Confined Space Entry Issues

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Confined Space Entry Issues

• Craig Schroll, CSP, CUSA
• FIRECON
• Craig_at_FIRECON.com

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Overview of Program

• Overall confined space issues
• Ways to address these issues
• Strategies for entries
• Types of confined spaces
• Hot work

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The Problem

• We continue to kill injure people
• Lack of warning
• Lucky versus smart

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Compliance

• Remember that compliance is the price of
  admission not the achievement of excellence.

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OSHA Information

• Standard
• Compliance Instruction
• Interpretive letters
• All are available on the web site www.osha.gov

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Other Standards

• ANSI Z117
• NFPA
• API
• International
• Australian
• United Kingdom
• European Union

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Hazard Exposure Risk
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Risk Assessment
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Example of a Risk Assessment Matrix Example of a Risk Assessment Matrix Example of a Risk Assessment Matrix Example of a Risk Assessment Matrix Example of a Risk Assessment Matrix
?- Severity of Injury or Illness Consequence and Remedial Action --? ?- Severity of Injury or Illness Consequence and Remedial Action --? ?- Severity of Injury or Illness Consequence and Remedial Action --? ?- Severity of Injury or Illness Consequence and Remedial Action --?
Likelihood of OCCURRENCE or EXPOSURE For selected Unit of Time or Activity CATASTROPHIC Death or permanent total disability CRITICAL Disability in excess of 3 months MARGINAL Minor injury, lost workday accident NEGLIGIBLE First Aid or Minor Medical Treatment
Frequent Likely to Occur Repeatedly HIGH Operation not permissible HIGH Operation not permissible SERIOUS High Priority Remedial action MEDIUM Take Remedial action at appropriate time
Probable Likely to occur several times HIGH Operation not permissible HIGH Operation not permissible SERIOUS High Priority Remedial action MEDIUM Take Remedial action at appropriate time
Occasional Likely to occur sometime HIGH Operation not permissible SERIOUS High Priority Remedial action MEDIUM Take Remedial action at appropriate time LOW Risk Acceptable Remedial Action Discretionary
Remote Not likely to occur SERIOUS High Priority Remedial action MEDIUM Take Remedial action at appropriate time MEDIUM Take Remedial action at appropriate time LOW Risk Acceptable Remedial Action Discretionary
Improbable Very unlikely may assume exposure will not happen MEDIUM Take Remedial action at appropriate time LOW Risk Acceptable Remedial Action Discretionary LOW Risk Acceptable Remedial Action Discretionary LOW Risk Acceptable Remedial Action Discretionary
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Design

• Eliminate the confined space
• Eliminate the need for entry
• Eliminate hazards
• Minimize risk

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Eliminate Confined Space

• Change access
• Design in hazard elimination

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Eliminate Need for Entry

• Design space/process to not require internal
  maintenance
• Access ports
• Pull out panels
• Pull up equipment i.e. pumps

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Eliminate Hazards

• Design confined space with hazard elimination in
  mind
• For example, improved isolation systems

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Minimize Risk

• Reduce number of entries
• Reduce duration of entries
• Reduce number of personnel

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Types of Spaces

• Confined space
• Permit-required confined space
• Reclassified space
• Space eligible for alternate procedures
• Non-permit space

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Confined Space
Large enough to bodily enter
A space must have all three characteristics to
meet the confined space definition.
Limited or restricted access
Not designed for continuous occupancy
Confined Space
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Permit-Required Confined Space
Has or has the potential to contain
a hazardous atmosphere?

• Oxygen deficient (19.5 or less)
• Oxygen enriched (23.5 or more)
• Flammable (10 LEL or more)
• Toxic (above PEL)
• Combustible dust (at or above LEL)
• Other IDLH

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Permit-Required Confined Space
Has the potential for engulfment?
Engulfment may occur by materials being
introduced or removed from the space or by an
entrant being drawn down into materials.
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Permit-Required Confined Space
Has an internal configuration such that an
entrant could be trapped or asphyxiated by
inwardly converging walls or by a floor which
slopes downward and tapers to a smaller
crosssection.
Internal configuration hazard?
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Permit-Required Confined Space
Any other recognized serious safety or
health hazard?
Other hazards capable of causing death, serious
physical harm, or interfering with the entrants
ability to escape.
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Non-Permit Confined Space

• Does not contain or, have potential to contain
  any hazard capable of causing death or serious
  physical harm.

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Reclassification

• No atmospheric hazards
• Eliminate all hazards
• Document reclassification
• Certification available to employees

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Elimination versus Control

• Elimination means hazard cannot return during
  entry operation.
• Control means that return of hazard is possible
  if control measures fail.

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Alternate Procedures

• Atmosphere is only hazard
• Ventilation can make space safe
• Monitoring data
• Data available to employee

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Alternate Procedures

• Safe to remove entry cover
• Guard opening
• Test atmosphere
• Continuous ventilation
• Periodic atmospheric testing
• Written certification

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Examples
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Recognition

• Recognition of an area as a confined space is a
  critical first step to safe operations.

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Confined Space Hazards

• Atmospheric
• Content
• Potential Energy
• Environment in Space
• Configuration of Space
• Nature of Work
• External
• Miscellaneous

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Sources of Hazards

• Inside the space
• External to the space
• From the work

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General Requirements

• Evaluate workplace
• Inform employees
• Develop Implement written program

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Programs

• General policy
• Specific guidelines
• Training requirements
• Permit system

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Programs

• Supervisors role
• Employees role
• Contractor procedures
• Emergency procedures
• Monitoring system

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Confined Space Policy Procedures

• Simple
• Brief
• Useful
• Clearly communicated
• Consistently enforced

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Evaluating Your Confined Spaces
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Confined Space Inventory

• Survey entire facility
• Identify all potential CS
• Classify spaces
• Maintain documentation

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Confined Space Evaluation

• Evaluate prior to entry (OSHA)
• Evaluate initially from a practical perspective
• Equipment
• Procedures
• Training

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Confined Space Evaluation

• Must be conducted
• Maintain documentation
• May be electronic
• May be a form
• Actually use the information
• Update at least annually
• Teach people to do review prior to entries

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Safe System of Work

• Risk assessment
• Hazard evaluation
• Work process that eliminates hazards when
  possible and controls them when not
• Safe system of work
• Catch variations

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Planning Entry

• Is entry necessary?
• Work plan
• Space preparation
• Permit
• Briefing

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Briefing

• Hazards
• Permit items
• Job tasks
• Emergency procedures

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Job Surveys

• Inspect area
• Review work
• Confirm safety issues
• Review preparations
• Check PPE
• Check equipment supplies

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Entry Supervisors

• Role is much more than a signature on a form
• Actually evaluate and resolve hazards

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Training

• Establish and maintain competence
• All personnel involved in entries must be
  competent

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Program Audit

• Review permits
• Update surveys
• Update policies procedures
• Update training
• Review equipment condition needs
• Job site surveys

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Hot Work

• Numerous safety health issues
• A few specific to confined space work
• Ventilation
• Introduction of ignition source
• Heating can contribute to release of contaminants

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