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Subpart J Confined Spaces. 29 CFR 1910.146. Background. OSHA estimates 239,000 general industry establishments employing over 12 million workers have confined spaces More than 4.8 million Permit Required Confined Spaces and millions more non-permit confined spaces
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Subpart JConfined Spaces 29 CFR 1910.146
Background • OSHA estimates 239,000 general industry establishments employing over 12 million workers have confined spaces • More than 4.8 million Permit Required Confined Spaces and millions more non-permit confined spaces • Over 30 different industries are affected by the hazards of confined space entry • BLS(2002) reports an average of 20 fatalities per year from confined space hazards
What kills people in confined spaces? • They _________ from lack of oxygen. • They are exposed to _________ chemicals. • They are killed by ______ or ________. • They are __________ by cave-ins. • They are __________ by unstable material. • They sustain _______ injuries from falls. • They are ______ __ objects or equipment.
What kills people in confined spaces? • They suffocate from lack of oxygen. • They are exposed to toxic chemicals. • They are killed by fire or explosions. • They are crushed by cave-ins. • They are engulfed by unstable material. • They sustain fatal injuries from falls. • They are struckby objects or equipment.
Why? • Why do we have a confined space standard? • 122 confined space accidents each year lead to 173 fatalities • 60% of the fatalities occurred during rescue attempts
Why? (continued) • Intended to protect workers from • toxic, flammable, explosive, or asphyxiating atmospheres • possible engulfment • any otherrecognized serious hazard (example - hazardous energy) • The standard focuses on areas with immediate health or safety risks, denoting them as “Permit Required Confined Space”
Chronology of 29 CFR 1910.146 • Advanced Notice of Proposed Rulemaking (ANPR) for General Industry July 24, 1975 and Oct 19, 1979 • ANPR for Construction Industry March 25, 1980 • Public Meetings held May, 1980 in Houston, Denver and Washington, D.C. • General Industry Proposed Standard June 5, 1989 • Hearings held Nov 14 & 15, 1989 in Washington, D.C., Dec 5 & 6, 1989 in Houston and Jan 30 - Feb 1, 1990 in Chicago • Public Record closed November 9, 1990 • Final Rule published Jan 14, 1993; effective April 15, 1993 • Final Rule changes published December 1, 1998; effective February 1, 1999
General Industry Standard • 29 CFR 1910.146 • (a) Scope • (b) Definitions • (c) General Requirements • (d) Permit-Required confined space program • (e) Permit system • (f) Entry permit • (g) Training
General Industry Standard • 29 CFR 1910.146 • (h) Duties of authorized entrants • (i) Duties of attendants • (j) Duties of entry supervisors • (k) Rescue and emergency services • (l) Employee participation
General Industry Standard • 29 CFR 1910.146 Appendices • Appendix A – Permit-required confined space decision flow chart • Appendix B – Procedures for atmospheric testing • Appendix C – Examples of permit-required confined space programs • Appendix D – Confined space pre-entry checklist
General Industry Standard • 29 CFR 1910.146 Appendices • Appendix E – Sewer system entry • Appendix F – Rescue team or rescue service evaluation criteria (non-mandatory)
December 1, 1998 Changes • Authorized representatives • Observation of testing • Clarified paragraph (k) • Added paragraph (l) • Added Appendix F
Scope and application - (a) • 29 CFR 1910.146 does not apply to: • Agriculture • Construction • Shipyards
Common Confined Spaces • Degreaser, Furnace • Pit, Pumping Station • Septic Tanks, Sewage Digestors • Silos, Barges • Manholes • Trenches, Shafts
How to Identify Confined Spaces • Limited Openings for Entry and Exit; and • Is large enough and so configured that an employee can bodily enter and perform assigned work; and • Not Designed for Continuous Worker Occupancy
Confined Space Triangle NOT DESIGNED FOR CONTINUOUS OCCUPANCY RESTRICTED ENTRY/EXIT CONFINED SPACE LARGE ENOUGH TO ENTER AND PERFORM WORK
Federal Register Jan 14, 1993 (p. 4477) “While OSHA is concerned that spaces that are too small for complete bodily entry may pose hazards for employees, the Agency did not intend to cover such spaces under the permit space standard.”
Federal Register Nov. 4, 1994 (p. 55208) “Limited - when an employee would be forced to enter or exit in a posture that might slow self-rescue or make rescue more difficult.” Standard Safety Requirements for Confined Spaces (ANSI Z117.1-1995) “Restricted entry and exit means physical impediment of the body, e.g., use of the hands or a contortion of the body to enter into or exit from the confined space”.
Federal Register Nov. 4, 1994 (p. 55208) “For example, even if the door or portal of a space is of sufficient size, obstructions could make entry into or exit from the space difficult. The Agency intended that spaces which otherwise meet the definition of confined spaces, and which have obstructed entry or exits even though the portal is a standard size doorway, be classified as confined spaces.”
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?
Federal Register Jan 14, 1993 (p. 4478) • OSHA believes that the final rule’s definition properly places the focus on the design of the space, which is thekeyto whether a human can occupy the space under normal operating conditions.
Dangerous Combinations • Presence of all three confined space characteristics can complicate the situation. • Working in and around the space. • Rescue operations during emergencies. • Worsened conditions due to work activities: • Welding and cutting, use of bonding agents • Cleaning with solvents, use of other chemicals • Use of gas-powered equipment
Permit Required Confined Space • Contains or has a potential to contain a hazardous atmosphere; • Contains a material that has the potential for engulfing an entrant; • Has an internal configuration such that an entrant could be trapped or asphyxiated by an 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.
Permit Required Confined Space Confined Space VS • Limited Openings for Entry & Egress • Large enough to bodily enter and perform work • Not designed for continuous worker occupancy • Hazardous atmospheres • Engulfment • trapped or asphyxiated by an inwardly converging walls or by a floor • Contains any other recognized serious safety or health hazard
Hazardous Atmosphere • Means an atmosphere that may expose employees to the risk of death, incapacitation, impairment of ability to self-rescue (escape from a permit space), injury, or acute illness from one or more of the following causes:
Hazardous Atmosphere • Flammable gas, vapor, or mist in excess of 10% of its lower flammable limit (LFL); • Airborne combustible dust at a concentration that meets or exceeds its LFL; • Atmospheric oxygen concentration below 19.5% or above 23.5%; • Atmospheric concentrations of any substance for which a dose or PEL is published in Subpart G or Z of this Part and which could result in employee exposure in excess of its dose or PEL; • Any other atmospheric condition that is IDLH
Evaluation – (c)(1) • Employers are required to evaluate workplaces to determine if any spaces are PRCS • * Proper application of the decision flow chart in Appendix A would facilitate compliance with this requirement
Categorizing Work Space * Space large enough to enter &; * Limited or Restricted entry or exit &; * Not designed for continuous worker occupancy. NO Not a confined Space YES Confined Space Permit- Required Confined Space Non Permit Required Space Hazardous Atmosphere Or Engulfment Hazard YES NO Or Configuration Hazard Or Any other recognized serious hazard
Signs - (c)(2) • Employees must be informed of the existence of confined spaces through the use of signs, etc. UNAUTHORIZED ENTRY MUST BE PREVENTED
Signs – (c)(2) A sign reading: - DANGER - PERMIT REQUIRED CONFINED SPACE “DO NOT ENTER” or other similar language would satisfy the requirement for a sign.
Ensure No Entry – (c)(3) • If employees will not enter permit spaces, the employer will take effective measures to prevent them from entering • Required to Still comply with paragraphs (c)(1), (c)(2), (c (6), and (c)(8)
Entering Permit Spaces – (c)(4) • If employees will enter permit spaces, the employer shall develop and implement a written permit space program • The written program shall be available for inspection by employee and their authorized representatives
“Changes” - (c)(6) When there are changes in the use or configuration of a non-permit confined space that might increase the hazards to entrants, the employer shall reevaluate that space and, if necessary, reclassify it as a permit-required confined space.
Host Employers – (c)(8) • (i) Inform contractor workplace contains permit spaces and that entry is only allowed through compliance with a permit system • (ii) Appraise the contractor of the elements, including hazards identified and employer’s experience with the space • (iii) Appraise the contractor of any precautions or procedures that have been implemented for the protection of employees in or near the spaces where the contractor will be working
Host Employers – (c)(8) • (iv) Coordinate entry operations with contractor, when both host employer personnel and contract personnel will be working in or near permit spaces • (v) Debrief contactor at conclusion of the entry operations regarding the program followed and any hazards confronted or created in the permit spaces during entry operations
Contractor – (c)(9) • (i) Obtain any available information regarding permit space hazards and entry operaitons • (ii) Coordinate entry operations with host employer • (iii) Inform the host employer of any hazards confronted or created in permit spaces, either through debriefing or during entry operations
Hazards of Confined Spaces • Oxygen Deficient Atmospheres • Oxygen Enriched Atmospheres • Flammable Atmospheres • Toxic Atmospheres • Temperature Extremes • Engulfment Hazards • Noise, Slick/Wet Surfaces, Falling Objects
Oxygen Deficient Atmospheres 19.5 % Minimum acceptable oxygen level. 15 - 19% Decreased ability to work strenuously. Impair coordination. Early symptoms. 12-14% Respiration increases. Poor judgment. 10-12% Respiration increases. Lips blue. 8-10% Mental failure. Fainting. Nausea Unconsciousness. Vomiting. 6-8% 8 minutes - fatal, 6 minutes - 50% fatal 4-5 minutes - possible recovery. 4-6% Coma in 40 seconds. Death
Oxygen Deficient Atmospheres • Exposure to atmospheres containing 12% or less oxygen will bring about unconsciousness without warning and so quickly that individuals cannot help or protect themselves. (Source: Compressed Gas Association Bulletin SB-2)