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Confined Space Entry Issues. Craig Schroll, CSP, CUSA FIRECON Craig@FIRECON.com. 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

Confined Space Entry Issues

Craig Schroll, CSP, CUSA

FIRECON

Craig@FIRECON.com


Overview of program
Overview of Program

  • Overall confined space issues

  • Ways to address these issues

  • Strategies for entries

  • Types of confined spaces

  • Hot work


The problem
The Problem

  • We continue to kill & injure people

  • Lack of warning

  • Lucky versus smart


Compliance

Compliance

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


Osha information
OSHA Information

  • Standard

  • Compliance Instruction

  • Interpretive letters

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


Other standards
Other Standards

  • ANSI Z117

  • NFPA

  • API

  • International

    • Australian

    • United Kingdom

    • European Union




Design
Design

  • Eliminate the confined space

  • Eliminate the need for entry

  • Eliminate hazards

  • Minimize risk


Eliminate confined space
Eliminate Confined Space

  • Change access

  • Design in hazard elimination


Eliminate need for entry
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
Eliminate Hazards

  • Design confined space with hazard elimination in mind

  • For example, improved isolation systems


Minimize risk
Minimize Risk

  • Reduce number of entries

  • Reduce duration of entries

  • Reduce number of personnel


Types of spaces
Types of Spaces

  • Confined space

  • Permit-required confined space

    • Reclassified space

    • Space eligible for alternate procedures

  • Non-permit space


Confined 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
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 space1
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 space2
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 space3
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
Non-Permit Confined Space

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


Reclassification
Reclassification

  • No atmospheric hazards

  • Eliminate all hazards

  • Document reclassification

  • Certification available to employees


Elimination versus control
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
Alternate Procedures

  • Atmosphere is only hazard

  • Ventilation can make space safe

  • Monitoring data

  • Data available to employee


Alternate procedures1
Alternate Procedures

  • Safe to remove entry cover

  • Guard opening

  • Test atmosphere

  • Continuous ventilation

  • Periodic atmospheric testing

  • Written certification



Recognition

Recognition

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


Confined space hazards
Confined Space Hazards

  • Atmospheric

  • Content

  • Potential Energy

  • Environment in Space

  • Configuration of Space

  • Nature of Work

  • External

  • Miscellaneous


Sources of hazards
Sources of Hazards

  • Inside the space

  • External to the space

  • From the work


General requirements
General Requirements

  • Evaluate workplace

  • Inform employees

  • Develop & Implement written program


Programs
Programs

  • General policy

  • Specific guidelines

  • Training requirements

  • Permit system


Programs1
Programs

  • Supervisor’s role

  • Employee’s role

  • Contractor procedures

  • Emergency procedures

  • Monitoring system


Confined space policy procedures
Confined Space Policy & Procedures

  • Simple

  • Brief

  • Useful

  • Clearly communicated

  • Consistently enforced


Evaluating your confined spaces

Evaluating Your Confined Spaces


Confined space inventory
Confined Space Inventory

  • Survey entire facility

  • Identify all potential CS

  • Classify spaces

  • Maintain documentation


Confined space evaluation
Confined Space Evaluation

  • Evaluate prior to entry (OSHA)

  • Evaluate initially from a practical perspective

    • Equipment

    • Procedures

    • Training


Confined space evaluation1
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
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
Planning Entry

  • Is entry necessary?

  • Work plan

  • Space preparation

  • Permit

  • Briefing


Briefing
Briefing

  • Hazards

  • Permit items

  • Job tasks

  • Emergency procedures


Job surveys
Job Surveys

  • Inspect area

  • Review work

  • Confirm safety issues

  • Review preparations

  • Check PPE

  • Check equipment & supplies


Entry supervisors
Entry Supervisors

  • Role is much more than a signature on a form

  • Actually evaluate and resolve hazards


Training
Training

  • Establish and maintain competence

  • All personnel involved in entries must be competent


Program audit
Program Audit

  • Review permits

  • Update surveys

  • Update policies & procedures

  • Update training

  • Review equipment condition & needs

  • Job site surveys


Hot work
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