Basic Requirements • IIPP (Section 3203)(a) “…every employer…” • (a) (4) Include procedures for identifying and evaluating work place hazards… • (C) Whenever the employer is made aware of a new or previously unrecognized hazard.
Reasons for Entry- and related deaths Construction 5% Inspection 10% Repair/Maintenance 40% Rescue 36% Retrieve Object 3% Dislodge material 5% Unknown 1%
Cal-OSHA Confined Space Special Emphasis Program • In place February 2012 • All Cal-OSHA units • Enforcement • Consultation • Every inspection will include an evaluation of confined spaces • Goal: Zero confined space fatalities in 2012
Cal-OSHA Confined Space Special Emphasis Program For ALL Inspections: • Ask ER if they have any confined spaces • Look for Confined Spaces during walk-around • Identify hazards • Verify that spaces are labeled • Ask ER if anyone enters spaces and how spaces are maintained & cleaned • Interview employees entering spaces
Cal-OSHA Confined Space Special Emphasis Program • Review written “Confined Space Program”, or procedures and documentation/records • Review alternate entry and/or reclassification procedures if applicable • Review rescue procedures • Audit last 6 months’ permits for PRCS-entry or certificates of reclassification
The Problem • Confined spaces present very special work requirements and preparations • Safety incidents involving confined spaces may result in fatalities; many have multiple serious injuries
The Solution • If confined spaces exist in your workplace • Post the space • Warn employees of the hazard • Prevent employees from entering until an effective and fully implemented confined space program is in place.
Look for spaces that are… • Large enough and configured so that they can be entered, and • Have restricted means for entry or exit, and • Are not designed for continuous employee occupancy
Typical Examples of Confined Spaces: • Tanks • Boilers • Vats • Kilns • Vaults • Silos • Pipelines • Sewers • Manure pits • Storage bins • Double hulls • Pumping stations • Pits, sumps • Vessels • Manholes • Water reservoirs
Questions to Ask • Does the person have to use their hands to enter or exit the space? • Is the person in an awkward posture when entering or exiting the space? • Is a person’s entry into or exit from the space slowed down or impeded by physical obstructions (such as pipes, ductwork, walls, holes in the floor, flanges, etc.)? • Would an employee be forced to enter or exit in a posture that might slow self-rescue or make rescue more difficult?
Questions to Ask • Is an acutely hazardous atmosphere or physical hazard present? • If it’s not present now, can it become present later?
Confined Spaces Title 8, CCR Sections 5156, 5157 & 5158 A “performance” standard: Every confined space is unique and must be treated on a case-by-case basis
General Industry Permit Required Confined Space – Section 5157 • Limited entrance and exit + potential atmospheric hazard or other hazards = “Permit Required Confined Space” • Applies to most workplaces such as: • Food production • Chemical manufacturing • Recycling operations • Sewer plants • Plating shops • Amusement parks
Other Industries -Section 5158 • Limited entrance and exit + hazardous atmosphere = “Confined Space” • Applies to: • Construction, • Agriculture, • Marine terminals • Telecommunication manholes and unvented vaults • Grain handling facilities, • Natural gas utility operation within distribution and transmission facility vaults,
5157 Confined Spaces • All Operations or Industries Except: • Construction • Agriculture • Marine Terminals • Telecommunication Manholes • Grain Handling Facilities • Natural Gas Utility • Electric Utility 5158 Applies
Hazardous Atmospheres • If a confined space has a hazardous atmosphere, or has the potential for a hazardous atmosphere, special confined space procedures must be taken • Hazardous atmosphere includes: • Oxygen deficiency or enrichment • Flammable atmosphere • Acutely toxic (Immediately Dangerous to Life or Health, or impairs ability to self-rescue)
Air Monitoring • Calibration • Sample Locations
Testing The Atmosphere Specific Gravity Methane: 0.55 Ammonia: 0.59 Carbon Monoxide: 0.96 Nitrogen: 0.97 Air: 1.0 Hydrogen Sulfide: 1.2 Carbon Dioxide: 1.5 Gasoline: 3- 4 Jet Fuel, JP-8: 4.7 Lighter than air gases Heavier than air gases So...Must test at multiple levels within space!
Type of Instruments • Use direct reading instruments with “real time” information on actual concentrations • “Alarm only” devices which do not provide readings, are not considered acceptable direct reading instruments
Confined SpaceAtmospheric Monitoring • Oxygen • Combustible gases and vapors • Toxic gases and vapors When testing for atmospheric hazards, test in the following order: OR, test for all simultaneously
Confined SpaceAtmospheric Monitoring – other issues • Aviation fuel • Sensor poisoning • Calibration • Employee medical exposure records
Causes of Hazardous Atmospheres • Inerting of the space • Product stored in a confined space: • Gases released when cleaning. • Materials absorbed into walls of confined space, even if space has been emptied or cleaned. • Rotting organic materials and other decomposition
Causes of Hazardous Atmospheres • Work performed in a confined space: • Welding, cutting, brazing, soldering • Painting, scraping, sanding, degreasing • Sealing, bonding, melting • Connections or pipes to other spaces, or leakage from adjacent areas or soils.
In most industries confined space precautions must also be taken if: • Water or other materials in the space, such as sand or sugar, are an “engulfment” hazard • A person may be trapped in the space due to sloping floor, converging walls, or piping or other obstacles • Any other recognized serious safety hazard such as energy sources, mechanical hazards, steam, or heat
Hazardous atmosphere Energy sources 5157 Permit-Required Confined Space One or more of the following: following characteristics: • electrical • mechanical • hydraulic • pneumatic, etc. • <19.5% Oxygen • > 23.5% Oxygen • >10% LEL (G/V) • =/> 10% LEL (Dust) • IDLH • >PEL (Acute) • Other • steam • corrosives, etc. • Engulfment • Entrapment
Entry • The action by which a person passes through an opening into a permit-required confined space, and includes ensuing work activities in that space • Considered to have occurred as soon as any part of the entrant’s body breaks the plane of an opening into the space
If confined spaces are to be entered the employer must… • Post the space and prevent unauthorized entry • Develop a program • Assess the space prior to and continually during each entry, including atmospheric monitoring • Train employees in required roles – entrant, attendant, supervisor, rescuers • Isolate the space from other energy sources & materials • Have effective rescue procedures
Rescue & Emergency Services • Non-entry rescue is preferred! You must utilize retrieval systems unless they would not be effective in the space • In addition to the attendant, there must be at least one standby person at the site who is trained and immediately available to perform rescue and emergency services. • Practice simulated rescue operations at least every 12 months in actual space or representative spaces based on opening size, configuration, and accessibility…. • “CALL 911” IS NOT A RESCUE PLAN!!!
Reference • “Confined Spaces: Is it Safe to Enter?” [under revision] • OSHA “Advisor” • Federal Register Preamble