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This course covers the role of confined spaces in today's industry, OSHA requirements, hazards, hazard recognition and control, confined space assessment techniques, fall protection systems, rescue and retrieval requirements. It is based on the 29 CFR 1910.146 standard.
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CONFINED SPACE OPERATIONS CORPORATE SAFETY TRAINING 29 CFR 1910.146 WELCOME
COURSE OBJECTIVES • Establish Confined Space’s Role in Today’s Industry. • Discuss OSHA’S requirements for Confined Spaces. • Discuss Principle Hazards involved with CS Entry. • Discuss Basic Skills in Hazard Recognition & Control. • Discuss Confined Space Assessment Techniques. • Discuss Confined Space Fall Protection Systems. • Discuss Hazards Associated with Fall Protection. • Discuss Rescue and Retrieval Requirements.
BASIS FOR THIS COURSE • 1.6 Million Workers Enter Confined Spaces Annually. • The Standard is Expected to Reduce Accidents by 85%. • Untrained Rescuers Account for 60% of Annual Deaths. • Most workers who survive lose time from their job. • This training helps improve: • Safety • Morale • Productivity • Employee well-being
FORWARD The key to horizontal entries into complex confined spaces is extraordinary preplanning, preparation, equipping and practice. Actual removals using volunteers or dummies to get the feel of real life victim handling is essential. Plan for all eventualities that could conceivably occur. Failing to plan means planning to fail. Billy N. Ring, Fire Captain Dayton Regional HAZMAT Coordinator 27 Years Experience
DANGER CONFINED SPACE PERMIT REQUIRED JP4 APPLICABLE REGULATIONS 29CFR - SAFETY AND HEALTH STANDARDS 1910 - INDUSTRIAL SAFETY 146 - CONFINED SPACE STANDARD
DANGER CONFINED SPACE PERMIT REQUIRED COMPLIANCE TIMETABLE 29CFR 1910.146 • JAN 14, 1993 - ENACTED • APR 15, 1993 - FINAL RULE TOOK EFFECT
APPLICABLE REGULATIONS CONTENTS OF 29 CFR 1910.146: • a. Scope and Application - practices and procedures • b. Definitions • c. General Requirements • d. Permit-Required Confined Space Program • e. Permit System • f. Entry Permit • g. Training Requirements • h. Duties of Authorized Entrants • i. Duties of Attendants • j. Duties of Entry Supervisors • k. Rescue and Emergency Services
APPLICABLE REGULATIONS APPENDICES TO 29 CFR 1910.146: 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 Entry Permit (Non-mandatory) Appendix E - Sewer System Entry (Non-mandatory)
APPLICABLE REGULATIONS ANSI - Z359.1 - 1992 SAFETY REQUIREMENTS FOR PERSONAL FALL ARREST SYSTEMS, SUBSYSTEMS AND COMPONENTS ANSI - A10.14 - 1991 REQUIREMENTS FOR SAFETY BELTS, LANYARDS AND LIFELINES FOR CONSTRUCTION AND DEMOLITION USE
GENERAL PROGRAM REQUIREMENTS ALL EMPLOYERS MUST: • INSTITUTE SAFE WORK PRACTICES • REVIEW JOB SPECIFIC CS HAZARDS • CONDUCT CS HAZARD ASSESSMENTS • POST DANGER SIGNS NEAR CONFINED SPACES • CERTIFY THAT ASSESSMENTS HAVE BEEN DONE • PROVIDE TRAINING TO ALL REQUIRED EMPLOYEES • COORDINATE CS OPERATIONS WITH CONTRACTORS • INSTALL ENGINEERING CONTROLS WHERE POSSIBLE • INSTITUTE ADMINISTRATIVE CONTROLS WHERE POSSIBLE • CONTROL HAZARDS USING PPE AS A LAST RESORT
TRAINING REQUIREMENTS • THE EMPLOYER MUST PROVIDE TRAINING: • CS ENTRY REQUIREMENTS. • RECOGNITION OF CS HAZARDS. • THE LIMITATIONS OF CS EQUIPMENT. • THE PROPER USE OF CS EQUIPMENT. • WHEN CS EQUIPMENT IS NECESSARY. • WHAT CS EQUIPMENT IS NECESSARY. • CARE AND MAINTENANCE OF CS PPE. • TRAINING MUST ESTABLISH PROFICIENCY. • TRAIN ALL EMPLOYEES PRIOR TO JOB ASSIGNMENT.
RETRAINING REQUIREMENTS • REQUIRED WHEN THERE IS A: • CLOSE-CALL EVENT • PROGRAM RELATED INJURY • CHANGE IN JOB ASSIGNMENT • NEW CS HAZARD OR EQUIPMENT • NEW CS HAZARD CONTROL METHODS • FAILURE IN THE CS SAFETY PROCEDURES • REASON TO DOUBT EMPLOYEE PROFICIENCY
Reduce fatalities. Reduce injury and illness rates. Acceptance of high-turnover jobs. Workers feel better about their work. Reduce workers’ compensation costs. Elevate OSHA compliance to a higher level of awareness. CONFINED SPACE TRAINING IS IMPORTANT A GOOD PROGRAM WILL HELP:
DEDICATION PERSONAL INTEREST MANAGEMENT COMMITMENT PROGRAM IMPLEMENTATION IMPLEMENTATION OF A CONFINED SPACE PROTECTION PROGRAM REQUIRES: NOTE: UNDERSTANDING AND SUPPORT FROM THE WORK FORCE IS ESSENTIAL, WITHOUT IT THE PROGRAM WILL FAIL!
Establish responsibility Establish policy and develop rules Conduct a confined space hazard analysis of the facility Determine appropriate confined space hazard control measures Eliminate confined spaces where possible Provide protection where hazard elimination is not possible Conduct training Perform inspections and maintenance Periodically audit the program Modify policies and rules as appropriate PROGRAM IMPLEMENTATION Continued DEVELOPMENT SEQUENCE:
The initial goal should be to reduce or eliminate confined space hazards by: 1. Elimination or substitution of equipment having confined spaces 2. Implementing engineering controls 3. Providing adequate Warnings to employees 4. Training and procedures 5. Personal protective equipment PROGRAM IMPLEMENTATION Continued DEVELOPMENT SEQUENCE:
IMPLEMENTATION STRATEGY • RECOGNITION • EVALUATION • CONTROL
ASSESSMENT OF CONFINED SPACE HAZARDS: Jobs/areas requiring confined space entries. Jobs/areas having a high CS “close-call” incidence. Jobs/areas having had recent operational changes. Jobs/areas with new equipment or processes. New jobs having little or no statistical injury data. IMPLEMENTATION STRATEGY • RECOGNITION
EVALUATION An identification of the nature and location of confined space hazards. CONTROL The introduction of measures designed to eliminate or reduce confined space hazards. Follow-up at predetermined intervals to determine if hazard control measures are effective. IMPLEMENTATION STRATEGY Continued
CONTROL MEASURES CONSIDERATIONS: Capital improvement plan to eliminated spaces. Costs involved in implementing control measures. Length of time necessary for implementation. Level of urgency in implementation. Compatibility with existing controls. Anticipated problems with employee use. IMPLEMENTATION STRATEGY Continued
PRIORITIZATION CONSIDERATIONS: Consequences of an injury at the worksite. Severity of injuries as a result of a CS entry. Likelihood that the operation will have an injury. The length exposure to the confined space hazard. Procedures necessary for retrieval or rescue. IMPLEMENTATION STRATEGY Continued
TRAINING WRITTEN PROGRAM SAFETY COMMITTEE PERMIT USAGE AND ANNUAL REVIEW CONFINED SPACE HAZARD ASSESSMENTS CONFINED SPACE HAZARD PREVENTION AND CONTROL KEY PROGRAM ELEMENTS KEY PROGRAM ELEMENTS INCLUDE:
TRAINING JOB-SPECIFIC HAZARD TRAINING TRAINING FOR FACILITY ENGINEERS ANNUAL AWARENESS TRAINING TRAINING FOR: - Affected employees - Managers - Supervisors - Maintenance personnel KEY PROGRAM ELEMENTS(Continued)
CONFINED SPACE ASSESSMENTS SYSTEMATIC SITE ANALYSIS DEPARTMENTAL SURVEYS JOB HAZARD ANALYSIS KEY PROGRAM ELEMENTS(Continued)
SAFETY COMMITTEE WRITTEN PROGRAM EMPLOYEE INVOLVEMENT TOP MANAGEMENT COMMITMENT REGULAR PROGRAM REVIEW AND EVALUATION KEY PROGRAM ELEMENTS(Continued)
CS HAZARD PREVENTION AND CONTROL ENGINEERING CONTROLS ADMINISTRATIVE CONTROLS OPTIMIZATION OF WORK PRACTICES CONFINED SPACE PPE REDUCTION DANGER JP4 CONFINED SPACE PERMIT REQUIRED KEY PROGRAM ELEMENTS(Continued)
CONSIDER THE FOLLOWING: THE SUPERVISOR’S ROLE • 1. DO (OR GET INVOLVED IN) THE CS HAZARD ASSESSMENTS. • 2. OBTAIN ASSISTANCE (IF NEEDED) FROM EXPERTS IN THE FIELD OF CONCERN. • 3. COMPLETE THE PAPERWORK (WORK ORDERS, POLICY • CHANGES, ETC.) TO MAKE CORRECTIVE ACTIONS. • 4. ATTEND THE SAME TRAINING AS YOUR WORKERS. • 5. FOLLOW-UP ON THE ACTIONS YOU TOOK.
WRITTEN PROGRAMS MUST BE: DEVELOPED IMPLEMENTED CONTROLLED PERIODICALLY REVIEWED WRITTEN PROGRAM
Document meetings. Include CS hazard topics during regular meetings. Encourage employee involvement in the process. Employee complaints, suggestions, or concerns can be brought to the attention of management. Analyze statistical data concerning Confined Space hazards, and make recommendations to management for corrective action. Follow-up is critical. SAFETY COMMITTEE COMMITTEES SHOULD:
Consider safety posters, brochures etc. Consider implementation of a suggestion program. Consider incentive programs. SAFETY COMMITTEE Continued COMMITTEES SHOULD:
Confined Space hazard assessments. Job hazard analysis assessments. Employee surveys. Review of results of facility evaluations. Analysis of trends in confined space injury rates. Up-to-date records of logs of confined space hazard improvements tried or implemented. Before and after surveys/evaluations of job/worksite confined space protection changes. PROGRAM REVIEW & EVALUATION EVALUATION TECHNIQUES INCLUDE:
INDUSTRIAL HYGIENE CONTROLS • ENGINEERING CONTROLS FIRST CHOICE • CS Elimination Equipment Modification • Process Modification Automatic Monitoring Systems • ADMINISTRATIVE CONTROLS SECOND CHOICE • Training Programs Job Rotation/Enlargement • Facility Signage Policy and Procedures • PERSONNEL PROTECTIVE EQUIPMENT LAST CHOICE • Body Harnesses/Belts Head Protection • Atmospheric Monitors Respiratory Equipment
WORKSITE ANALYSIS IS DIVIDED INTO FOUR MAIN PARTS: WORKSITE ANALYSIS 1. Gathering information from available sources. 2. Conducting baseline screening surveys to determine which equipment, areas or jobs need a closer analysis. 3. Performing confined space assessments and job hazard analyses to identify hazards. 4. After implementing control measures, conducting periodic surveys and follow-up to evaluate changes.
CONFINED SPACE OPERATIONS SCENARIOS • WORK INVOLVING: • Pits • Silos • Tanks • Vaults • Hoppers • Storage Bins • Chemical Tanks • Reactor Vessels • Railroad Tank Cars • Machinery Enclosures
NO PROBLEM I CAN WELD ANYTHING! JP4 CONFINED SPACE DEATHS • MOST DEATHS OCCUR BECAUSE: • Employees are unaware of the potential hazard. • Employees are uneducated of the potential hazard. • Employees are poorly equipped to manage the • resulting situation.
JP4 CONFINED SPACE DEATHS Continued • MOST DEATHS OCCUR BY: • Asphyxiation due to hazardous atmospheres. HELP! I FEEL DIZZY!!!
OXYGEN CONTENT (% BY VOLUME) EFFECTS AND SYMPTOMS 19.5% Minimum permissible oxygen level. 15-19.5% Decreased ability to work strenuously. May impair coordination. 12-14.9% Respiration increases, judgment affected 10-11.9% Lips begin to turn blue. 8-9.9% Mental failure, nausea and vomiting. 6-7.9% 8 Minutes, 100% fatal 6 Minutes, 50% fatal 4 Minutes, recovery with treatment 4-5.9% Coma in 40 seconds then death CONFINED SPACE DEATHS Continued APPROXIMATE VALUES
CONFINED SPACE DEFINITIONS Continued • CONFINED SPACE: • Limited or restricted means of entry and exit • Not designed for continuous human occupancy • Large enough and so configured to enter for work • NON-PERMIT CONFINED SPACE: • No potential to develop hazards • No atmospheric, safety, or health hazards
JP4 CONFINED SPACE DEFINITIONS Continued • PERMIT REQUIRED CONFINED SPACE: • Contains a hazardous atmosphere or the potential • Contains engulfment potential • Internal configuration that could trap an entrant • Contains any other serious safety or health hazard
CONFINED SPACE DEFINITIONS Continued • ATMOSPHERIC HAZARD: • May expose employees to risk of death, incapacitation, impairment of ability to self-rescue, injury, or acute illness from one or more of the following causes: • Flammable gas, vapor, or mist exceeding 10% LEL • Airborne combustible dust in excess of its LEL (5 ft) • Oxygen concentration below 19.5% • Oxygen concentration above 23.5% • Concentration of any substance exceeding its PEL • Another atmospheric condition that is IDLH
CONFINED SPACE DEFINITIONS Continued • ATTENDANT: • - An observer stationed OUTSIDE of a confined space. • AUTHORIZED ENTRANT: • - A worker authorized to ENTER a confined space. • ENTRY SUPERVISOR: • - The worker responsible for OVERSEEING confined • space entry operations, permit signing and safety • conformance.
CONFINED SPACE DEFINITIONS Continued PERMISSIBLE EXPOSURE LIMIT (OSHA): • PERMISSIBLE EXPOSURE LIMITS (PEL’s) • FOUND IN 29 CFR 1910.1000 (THE “Z” TABLES) • ESTABLISHES OSHA’s EXPOSURE LEVELS • LEGALLY ENFORCEABLE RECOMMENDED EXPOSURE LIMITS (NIOSH): • RECOMMENDED EXPOSURE LIMITS (REL’s) • USED TO DEVELOP NEW OSHA STANDARDS • FOUND IN: “NIOSH RECOMMENDATIONS FOR OCCUPATIONAL • HEALTH STANDARDS”
CONFINED SPACE DEFINITIONS Continued THRESHOLD LIMIT VALUE The TLV is the upper limit of a toxin concentration to which an average healthy person may be repeatedly exposed on an all-day, everyday basis without suffering adverse health effects. Gaseous substances - usually expressed as parts per million (ppm). Fumes or mists - expressed in milligrams per cubic meter (mg/m3). American Conference of Governmental Industrial Hygienist (ACGIH).
CONFINED SPACE DEFINITIONS Continued IMMEDIATELY DANGEROUS TO LIFE & HEALTH An IDLH level represents a maximum concentration from which one could escape within 30 minutes without experiencing any irreversible adverse health effects. In practice, when the concentration of a toxic substance in a given area is known, IDLH levels may be used for determining whether self-contained breathing apparatus is needed when entering the area. If the concentration exceeds the IDLH level, positive- demand, self-contained breathing apparatus should be used.
CONFINED SPACE DEFINITIONS Continued UPPER FLAMMABLE LIMIT (UFL) The “richer” point at which a mixture of flammable vapor and air will no longer support combustion LOWER FLAMMABLE LIMIT (LFL) The “leaner” point at which a mixture of flammable vapor and air will no longer support combustion COMBINED, THE ABOVE EQUAL THE FLAMMABLE RANGE
100% 75% 50% 13% 2.5% 0% CONFINED SPACE DEFINITIONS Continued PERCENTAGE OF ATMOSPHERE ACETONE FLAMMABLE RANGE OF ACETONE 2.5 - 13%
RESPONSIBILITIES • ENTRANT DUTIES: • Know the hazards associated with the space • Follow the instructions on the permit • Use required equipment properly • Continually communicate with attendant • Alert the attendant when necessary • Exit the space quickly when so required
RESPONSIBILITIES Continued • ATTENDANT DUTIES: • Know the hazards associated with the space • Be aware of the effects of hazardous exposures • Maintain accountability of entrants • Remain on duty until properly relieved • Monitor the status of the entrant as appropriate • Communicate with the entrant as appropriate • Monitor activities inside and outside the space • Order evacuation of the space when dictated • Summon rescue and/or emergency assistance • Perform non-entry rescue in accordance with policy • Perform no duties that interfere with attendant duties
RESPONSIBILITIES Continued • ENTRY SUPERVISOR DUTIES: • Know the hazards associated with the space • Ensure all entries on the written permit are appropriate • Ensure all tests, procedures and equipment are used • Terminate entry authorization when appropriate • Verify that rescue services are available • Verify methods are in place to summon rescue services • Remove unauthorized individuals attempting spaces • Determine when transfer of responsibility takes place • Ensure operations are consistent with the permit • Perform non-entry rescue in accordance with policy • Perform no duties that interfere with supervisor duties
CONTRACTORS CONSIDERATIONS • HOST RESPONSIBILITIES: • Inform the contractor that permits spaces exist • Apprise the contractor of known hazards • Apprise the contractor of precautions & procedures • Coordinate entry operations with the contractor • Debrief the contractor at termination of operations • Determine when transfer of responsibility takes place • Ensure operations are consistent with the permit