Confined Space Safety

Confined Space Safety SOLAS III Regulation 19 (entry, drills) & USCG 46 CFR 148.86 (b) (emergency entry) Understanding the Requirements of Permit Required Confined Spaces Rev. March 24, 2017

ObjectivesPart I • Understand the 3 types of spaces on TDI vessels • Understand the 3 types of Conf. Space entries • Recognize hazards of confined spaces • Understand roles of the entry team members

ObjectivesPart II • Know how to properly ventilate a space • Understand the safe work practices for working in an around confined spaces. • Confined Space Drill requirements

Part I For Brooks McCall - SOP-BMC-2016C applies (BMC only: No entry to confined space except in extreme emergency) For Vanuatu flagged vessels SOP-GEN-007G applies

Part I There are 3 Categories of Confined Spaces on TDI vessels

Part I Category 1- Confined spaces that would be entered at sea only in extreme emergency and then must follow emergency entry procedure Emergency Only

Category 2- Confined/ enclosed spaces that may be entered at sea with an appropriate permit, atmospheric oxygen testing and forced air ventilation if necessary Permit Required

Part I Category 3- Confined/ enclosed spaces that may be entered at sea without a permit due to lack of atmospheric risk on entry Non-Permit Required

Emergency entry must follow the requirements of 46 CFR 148.86 (b) and TDI requires four people trained in confined space entry to fill the following roles: Supervisor-A Responsible Person must supervise the entry and maintain communications with the bridge. For an Emergency entry only (Category 1):

For an Emergency entry only (Category 1): The Entrantmust be trained in the use of an SCBA , wear an SCBA and a wire rope lifeline attached to him/ her, wear appropriate protective clothing and other applicable PPE.

For an Emergency entry only (Category 1): The Attendant/ Line Tender must: remain outside the confined space to monitor the entrant, have agreed on some means of communication with the entrant. [Can be a simple as one tug on the line means “Are you ok?” and two tugs back mean “yes”.]

For an Emergency entry only (Category 1): The Stand by Rescuer must: remain outside the confined space wearing full SCBA gear, wear wire rope lifeline and be ready to enter the space to assist the entrant.

Permit Required Entry(Category 2): To enter these spaces, a confined spaces permit with integrated JSA is required, as well as atmospheric O2 testing both prior to and during the confined space entry. All personnel involved in the entry must participate in the development and review of the JSA for the permit, and sign off on it. Personnel required for a regular permit confined space entry include:

Permit Required Entry(Category 2): Supervisor-A Responsible Person must supervise the entry and maintain communications with the bridge. The Entrantmust: be trained in the use of an SCBA, wear a wire rope lifeline attached to him/ her, wear appropriate protective clothing and other applicable PPE.

Permit Required Entry(Category 2): The Attendant/ Line Tender must: remain outside the confined space to monitor the entrant, monitor the O2 levels and have agreed on some means of communication with the entrant. [Can be a simple as one tug on the line means “Are you ok?” and two tugs back mean “yes”.]

Permit Required Entry(Category 2): The Stand by Rescuer must: remain outside the confined space wearing full SCBA gear, wear wire rope lifeline and be ready to enter the space to assist the entrant.

The main differences between emergency and permit entries are: Both assume hazardous atmosphere, but— Emergency Entry means no time to ventilate. So there is no atmospheric testing and the entrant wears full SCBA gear to breathe. Permit Entry ventilation is used to displace the hazardous atmosphere and atmosphere is tested and confirmed safe before and during entry.

In both emergency and permit entries The team member roles and responsibilities remain the same. The Stand by Rescuer must be fully dressed out in SCBA with wire rope lifeline, ready to rescue the entrant.

Non-permit required entry (Category 3): These spaces do not present an atmospheric hazard- therefore a permit is not required to enter these spaces. Prior to entry to perform any task, the bridge should be notified and an attendant should be posted outside the space to monitor the entrant. HOWEVER…

Non-permit required entry (Category 3): If the work activity alters the atmosphere (i.e. painting, welding, grinding), then a confined space entry permit must be filled out and all steps for regular permit required space entry must be followed.

How will you know? • TDI has evaluated all the spaces on its vessels and created a Confined and Enclosed Spaces Registerin the SMM. • SOP-GEN-007G lists all the confined/ enclosed spaces on each vessel • Permit required confined spaces are clearly labeled “DO NOT ENTER/ Confined Space”

Permit Required Confined Spaces Permit required when any oneof the following is present: • An atmospheric hazard. (Real or potential) • The potential for entrapment or engulfment. • A hazardous configuration. • Any other serious safety or health hazard.

Permit Required Confined Spaces This sewer has an atmospheric hazard, and the potential for engulfment, which makes it a permit required confined space. These hazards must be dealt with prior to entry!

Atmospheric Hazard • The main atmospheric hazard on TDI vessels is lack of oxygen. This could be due to rusting in a confined space or after a fire in any space. • However, common work on the vessel can create others. Can you think of some?

Atmospheric Hazard • Chemical fumes in a small space- like bleach in the bathrooms • Paint fumes in a small space • Flammable gasses created by OSPHO application to metal • Welding with insufficient ventilation

Engulfment • The simplified OSHA definition: Basically any substance that can trap you, crush you or stop you from breathing.

Engulfment Common examples of engulfment hazards on vessels: • Grain shipments • Storage Tanks • Sand, gravel or other small grained construction material • Sewage Tanks

Hazardous Configuration • The simplified OSHA definition: Basically, any tight space in which you could get trapped. What spaces on this vessel have hazardous configurations? Where could you get trapped?

Other “Serious” Hazards • Extreme temperatures • Mechanical and hydraulic energy • Lighting problems • Noise • Slippery surfaces Can you think of other safety hazards?

Reclassifying Permit Required Confined Spaces • If all hazards from a confined space can be eliminated, the space can be reclassified as a non-permit required space. • This means that the space has no real or potential atmospheric hazards, and all other hazards have been permanently eliminated.

Reclassifying Permit Required Confined Spaces • The PRT chain locker requires a permit because the atmospheric hazard must be eliminated each time the space is entered. • The space has to be ventilated long enough to displace oxygen deficient atmospheres caused by the rusting process. • Atmosphere isn’t the only hazard in a chain locker. What other hazards are there?

Confined Space Permits The permit requires the entry/ rescue team to: • Evaluate potential hazards in the space • Conduct a Job Safety Analysis on how to accomplish the work and • Have a rescue plan ready in case the entrant cannot get himself out of the space

Entry Team – All members should • Be familiar with the hazards of the space • Recognize the symptoms and consequences of oxygen deprivation • Understand how to use the oxygen tester • Keep unauthorized personnel out of the space • STOP WORK if they are unsure of their duties or see a potential hazard that has not been addressed

You are halfway through. Now may be a good time for a break…

Part IIAccessing the Space • Any conditions that make it unsafe to remove an entry cover must be eliminated before the cover is removed. (pressure, fumes) • There have been multiple incidents where people outside of the space became overwhelmed by fumes coming from the space.

Accessing the Space When entrance covers are removed, the opening must be guarded to prevent accidental falls into the opening, and protect workers inside from objects entering the space.

Don’t be an … Put up barricades or warnings to protect your coworkers!! Even if it’s just open “for a little while”.

Testing the Atmosphere • Gas testers on TDI vessels only test for oxygen. • We do not carry hazardous cargoes that would require testing for other hazardous gasses. Oxygen is tested first because many meters will not detect other contaminants in low oxygen environments.

Testing The Atmosphere • Be sure to test the atmosphere at different levels in the space. • Good air near the opening of the space does not mean that there is good air at the bottom. Good Air Poor Air Deadly Air

Oxygen Readings on the permit • Oxygen MUST READ between 19.5% and 21.5% to enter • at ALL levels in the space. • If not, SCBA is required!!

Continuous Forced Air Ventilation The ventilation must: • Eliminate the hazard. • Be directed to the immediate work space of the entrant. • Be from a clean source and not increase the hazard in the space. • The atmosphere in the space must be periodically tested to ensure effective ventilation.

Eliminate hazard- get all bad air out Don’t just ventilate the top!! The deadly air is at the bottom! Proper ventilation technique is important.

Ventilate from bottom up long enough to displace all the air at least once.

Put the fresh air close to where the worker will be.

Make sure air you are putting in is CLEAN

Communication • Create a communication plan before entering. • May be verbal communication or radios. • Test the comms system before starting work. • Comms must have enough power to last the length of the work. If using radios, make sure they work in the space and that the batteries are fully charged.

Monitoring Work In The Space It is important to remain in frequent contact with employees in the space. Be alert for: • Changes in behavior. • An unexpected stop in work. • New or changing hazards.

Performing Work In The Space • Do not perform work that was not in the JSA. • If new work needs to be performed, exit the space and conduct a brief JSA on the new work. • Always use the proper tools for the job. • If you start to feel tired or ill, exit the space immediately. Workers who start work that was not included in the JSA risk introducing new hazards to the space.

Evacuating The Space • If new hazards arise, evacuate the space immediately! • Stick to the rescue plan!! • Do not attempt an unplanned rescue-- this is where most confined space fatalities occur. • Determine how the hazard developed and implement protective measures before allowing re-entry.

Completing the Work • Employees then return the space to its normal condition. • Once the work has been completed, the Entry Supervisor completes the permit.

Confined Space Safety