Facility Safety Frequently Asked Questions
Q: What is a confined space?
A: A confined space is an area or location that meets all three of the following criteria:
- Is large enough and so configured that an employee can enter and perform assigned work
- Has limited or restricted means of entry or exit (e.g., tanks, vessels, silos, storage bins, hoppers, vaults and pits)
- Is not designed for continuous occupancy
Q: What is the difference between non-permit and permit-required confined spaces?
A: A non-permit confined space does not contain or, with respect to atmospheric hazards, have the potential to contain any hazard capable of causing death or serious physical harm.
A permit-required confined space (permit space) has one or more of the following characteristics:
- Contains or has the potential to contain a hazardous atmosphere
- Contains a material that has the potential for engulfing an entrant
- Has an internal configuration such that an entrant could be trapped or asphyxiated by inwardly converging walls or by a floor that slopes downward and tapers to a smaller cross-section
- Contains any other recognized serious safety or health hazard
Q: What air monitoring needs to be performed prior to entering a confined space?
A: At a minimum, oxygen and lower explosive limit (LEL) levels need to be monitored. If other toxins are suspected, then those levels also need to be monitored. Air within a confined space should be monitored prior to entry in the following order:
- Oxygen: Test for oxygen first to help ensure you get an accurate LEL reading. Most combustible gas meters are oxygen-dependent and will not provide reliable readings in an oxygen-deficient atmosphere. Oxygen levels should be from 19.5 to 23.5%.
- LEL: Test flammable gas and vapor levels due to the threat of fire or explosion, which can be immediate and life threatening.
- Toxic air contaminants: Test for impurities such as carbon monoxide (CO), hydrogen sulfide (H2S) and/or chlorine (Cl2).
Q: Must air monitoring of a confined space be ongoing if prior to entry the levels are acceptable?
A: 29 CFR 1910.146 (c)(5)(ii)(F) requires periodic testing as necessary to ensure the space is maintained within the limits of the acceptable entry conditions. This is critical. OSHA states that all permit space atmospheres are dynamic due to variables such as temperature, pressure, physical characteristics of the material posing the atmospheric hazard, variable efficiency of ventilation equipment and air delivery system, etc.
Q: Is a tripod/winch required if the confined space has a ladder? Does the depth of a confined space matter?
A: Upon initial inspection and evaluation of the confined space, if it is determined that a person could be injured in such a way that he/she would not be able to self-rescue (i.e., climbing a ladder), then a retrieval system is necessary. If entering a confined space where the potential for a fall could occur (i.e., a person could slip or lose control climbing a ladder), then fall protection must be included in the confined space entry system. A self-retracting lifeline with a winch retrieval system provides rescue retrieval for a worker entering a confined space should he/she become incapacitated.
It is the responsibility of the employer to evaluate each space separately, and develop entry and rescue procedures for each individual space, according to 29 CFR 1910.146(d)(3) and 29 CFR 1910.146(d)(4). Generally speaking, according to the Preamble to the Confined Space Standard, at a depth of five feet or greater, some form of mechanical means is needed to extract the worker from a vertical confined space.
Q: When is a two-way winch appropriate? How about a three-way winch?
A: A two-way winch/hoist is used to lower a worker into the confined space and raise the worker out of the confined space. This is the only option for persons who don’t have a primary means (i.e., a ladder) of entry or the primary means of entry is in questionable condition.
If there is a ladder that can be used to enter or exit the confined space and there is a potential for a fall, then employ a three-way winch system that incorporates a self-retracting lifeline (SRL) plus a manual-operated winch for use as a rescue winch if needed. The features of a three-way winch help protect users against falling with the SRL feature, and also serve the purpose to raise or lower an individual during a confined space rescue.
Q: What is required for retesting electrical insulated rubber gloves?
A: As noted in ATSM F496, gloves received by a distributor or customer that have not been put into service have a 12-month cycle from the original factory date stamp before they need to be retested. Once these gloves have been put into service, they can be used for up to six months. After the six-month cycle ends, a certified test lab must retest the gloves before they can be put back into service.
Q: How do I select and use the correct electrical rubber-insulating glove?
A: 29 CFR 1910.137 provides the design and in-service requirements for rubber-insulating gloves and other insulating products. Rubber-insulating gloves are categorized by their level of voltage protection and whether or not they are ozone resistant. Ozone resistance is covered by the “Type” designation: Type 1 gloves are not ozone resistant; Type II gloves are ozone resistant.
Voltage protection is broken down into the following classes:
- Class 00: Maximum use voltage of 500 volts AC/proof tested to 2500 volts AC
- Class 0: Maximum use voltage of 1000 volts AC/proof tested to 5000 volts AC
- Class 1: Maximum use voltage of 7500 volts AC/proof tested to 10,000 volts AC
- Class 2: Maximum use voltage of 17,000 volts AC/proof tested to 20,000 volts AC
- Class 3: Maximum use voltage of 26,500 volts AC/proof tested to 30,000 volts AC
- Class 4: Maximum use voltage of 36,000 volts AC/proof tested to 40,000 volts AC
Q: Is compliance with the NFPA 70E electrical standard mandatory?
A: No. NFPA 70E is a national consensus safety standard published by the National Fire Protection Association primarily to assist OSHA in preparing electrical safety standards. Federal OSHA has not incorporated it into the Code of Federal Regulations.
Q: How is the level of protection needed determined using NFPA 70E?
A: NFPA 70E was updated in 2015. There are now two basic methods that can be used to determine the level of protection needed:
- Table method
- Refer to NFPA 70E-2015 Article 130, Tables 130.4(D)(a) or (b) for shock risk assessment*
- Tables 130.7(C)(15)(A)(a) and 130.7(C)(15)(A)(b) or (B) for arc flash assessment
- Incident energy analysis method
- Use an industry accepted software program
- Use a consulting firm to complete the risk assessment according to Annex D of NFPA 70E-2015
*This method can only be used if the specific job task appears in the Table and meets the parameters listed. Otherwise, the incident energy must be calculated for that job task using NFPA 70E Annex D or methods 2a or 2b listed above.
Q: What components are required on labels for marking electrical hazards?
A: New equipment labeling requirements were added to the 2015 edition of NFPA 70E (130.5(B)). Employers are now required to field mark electrical equipment as part of their arc flash risk assessment. The label must contain the following:
- At least one of the following:
- Available incident energy and the corresponding distance
- Minimum arc rating of clothing
- Site-specific level of PPE
- PPE category in 130.7(C)(15) for equipment
- Nominal system voltage
- Arc flash boundary
It is important to note with the 2015 edition the information displayed on the label should only be present based on the method used to determine the PPE equipment. If the Table method is used, only the PPE category should appear (1-4). If incident energy analysis is used, the incident energy (cal/cm2) should appear. The key is both should not appear on the same label; one or the other must be displayed.
Q: Do flammable liquid storage cabinets have to be vented?
A: National Fire Protection Association (NFPA) 30, Chapter 4.3.4 says that a storage cabinet is not required to be vented for fire protection purposes, but vent openings should be sealed with the bungs supplied with the cabinet or with bungs specified by the cabinet manufacturer. However, if the storage cabinet is vented for any reason, the cabinet shall be vented directly to outdoors in such a manner that will not compromise the specified performance of the cabinet and is acceptable to the authority having jurisdiction.
Q: What is the difference between Type I and Type II safety cans?
A: A Type I safety can has one spout for both pouring and filling. A Type II safety can has two openings: one for pouring and one for filling.
Q: What is the difference between universal/chemical sorbents, petroleum/oil-only sorbents and maintenance sorbents?
A: Universal/chemical sorbents are designed to absorb any liquid. They absorb aggressive liquids such as acids and bases, plus non-aggressive liquids and solvents such as cleaners, water-based fluids, gasoline and alcohols. Petroleum/oil-only sorbents absorb oil and/or petroleum-based liquids. These sorbents are hydrophobic, meaning they won’t absorb water or water-based liquids. Maintenance sorbents absorb water- or oil-based nonaggressive liquids commonly found in manufacturing/maintenance operations, including coolants, lubricants, oils and cutting fluids.
Q: What does “means of egress” mean?
A: Means of egress is defined in NFPA 101 Life Safety Code as the way to exit a building or structure, especially during an emergency. OSHA requirements for exiting are found in 29 CFR, 1910.36 and 1910.37.
Q: Is there a requirement for specific exit sign colors?
A: There is no OSHA requirement for a specific color. NFPA 101 Section 18.104.22.168 states “signs must be of a distinctive color and design that is readily visible and shall contrast with decorations, interior finish and other signs.” Some states or local jurisdictions may require a certain color.
Q: When are “No Exit” signs required?
A: According to NFPA 101 Section 22.214.171.124, a “No Exit” sign is needed “where any door, passage or stairway that is neither an exit nor a way of exit access that is located or arranged so that it is likely to be mistaken for an exit shall be identified by a sign that reads: NO EXIT.”
Q: Why is it important to keep exits clear?
A: It’s important to keep paths, escape routes and aisles clear to ensure everyone can quickly exit the building. Clutter and debris might prohibit an exit door from opening to allow for escape.
Q: According to the NFPA Life Safety Code, what are the requirements for emergency lighting?
A: Emergency illumination, when required, must be provided for a minimum of 1.5 hours in the event of failure of normal lighting. The emergency lighting must be arranged to provide initial illumination of not less than an average of one foot-candle and a minimum at any point of 0.1 foot-candle measured along the path of egress at floor level. The maximum illumination at any one point can be no more than 40 times the minimum illumination at any one point to prevent excessively bright and dark spots and must be arranged to provide illumination automatically in the event of any interruption of normal lighting.
Q: Can a tagout procedure be used instead of a lockout when it’s impossible to lock out the equipment?
A: When it’s impossible to lock out or in industries where tag use has been well established and accepted as a recognized prohibitive to the operation of energy-isolating devices, a tagout procedure is acceptable.
Q: Does a machine that only requires the unit to be unplugged have to be locked out/tagged out?
A: No. The Control of Hazardous Energy (Lockout/Tagout) Standard, 29 CFR 1910.147, does not apply in situations where work on cord-and-plug-connected electric equipment is under the exclusive control of the employee servicing or maintaining the equipment.
Q: What is the difference between an authorized and an affected employee?
A: An authorized employee is one who performs lockout/tagout procedures in order to service or maintain equipment and machinery. An affected employee is one who works in or around the area in which the service or maintenance is being performed. Affected employees are not permitted to perform lockout/tagout procedures.
Q: Is a written lockout/tagout procedure required for every piece of equipment that may be locked or tagged out?
A: No. A written procedure is only required for each piece of equipment that involves a different lockout/tagout procedure.
Q: Are there other OSHA standards related to lockout/tagout besides 29 CFR 1910.147, the Control of Hazardous Energy (Lockout/Tagout) Standard?
A: Yes. OSHA has cited 29 CFR 1910.212, General Requirements for All Machines, and 29 CFR 1910.219, Mechanical Power Transmission Apparatus, for lack of lockout/tagout compliance. These two standards allow OSHA to issue double citations for noncompliance.
Q: What are the primary methods used to safeguard machines?
A: The two primary methods used to safeguard machines are guards and safeguarding devices. Guards provide physical barriers that prevent access to danger areas. Safeguarding devices either prevent or detect operator contact with the point of operation or stop potentially hazardous machine motion if any part of an individual’s body is within the hazardous portion of the machine.
Q: What does “guarded by location” mean?
A: Guarded by location means that the location of a component eliminates potential hazards. A component seven feet or more above a working surface is considered guarded by location.
Q: What are the three basic categories of dangerous moving parts that need guarding?
A: Dangerous moving parts that need guarding fall into three basic categories:
- Point of operation: The point at which work is performed on the material, such as cutting, shaping, boring or forming of stock.
- Power transmission: Any system that transmits energy to the machine part performing the work. These components include flywheels, pulleys, belts, connecting rods, couplings, cams, spindles, chains, cranks and gears.
- Moving parts: Parts of a machine that move while the machine is working. These can include reciprocating, rotating and transverse moving parts, plus feed mechanisms and auxiliary parts.
Q: What minimum requirements must machine guards meet to help protect workers from mechanical hazards?
A: Machine guards must meet the following minimum general requirements:
- Prevent contact between the worker and the machine. Guards must minimize the possibility of workers placing their hands or other body parts into the machine’s moving parts.
- Machine guards should be designed so that they are not easily tampered with or removed.
- Ensure that no objects can fall into moving parts.
- Create no new hazard. A machine guard defeats its purpose if it creates a hazard of its own.
- Create no interference. Any guard that limits or impedes workers from performing their job quickly and efficiently might soon be overridden or disregarded.
- Allow safe lubrication of the machine. It should be possible to lubricate the machine without removing the guard.
Q: What functions do safeguarding devices perform?
A: These devices control access to the point of operation and may replace or supplement guards. Safeguarding functions include:
- Stopping the machine if a hand or any part of the body is inadvertently placed in the danger area.
- Restraining or withdrawing the operator's hands from the danger area during operation.
- Requiring operators to use both hands on machine controls, helping keep both hands and body out of danger.
- Providing a barrier synchronized with the machine’s operating cycle to prevent entry to the danger area during the hazardous part of the cycle.
Q: Why are most machine guards yellow?
A: 29 CFR 1910.144(a)(3) states that yellow shall be the basic color for designating caution and for marking physical hazards such as: striking against, stumbling, falling, tripping and “caught in between.” If there is a portion of a machine that creates a particular hazard and the use of color-coding will enhance employee safety, then that part or hazard must be color-coded in compliance with 29 CFR 1910.144.
Q: What are the types and differences between the reflective materials used in traffic signs based on the Manual on Uniform Traffic Control Devices (MUTCD)?
A: Three different types of reflective material are referenced in the MUTCD:
- Engineer Grade (EG): Minimum level of reflectivity allowed by the MUTCD. Good for signs on side streets and parking lots.
- High-Intensity Prismatic (HIP): Recommended level of reflectivity for all roads and byways. It is three times more reflective than Engineer Grade.
- Diamond Grade (DG): Highest reflectivity level available. 14 times brighter than Engineer Grade.
Q: What is the expected outdoor lifespan for sign materials?
A: Aluminum and self-adhesive polyester signs have an approximate eight-year outdoor durability. Polystyrene has an approximate five-year outdoor durability. Fiberglass has an approximate 25-year outdoor durability.
Q: What is the difference between V-projecting and L-projecting signs? Are projecting signs printed on both sides?
A: V-projecting signs project from a wall in the shape of a triangle. The V shape allows signs to be seen and read when directly facing the wall the signs are on because the panels are angled to the sides. L-projecting signs project at a right angle to the wall they’re mounted on. That means you can’t view the sign information when approaching the sign wall directly. All projecting signs are printed on both sides of the sign.
Q: If a fall occurs when wearing a full-body fall protection harness and a six-foot fall arrest shock-absorbing lanyard, how many feet can the lanyard potentially deploy?
A: According to ANSI Z359.13, the six-foot shock-absorbing lanyard can deploy an additional four feet.
Q: Depending on the type of fall arrest system used, what are the important items to consider when calculating fall distance?
A: Five primary items that should be taken into consideration when calculating fall distance are lanyard length, harness stretch, deceleration distance, employee height and safety factor.
Q: Are you required to have a rescue and retrieval procedure as a part of a personal fall arrest program?
A: Yes. ANSI Z359.2 requires all worksites to have a rescue and retrieval plan/procedure. For instances where a fall may occur, suspension trauma is one of the most common occurrences that can be prevented if there is a prompt rescue/retrieval plan in place.
Q: What are the components of a Personal Fall Arrest System (PFAS)?
A: The three basic components (or the ABCs) of a PFAS are:
- Anchor/anchorage: Point of attachment
- Body support: Full-body fall protection harness
- Connector: Shock-absorbing lanyard or self-retracting lifeline
Q: What type of matting features should be considered when attempting to provide a safe, slip-resistant surface that may be exposed to liquids in a wet environment?
A: Choose slip-resistant mats pre-engineered with holes to help prevent liquids from building up on the matting surface. The holes provide an avenue for liquids to drain through.
Q: Are there OSHA standards specifically addressing workplace violence or security?
A: No OSHA standards specifically address workplace violence or security. Employers who fail to provide a work environment that protects workers can be sited under the General Duty Clause found in Section 5, paragraph (a)(1) of the Occupational Safety and Health Act:
“Each employer shall furnish to each of his employees employment and a place of employment which are free from recognized hazards that are causing or are likely to cause death or serious physical harm to his employees.”
Q: What steps must employers take to secure their workplace?
A: Where appropriate, employers should consider installing perimeter fencing, video surveillance, extra lighting and alarm systems. Minimize access by outsiders through the use of identification badges, electronic keys and security doors. Doors should be locked or at least monitored so the presence of any entrants can be detected and controlled. Employers may also want to equip their employees with cellular phones or two-way radios to help maintain contact.
Q: What determines the design and level of sophistication of a company’s security system?
A: A security system’s design and level of sophistication is usually determined by what is being protected. The best systems are designed to help protect people, property and the environment.
Q: What is a security mirror?
A: Security mirrors are devices used for monitoring and surveillance purposes. They allow sight in hard-to-see areas, are typically a form of convex mirrors that provide a larger overview of an area and are available in unbreakable lens materials.