The Elements of Confined Space Success
Never be afraid to go to the next highest level of compliance for your employees. They'll thank you for it.
"Rescue 7, Squad 2. Men down, unknown causes, at the industrial complex at North 10th Street and Bay Ave. Caller states man was entering an access shaft into a tunnel when he went unconscious and fell. An employee on-scene attempted rescue and is also believed unconscious. Area has been cordoned off. Contact center on arrival."
Does this sound familiar? Events like this happen all too frequently among general industry employers across the country each year. An employee enters a hazardous confined space. Something goes wrong. Seeing a co-worker in distress, another employee attempts rescue under the same conditions, and is now an additional part of the problem.
OSHA's rules for Permit Required Confined Space Entry can be found in 29 CFR 1910.146. This standard does not apply to construction, shipyard, or agricultural employment. Looking at this globally, OSHA's standard is relatively simple. It's based on the premise that bad things can happen to good people if employees have to enter spaces where hazards exist, and therefore the employer needs to assess those hazards and either make them go away, rendering the area safe, or initiate a higher level of action and protection. And, even if those requirements are satisfied, the employer must be ever vigilant to look for changing conditions while the employees are in harms way.
Because entry into spaces has been "OK"" in the past does not necessarily mean conditions haven't changed since last entry. Therefore, start with a clean sheet of paper with every entry.
Let's look at some of the specifics of the rule.
Some Key Definitions
- A space that is large enough and so configured that an employee can bodily enter and perform assigned work, and;
- Has limited or restricted means for entry or exit (for example, tanks, vessels, silos, storage bins, shafts, etc.), and;
- Is not designed for continuous human occupancy.
Permit required confined space: A confined space that 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 which slopes downward and tapers to a smaller cross section; or,
- Contains any other recognized serious safety or health hazards.
Entry permit: That document provided by the employer to allow and control entry into a permit space. It contains information pertaining to the space to be entered, the purpose of the entry, the date and the authorized duration of the entry permit, the authorized entrants within the permit space, who the attendants are, who the entry supervisor is, what hazards have been assessed, how those hazards were isolated or eliminated, and other detailed information to include the acceptable entry conditions, rescue criteria, communications procedures, PPE, etc. Consult 1910.146(f) for a complete listing of the entry permit requirements.
The definition of a permit required confined space often uses the wording, "has the potential to. . . ." This implies employers must look beyond the obvious in assessing spaces to be entered, and they must consider worst-case scenarios. Therefore, a key provision of the standard is that the employers must perform audits and hazard assessments to determine that which must be either eliminated or reduced to acceptable levels.
Because entry into spaces has been "OK" in the past does not necessarily mean conditions haven't changed since last entry. Therefore, start with a clean sheet of paper with every entry.
The employer must then notify all employees of the dangers of the permit space by posting signage designating the space as hazardous. An example would be a sign stating, "DANGER--PERMIT-REQUIRED CONFINED SPACE. DO NOT ENTER," which typically would suffice. If employees will not be entering the space, the employer must take steps to prevent unauthorized entry. If employees will need to enter permit spaces to perform work, then the employer must develop and implement a written program that complies with the standard. It must be available for inspection by employees and their authorized representatives. Employees need to be trained to a competence level (encompassing knowledge, skills, and understanding) before assuming permit space entry responsibilities.
The area is assessed, and hazards are identified. (If the permitted space poses no actual or potential atmospheric hazards, and if all hazards can be eliminated without making entry, then the space can be reclassified as a non-permitted confined space. However, it is imperative to ensure that all atmospheric hazards remain eliminated.) The entry permit is prepared, in accordance with the standard and your site-specific requirements and signed by the supervisor authorizing entry.
The permit will clearly state the methods used to isolate the permit space and how the hazards were eliminated or reduced. It will also contain information on the equipment used to perform testing, personal protective equipment, communications equipment, alarm systems, and rescue and emergency services' availability and means to contact them. The authorized entrants (or their authorized representatives) have the opportunity to observe the testing and monitoring of the spaces. They also have the right to question the validity of test results and to request retesting. Permits are issued for a specific time period, and may not exceed the time necessary to complete the job identified on the permit.
Once entry is established, the space must be continuously monitored for changing conditions. OSHA has determined that asphyxiation is the main cause of deaths and serious injuries, through asphyxiating, toxic, or flammable and explosive atmospheres, but attendants and supervisors must be on guard for engulfment and entrapment hazards, as well. For example, can a machine/system downstream of the entry activate, harming the entrants? Therefore, has the area been secured through a lockout/tagout program?
Once the job is complete, the permit is cancelled. Employers must retain cancelled permits for one year so they may be reviewed and the permit required confined space program can be modified and improved as necessary. Any problem encountered during the entry must be listed on the permit. Additionally, during the entry the entry supervisor may cancel the permit at any time an unsafe or hazardous condition develops.
Employers are required to train employees to a competence level; that is, they have the knowledge, skills, and understanding to safely perform the task at hand.
The authorized entrants (or their authorized representatives) have the opportunity to observe the testing and monitoring of the spaces. They also have the right to question the validity of test results and to request retesting.
We often perform knowledge training and usually verify skills, but do we always pay attention to the employee's level of understanding? As an employer, ask yourself, is this employee accountable--i.e., does he not only know what to do, but what not to do? While in a permit space, the employees may be tasked with making critical decisions without having their usual decision-maker, the supervisor, standing alongside. While the process mandates that communications methods be available for just this reason, delays, line-of-sight issues, and interference with electronic devices, to name a few, all serve to highlight this aspect.
Employees must be trained before first being assigned to the job, whenever there is a change in permit space operations that imposes new hazards, and whenever the employer believes the employee's level of training is inadequate. Training must be documented via a written certification that includes the employee's name, the signatures or initials of trainers, and the dates of training.
Rescue and Emergency Services
OSHA states an employer must evaluate the ability of rescue providers to render aid, and 1910.146(k) gives specific guidance on what to look for in a rescue service. Some employers have additional trained employees available to perform rescue and emergency service tasks, and they have the ability to practice and train within the actual confined spaces that exist in the workplace. However, let's assume an employer chooses to utilize a local community rescue service, such as a fire department.
These departments will have well-trained and dedicated members who may be trained under generic confined space rescue scenarios. As the employer, and thus responsible for your employees' health and safety, have you made provisions for this local department to pre-plan and assess your workplace, and have its personnel had the ability to train with your employees? This excellent training method instills confidence and rapport with those who will be summoned.
Another point to consider and plan for: If you choose a local, community-based rescue service and they are volunteers, will they be available if you have an emergency that occurs during their usual working day? This could mean that, while they may be highly trained and motivated, they just might not be able to make it in time in the event of an emergency.
Thorough workplace assessments of permit required confined spaces, a comprehensive, site-specific written program, detailed training for all employees, a good permit process, and constant review of the entry procedures are all elements of OSHA's Permit Required Confined Space Entry standard. Take the time to examine OSHA's standard and never be afraid to go to the next highest level of compliance for your employees. They'll thank you for it.
This article originally appeared in the August 2003 issue of Occupational Health & Safety.