Facing Unexpected Hazards

Every confined space entry is a new and different situation with potential for harm.

"IT showed something bad. . . . Come check this thing out, it showed something!" were the gasping utterances of a dirty, sweat-streaked, very excited (and obviously frightened) maintenance fellow. The multi-gas monitor, after months of use, had sounded an alarm that startled the crew while working in a tunnel. The guys thought it was broken when the alarm went off, until the meaning of the alarm hit home and they scampered up to safety.

At first glance, the safety officer thought, "This is what is supposed to happen: The monitor worked." The reality of the situation was much worse for a fledgling safety program dealing with a new confined space requirement. Upon closer investigation, it was determined this crew, who had been trained and had all the tools, often did not test the atmosphere because nothing had ever been found. Several (including the supervisor) routinely worked in confined spaces they believed safe with no thought of any hazard, other than being late for break time because they had always done it that way. These well-trained individuals saw Confined Space as a time drag, another useless program that made them sit half awake through classes and use or have present additional equipment that strapped the budget for other needed equipment. There was little benefit to the guys doing the work.

Until that little alarm went off. . . . That day, it was hydrogen sulfide. Repeated testing verified the results. At that facility, it was the only time anyone remembered "finding" anything wrong with a confined space. I learned more about the confined space program that day than any other day from listening carefully to the comments of the employees.

"We weren't sure the thing even worked," one said. "We dropped it several times last month but did not tell anyone." And there was the second-level supervisor who wanted to argue the standard and procedure, until reminded he had sent his employees to the confined space training but had never bothered to attend himself. He was too busy. (He attended the next one and sat in the front row along with the rest of upper management.)

Confined spaces and the need for ventilation and testing took on a whole new meaning for that crew. Budget for better equipment materialized without a grumble from the highest management. They purchased equipment safety professionals only dream about.

I had forgotten this event until recently being stopped at a local market by a creaky, little man who was one of those now-long-retired maintenance employees. He remembered it clearly and as a life-changing moment because it was his life at risk. His attitude about safety was forever changed that day.

As safety professionals, we do make an impact every day. We may not know it at the time (or ever), but our actions, statements, and work ethics touch positively the lives of those we serve. We can effect change to help employees help themselves one standard at a time and return home safely. With all the headaches, stress, and hardships we as safety professionals endure, it is a great reward in an often thankless job.

Barriers to Education
Confined space is one of the toughest standards to enforce and get the danger message across to your employees. Every safety professional must walk that tightrope between paranoia and safe work practices each and every day when dealing with confined space issues. There is nothing simple here; each entry is completely different. There is no history to rely on, every entry is unique and must be treated as extremely hazardous, and therein comes one of a multitude of problems.

Often employees become complacent over time when there are no hazards noted. Much of confined space prevention is potential, a series of "what if" situations. Often, maintenance employees believe themselves to be 10 feet tall and bulletproof each and every day. The entry permit is pencil whipped without thought and approved from afar, or not completed at all and not followed up on.

Employees who test the atmosphere and find no problems repeatedly become lax and begin skipping tests to save time or effort. Some employees have no idea what an "alarm" sounds or looks like on monitors. Employees brace themselves for the dangers of asphyxiation, toxic gases and vapors, mold, bloodborne pathogens, heat stress, engulfment, falls--yet this entry is uneventful, so the worry and extra manpower is seen as an unnecessary cost and worry. Stress is high, readiness is in place, and then nothing happens "out of the ordinary." It all becomes a letdown. Such a situation without added reinforcement of training--and, unfortunately, real deaths and injuries in the type of work being done--becomes a "cry wolf" standard of enforcement.

Sadly, many of the best confined space programs are built on a workplace fatality or severe injury. But for every great program, there are thousands that are more fluff than substance. Employees often have the tools to use: monitors and retrieval and communication elements to protect each employee entering the confined space. Training is often up to date. Yet just as often, these same employees do not bother testing the atmosphere or utilizing any of the equipment unless "the brass" is around. The respect for potential hazards just is not present.

Making Changes
Does your confined space entry program protect all employees? Are you sure it is a living, working program, or is it a paper chase that gets tossed up on the dashboard of the work truck to satisfy any inspector who may come nosing around? How do you ensure the success of your confined space program so that it protects lives instead of simply meeting paper demands of the standard?

  • Train, educate, and train again on confined space hazards! Each entry has to have an established routine that must be followed. Change your training styles, times, and formats. Keep the topic fresh and more unpredictable.
  • Ensure each employee knows the equipment. He or she has the opportunity to ask questions (alone and in a group) and knows what the alarm sounds/looks like and what it means. More importantly, he or she knows what to do immediately without any fear of teasing or reprimand because of the time used. This is a tough situation for the small employer who has limited confined space work. Some companies have specific training before each entry if it is a non-routine event to prevent ignorance.
  • Keep the equipment in good repair, available, and with enough employees to use it. Make sure equipment is reliable and calibrated if required. Make sure the admission of dropping an instrument or that something is "not working right" is taken seriously from employees and followed up on by qualified service vendors. Confined space equipment/monitor repair is not "shade tree" mechanic work.
  • Make sure each employee knows and fully understands he or she can raise any question or stop the confined space activity immediately and at any time if he or she thinks there is a problem.
  • Have rescue procedures and also have a back-up plan. Test these, too.
  • Enforce policy/procedures consistently, from the very top of the organization down to the worker bees. It has to be the same for everyone, from attending training to working with equipment. Your employees follow management's attitude. If you think confined space is important, they are more likely to also.
  • Have adequate hazard assessment for all confined space situations. Many organizations use outside consultants as a pair of "fresh eyes" that may add to the program's safety awareness.
  • Have good facility maps, including the utilities. If something does go wrong, it sure helps to know where everything is without searching or guessing.
  • Update the confined space program regularly, including keeping all workers up to date on injuries/fatalities from confined space entries. There is a wealth of news on confined spaces from magazines, Web sites, newsletters, and other news sources. This keeps the information and potential for injury or disaster fresh and also provides failures from other programs to help you improve your own. Keep your employees talking and thinking about what can go wrong.

Regrets over a dead or injured employee are not a good way to build your confined space program. Success comes through prevention, planning, communication, and sticking to the message of ensuring workplace safety. It is time and effort well spent to prevent even one workplace death or injury.

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

Confined Spaces Audit Checklist

Yes

No

Is there a designated place for confined space policy materials, entry permits, and training records? Is it available at all times to employees who need access?

Yes

No

Is the program reviewed and updated regularly by qualified persons?

Yes

No

Are entry permits reviewed by qualified supervisory personnel prior to work being done?

Yes

No

Are adequate funds and resources dedicated to confined space efforts?

Yes

No

Has your facility been evaluated by a competent person as to the presence of confined spaces where employees may have to enter?

Yes

No

If confined space entry is an unusual event at your site, is refresher training done immediately prior to entry? Is this documented?

Yes

No

Is there a designated person responsible for the safety program dealing with confined space? Is this person knowledgeable about confined space situations at your facility? If this person is a consultant, is he/she at the facility during confined space work being done? (This allows better understanding of your operations but is not required.)

Yes

No

Has adequate time been allotted for the development of this program? Is it a custom application for unique situations?

Yes

No

Is the equipment chosen by the workers and supervisors who use that equipment for confined spaces, rather than chosen by cost alone by an accounting department without a full knowledge of the needs?

Yes

No

Is the equipment tested prior to purchase and compared with other like items for employees' acceptance and usefulness for your needs?

Yes

No

Are employees designated for confined space work, or is it volunteer only?

Yes

No

Is a written description and designation of each confined space type and location maintained with the policy materials, in order to identify potential hazards associated with confined spaces? Are these updated as necessary?

Yes

No

Are accurate facility maps, descriptions, and locations readily available to emergency personnel if needed?

Yes

No

Is each confined space evaluated carefully as to hazards within them such as safe entry? Is descent equipment (e.g., ladders and steps) in good working condition?

Yes

No

Are communication hazards such as loud machinery, cutting torches, etc. present?

Yes

No

Are there other conditions, such as remote sites or unusual work environments, that would require special communication equipment?

Yes

No

Are confined spaces thoroughly emptied/tested/purged of any corrosive or hazardous substances, such as acids or caustics, before entry?

Yes

No

Are all lines to a confined space containing inert, toxic, flammable, or corrosive materials valved off and blanked or disconnected and separated before entry? Is this verified by supervision?

Yes

No

Are impellers, agitators, or other moving equipment inside confined spaces required to be locked out if they present a hazard? Is this verified by supervision?

Yes

No

Is natural or mechanical ventilation provided before anyone enters the confined space? Are back-up ventilation and a power source available?

Yes

No

Is adequate illumination provided for the work to be performed in the confined space? Are various types of illumination available for unique situations, such as portable lighting, floodlights, and explosion-proof lighting if needed?

Yes

No

Is the atmosphere inside the confined space frequently tested or continuously monitored during work?

Yes

No

Are all employees knowledgeable of the monitoring and understand the sounds, flashing lights, etc. that indicate a problem? Is this often trained upon to ensure everyone understands what to expect?

Yes

No

Is there an assigned safety standby employee outside the confined space, when required, whose sole responsibility is to watch the work in progress, sound an alarm if necessary, and render assistance?

Yes

No

Is the standby employee appropriately trained and equipped to handle an emergency?

Yes

No

Are the standby employee or other employees prohibited from entering the confined space without lifelines and respiratory equipment if there is any question as to the cause of an emergency?

Yes

No

Is all portable electrical equipment used inside confined spaces either grounded and insulated or equipped with ground fault protection?

Yes

No

If employees will be using oxygen-consuming equipment such as salamanders, torches, furnaces, etc., in a confined space, is sufficient air provided to ensure combustion without reducing the oxygen concentration of the atmosphere below 19.5 percent by volume?

Yes

No

Is each confined space checked for possible industrial waste that could contain toxic properties? Is this repeated regularly in event of a flood or industrial accident or other disaster such as earthquake?

Yes

No

Is the confined space checked continuously if needed for possible air contaminants, oxygen deficiency, or unique hazards of the work being done?

Yes

No

If the confined space is below the ground and near areas where motor vehicles will be operating, is it possible for vehicle exhaust or carbon monoxide to enter the space?

Yes

No

Is carbon monoxide also tested for in confined spaces?

Yes

No

Are changes of direction or elevations readily identifiable? Is non-slip used where needed on ladders and on flooring materials where possible?

Yes

No

Are these marked clearly?

Yes

No

Is adequate headroom provided for the entire length of any space? Do employees utilize appropriate head protection in confined spaces?

Yes

No

Are spaces and entry points kept clear of scrap, debris, and waste from previous work?

Yes

No

Has all equipment been inspected recently? (This is especially important for non-routine work in confined spaces.)

Yes

No

Does every employee understand he/she has the right to stop the confined space entry if needed? Do they fear reporting a problem?

This checklist was written by Linda Johnson Sherrard, MS, CSP, the technical editor of Occupational Health & Safety. A checklist is not a substitute for a comprehensive safety program but is to be used only as a reminder of potential areas on which to concentrate.

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

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