Confined space entry issues
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Confined Space Entry Issues. Craig Schroll, CSP, CUSA FIRECON [email protected] Overview of Program. Overall confined space issues Ways to address these issues Strategies for entries Types of confined spaces Hot work. The Problem. We continue to kill & injure people Lack of warning

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Confined Space Entry Issues

Craig Schroll, CSP, CUSA

FIRECON

[email protected]


Overview of Program

  • Overall confined space issues

  • Ways to address these issues

  • Strategies for entries

  • Types of confined spaces

  • Hot work


The Problem

  • We continue to kill & injure people

  • Lack of warning

  • Lucky versus smart


Compliance

Remember that compliance is the price of admission not the achievement of excellence.


OSHA Information

  • Standard

  • Compliance Instruction

  • Interpretive letters

  • All are available on the web site – www.osha.gov


Other Standards

  • ANSI Z117

  • NFPA

  • API

  • International

    • Australian

    • United Kingdom

    • European Union


Hazard + Exposure = Risk


Risk Assessment


Design

  • Eliminate the confined space

  • Eliminate the need for entry

  • Eliminate hazards

  • Minimize risk


Eliminate Confined Space

  • Change access

  • Design in hazard elimination


Eliminate Need for Entry

  • Design space/process to not require internal maintenance

  • Access ports

  • Pull out panels

  • Pull up equipment i.e. pumps


Eliminate Hazards

  • Design confined space with hazard elimination in mind

  • For example, improved isolation systems


Minimize Risk

  • Reduce number of entries

  • Reduce duration of entries

  • Reduce number of personnel


Types of Spaces

  • Confined space

  • Permit-required confined space

    • Reclassified space

    • Space eligible for alternate procedures

  • Non-permit space


Confined Space

Large enough

to bodily enter

A space must have all three characteristics to meet the confined space definition.

Limited or restricted

access

Not designed for

continuous occupancy

Confined

Space


Permit-Required Confined Space

Has or has the

potential

to contain a

hazardous

atmosphere?

  • Oxygen deficient (19.5% or less)

  • Oxygen enriched (23.5% or more)

  • Flammable (10% LEL or more)

  • Toxic (above PEL)

  • Combustible dust (at or above LEL)

  • Other IDLH


Permit-Required Confined Space

Has the potential

for engulfment?

Engulfment may occur by materials being introduced or removed from the space or by an entrant being drawn down into materials.


Permit-Required Confined Space

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 crosssection.

Internal

configuration

hazard?


Permit-Required Confined Space

Any other

recognized serious

safety or health

hazard?

Other hazards capable of causing death, serious physical harm, or interfering with the entrants ability to escape.


Non-Permit Confined Space

Does not contain or, have potential to contain any hazard capable of causing death or serious physical harm.


Reclassification

  • No atmospheric hazards

  • Eliminate all hazards

  • Document reclassification

  • Certification available to employees


Elimination versus Control

  • Elimination means hazard cannot return during entry operation.

  • Control means that return of hazard is possible if control measures fail.


Alternate Procedures

  • Atmosphere is only hazard

  • Ventilation can make space safe

  • Monitoring data

  • Data available to employee


Alternate Procedures

  • Safe to remove entry cover

  • Guard opening

  • Test atmosphere

  • Continuous ventilation

  • Periodic atmospheric testing

  • Written certification


Examples


Recognition

Recognition of an area as a confined space is a critical first step to safe operations.


Confined Space Hazards

  • Atmospheric

  • Content

  • Potential Energy

  • Environment in Space

  • Configuration of Space

  • Nature of Work

  • External

  • Miscellaneous


Sources of Hazards

  • Inside the space

  • External to the space

  • From the work


General Requirements

  • Evaluate workplace

  • Inform employees

  • Develop & Implement written program


Programs

  • General policy

  • Specific guidelines

  • Training requirements

  • Permit system


Programs

  • Supervisor’s role

  • Employee’s role

  • Contractor procedures

  • Emergency procedures

  • Monitoring system


Confined Space Policy & Procedures

  • Simple

  • Brief

  • Useful

  • Clearly communicated

  • Consistently enforced


Evaluating Your Confined Spaces


Confined Space Inventory

  • Survey entire facility

  • Identify all potential CS

  • Classify spaces

  • Maintain documentation


Confined Space Evaluation

  • Evaluate prior to entry (OSHA)

  • Evaluate initially from a practical perspective

    • Equipment

    • Procedures

    • Training


Confined Space Evaluation

  • Must be conducted

  • Maintain documentation

  • May be electronic

  • May be a form

  • Actually use the information

  • Update at least annually

  • Teach people to do review prior to entries


Safe System of Work

  • Risk assessment

  • Hazard evaluation

  • Work process that eliminates hazards when possible and controls them when not

  • Safe system of work

  • Catch variations


Planning Entry

  • Is entry necessary?

  • Work plan

  • Space preparation

  • Permit

  • Briefing


Briefing

  • Hazards

  • Permit items

  • Job tasks

  • Emergency procedures


Job Surveys

  • Inspect area

  • Review work

  • Confirm safety issues

  • Review preparations

  • Check PPE

  • Check equipment & supplies


Entry Supervisors

  • Role is much more than a signature on a form

  • Actually evaluate and resolve hazards


Training

  • Establish and maintain competence

  • All personnel involved in entries must be competent


Program Audit

  • Review permits

  • Update surveys

  • Update policies & procedures

  • Update training

  • Review equipment condition & needs

  • Job site surveys


Hot Work

  • Numerous safety & health issues

  • A few specific to confined space work

  • Ventilation

  • Introduction of ignition source

  • Heating can contribute to release of contaminants


Q & A


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