1. © 1 Confined Space Entry Issues Craig Schroll, CSP, CUSA FIRECON Craig@FIRECON.com

2. © 2 Overview of Program Overall confined space issues Ways to address these issues Strategies for entries Types of confined spaces Hot work

3. © 3 The Problem We continue to kill & injure people Lack of warning Lucky versus smart

4. © 4 Compliance Remember that compliance is the price of admission not the achievement of excellence.

5. © 5 OSHA Information Standard Compliance Instruction Interpretive letters All are available on the web site – www.osha.gov

6. © 6 Other Standards ANSI Z117 NFPA API International Australian United Kingdom European Union

7. © 7 Hazard + Exposure = Risk

8. © 8 Risk Assessment

9. © 9 Example of a Risk Assessment Matrix  - Severity of Injury or Illness Consequence and Remedial Action --  Likelihood of OCCURRENCE or EXPOSURE For selected Unit of Time or Activity CATASTROPHIC Death or permanent total disability C RITICAL Disability in excess of 3 months MARGINAL Minor injury, lost workday accident NEGLIGIBLE First Aid or Minor Medical Treatment Frequent Likely to Occur Repeatedly HIGH Operation not permissible HIGH Operation not permissible SERIOUS High Priority Remedial action MEDIUM Take Remedial action at appropriate time Probable Likely to occur several times HIGH Operation not permissible HIGH Operation not permissible SERIOUS High Priority Remedial action MEDIUM Take Remedial action at appropriate time Occasional Likely to occur sometime HIGH Operation not permissible SERIOUS High Priority Remedial action MEDIUM Take Remedial action at appropriate time LOW Risk Acceptable: Remedial Action Discretionary Remote Not likely to occur SERIOUS High Priority Remedial action MEDIUM Take Remedial action at appropriate time MEDIUM Take Remedial action at appropriate time LOW Risk Acceptable: Remedial Action Discretionary Improbable Very unlikely – may assume exposure will not happen MEDIUM Take Remedial action at appropriate time LOW Risk Acceptable: Remedial Action Discretionary LOW Risk Acceptable: Remedial Action Discretionary LOW Risk Acceptable: Remedial Action Discretionary

10. © 10 Design Eliminate the confined space Eliminate the need for entry Eliminate hazards Minimize risk

11. © 11 Eliminate Confined Space Change access Design in hazard elimination

12. © 12 Eliminate Need for Entry Design space/process to not require internal maintenance Access ports Pull out panels Pull up equipment i.e. pumps

13. © 13 Eliminate Hazards Design confined space with hazard elimination in mind For example, improved isolation systems

14. © 14 Minimize Risk Reduce number of entries Reduce duration of entries Reduce number of personnel

15. © 15 Types of Spaces Confined space Permit-required confined space Reclassified space Space eligible for alternate procedures Non-permit space

16. © 16 Confined Space Large enough to bodily enter Limited or restricted access Not designed for continuous occupancy Confined Space A space must have all three characteristics to meet the confined space definition.

17. © 17 Permit-Required Confined Space Has or has the potential to contain a hazardous atmosphere? Oxygen deficient (19.5% or less) Oxygen enriched (23.5% or more) Flammable (10% LEL or more) Toxic (above PEL) Combustible dust (at or above LEL) Other IDLH

18. © 18 Permit-Required Confined Space Has the potential for engulfment? Engulfment may occur by materials being introduced or removed from the space or by an entrant being drawn down into materials.

19. © 19 Permit-Required Confined Space Internal configuration hazard? Has an internal configuration such that an entrant could be trapped or asphyxiated by inwardly converging walls or by a floor which slopes downward and tapers to a smaller crosssection.

20. © 20 Permit-Required Confined Space Any other recognized serious safety or health hazard? Other hazards capable of causing death, serious physical harm, or interfering with the entrants ability to escape.

21. © 21 Non-Permit Confined Space Does not contain or, have potential to contain any hazard capable of causing death or serious physical harm.

22. © 22 Reclassification No atmospheric hazards Eliminate all hazards Document reclassification Certification available to employees

23. © 23 Elimination versus Control Elimination means hazard cannot return during entry operation. Control means that return of hazard is possible if control measures fail.

24. © 24 Alternate Procedures Atmosphere is only hazard Ventilation can make space safe Monitoring data Data available to employee

25. © 25 Alternate Procedures Safe to remove entry cover Guard opening Test atmosphere Continuous ventilation Periodic atmospheric testing Written certification

26. © 26 Examples

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32. © 32 Recognition Recognition of an area as a confined space is a critical first step to safe operations.

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34. © 34 Confined Space Hazards Atmospheric Content Potential Energy Environment in Space Configuration of Space Nature of Work External Miscellaneous

35. © 35 Sources of Hazards Inside the space External to the space From the work

36. © 36 General Requirements Evaluate workplace Inform employees Develop & Implement written program

37. © 37 Programs General policy Specific guidelines Training requirements Permit system

38. © 38 Programs Supervisor’s role Employee’s role Contractor procedures Emergency procedures Monitoring system

39. © 39 Confined Space Policy & Procedures Simple Brief Useful Clearly communicated Consistently enforced

40. © 40 Evaluating Your Confined Spaces

41. © 41 Confined Space Inventory Survey entire facility Identify all potential CS Classify spaces Maintain documentation

42. © 42 Confined Space Evaluation Evaluate prior to entry (OSHA) Evaluate initially from a practical perspective Equipment Procedures Training

43. © 43 Confined Space Evaluation Must be conducted Maintain documentation May be electronic May be a form Actually use the information Update at least annually Teach people to do review prior to entries

44. © 44 Safe System of Work Risk assessment Hazard evaluation Work process that eliminates hazards when possible and controls them when not Safe system of work Catch variations

45. © 45 Planning Entry Is entry necessary? Work plan Space preparation Permit Briefing

46. © 46 Briefing Briefing Hazards Permit items Job tasks Emergency procedures

47. © 47 Job Surveys Inspect area Review work Confirm safety issues Review preparations Check PPE Check equipment & supplies

48. © 48 Entry Supervisors Role is much more than a signature on a form Actually evaluate and resolve hazards

49. © 49 Training Establish and maintain competence All personnel involved in entries must be competent

50. © 50 Program Audit Review permits Update surveys Update policies & procedures Update training Review equipment condition & needs Job site surveys

51. © 51 Hot Work Numerous safety & health issues A few specific to confined space work Ventilation Introduction of ignition source Heating can contribute to release of contaminants

52. © 52 Q & A