12/1/15
Quick Tips #115
Confined spaces in the workplace can pose serious physical hazards to employees. Employees can become entrapped or engulfed within a confined space and/or they could be exposed to dangerous atmospheric conditions. All of which could result in tragic consequences.
The Occupational Safety and Health Administration (OSHA) defines a confined space as one that meets all three of the following conditions 29 Code of Federal Regulations (CFR) 1910.146(b):
Examples of confined spaces include underground vaults, tanks, storage bins, manholes, pits, silos and pipelines.
According to OSHA, a permit-required confined space is a space that has one or more of the following characteristics:
A non-permit required confined space is a space that does not contain or, with respect to atmospheric hazards, have the potential to contain any hazard capable of causing death or serious physical harm.
There are several steps an employer should follow when beginning a confined space program. The first is to evaluate the workplace and determine whether it contains permit-required confined spaces as defined by OSHA. If it is determined that there are permit-required confined spaces, the employer must inform all exposed employees of the dangers by posting signs or some other equally effective means. Signs should read: "DANGER--PERMIT-REQUIRED CONFINED SPACE, DO NOT ENTER" or other similar language.
The next decision the employer must make is whether or not the confined space should be entered:
The Confined Space standard requires the employer’s written program to:
OSHA also requires training to ensure that employees involved in confined space work can perform their job functions safely before the initial work begins. Additional training is required when:
After completion of training, the employer must keep a record of employee training and make it available for inspection by employees and their authorized representatives. The record must include the employee's name, the trainer's signature or initials and dates of the training.
This training must cover specific requirements for the authorized entrant, the attendant and the entry supervisor.
Authorized Entrant responsibilities:
Attendant duties:
Entry Supervisor responsibilities:
When an employer has designated a rescue and emergency service to perform confined space rescue, the employer is responsible for:
: Non-mandatory Appendix F— Rescue team or rescue service evaluation criteria has been added to 29 CFR 1910.146 to assist employers in their evaluation of rescue and emergency services.
According to OSHA, employers whose employees will perform rescue duties in confined spaces are responsible for:
To facilitate non-entry rescue, retrieval systems or methods must be used whenever an authorized entrant enters a permit space, unless the retrieval equipment would increase the overall risk of entry or would not contribute to the rescue of the entrant 29 CFR 1910.146 (k)(3). Each authorized entrant must use a chest or full-body harness with a retrieval line attached at the center of the entrant's back near shoulder level, above the entrant's head, or at another point which the employer can establish presents a profile small enough for the successful removal of the entrant. Wristlets may be used in lieu of the chest or full-body harness if the employer can demonstrate that the use of a chest or full-body harness is infeasible or creates a greater hazard and that the use of wristlets is the safest and most effective alternative. The other end of the retrieval line shall be attached to a mechanical device or fixed point outside the space so the rescue can begin as soon as the rescuer becomes aware that rescue is necessary. If the space is vertical and more than 5' deep, a mechanical device for removing the entrant must be available for use 29 CFR 1910.146(k)(3)(ii).
Employers should obtain a copy of 29 CFR 1910.146 to ensure that they are in full compliance with the standard. There are also several appendices to the standard that provide information and non-mandatory guidelines to assist employers and employees in meeting the appropriate requirements.
Q: What air monitoring needs to be performed prior to entering a confined space?
A: Air monitoring should be performed prior to entry. At a minimum, oxygen and lower explosive limits (LEL) need to be monitored. If other toxins are suspected, then those levels also need to be monitored. Air should be monitored in the following order:
Q: What is an immediately dangerous to life and health (IDLH) atmosphere?
A: IDLH is an atmospheric concentration of any toxic, corrosive or asphyxiant substance that poses an immediate threat to life or would cause irreversible or delayed adverse health effects or that would interfere with an individual’s ability to escape unaided from a permit space.
Q: If I perform air monitoring prior to entry and my readings are OK, do I need to continue monitoring while I'm in the confined space?
A: 29 CFR 1910.146 paragraph (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. The employer must determine and document on an individual permit space basis what the frequency of testing is and under what conditions the verification testing is done.
Q: What is the difference between a two-way and a three-way confined space retrieval winch?
A: The two-way winch is used for hoisting people and/or equipment into or out of the confined space. A three- way winch, which has a braking mechanism, is used for fall protection. The only time a three-way winch should be used to hoist someone is if a fall has occurred and a rescue needs to be performed. Otherwise, the two-way winch should be used so the teeth on the three-way winch do not become worn and nonfunctional should a rescue need to be performed.
OSHA Confined Space Standard, 29 CFR 1910.146
The information contained in this article is intended for general information purposes only and is based on information available as of the initial date of publication. No representation is made that the information or references are complete or remain current. This article is not a substitute for review of current applicable government regulations, industry standards, or other standards specific to your business and/or activities and should not be construed as legal advice or opinion. Readers with specific questions should refer to the applicable standards or consult with an attorney.
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