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

2. Objectives Part 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

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

4. 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

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

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

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

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

9. For an Emergency entry only (Category 1):
Emergency entry must follow the requirements of 46 CFR (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. 

10. For an Emergency entry only (Category 1):
The Entrant must 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.

11. 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”.]

12. The Stand by Rescuer must:
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.

13. 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:

14. Permit Required Entry (Category 2):
Supervisor- A Responsible Person must supervise the entry and maintain communications with the bridge.
The Entrant must:
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.

15. 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”.]

16. The Stand by Rescuer must:
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.

17. 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.

18. 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.

19. 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… 

20. 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.

21. How will you know?
TDI has evaluated all the spaces on its vessels and created a Confined and Enclosed Spaces Register in 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”

22. Permit Required Confined Spaces
Permit required when any one of 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.

23. 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!

24. 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?
Effects of Low Oxygen:
% O2 in Air Deep breathing, fast heartbeat, poor attention,
poor thinking, poor coordination
% O2 in Air Faulty judgment, intermittent breathing,
rapid fatigue (possibly causing heart damage),
very poor coordination, lips turning blue
10% or less O2 in Air Nausea (vomiting), loss of movement,
loss of consciousness followed by death
Less than 6% O2 in Air Spasmodic breathing, convulsive movement,
death in approx. eight minutes
4% - 6% O2 in Air
Coma in 40 seconds

25. Chemical fumes in a small space- like bleach in the bathrooms
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
Effects of Low Oxygen:
% O2 in Air Deep breathing, fast heartbeat, poor attention,
poor thinking, poor coordination
% O2 in Air Faulty judgment, intermittent breathing,
rapid fatigue (possibly causing heart damage),
very poor coordination, lips turning blue
10% or less O2 in Air Nausea (vomiting), loss of movement,
loss of consciousness followed by death
Less than 6% O2 in Air Spasmodic breathing, convulsive movement,
death in approx. eight minutes
4% - 6% O2 in Air
Coma in 40 seconds

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

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

28. 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?

29. Other “Serious” Hazards
Extreme temperatures
Mechanical and hydraulic energy
Lighting problems
Noise
Slippery surfaces
The “other serious safety hazard” category is important, and often catches employers unaware. Typically, if any type of operation must occur in a confined space to make it completely safe, it is permit required. This includes lockout tagout, use of PPE, noise control, or any special procedures. Just use this thumb rule: If there is any doubt, then there is no doubt, it is a permit required confined space.
Can you think of other safety hazards?

30. 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.

31. 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?

32. 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
Activity
Distribute your companies Entry permit and discuss how to properly complete the form.

33. 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
Discuss the role of the entry supervisor with participants. Ask them if the supervisor should perform other duties at the same time. Discuss why it is important that the entry supervisor focus on his responsibilities.

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

35. Part II Accessing 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.
What equipment do you have in your work place to secure the opening around a confined space?

36. 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.
What equipment do you have in your work place to secure the opening around a confined space?

37. Don’t be an …
Put up barricades or warnings to protect your coworkers!!
Even if it’s just open “for a little while”.
What equipment do you have in your work place to secure the opening around a confined space?

38. 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.
Atmospheric testing is an important part of any confined space entry. If you do not have someone on staff trained in atmospheric testing, it is good practice to consult with an industrial hygienist
Oxygen is tested first because many meters will not detect other contaminants in low oxygen environments.

39. 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

40. 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!!

41. 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.

42. 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.

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

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

45. Make sure air you are putting in is CLEAN

46. 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.

47. 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.

48. 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.
Discussion Point: What other things should workers be aware of while in a confined space?
Workers who start work that was not included in the JSA risk introducing new hazards to the space.

49. 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.

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

51. Drill Requirements Monthly Full dress out
ALL steps of the process – from filling out the permit to setting up rescue equipment and wearing appropriate PPE, retractable lifelines and SCBA gear – will be followed.
However NO Category 1 space shall be entered as part of the drills.
Important Note: This training program is not sufficient for training for individual entries. The employer must provide training on the specific hazards that are unique to each entry. This can be done by the entry supervisor and documented as part of the preparation for entry.

52. Drill Requirements
In drills, ALL steps of the process – from filling out the permit to setting up rescue equipment and wearing appropriate PPE, retractable lifelines and SCBA gear – will be followed.
However NO Category 1 space shall be entered as part of the drills.
Important Note: This training program is not sufficient for training for individual entries. The employer must provide training on the specific hazards that are unique to each entry. This can be done by the entry supervisor and documented as part of the preparation for entry.

53. Drill Requirements
Enclosed space entry and rescue drills shall include checking and use of:
required PPE
Communication equip/ procedures
Atmospheric tester
Rescue equipment and procedures
First Aid and resuscitation instruction
Important Note: This training program is not sufficient for training for individual entries. The employer must provide training on the specific hazards that are unique to each entry. This can be done by the entry supervisor and documented as part of the preparation for entry.

54. Vanuatu vessels drill on both
The main differences between drills on the BMC and Vanuatu flagged vessels are:
The BMC has no confined spaces that would be entered at sea, so ALL drills are for Emergency Entry only.
Vanuatu vessels drill on both
Permit Entry with atmosphere testing
and Emergency Entries with SCBAs.

55. Completed permits must be retained for at 3 years.
Summary
The Confined Space Entry team consists of an Entry Supervisor, Attendant, Entrant(s) and Stand By Rescuer.
Completed permits must be retained for at 3 years.

56. A Permit Required Confined Space has any one of the following:
Summary
A Permit Required Confined Space has any one of the following:
Atmospheric Hazard
Potential for engulfment or entrapment
Hazardous Configuration
Any serious safety hazards

57. Questions?
Answer any questions and distribute the quiz.