Standard 29 CFR Part 1910.146

1. Standard 29 CFR Part 1910.146 Permit Required Confined Space Entry

2. Agenda • Permit Required Spaces - Definition • Hazards and hazard control • Permit system • Entry procedure • Emergency procedures

3. Confined spaces: What are they? Confined Spaces: • Are large enough and so configured that an employee can bodily enter and perform assigned work; and • Have limited or restricted means of entry or exit (for example, tanks, vessels, silos, storage bins, hoppers, vaults and pits are spaces that may have limited means of entry); and • Are not designed for human occupancy In addition to the above, Permit Required Confined Spaces: • Contain, or has the potential to contain, a hazardous atmosphere; • Contain a material that has the potential for engulfing an entrant; • Have 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 cross section; or • Contains any other recognized serious safety or health hazard

4. Atmosphere hazards: Oxygen content Oxygen deficiency • Room air contains approximately 20.9% oxygen • Below 19.5% oxygen we can develop physical problems • Oxygen deficiency can cause light headedness, nausea, and loss of coordination and concentration, and the ability to think and react normally: we can hallucinate, depriving us of our ability to recognize hazards and to escape from them (self rescue) Oxygen deficiency can be caused by many things, including: • Nitrogen or inert gas piped into the space • Chemical processes, including rust • Chemical evaporation or leakage • Exhaust from internal combustion engines or other external sources NEVER ENTER AN AREA WITH LESS THAN 19.5% OXYGEN CONTENT

5. Atmosphere hazards: Oxygen content Oxygen Enrichment • Oxygen concentration above 23.5% is called oxygen enrichment • Oxygen enrichment causes all combustible materials to burn with explosive force that makes escape from a fire in a confined space doubtful NEVER ENTER AN AREA WITH GREATER THAN 23.5% OXYGEN Oxygen enrichment can be caused by many things including: • Use of oxygen to ventilate a space (which is never allowed) • Leaking hose on a torch set • Some chemical processes

6. Atmosphere hazards: Lower flammable unit • The lower flammable limit (LFL) is the minimum concentration of flammable vapor, mist, gas or dust mixed or suspended in air that will ignite. Technically, 100% of the LFL must be present to allow a fire or explosion. • There must be 19.5% or greater oxygen content present in the area being sampled to get an accurate LFL meter reading • Since there can be some variation in meter readings, we set a wide safety margin for acceptable LFL readings NEVER ENTER AN AREA WITH GREATER THAN 10% LFL • High LFL can be caused by many things including: -Flammable chemicals -Flammable material brought into the space for the project -External processes that leak or seep into the space

7. Atmosphere hazards: Toxic and hazardous substances • Some confined spaces can contain hazardous materials such as hydrogen sulfide (in sewers) • Exposure to chemical vapor and/or gas and/or particulate above the Permissible Exposure Level (PEL) can cause damage to your health and impair your ability to exit the confined space • To determine what toxic or hazardous chemicals might be present we must know what chemicals were present in the space • PEL exposure data is listed in the OSHA Standards and on Material Safety Data Sheets NEVER ENTER AN AREA WITH AN EXPOSURE FOR A TOXIC OR HAZARDOUS CHEMICAL GREATER THAN THE PEL (OR OTHER MAXIMUM EXPOSURE NUMBER) • A high PEL can be caused by many things including: -Chemicals stored or used in the space - External processes that leak or seep into the space

8. Controlling atmosphere hazards • All atmosphere hazards are detected and quantified by using direct reading meters: We always use a meter to check that the atmosphere is safe prior to space entry • In addition, we continuously monitor the space throughout the entry • We will look at the meter we use for permit confined space entry now • Ventilation is occasionally used to improve the atmosphere. Tips on ventilation are: -Positive pressure ventilation is always more effective -Deliver the fresh air as close as possible to the entrant -Be sure the fan intake is located in clean air

9. Engulfment hazard • Engulfment occurs when a person is covered with a substance from a pipe, hopper, duct or other source of materials being added to a confined space • Engulfment can suffocate a person, cause serious injury or make escape from a space impossible NEVER ENTER A SPACE WITH ENGULFMENT HAZARDS THAT HAVE NOT BEEN RENDERED SAFE • An engulfment hazard can be caused by many things including: -Connected pipe lines, ducts and hoppers • Engulfment hazards are controlled by disconnecting, blanking or capping connecting pipes, ducts and hoppers

10. Other hazards • There are often mechanical, hydraulic, thermal and electrical hazards in confined spaces • These other hazards are generally controlled through standard lockout and tagout (LOTO) procedures: REFER TO OUR FACILITY PROCEDURE ON LOTO • Other hazards can be caused by many things including: -Heating jackets, coils, etc. -Mixers and agitators -Moving equipment -Electrical equipment NEVER ENTER A SPACE WITH OTHER HAZARDS PRESENT

11. Hazard summary • Hazards present in permit confined spaces are extremely dangerous because: • Space entry and exit is difficult and slow, both for entrants and for rescuers • Many of the hazards are difficult to see, feel or smell without using instruments • Ventilation of confined spaces is poor unless supplemental mechanical ventilation is used

12. Entry permit The permit contains: • The names of all involved individuals • A list of steps taken to render the space safe • Atmosphere readings • The time that the permit expires • Information needed for contacting the rescue team Critical steps in permit completion: • Isolate or make safe all hazards • Use a meter to determine a safe atmosphere • Provide access into space • Have all equipment ready • Notify the Rescue Service • COMPLETE ALL INFORMATION REQUESTED ON THE PERMIT

13. Entry procedure • A permit is used to control all confined space entry • All personnel who are involved in the entry must have current training and be authorized for their role • Three types of responsible positions are involved in an entry and each has an equal decision in allowing the entry, not allowing the entry or cancelling it (if already in progress). These positions are: -The entry supervisor -The entrant -The attendant

14. Duties • Entry Supervisor: -Makes all arrangements -Begins permit and oversees completion -Contacts rescue service to alert them of the entry -Supervises the entry, frequently visiting the site -Returns completed permit to program administrator • Entrant: -Reviews the permit to assure proper completion and her/his agreement -Follows all directions from the Attendant • Attendant: -Functions to assure safety -Continuously evaluates external and internal hazards -Is willing to terminate the entry for safety reasons -Is ready to perform a non-entry rescue

15. Emergency procedures • Immediately terminate the permit if: -Any altered level of consciousness is detected in the entrant (clumsiness, slurred speech, behavior or speech changes) -An emergency is detected inside the space -An emergency occurs outside the space -Communication is lost • Never enter a space to affect a rescue: practice non-entry rescue only • Immediately summon the rescue service and the entry supervisor if any emergency condition is suspected • Continue to attempt non-entry rescue and continue to provide fresh air until the rescue service arrives • We will now discuss our rescue service

16. Conclusion • Permit required confined spaces present many unique hazards: NEVER UNDERESTIMATE THEM • Control all hazards: -Atmosphere -Engulfment -Other (mechanical, thermal,. Etc) • Preparation saves lives: follow the permit system • Every member of the team has a part to play: the supervisor, entrant and attendant must all agree on safety and must all agree on procedures

17. For more information For more information regarding Permit Required Confined Spaces , or other safety issues, please contact: Gregory & Appel Insurance Mike Salazar, Vice President Direct: 317-686-6407 Email: msalazar@gregoryappel.com