Confined Space Entry, Part 3

Workers who enter confined spaces are at extreme risk, and they have a right to their "Bill of Rights."

MANY decisions to enter confined spaces are made without recognition of the expected danger. Lack of knowledge, carelessness, and simple acceptance of the hazard are the main reasons. The decisions to enter are made in spite of all efforts to provide hazard awareness and safety training.

Individuals who act alone--either because "it is my job" or because "I had to do it"--are responsible. When problems develop, it is usually too late. Accident investigations always conclude that "an ounce of prevention" could have averted the tragedy. Acceptance of responsibility for one's own safety is a major consideration that must be addressed.

Working in confined spaces requires a special individual. The spaces are generally small, with minimal clearances. Claustrophobia is a real issue. Work is usually accomplished without the benefit of a "buddy system," and there is limited communication with individuals outside the work space. Breathable air is limited and, if not contaminated, will usually become contaminated by the work being performed. Safety equipment can be uncomfortable and can restrict normal body movements. Performing routine tasks can become difficult if not impossible. Escape from the space is limited and usually must be accomplished without assistance in times of emergency. These and many other characteristics make the desirability of confined space work attractive to only a few special individuals who are willing to accept the risks. Acceptance of the "confined space risk" and the desire to work safely can become congruent only when the individual performing the work has the right to challenge work procedures and approve proposed safety precautions.

Most individuals rely on the professionalism and integrity of safety managers and supervisors to provide safe work procedures. Safety regulations and accepted industry practices usually govern safety conduct. The individual entering the confined space must be aware of required precautions and all potential hazards inherent within the work process. Chemicals and solvents used inside the space can produce significant contamination of breathable air. Lack of sufficient oxygen can result in drowsiness, fatigue, and disorientation. Entrapment and/or engulfment can result if retaining devices are not adequate. Escape and/or rescue can become impossible when, and if, hazardous conditions result.

The individual must know and understand all of the scenarios before the work begins. This is the most basic element in accepting responsibility for one's own safety. The adage "Look before you leap or you may become a victim" should have significant meaning to anyone who works inside confined spaces.

The 'Bill of Rights'
Confined space workers also have a "Bill of Rights" (i.e., the right to veto any and all work they feel places them at "undue risk"). This right is guaranteed by OSHA regulations. When it is exercised, the worker cannot be disciplined.

All legitimate safety concerns must be resolved before work begins. These concerns usually require a complete review of four issues: work space personnel, work environment, work space rescue team, and work space hazards. (See Table 1; the green shaded area means proceed with operations, yellow means caution, and red means "stop work.")

No work inside a confined space can begin until an entry permit has been issued by the Entry Supervisor. In certain cases where no immediate hazard exists inside the work space, this requirement can be waived. When this is done, the Entrant has the right to a satisfactory explanation of the proposed work routine. Failure to obtain this information when no permit is issued places the Entrant in immediate danger. All entry permits must be posted at the work site by the Entry Supervisor.

The work permit must identify all workers who are authorized to enter the work space during the life of the work permit. All permits must have a start time and finish time. The work procedures to be followed must be explained and the potential hazards must be identified. Required safety procedures must be listed, a Rescue Team must be established, and an Attendant must be assigned to monitor compliance with the work permit.

When any procedure on the work permit is not followed, the Attendant must have the authority to order an immediate evacuation of the work space. These are basic safety requirements that all workers who enter a confined space have a "Right to Expect."

The environment inside the work space is another safety concern. All work spaces must be evaluated before entry to ensure contamination levels are not hazardous. The Entrant should know "what to expect" when the work proceeds and also when, and if, an emergency develops. In some cases, forced air ventilation may be required to reduce internal hazards.

When chemicals, solvents, or other potential contaminants are used inside the work space, periodic monitoring to ensure that contamination levels do not become hazardous may be required. Whenever monitoring is required, all results must be posted at the work site.

The Attendant should know when exposure levels require changes in safety equipment or an evacuation of the work space. All information associated with work space hazards must be resolved before entry in the work space. The Entrant has a "Right to Know."

Rescue Situations
Emergency rescue becomes an issue only when procedures are not followed or when unanticipated safety problems result. These situations can develop for many reasons.

There can be an emergency outside the work space that places the Entrants at risk; new chemicals, solvents, or procedures can be introduced into the work space; unauthorized entry into the work space by other workers can occur; failures in communication procedures can result; workers inside the work space can develop physical problems; and many others. When these situations develop, rescue equipment and a trained Rescue Team must be available.

Rescue equipment must be "stand alone" equipment with sufficient breathable air supplies, air lines, and air masks to ensure safe rescue of all workers inside the work space. The rescue equipment should have a cascade air supply system with a low-air alarm. It must be readily available and operational at the work site before work begins. Use of plant supplied air when emergency rescue is necessary is illegal.

The Rescue Team must be trained and proficient in basic rescue techniques, and its members must be immediately available. They cannot be assigned elsewhere or out to lunch. They must be able to physically conduct the rescue. Tall rescuers do not function well in low-clearance work spaces, and large rescuers may not fit into work spaces with limited openings. All Entrants should be satisfied that the procedures, response time, equipment, and rescue workers can ensure their safe rescue in an emergency.

Communications
Entrants must also know that a reliable communication system is available. They must be able to advise the Attendant whenever safety issues develop inside the work space. Conversely, the Attendant must be able to contact the Entrants when an evacuation of the work space is necessary.

Conclusion
Workers who enter confined spaces are at extreme risk, and they have a right to their "Bill of Rights." Each Entrant must have a "comfortable feeling" about the safety practices that will ensure safe rescue. No worker should ever enter a work permit-required confined space with reservations about safety procedures or rescue operations.

This article appears in the April 2006 issue of Occupational Health & Safety.

References

1. American National Standards Institute, Safety Requirements For Working In Tanks and Other Confined Spaces, Z117.1.

2. National Institute for Occupational Safety and Health, Criteria for a Recommended Standard: Working in Confined Spaces (Publication No. 80-106).

3. National Institute for Occupational Safety and Health, A Guide to Safety in Confined Spaces (Publication No. 87-113).

4. National Safety Council, Confined Space Entry Control System for R&D Operations, Data Sheet No. 704.

5. U.S. Department of Labor, Code of Federal Regulations, Part 1910.146, Permit Required Confined Spaces.

This article originally appeared in the April 2006 issue of Occupational Health & Safety.

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