What you need to do prior to working a confined space job

Patrick Basil, Senior Safety Manager at Michels

Confined space work is one of the most hazardous activities that one can be involved with. An estimated six fatalities and 812 injuries occur yearly in the construction industry. They occur due to accumulation of hazardous vapors and gases or displacement of oxygen in spaces. Some of the gases can be odorless and tasteless. Burns, systemic poisoning, drowning and explosive (LEL) atmosphere all can lead to injury and death. Prior to starting work, one should review your companies’ policies and the latest regulations on Confined Spaces in Construction (29 CFR Part 1926.1201 Subpart AA issued in May of 2015).

Defined by OSHA: A confined space has limited or restricted means for entry or exit and is not designed for continuous occupancy. Confined spaces include, but are not limited to, tanks, vessels, silos, storage bins, hoppers, vaults, pits, manholes, tunnels, equipment housings, ductwork, pipelines, etc.

When starting to prepare for confined space work your employer is responsible to ensure that workers are trained and are equipped with the required PPE. Basic PPE requirements include Hard Hat, Safety Glasses, Steel or composite boots, FRC (disposable clothing if required) in good condition, gloves (appropriate for task), hearing protection. Other PPE may be required depending on conditions.

Meetings with the client to determine hazards that are around the work area. They could also include fall hazards, traffic, pits, loose terrain, contaminate soil etc. Also, any history of products that were in the unit being worked on. This could include flammable powders and liquids, fossil fuels, chemicals, hazardous waste, biohazardous material, radioactive and other products. Any unit that has had flammables liquids and powders may require the use of non-sparking tools, supplied air and special outer wear. See the SDS sheets and discuss with client. Contacting the local fire department or on-site rescue team and let them know that on said date and time this operation will be taking place. This is important that the fire department knows in case they are called to do a rescue operation and they know what it is going on. Do not enter a confined space to rescue someone, unless you are part of the rescue team, authorized and trained to perform rescue duties. Historically the stats show that would-be rescuers, who are not prepared account for 60 percent of fatalities in confined spaces.

When dealing with tanks and vessels you will want documentation that states that the work area is certified clean by a reputable group. All energy sources have been disengaged and made inert. That includes all electrical sources, hydraulic, mechanical, pressurize parts. All hoses, pipes and ventilation need to be separated and capped off to prevent accidental exposures. All these items must follow LOTO (Lock out/ Tag Out) procedures either by the facility or the people doing the work. Any movable parts will need to be blocked off or in some cases made fixed during the work.

The workers on a confined space project will be required to have been confined space trained. Do not enter a confined space unless you are authorized and trained additional training may be required depending on site conditions and requirements by your State, Local entities or the customer. They may include site safety training or an orientation. Other training may consist of mask fit testing, lead base testing, SCBA, Safety equipment, fall protection, LOTO, decon and others. Most facilities will also require at least one person in a 5-man crew is Certified in first aid and has certification on site.

Confine space work requires having specialized equipment to perform the work. They include but are not limited to 4 or in some cases a 5-gas monitor. These units need to be calibrated once a month and bump tested daily for use. Records are required to be kept on hand to show that this is being completed. Filters should be replaced as needed and a sniffing wand attachment should be connected to the monitor. The wand should be placed deep inside the units near workers but should be kept off the floor to prevent to wand from sucking up debris or liquids. The monitor needs to be viewable by the hole watch from outside the unit. Lighting in these areas need to be intrinsically sealed to prevent the possibility of a spark. That will include any tools used. Compressed air tools are a safe alternative and can be used with fans as well. Fire extinguishers will be needed on site as well and will require to be service once a year and inspected monthly and noted on a tag or sticker on the unit. The types of extinguishers may vary on materials and products on hand. Harnesses and a safety tripod will be necessary for sites that require a worker to be lowered into him. Prior to start, all workers should be fall protection trained and fitted properly for a harness. A double lanyard and or a retractable lanyard (yoyo) should be used and mounted per the required situation. These items require to be inspected quarterly and documented and tagged (for the color of the quarter) and inspected prior to use. A basic first aid kit, hand washing and toilets, trash bags, drinking water should be available on site.

Signs on the tank (work overhead, emergency response, contact information, confined space, no dark glasses etc.) will be required at entry manway. Other signage may also be required. The use of magnetic signage makes mounting on units easy. Access outside and inside at the manway should be five foot clear.

Ventilation is an especially important part of confined space work. Providing fresh air in these areas help make working in these airs more manageable and can help control temperatures and more possible stagnate air out. Also, it is important to keep any gas-powered equipment minimum twenty feet away from any opening in the unit to prevent exhaust from entering the unit.

Acceptable Entry Conditions

The 3 atmosphere conditions that must be meet for entry are the following:

1. Oxygen content must be above 19.5% and below 23.5%.

2. Explosive gases, vapors & dusts must be below 10% of the Lower Explosive Limit (L.E.L.)

3. The Permissible Exposure Level (P.E.L.) of a substance must never be exceeded except under special circumstances. The P.E.L. is the atmospheric concentration of a substance that a worker may be exposed to for an 8 to 10 hour workday and experience no adverse health effects.

Duties of the Attendant / Hole Watch

1. Knows the hazard that may be faced and symptoms and behavioral changes caused by exposure to these hazards.

2. Make proper notification security, prior to anyone entering the confined space. Notification should then be made when the entry is complete for the day, or the shift has ended.

3. Maintain an accurate count and identity of authorized entrants with a roster or sign in/out sheet.

4. Remain outside the space until relieved.

5. Maintain communication with entrants (i.e., radio, hand signals, voice etc.)

6. Monitors conditions inside and outside of space to ensure safety of entrants.

1. Attendant must order an evacuation if:

a. A prohibited condition exists.

b. Attendant detects a behavioral change.

c. Attendant must leave or cannot safely perform his/her duties.

1. Summon Rescue Services as soon as it is determined entrants need assistance to escape (i.e., radio, hand signals, voice etc.)

2. Warn off and evict unauthorized entrants from the permit space.

3. Shall inform entry supervisor and authorized entrants of unauthorized entry.

4. Performs no other activities that would interfere with duties to monitor and protect entrants.

Performs NON-ENTRY rescue. This includes calling for help on radio or cellphone if permitted. OSHA clearly spells out that unless the attendant has been trained and equipped for rescue operations and has been relieved as attendant that person shall not enter the permit space for rescue purposes.

Duties of the Entrant

1. Know the hazards that may be faced and the signs and symptoms of exposure.

2. Properly use equipment supplied such as:

a. Air monitoring equipment

b. Ventilating equipment

c. Communication equipment

d. All Personal Protective Equipment (P.P.E.)

NOTE:    All confined space entries may require the entrant to wear a full body harness inside of the confined space.

1. Communicate with attendant as needed so that attendant may initiate rescue operations, if needed.

2. Alert the attendant when the entrant detects any warning signs or symptoms or a prohibited condition.

3. Exit the permit space immediately when:

a. An order to evacuate is given by attendant or entry supervisor.

b. Entrant detects a hazard or evacuation alarm is sounded.