Confined Space Hazard Awareness WAC 296-809 Introduction Who you are Consultation Information The goal of the presentation is to increase awareness of the hazardous nature of working in a confined space, the steps that can be taken to reduce the hazards, and what the standard is asking for. Chuck Durham Industrial Hygienist durc235@lni.wa.gov

Objectives What is a Confined Space Confined Space Hazards Do’s and Don’ts Controlling hazards

NIOSH “FACE” Study For confined space fatal incidents: Locations types include: 31% tanks, 26% vats/pits, and 27% sewers 36% involved multiple victims 79% hazardous atmospheres 43% had oxygen deficient atmospheres 29% had toxic atmospheres 7% had flammable atmospheres 21% involved physical hazards Workers can face life threatening hazards in confined spaces. They may be exposed to toxic chemicals, suffocation hazards, fire and explosion hazards. ‘Epidemiology of Confined-Spaces-Related Fatalities” Part I of the FACE Study. (70 incidents and 109 fatalities) The listing above does not include all the statistics from this study.

What is The Definition of a Confined Space WAC 296-809-100

A Confined Space Is a space that is all of the following: Large enough for the whole body to enter and work, and Has limited or restricted means for entry or exit, and Is not designed for continuous employee occupancy Emphasize that a confined space must have all three characteristics, if any one is not present then the space cannot be considered a confined space. Large enough to enter: Restricted entry or exit: OSHA uses the emergency exit rule of thumb, that is, will the configuration of the space restrict the worker’s exit from the space. For example, air locks that have two doors could cause a space to meet the definition of confined if both doors can’t be locked open while workers are inside. Not designed for continuous occupancy: Some equipment vaults may have lighting installed to help the maintenance workers and it may have a forced air ventilation system to help cool the equipment, but if the ventilation was designed solely for equipment cooling and not for the maintenance workers, the space would not be designed or intended for continuous occupation.

Non-Permit Confined Space WAC 296-809-20002 Is a confined space that does not contain actual hazards or potential hazards capable of causing death or serious physical harm.

Hazards found Within Confined Space s Contains or has a potential to contain a hazardous atmosphere, toxic gases, fumes and vapors Contains a material with potential for engulfing or causing asphyxiation Internal configuration that could allow someone entering to be trapped by inwardly converging walls or by a floor which slopes downward and tapers to a smaller cross-section Contains any physical hazard such electrical or mechanical or any other recognized serious safety and health hazard. A Permit-Required Confined Space (PRCS) will meet all three characteristics of a confined space and have any one of these four characteristics*. Any potential hazard as defined by the standard, the space is permit-required. PRCS hazards can be many and varied. See the standard. See also OSHA preamble to the final rule and notes from the Oti course. OSHA CPL Each of these characteristics will be discussed on the following slides.

Confined Spaces That You May Be Familiar With Silos Grain bins Well shafts Chemical tanks Cold storage rooms Hopper rail cars Truck tanks Sewers An atmosphere that may expose employees to the risk of death, incapacitation, impairment of ability to self-rescue (that is, escape unaided from a permit-required confined space), injury, or acute illness caused by one or more of the following: - 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. Note: This concentration may be approximated as a condition in which the dust obscures vision at a distance of 5 feet (1.52 m) or less. - Atmospheric oxygen concentration below 19.5% or above 23.5%. - Atmospheric concentration of any substance which may exceed a permissible exposure limit. For additional information about atmospheric concentration, see chapter 296-62 WAC, Parts F, G, and I, General Occupational Health Standards and chapter 296-841 WAC, Airborne contaminants. An airborne concentration of a substance that isn't capable of causing death, incapacitation, impairment of ability to self-rescue, injury, or acute illness due to its health effects isn't covered by this definition. - Any other atmospheric condition that is immediately dangerous to life or health. You can find guidance on establishing acceptable atmospheric conditions for air contaminants, which have no WISHA-determined doses or permissible exposure limits using other sources of information, such as: - Material safety data sheets required by WAC 296-800-170, Employer Chemical Hazard Communication. - Published information - Internal documents.

Do’s and Don’ts Evaluate the worksite for confined spaces Develop a written program Train employees Provide safety equipment Test the atmosphere if necessary

Confined Space Don’ts Don’t enter unless you have to Don’t enter without a permit Don’t enter without proper PPE Don’t enter without proper training Don’t operate in or around confined spaces with equipment that could cause sparks

Controlling Hazards In Permit-Required Confined Space Post warning signs at the entrance of confined spaces. Limit employee access to confined spaces by using entry barriers or locks. Once you have evaluated and identified the permit-required confined spaces at your workplace, inform employees through signs and/or other equally effective means. If permit-required confined spaces will not be entered, you must still take all measures to prevent entry. Questions: What are effective measures to prevent entry? Physical barriers Permanent closing of the space Reinforce non-entry policy through employee training Special tools Make sure that unauthorized workers do not enter the confined space.

Controlling Hazards (cont). Written program Complete a permit for each entry Extensive employee training Employee assigned duties Question: Ask this before addressing the slide to remind the audience of PRCS hazards. Remember, a PRCS will meet all three characteristics of a confined space and have any one of these four hazard elements we’ve covered. What are the four hazard elements? When workers enter PRCS, WISHA standards require certain preventative measures to be taken to ensure safe entry (Written permit space program). This program includes a written program, entry permits, entry team, rescue plan, and training.

Controls (cont.) Drain or pump out liquid contents, if any. Blank off all in-feeding lines. Air test and ventilate. Continue ventilating constantly. If possible, remove any sludge deteriorate from inside the confined space. Exit space if conditions change Blanking or blinding refers to the absolute closure of a pipe, line, or duct. Ventilation: Blowers and fans provide mechanical dilution ventilation. Blowers need to be explosion proof, and its intake is placed far enough away from any source of contamination. Blanking or blinding: refers to the absolute closure of a pips, line, or duct. Double block or bleed refers to the closure of a line, duct, or pipe by closing and locking or tagging two in-line valves and by opening and locking or tagging a drain or vent valve in the line between the two closed valves.

Entry Permit Describes each individual’s roles and responsibilities, Specifies safety equipment and respiratory protection, Tells how long the job will take, States hazards found in the space includes atmospheric monitoring. Note: Have an example of an entry permit with you so you can go into more specifics, is needed, on what is contained on an entry permit. A written permit space program must be established when spaces cannot be reclassified or alternative procedures cannot be used. An entry permit is a document prepared by the employer or employer representative. The entry supervisor shall sign the entry permit to ensure that acceptable conditions have been attained in the permit space and to authorize entry. The permit shall be posted near the confined space entry for entrants to verify that pre-entry procedures have been completed. Completed permit must be available to the entrants or their authorized representatives. Duration of the permit must not exceed the time required to accomplish the identified task. Canceled permits must be retained for one year to assist in the evaluation of the confined space program. Questions: Communication system is an element to be addressed on the entry permit. What are some different types of communication systems?

Training WAC 296-809-400 Before first assigned duty Before any changes in assigned duty Whenever there is a change in the PRCS Any deviations from the PRCS procedures Inadequacies in employee’s knowledge or use of procedures Annually for rescue team members Employees who work in and around PRCS must be trained in order to acquire the understanding, knowledge, and skills necessary to safely perform their assigned duties. Training must include: Nature of the hazards Procedures to take when exposed to hazards Use of rescue and emergency equipment Verify training through written certification as proficient in their job duties. Must contain each employee’s name, signature of trainer (written, electronic or initials), and dates of training. Note: Have WAC 296-809 available to outline specific training topics for entrant, attendant, entry supervisor. That seems to work better than having them listed on slides.

Rescue and Emergency Services WAC 296-809-50014 Rescue can be performed by another employees or professional rescuers as long as they have been fully trained and qualified to act as a rescuer. You must evaluate both internal and external rescue services. There is a helpful evaluation tool in the helpful tools section WAC 296-809.

Rescue and Emergency Service Non-Entry rescue is preferred Arrange for rescue service from an outside source. Arrange for your own employees to provide rescue. Provide for non-entry rescue. There is no actual training course on rescue systems, employers need to enlist the help of experts. Depending on the severity of the emergency, different rescue methods can be employed. When an emergency is minor, self-rescue is often the best approach. However, if a worker is disabled, it is likely that non-entry or entry rescue will be necessary. Non-entry rescue can be started right away and prevents additional personnel from being exposed to unidentified or uncontrolled hazards. If situations where configuration or the space or other elements prevent non-entry rescue, entry rescue may be the only solution. Entry rescue involves rescuers entering the space to retrieve the entrant(s) and/or provide emergency assistance. An entry rescue plan needs to be developed ahead of time in the event of an emergency for which the non-entry rescue plan is not appropriate. The following example do not meet the requirements: Posting a rescue service’s number without contacting them Planning to rely on 911 emergency services

Rescue Training and Practice Rescue practices in simulated or actual spaces are required at least once every 12 months. More frequently where the employer deems necessary. Rescue teams must be trained and proficient in: The use of PPE and other equipment (air monitoring, rescue) As an entrant of PRCS Safety perform assigned rescue and emergency duties Basic first aid and CPR

Rescue Equipment Rescue equipment may include: Full body harness with retrieval lines Wristlets Hand-cranked mechanical winch with tripod NOTE: A mechanical device must be available from vertical spaces more than 5 feet (1.52 m) deep. Ladders Explosive proof lighting SCBA/SAR Stretchers Proper PPE for confined space

Where do I go to find additional information? http://www.lni.wa.gov/wisha/rules/confinedspace www.cdc.gov/niosh www.osha.gov/ Go live on-line whenever possibly to actually show what these sites look like and what information they contain.

DOSH Consultation Safety & health program review and worksite evaluation Free Confidential By employer invitation only No citations No penalties Letter explains findings Follow-up all serious hazards Risk Management assistance Workshops, classes & video library Safety Consultants - Provide consultation on Physical Safety hazards for voluntary compliance – Machine guarding, LOTO, fall protection, PPE use, etc Industrial Hygiene Consultants – Provide consultation on voluntary compliance for health issues- Hearing loss, confined space, air quality, etc A comprehensive consultation visit will remove your business’s name from the current cycle of scheduled compliance inspections but will not exempt you from imminent danger fatality accident complaint/referral inspections by compliance Comprehensive consultation means a review of injury data, all written safety programs, physical walk through of the entire workplace, written report to the employer and confirmation of correction of all serious hazards identified. Other services available – Risk Managers can give you help in Controlling Your Claims and Premium Costs by providing information and tools to reduce those costs through claims mgt,/ RTW, HR practices, safety and accident preventions (non-code hazards) Ergonomists - Consolation and worksite evaluation to prevent musculoskeletal injuries and risks Video library no charge except return postage by traceable means. http://www.lni.wa.gov/wisha/videocat/default.htm Workshops on a variety of safety topics

Questions