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Permit-Required Confined Spaces Identify and Classify

Permit-Required Confined Spaces Identify and Classify. Presented By: Consultation Education and Training Division Michigan Occupational Safety & Health Administration Michigan Department of Licensing and Regulatory Affairs www.michigan.gov/miosha (517) 322-1809. This Door Leads to a Room.

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Permit-Required Confined Spaces Identify and Classify

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  1. Permit-Required Confined SpacesIdentify and Classify Presented By: Consultation Education and Training DivisionMichigan Occupational Safety & Health Administration Michigan Department of Licensing and Regulatory Affairs www.michigan.gov/miosha(517) 322-1809

  2. This Door Leads to a Room If You Never Enter the Room, IS IT STILL A ROOM?

  3. “We never go in there.” • Evaluate a space based on definitions, not on whether you enter the space.

  4. Why Identify and Classify? • Performance standard • Analysis of hazards is open for discussion between you and MIOSHA • If you have permit spaces and have done nothing you are assumed to be in violation • Therefore, employers must establish criteria and make judgements

  5. Benefits of Identifying and Classifying • Puts employees on notice not to enter or how to enter safely • Enables employer to use “alternate entry” and/or reclassification to “non-permit” status, both of which are less resource intensive (i.e., no attendant, no rescue service, no entry supervisor, etc.)

  6. VERTICAL - if a particular standard is specifically applicable... it shall prevail over any different general standard which might otherwise be applicable. HORIZONTAL - any general standard shall apply according to its terms to any employment and place of employment in any industry, even though particular standards are also prescribed for the industry, to the extent that none of such particular standards applies. Horizontal vs VerticalStandards Next….. Part 90-Confined Space Entry

  7. GI Standards - Vertical • Health • Rule 3240 Welding, Cutting & Brazing • Rule 3303 (1) Entry of Open Surface Tanks • Rule 3303 (2) Welding in Confined Spaces • Rule 3303 (3) Vessel Entry in Pulp, Paper and Paperboard Mills • Safety • Part 1. General Rules • Part 12. Welding and Cutting • Part 63. Pulp, Paper, and Paperboard Mills • Part 77. Grain Handling Facilities • Part 81. Baking Operations • Part 86. Electric Power Generation

  8. Construction Standards-Vertical • Health • Rule 6310 Health Hazard Control for Specific Equipment and Operations • Rule 6402 Control Measures for Hazardous Atmospheres in Confined Spaces • Safety • Part 1. General Rules • Part 7. Welding and Cutting • Part 30. Telecommunications

  9. It is a CONFINED SPACEif all three are true • Is large enough and so configured that an employee can bodily enter and perform assigned work (average person, full body entry); AND • Has limited or restricted means for entry or exit (ladders, climb, be lowered); AND • Is not designed for continuous employee occupancy.

  10. Large Enough to Bodily Enter • Average Person • Capable of Full Body Entry • …bodily enter and Perform Assigned Work • There Must be a Means of Entry • This could be pre-existing opening or one the employer has mandated be created

  11. 2. Restricted Entry or Exit • Porthole, portable ladder, vertical fixed ladder, hatchway, etc. • Internal configuration which makes movement in space difficult • KEY PHRASE: “Route/Method of Exit Creates an Impediment to Self Rescue”

  12. 3. Not Meant for Continuous Human Occupancy • Not a workstation • Employees may have assigned tasks which put them in those spaces on a routine basis as an excursion to flip a switch, check a reading, clean a filter or trap, etc. • Does include longer excursions like maintenance, service, or repair

  13. Not a Confined Space? • Can still have hazards regulated by other standards

  14. JOURNEY FROM AN IDENTIFIED CONFINED SPACE TO A PERMIT REQUIRED CONFINED SPACE

  15. Is the CONFINED SPACEpermit required? • Yes, if the CONFINED SPACE has one or more hazards: 1. Actual/potential atmospheric hazards 2. Materials that could engulf entrant 3. Internal configuration that could trap or asphyxiate entrant 4. Any other serious safety or health hazard

  16. Analysis for Hazards • Immediately Dangerous to Life and Health-IDLH • Capable of Causing Death • Capable of Causing Incapacitation • Conditions Cause Inability to Self Rescue

  17. 1. Hazardous Atmosphere • Lack of Oxygen - 19.5% - 23.5% • Displacement by other gases • Consumption from rust, organic materials, electrical sparking, chemical process, other • Flammable Atmosphere - <10% LEL • O2 enriched atmosphere, flammable vapors, chemical reactions, combustible dusts, other • Carbon Monoxide - 35PPM/8hr. • Other Toxic Air Contaminants • Corrosive Atmosphere

  18. Analysis for Explosivity • H2S and CH4 are naturally occurring and are flammable • Standard requires such airborne hazards to be controlled to below 10% of the LEL. (Refer to MSDS) • Remember to consult conversion sheet which comes with air monitor - some flammables can require adjustments of +/- 30%

  19. 2. Engulfment • Powders, beads, grains, pellets, coal, dust, sludge, etc. • Breakthrough bridging

  20. Analysis for Engulfment • Flowable materials in containers which are intact can be assumed to keep their integrity • The volume of the material in the space must be sufficient to cause death or impediment to self rescue

  21. 3. Internal Configuration • Sloping Floors and Walls • Bottoms of Feed Hoppers or Silos • Drainage areas • Sluice ways • Baffles • High and Low Pipes • Low Ceiling Especially Hazardous when combined with engulfment hazards

  22. 4. Other Serious Hazards • Exposed, Live Electrical Circuits • Unguarded Mechanical Hazards • Critters • Slippery Surface • Noise • Vibration • Heat • Poor Visibility • Others

  23. JOURNEY FROM IDENTIFICATION TO CLASSIFICATION

  24. Dynamics of Classification • The space must be identified and classified as a PRCS if it contains a hazard(s) • However, you may never enter it as a PRCS • Because you will always reclassify it by performing certain tasks prior to entry (i.e. emptying, locking out, cooling, blanking, etc.)

  25. Classifications - There are 3 • ALTERNATE PROCEDURE • The atmospheric hazard(s) can be CONTROLLED creating a “temporary” C5 space? • RECLASSIFICATION - NON-PERMIT SPACE • The hazard(s) can be ELIMINATED creating a “temporary” C7 space • FULL PERMIT-ENTRY • The hazard(s) cannot be evaluated, eliminated and/or controlled

  26. Alternate Entry Space - (C)(5) • A confined space in which the only hazard is atmospheric (actual or potential) • The employer can show through monitoring data that the atmospheric hazard can be controlled through ventilation • If any non-atmospheric hazards exist but they can be eliminated from outside the space (C7) or by an initial full permit entry, you can use this method

  27. Necessary Proofs - (C)(5) • MSDS including an appraisal of the use of the product and its status in the space • Air monitoring data to prove elimination, control, or non-existence of atmospheric hazards (esp. of unintended contaminants) • certification of non-existence of atmospheric hazards lasts for as long as the conditions certified remain

  28. C5-Alternate Entry • Eliminate hazards, remove cover • Guard opening • Test w/calibrated, direct-reading meter • Start continuous, forced-air ventilation • If test shows hazard, wait, test until good

  29. C5-Alternate EntryCont… • Ventilate as follows: • Any hazardous atmosphere eliminated • Continuous and directed to immediate area where employees work • From a clean air source • Test periodically

  30. C5-Alternate EntryCont… • If hazard detected: • Leave, evaluate, additional measures before next entry • Verify through written certification • Date • Location • Signature

  31. Non-Permit Space - (C)(7) • A permit space which has no actual or potential atmospheric hazards • All hazards within the space are eliminated without entry into the space • If it is necessary to enter the space to eliminate hazards, do a full-permit entry. • Document basis for determining elimination: • date, location, signature

  32. Full Permit Entry When… • Hazard cannot be evaluated from outside the space • You are taking the hazard in with you • The employer cannot guarantee an ability to control the hazard during the operation • Remember: you must be able to state the pre-entry “Acceptable Entry Conditions” under which the entry will be made.

  33. Full Permit Entry Requires... 1910.146 (d) PRCS Program • Develop, implement, review (e) Permit system (f) Entry permit (g) Training (h) Duties of authorized entrants (i) Duties of attendants (j) Duties of entry supervisor (k) Rescue and emergency services

  34. Prohibited Conditions • Are changes in the space which were not a part of the original or current classification scheme. They require exiting or not entering the space until re-evaluation is performed.

  35. In Conclusion • IDENTIFY based on space meeting all 3 portions of the confined space definition • CLASSIFY based on the hazards present and potentially present in the space • ENTER based on your ability to eliminate and/or control the hazards, preferably from outside the space, which defines your reclassification options

  36. Need Assistance? • CET Division • (517) 322-1809 • GI Safety & Health Division • (517) 322-1831

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