Confined Space Hazards

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Confined Space Hazards
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Basic Requirements

• 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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Reasons for Entry- and related deaths
Construction 5 Inspection 10
Repair/Maintenance 40 Rescue 36
Retrieve Object 3 Dislodge material 5
Unknown 1
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Cal-OSHA Confined Space Special Emphasis Program

• 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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Cal-OSHA Confined Space Special Emphasis Program

• For ALL Inspections
• Ask ER if they have any confined spaces
• Look for Confined Spaces during walk-around
• Identify hazards
• Verify that spaces are labeled
• Ask ER if anyone enters spaces and how spaces are
  maintained cleaned
• Interview employees entering spaces

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Cal-OSHA Confined Space Special Emphasis Program

• 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

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The Problem

• 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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The Solution

• 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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Look for spaces that are

• 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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Typical Examples of Confined Spaces

• Manure pits
• Storage bins
• Double hulls
• Pumping stations
• Pits, sumps
• Vessels
• Manholes
• Water reservoirs

• Tanks
• Boilers
• Vats
• Kilns
• Vaults
• Silos
• Pipelines
• Sewers

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Questions to Ask

• 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 persons 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 self-rescue or make
  rescue more difficult?

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Questions to Ask

• Is an acutely hazardous atmosphere or physical
  hazard present?
• If its not present now, can it become present
  later?

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Confined Spaces
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
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General Industry Permit Required Confined Space
Section 5157

• 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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Other Industries -Section 5158

• 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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5157 Confined Spaces

• All Operations or Industries Except
• Construction
• Agriculture
• Marine Terminals
• Telecommunication Manholes
• Grain Handling Facilities
• Natural Gas Utility
• Electric Utility

5158 Applies
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Hazardous Atmospheres

• 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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Air Monitoring

• Calibration
• Sample Locations

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Testing The Atmosphere
Specific Gravity
Methane 0.55 Ammonia
0.59 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
Lighter than air gases
Heavier than air gases
So...Must test at multiple levels within space!
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Type of Instruments

• 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

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Confined SpaceAtmospheric Monitoring
When testing for atmospheric hazards, test in the
following order

• Oxygen
• Combustible gases and vapors
• Toxic gases and vapors

OR, test for all simultaneously
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Confined SpaceAtmospheric Monitoring other
issues

• Aviation fuel
• Sensor poisoning
• Calibration
• Employee medical exposure records

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Causes of Hazardous Atmospheres

• 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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Causes of Hazardous Atmospheres

• 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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In most industries confined space precautions
must also be taken if

• 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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5157 Permit-Required Confined Space
One or more of the following
following characteristics

• Hazardous atmosphere

• Energy sources

• electrical
• mechanical
• hydraulic
• pneumatic, etc.

• lt19.5 Oxygen
• gt 23.5 Oxygen
• gt10 LEL (G/V)
• /gt 10 LEL (Dust)
• IDLH
• gtPEL (Acute)

• Other

• steam
• corrosives, etc.

• Engulfment
• Entrapment

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Entry

• 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 entrants body breaks the plane of an
  opening into the space

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If confined spaces are to be entered the employer
must

• 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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Rescue Emergency Services

• 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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Commonly Cited Sections
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)
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Reference

• Confined Spaces Is it Safe to Enter?
• under revision
• OSHA Advisor
• Federal Register Preamble