
• Equipment training (Fall Protection)
Training and Education
• All workers who must enter confined
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spaces
All attendants and rescue team members.
Prior to initial work assignment.
Retraining:
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Job duties change.
Change in permit-space program.
New hazards are present.
Job performance indicates deficiencies.
QUESTIONS
Disclaimer
•
This information has been developed by an OSHA Compliance Assistance
Specialist and is intended to assist employers, workers, and others as they
strive to improve workplace health and safety. While we attempt to
thoroughly address specific topics or hazards, it is not possible to include
discussion of everything necessary to ensure a healthy and safe working
environment in a presentation of this nature. Thus, this information must be
understood as a tool for addressing workplace hazards, rather than an
exhaustive statement of an employer’s legal obligations, which are defined
by statute, regulations, and standards. Likewise, to the extent that this
information references practices or procedures that may enhance health or
safety, but which are not required by a statute, regulation, or standard, it
cannot, and does not, create additional legal obligations. Finally, over time,
OSHA may modify rules and interpretations in light of new technology,
information, or circumstances; to keep apprised of such developments, or to
review information on a wide range of occupational safety and health topics,
you can visit OSHA’s website at www.osha.gov.