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Confined Space Safety
1006
OR-OSHA 215
INSTRUCTOR VERSION
Workbook pages found on odd numbered pages.
Instructor notes found on even numbered pages.
Instructor version, workbook, and overheads are also available at
www.orosha.org
Education
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Portland Field Office (503) 229-5910
Salem Field Office (503) 378-3274
Eugene Field Office (541) 686-7562
Medford Field Office (541) 776-6030
Bend Field Office (541) 388-6066
Pendleton Field Office (541) 276-9175
Salem Central Office: (800) 922-2689 or
(503) 378-3272
Web Site: www.orosha.org
OR-OSHA Mission StatementTo advance and improve workplace safety and health for all workers in Oregon.
Go online to check out our
Professional Development Certificate Program!
Additional Public Education Services
Safety for Small Business workshops
Interactive Internet courses
Professional Development Certificates
On-site training requests
Access workshop materials
Spanish training aids
Training and Education Grants
Continuing Education Units/Credit HoursFor more information on Public Education services,
please call (888) 292-5247 Option 2
Consultative Services
Offers no-cost on-site safety and health assistance to help Oregon employers recognize and correct safety and health
problems in their workplaces.
Provides consultations in the areas of safety, industrial hygiene, ergonomics, occupational safety and health
programs, new-business assistance, the Safety and Health Achievement Recognition Program (SHARP), and theVoluntary Protection Program (VPP).
Enforcement
Offers pre-job conferences for mobile employers in industries such as logging and construction.
Provides abatement assistance to employers who have received citations and provides compliance and technical
assistance by phone.
Inspects places of employment for occupational safety and health rule violations and investigates workplace safety
and health complaints and accidents.
Appeals, Informal Conferences
Provides the opportunity for employers to hold informal meetings with OR-OSHA on workplace safety and health
concerns.
Discusses OR-OSHAs requirements and clarifies workplace safety or health violations.
Discusses abatement dates and negotiates settlement agreements to resolve disputed citations.
Standards & Technical Resources
Develops, interprets, and provides technical advice on safety and health standards.
Provides copies of all OR-OSHA occupational safety and health standards.
Publishes booklets, pamphlets, and other materials to assist in the implementation of safety and health standards and
programs.
Operates a Resource Center containing books, topical files, technical periodicals, a video and film lending library,
and more than 200 databases.
Public Education & Conferences
Conducts conferences, seminars, workshops, and rule forums.
Presents many workshops that introduce managers, supervisors, safety committee members, and others to
occupational safety and health requirements, technical programs, and safety and health management concepts.
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OR-OSHA 215 Confined Space Safety
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This material is for training use only
Because there are confined spaces in many Oregon workplaces, serious caution should bepracticed to determine if any contain unique problems because of their contents and/orconfiguration. For example, some confined spaces pose entrapment hazards for entrants, whileothers restrict air circulation so that hazardous atmospheres can accumulate. Confinement
itself can increase the risk of injury or death by making employees work closer to hazards thanthey would otherwise. Safety and health professionals have long recognized and directedemployer and employee attention to the significant dangers of confined spaces.
This workshop introduces you to the basic requirements and procedures involved withpermit-required confined spaces as described in OR-OSHA Division 2/Subdivision J 29 CFR1910.146, Permit-Required Confined Spaces. This information is vitally important to all thosewho work in or have responsibility for those who work inpermit-required confined spaces(PRCS). Please feel free to ask questions at any time. If you have experience in confinedspace operations, please participate so that we might all benefit from that experience!
Introduction
Goals
Review criteria for confined spaces and permit-required confined spaces
Describe the hazards which exist in permit-required confined spaces
Describe the steps in developing a permit-required confined space program
Review training requirements
Please Note: This material, or any other material used to inform employers of compliance requirements of Oregon OSHA
standards through simplification of the regulations should not be considered a substitute for any provisions of the Oregon
Safe Employment Act or for any standards issued by Oregon OSHA. This workbook is intended for classroom use only.
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Why is this important?
Two workers died from asphyxiation due to oxygen deprivation one wasattempting rescue. Five workers cleaning a storage tank killed from explosion at refinery. Five farmers overcome by methane fumes from manure pit. Four of the deaths
were from rescue attempts. There was about a foot of manure in the 12-foot deeppit.
Wastewater supervisor died entering manhole deficient of oxygen. Secondsupervisor died attempting rescue.
Two wastewater worker drowned when pipe gallery flooded during entry.
Meter reader died due to methane and CO in a meter vault.
Maintenance worker drowned in wet well.
Two sewer workers and police officer died at bottom of pumping station. Worker died entering 8 foot vault to bleed line.
Worker died when inflatable sewer plug bursts.
Two workers drown with sewer plug fails. Worker died from asphyxiation while working inside residential sewer. Two dead and five injured from asphyxiation in Oregon.
and the list goes on and on
Rescuers account for over 60% of all confined space fatalities!
More fatals can be found from the Fatality Assessment and ControlEvaluation surveillance program at www.cdc.gov/niosh (national) andwww.croetweb.com (Oregon).
Wonderful info on confined space safety found at the above two websitesplus www.osha.gov and www.orosha.org
A video I have used at the beginning of this class is Inside Maneuvers from Coastal.Also, many videos available through OR-OSHAs Resource Center.
OR-OSHA has a very good general publication on permit-required confined spacestitled, Not designed to be occupied - How to work safely in a permit-required confinedspace (Pub. #2864).
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Evaluate Your Workplace
1. Does your workplace contain confined spaces?
A confined space is...
Large enough for the whole _______ to enter and work, and
Has ___________ entry or exit, and
Is not _____________ for continuous occupancy.
If not a permit-required confined space, other rules may stil l apply such as Hazard Communication,Lockout/Tagout, Personal Protective Equipment, Welding, etc.
Apermit-required confined space is a confined space that contains
one or more of the following characteristics...
Restricted (or limited) entry or exit exists when an entrants abilityto self-rescue is hindered. Common examples include smallopenings, ladders, and long tunnels.
The OR-OSHA standard applies only to permit-required confined spaces.
However, a permit-required confined space must be a confined space first.
2. Does your workplace contain permit-required confinedspaces?
Contains or potentially contains a hazardous a________________, or
Has potential for e_________________, or
Has dangerous c__________________, or
Contains any other recognized serious safety or health h___________.
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1. Does your workplace contain confined spaces?
A confined space is...
Large enough for the whole body to enter and work, and
Has restricted entry or exit, and
Is not designed for continuous occupancy.
Important
If not a permit-required confined space, other rules may still apply such asHazard Communication, Lockout/Tagout, Personal Protective Equipment,
Welding, etc. Remember, welding has its own confined spacerequirementsfound at OR-OSHA Div 2/Sub Q.
Apermit-required confined space is a confined space that
contains one or more of the following characteristics...
Restricted (or limited) entry or exit exists when an entrants ability to self-rescue is hindered. Common examples include small openings, ladders, and
long tunnels. Have class come up with more examples.
2. Does your workplace contain permit-requiredconfined spaces?
Contains or potentially contains a hazardous atmosphere, or
Has potential for engulfment, or
Has dangerous configuration, or
Contains any other recognized serious safety or health hazard.
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Hazardous Atmospheres
Evaluating Permit-Required
Confined Spaces
Examples of permit-required confined spaces include tanks, sewers, hoppers, vaults, boilers,silos, pits, vats, bins, pipes, and manholes.
The leading cause of death in permit-required confined spaces are hazardous atmospheres.
A hazardous atmosphere means an atmosphere that may expose employees to the risk of death,
incapacitation, impairment of ability to self-rescue (escape unaided from a permit space),injury, or acute illness from one or more of the following causes:
Oxygen concentration below 19.5% or above 23.5%
Flammable gas, vapor, or mist in excess of 10% of its lower explosive limit (LEL)
Combustible dust at a concentration that meets or exceeds its LEL
Atmospheric concentration in excess of any substances published dose orpermissible exposure limit (PEL) which is capable of causing death, incapacitation,impairment of ability to self-rescue, injury, or acute illness due to its health effects
Any other atmospheric condition that is immediately dangerous to life or health
* Permissible exposure limits can be found in OR-OSHA Div 2/Sub G Occupational Healthand Environmental Controls and OR-OSHA Div 2/Sub Z Toxic and Hazardous Substances.Other sources include material safety data sheets.
You must do air monitoring to determine if
a hazardous atmosphere exists.
Atmospheric conditions in a confinedspace can change very quickly.
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Examples of permit-required confined spaces include tanks, sewers, hoppers,vaults, boilers, silos, pits, vats, bins, pipes, and manholes. Have class come up withmore examples.
Although excavations and trenches are covered under OR-OSHA Div 3/Sub P, Ioften emphasize the potential for hazardous atmospheres developing outdoors intrenches and excavations.
Emphasize - The leading cause of death in permit-required confined spaces arehazardous atmospheres.
A hazardous atmosphere means an atmosphere that may expose employees to therisk of death, incapacitation, impairment of ability to self-rescue (escape unaided
from a permit space), injury, or acute illness from one or more of the followingcauses:
Oxygen concentration below 19.5% or above 23.5%
Flammable gas, vapor, or mist in excess of 10% of its lower explosive limit(LEL)
Combustible dust at a concentration that meets or exceeds its LEL
Atmospheric concentration in excess of any substances published dose orpermissible exposure limit (PEL) which is capable of causing death,incapacitation, impairment of ability to self-rescue, injury, or acute illness due
to its health effects Any other atmospheric condition that is immediately dangerous to life or
health
* Permissible exposure limits can be found in OR-OSHA Div 2/Sub G OccupationalHealth and Environmental Controls and OR-OSHA Div 2/Sub Z Toxic andHazardous Substances. Other sources include material safety data sheets.
Atmospheric conditions in a confined space can change quickly!
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Oxygen Level {too high or too low?}
23.5% and above = High
20.8 - 21% = Normal
19.5% and below = Deficient
16 - 12% O2 in air generally causes deep breathing, fast heartbeat, poor attention, poor
thinking, and poor coordination.
14 - 10% O2 in air generally causes faulty judgment, intermittent breathing, rapid fatigue
(possibly causing heart damage), very poor coordination, and lips turning blue.
10% or less O2 in air generally causes nausea (vomiting), loss of movement, and loss of
consciousness followed by death.
Less than 6% O2 in air generally causes spasmodic breathing, convulsive movement, and
death in approx. eight minutes. 4% - 6% O2 in air can lead to a coma in 40 seconds.
Dangers of Low Oxygen Levels
Why might oxygendeficiency be considered
the most dangerousatmospheric hazard?
What are some causes or indications of possibly having a deficient oxygen atmosphereinside a space?
Evaluating Hazardous Atmospheres
Inerting, or purging, means the displacementof the atmosphere in a permit space by anoncombustible gas (such as nitrogen) to such an
extent that the resulting atmosphere is non-combustible. This procedure produces anoxygen-deficient atmosphere.
Inerting, or purging, means the displacementof the atmosphere in a permit space by anoncombustible gas (such as nitrogen) to such anextent that the resulting atmosphere is non-
combustible. This procedure produces anoxygen-deficient atmosphere.
NIGNIG
____________________________________________________
____________________________________________________
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Why might oxygen deficiency be considered the most dangerousatmospheric hazard?
Colorless and odorless! Plus, we often take oxygen for granted.
What are some causes or indications of possibly having a deficient oxygenatmosphere inside a space?
Corrosion/rusting activityDead animals and/or rotted vegetationSealed/closed for long period of timeWas purged previously
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UEL
LEL
Too lean
FlammableRegion
Flash Point
Temperature
ConcentrationinAir
Too rich
10% LEL
Flammable/Explosive Gases, Vapors, or Mists
Evaluating Hazardous Atmospheres
Check your material safety data sheets or other resources for the chemicals LEL & UEL.
Hazardous if it exceeds 10% of its lower explosive limit (LEL)
FuelOxygen
Ignition
Lower explosive limit (LEL) is the lowestconcentration where a material isflammable in the air. Upper explosive limit(UEL) is the highest concentration where amaterial is flammable in the air.
* LEL and UEL is also called LFL (lower flammable limit) and UFL (upper flammable limit ).* LEL and UEL is also called LFL (lower flammable limit) and UFL (upper flammable limit ).
The 10% LEL level was adopted by OSHA from NFPA 306, Appendix A, andreflects current practices and sampling technology. OSHA believes it providesa sufficient margin of safety in making the measurement and to allow thepotential for pockets of higher vapor concentrations to develop.
This diagram shows the flammable or explosive range from minimum (LEL) to maximum(UEL) limits. It also shows where 10% LEL is.
Dont forget airbornecombustible dust.Combustible solids,when finely dispersedand raised, canexplode when itsconcentration isbetween the LEL &
UEL.
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UEL
LEL
Too lean
FlammableRegion
Flash Point
Temperature
ConcentrationinAir
Too rich
10% LEL
FuelOxygen
Ignition
Important to point out where 10% LEL is in relation to LEL.Important to point out where 10% LEL is in relation to LEL.
Its always a goodidea to keep thefire triangle inmind.
Its always a goodidea to keep thefire triangle inmind.
Why is 10% used?
The combustible gas detection instrumentmeasures % LEL, not Actual % gas in air.Depending on calibration gas used, some gases willgive a much lower LEL reading than the actualLEL concentration.
Their is a very small percentage difference at 10%.For this reason, 10% LEL should be used as themax LEL concentration for worker entry.
Why is 10% used?
The combustible gas detection instrumentmeasures % LEL, not Actual % gas in air.Depending on calibration gas used, some gases will
give a much lower LEL reading than the actualLEL concentration.
Their is a very small percentage difference at 10%.For this reason, 10% LEL should be used as themax LEL concentration for worker entry.
Air
100%
Methane
100%
Air
0%
Methane
0%
Too Rich
5.3%
LFL
15.0%
UFL
Boom!
Too Lean
Methane exampleMethane example
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Evaluating Hazardous Atmospheres
Sources to find exposure limits and toxic levels of chemicals:
OR-OSHA Division 2/Subdivision G Occupational Health &Environmental Control
OR-OSHA Division 2/Subdivision Z Toxic & Hazardous Substances National Institute of Occupational Safety and Health (NIOSH) PocketGuide to Chemical Hazards
American Conference of Governmental Industrial Hygienists (ACGIH) Your material safety data sheets
Toxic Substances
Hazardous if exceeds dose orpermissible exposure limit(PEL) and capable of causing death,incapacitation, impairment of ability to self-rescue, injury, or acute illness due to its healtheffects. Most chemicals have permissible exposure limits.
* Even non-toxic or low-toxic chemicals can replace oxygen if levels are high enough.
The most common toxic chemicals in confined space fatalities are hydrogen sulfide and carbon
monoxide.
Hydrogen sulfide (H2S) gas is commonly found in sewers and can be instantly fatal at higher
levels in a confined spaces. Disturbing sewage sludge can release hydrogen sulfide gas.
Carbon monoxide (CO) comes from operating internal combustion and propane-powered
engines in or near confined spaces. Fatal levels of CO are quickly reached in confined spaces.
Other toxic chemicals can include welding fumes, vapors from liquid residues in storage tanks,
or chemical products used in the confined spaces. Chemicals can quickly reach toxic levels in
the air of a confined space, especially gases, solvent vapors, or sprayed products.
Propane-
powered
manlift in
a large
tank
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The best sources include:
OR-OSHA Division 2/Subdivision Z Toxic & Hazardous Substances
National Institute of Occupational Safety and Health (NIOSH)Pocket Guide to Chemical Hazardshttp://www.cdc.gov/niosh/npg/default.html
American Conference of Governmental Industrial Hygienists (ACGIH)www.acgih.org
Your material safety data sheets
A Very Important AND
Hazardous if exceeds dose orpermissible exposure limit (PEL) and capable ofcausing death, incapacitation, impairment of ability to self-rescue, injury, or acuteillness due to its health effects. Most chemicals have permissible exposure limits.
Wouldnt hurt to provide more info (handouts, alerts, etc.) on CO and H2S.
ACGIH produces TLVs Threshold Limit Values. These are often more stringent
than OSHAs PELs. Also, NIOSH will publish Recommended Exposure Levels
(RELs). These are often more restrictive too.
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Can an engulfment hazard be isolated?
Evaluating Permit-Required
Confined Spaces
Engulfment is defined as the surrounding and effective capture of a person by a liquid orfinely divided (flowable) solid substance that can be aspirated to cause death by filling orplugging the respiratory system or that can exert enough force on the body to cause death bystrangulation, constriction, or crushing.
Engulfing materials include liquids or
loose solids such as grain, seed, sand,
dirt or other granular material. Workers
often get engulfed when in-feed or out-
feed lines are inadvertently opened or
activated. Workers can suffocate becausethey cannot escape when caught in liquid
or moving loose solids.
Blanking or blinding means the absolute closure of a pipe, line, or duct by thefastening of a solid plate (such as a spectacle blind or a skillet blind) thatcompletely covers the bore and that is capable of withstanding the maximum
pressure of the pipe, line, or duct with no leakage beyond the plate.
Double block and bleed means the closure of a line, duct, or pipe by closingand locking or tagging two in-line valves and by opening and locking ortagging a drain or vent valve in the line between the two closed valves.
Line breaking means the intentional opening of a pipe, line, or duct that is orhas been carrying flammable, corrosive, or toxic material, an inert gas, or anyfluid at a volume, pressure, or temperature capable of causing injury.
National AG Safety DatabaseNational AG Safety Database
Isolation means the process by which a permit space is removed from serviceand completely protected against the release of energy and material into thespace by such means as:
blanking or blinding misaligning or removing sections of lines,
pipes, or ducts double block and bleed system lockout or tagout of all sources of energy blocking or disconnecting all mechanical
linkages
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Have class provide examples of engulfment sources. Water, steam, grain, dirt,seed, etc.
Although excavations are covered under OR-OSHA Div 3/Sub P, I often emphasizehow trenches and excavations can be confined spaces and permit-required confinedspaces by definition. On average, a cubic foot of dirt weighs approx. 100lbs. and acubic yard weighs approx. a ton.
Wouldnt hurt to provide more info (publications, alerts, summaries, etc.) oflockout/tagout or other isolation methods (e.g. double block and bleed).
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Evaluating Permit-Required
Confined Spaces
Hazardous Configuration is when the permit space has an internal configuration suchthat an entrant can be trapped or asphyxiated by inwardly converging walls or by a floor thatslopes downward and tapers to smaller cross-section.
Common examples includehoppers and cyclones.
The best practice of controllingthis hazard is eliminating thehazardous configuration by
redesign or installing aneffective, permanent barrier orguard to prevent a worker fromfalling and becoming trapped.
Personal fall protection wouldnot eliminate a fall hazard but
rather control the hazard.
Other Recognized Serious Safety or Health Hazards
Energized lines or parts
Live steam lines
Live hydraulic lines
Moving parts (mechanical hazards)
Welding
Painting
Fall Temperature
Lighting
Falling objects
Noise
Standing water obscuring openings
Energized lines or parts
Live steam lines
Live hydraulic lines
Moving parts (mechanical hazards)
Welding
Painting
Fall Temperature
Lighting
Falling objects
Noise
Standing water obscuring openings
OR-OSHAs Permit-Required Confined Space standard applies when a safety or healthhazard is serious enough to inhibit an entrants ability to rescue themselves.
OR-OSHAs Permit-Required Confined Space standard applies when a safety or healthhazard is serious enough to inhibit an entrants ability to rescue themselves.
Live steam lines? Electrical lines?Live steam lines? Electrical lines?
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Once you have evaluated and identified the permit-
required confined spaces at your workplace, inform
employees through signs and/or other equally
effective means.
Note: Signs, or other equally effective means ofinforming, are required even if employees willnot enter.
Entering Permit-Required
Confined Spaces
If permit-required confined spaces will not beentered, you must still take all measures to prevententry.
Entry is defined whenany part of the body breaksthe plane of the opening in apermit-required confinedspace.
When workers will enter permit-required confined spaces, OR-OSHAs Permit-
Required Confined Space standard requires certain preventative measures to be
taken to ensure safe entry. This is commonly referred to as a written permitspace program and includes a written program, entry permits, entry team,
rescue plan, and training. However, the OR-OSHA standard provides two
additional options for permit space entry and, if employers comply with all
requirements, excludes most of the elements under apermit space program
(basically everything but training).
The two options are reclassifying permit spaces to nonpermit spaces or the use
of alternative procedures to effectively control hazardous atmospheres. These
two options are independent of each other meaning they cannot becombined and used together.
The following page describes these two options and when they can be used.
Note: Specific requirements for Telecommunication and Electrical Generation,Transmission, and Distribution are found in OR-OSHA Div 2/Sub R.
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Important to emphasize
The two options are reclassifying permit spaces to nonpermit spaces or the use of
alternative procedures to effectively control hazardous atmospheres. These two
options are independent of each other meaning they cannot be combined and
used together.
Fed OSHA has letters of interp on this.
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1. Can the hazard(s) which made the space a permit space be eliminated?
If YES The space can be reclassified as a nonpermit-required space.
This is when the space has no actual or potential atmospheric hazards and when all otherhazards (i.e. engulfment, configuration, moving parts, etc.) are eliminated without entering thespace. If its necessary to enter the permit space to eliminate the hazards, the entry must be infull compliance with the written permit space program.
Control of atmospheric hazards through forced air ventilation does not constitute elimination ofthe hazard. Question #2 below addresses this.
If hazards arise during entry into a reclassified space, the entrant must exit immediately and thespace must be reevaluated.
There must be documentation detailing that the hazards were eliminated. This certificationmust contain the date, location of the space, and signature of the person certifying and must beavailable to all entrants or their representative.
Entering Permit-Required
Confined Spaces
2. Is the only hazard of the permit space an actual or potential atmospherichazard?
If NO Entry must be made under the written permit space program only.
If YES You can follow the alternate (c)(5) procedures.
This alternate procedure can only be used when (1) verification is made that using continuousforced air ventilation is safe, (2) monitoring and inspection data supports the atmospheric hazardis the only hazard and the forced air ventilation is effective, and (3) the data is documented andmade available to the entrant(s).
If its necessary to enter the permit space to obtain the monitoring data, the entry must be in fullcompliance with the written permit space program. When following these alternate procedures,the employer is not required to develop a written permit space program (training and employeeparticipation are still required).
More on the alternate (c)(5) procedures on the next page
If NO Prepare for permit entry or consider another questionIf NO Prepare for permit entry or consider another question
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One must be careful when asking these two questions. Consider all potentials.
The documentation doesnt require much here (names and dates). Why not
implement it similar to the permit system (discussed later)? In other words,
adding more to this checklist process might allow you to easily check and double
check all potentials. If done this way, it wouldnt be much different than the full
blown permit system.
Specific requirements for Telecommunications and Electrical Generation,Transmission, and Distribution are found in OR-OSHA Div 2/Sub R.
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The following must also be done when using the alternate (c)(5) procedures
ensure safety before removing a cover and guard opening immediately test internal atmosphere (Oxygen, Flammables, Toxins) - observation available to entrant continuous forced air ventilation atmosphere periodically tested - observation available to entrant evacuate immediately if necessary and evaluate what went wrong verify these procedures were conducted through a written certification
There must be documentation detailing that the space is safe for entry and the pre-entry
measures were conducted. This certification must contain the date, location of the space, andsignature of the person making the verification. The certification must be made before entryand must be made available to all entrants or to their authorized representative(s).
Continuous forced air ventilation (FAV) must be used as follows:
no entry until FAV has eliminated any hazardous atmosphere direct FAV to ventilate immediate work area and areas where the entrant will likely be (be
aware of pockets within the space) FAV must continue until all workers have left the space FAV must have clean source FAV must not increase the hazards in the space
Entering Permit-Required
Confined Spaces
Using ContractorsThe host employer must:
Ensure compliance with permit space program Hazards of the permit space Precautions and procedures Coordinate entry operations (if conducted) Debrief when completed (hazards found or
created)
The contractor must:
Obtain information about permit space hazards& entry operations
Coordinate entry operations (if conducted) Brief employer on permit space program being
used Debrief employer on hazards confronted or
created
What does this basically involve?What does this basically involve?
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Using Contractors
What does this basically involve?
Sharing Information
What does this basically involve?
Sharing Information
An established orientation-type of process with contractors can help here. Manylarge host employer sites will require this through policy. Having a record of thishappening wouldnt hurt either.
An established orientation-type of process with contractors can help here. Manylarge host employer sites will require this through policy. Having a record of thishappening wouldnt hurt either.
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The completed permit must be made available
to the entrants or their authorizedrepresentatives by posting or other effectivemeans.
The duration of the permit must not exceedthe time required to accomplish the identifiedtask. The permit must be immediatelycanceled when the entry operations have beencompleted or a condition not allowed underthe entry permit arises in or around the permitspace.
Entering Permit-Required
Confined Spaces
Written Permit Space Program
A written permit space program must be established when spaces cannot bereclassified or alternative procedures cannot be used. This permit system simplyensures that all means, practices, and procedures necessary for safe permit spaceentry has been conducted.
The entry permit must document:
1. Permit space to be entered;2. Purpose of the entry;3. Date & duration of the entry permit;4. Authorized entrant(s) and Attendant(s);5. Entry supervisor and place for signature;
6. Hazards of the permit space;7. Isolation measures - hazard controls (purging, ventilating, etc.);8. The acceptable entry conditions;9. Test results (initial/periodic) with initials/name of tester & time;
10. Rescue/emergency services available and means to summon;11. Communication procedures between entrant and attendant;12. All necessary equipment (PPE, Testing/Communication equipment, etc.);13. Other necessary information and/or additional permits (hot work, etc.).
Cancelled permits must be retained for one year to assist in evaluating the permit spaceprogram. Any problems during entry must be noted on the respective permit so this annualreview can be effective!
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I put the permit system before the written program because I thought it workedbetter this way. However, if you fell the program should be described before thepermit process, jump ahead a page then back up to this one.
The permit is theprocedure. The company-created procedure. The writtenprogram is theplan.
Important rule here Cancelled permits must be retained for one year to assist
in evaluating the permit space program. This is a rule that requires you toimprove your plan and procedure. Nice rule to have.
There is no standard format to follow when it comes to developing or creating apermit. As long as all bulleted items are on the permit and its consistentlyfollowed and enforced you should be good to go! Making it user-friendly seems tohelp a lot. Ensure all affected parties (entrants, attendants, and supervisors) areinvolved in its creation and evaluation.
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Your written plan must include:
The measures implemented to prevent unauthorized entry
The identification and evaluation of all permit space hazards prior to entry
The development and implementation of safe entry operations
Providing and maintaining all necessary equipment (PPE, monitors, etc.)
Evaluating permit space conditions before and during entry operations
Providing at least one attendant and developing procedures for multiple spaces
Designating and training all persons who have active roles
Developing and implementing rescue and emergency procedures
Developing and implementing the entry permit procedures (issue, use, cancel)
Coordinating multi-employer entry procedures
Developing procedures for concluding the entry (closing off the space)
The review and evaluation of entry operations during the year (as needed)
The annual permit space program review using the historic permits
What should be your goal of this written plan?
Entering Permit-Required
Confined Spaces
The intent of this permit space program is to manage and evaluateyour permit space entries. The items on the permit address thecomponents of your written plan to ensure safety and health of allinvolved.
Written Permit Space Program
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What should be your goal of this written plan?
User-friendly Enforced Interested parties were involved in the development and/or evaluation Updated Relevant Specific Available
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The Entry Supervisor
The Attendant
Knows the hazard(s), symptoms, and consequences Aware of potential behavioral effects Monitors entrants and maintains count Monitors hazards and activities in and outside of the permit space
Remains outside entry point Communicates with entrant(s) Controls entry point Summons rescuers Initiates/performs non-entry rescue if required
The Entrant
Knows the hazard(s), symptoms, and consequences Uses equipment properly Communicates regularly with the attendant
If the unexpected occurs - alert the attendant Exits immediately if hazard(s) develops
The entrant(s) and/or their authorized representative must be given the opportunity to observethe atmospheric testing and completion of the permit.
Knows the hazard(s), symptoms, and consequences Verifies the permit by determining if acceptable entry conditions exist Authorizes entry Oversees entry operations Terminates entry
Verifies rescue services Removes unauthorized individuals Serves as attendant (if necessary)
Entering Permit-Required
Confined Spaces
The Entry Team and their Roles
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Notice the first bullet under all three. They should all know the hazardsand consequences
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Initially and during entry.
Test for: (1) Oxygen; (2) Flammables; and (3) Toxins.
Detector Tubes
Sealed glass tubes
Chemical reaction results in color change Specific for the substance of concern High error rate (25-30%)
Sensors measure concentrations Results in a meter or digital reading; alarms Portable multi-gas instruments Calibration is critical
Sampling
The individual conductingthe air monitoring must becompetent in the properselection, use (placement,space stratification, etc.),maintenance, limitations(cross-sensitivity andchemical interference),and calibration. Be sureto read the manufacturer'sspecifications.
Gas Detection Instruments
Methane: 0.55
Ammonia: 0.59
Carbon Monoxide: 0.96
Nitrogen: 0.97
Air: 1.0
Hydrogen Sulfide: 1.2
Carbon Dioxide: 1.5
Gasoline: 3- 4
Jet Fuel, JP-8: 4.7
Lighter than air gases
Heavier than air gases
Entering Permit-Required
Confined Spaces
Atmospheric Testing
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Key language here
The individual conducting the air monitoring must be competent in the properselection, use (placement, space stratification, etc.), maintenance, limitations(cross-sensitivity and chemical interference), and calibration. Be sure to readthe manufacturer's specifications.
And calibration, calibration, calibration
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Blowers & fans providemechanical dilutionventilation. Be sure theblower is appropriatelysized, explosion-proof,and its intake is placedfar enough away from
any source ofcontamination - like an exhaust pipe on a vehicle!
A space under positive pressure will eventually expel the contaminant through an openingbut the time it takes is the real question.
Localized exhaust ventilation is bettersuited to capture fumes (welding), dust,and chemical contaminants.
Ventilation must be continuous when there isan existing or potential atmospheric hazard.
Entering Permit-Required
Confined Spaces
Ventilation
Effective?Effective?
Effective?Effective?
Remember, purging a space with
an inert gas expels a flammable butleaves no oxygen.
Respirators may be required at times. Respirators must be worn inoxygen deficient atmospheres or when toxins are capable of causingdeath, incapacitation, impairment of ability to self-rescue, injury, oracute illness due to their health effects.
A supplied air respirator is required for oxygen deficiency or toxicchemical levels that are immediately dangerous to life or health(IDLH). An air-purifying respirator (respirators that filtercontaminated air) cannot be used in these atmospheres.
Employees must have complete training on the proper use of
respirators. Please refer to OR-OSHA Div 2/Sub I 29 CFR 1910.134
for more details.
Respiratory Protection
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Respirator use requires many additional components including:
Written program
Safe use procedures
Program administrator
Fit testing
Medical evaluation
Training
etc.
OR-OSHA Div 2/Sub I 29 CFR 1910.134 for more details. OR-OSHA also has
a publication titled Breathe Right Pub. #3330. This publication
summarizes the respiratory protection requirements.
Estimating Purge TimesEstimating Purge Times
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Training must be provided to each affected employee:
before their first assigned duty
before there is a change in assigned duties
whenever there is a change in permit space operations and the affected employee(s)
has not previously been trained on the hazard(s)
whenever there is reason to believe there are deviations from the permit space entry
procedures or inadequacies in the employee's knowledge or use of the procedures
All employees who work in and around permit-required confined spaces must be
trained in order to acquire the understanding, knowledge, and skills necessary tosafely perform their assigned duties.
The content of the training must include:
nature of the hazards
procedures to take when exposed to hazards
use of rescue and emergency equipment
Should you include more on the training record?Should you include more on the training record?
Training
Training must establish worker proficiency and include new orrevised procedures to ensure compliance with permit spacestandards. Be sure to include a demonstration!
Verify the appropriate training was completed through a written certification. The
certification must contain each employees name, the signature(s) of the trainers, and the
date(s) of the training.
What more can be included?
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All employees who work in and around permit-required confined spaces must be
trained in order to acquire the understanding, knowledge, and skills necessary to
safely perform their assigned duties.
The content of the training must include:
nature of the hazards
procedures to take when exposed to hazards
use of rescue and emergency equipment
Should you include more on the training record?
Topics/subjects, test, where it was done, how it was presented, course outline,exercises, demonstrations, etc. Not only can this help when you review yourtraining records for improvement reasons but it can also help when somebody newcomes in and takes on the training responsibilities. You will have a training planalready created.
Should you include more on the training record?
Topics/subjects, test, where it was done, how it was presented, course outline,exercises, demonstrations, etc. Not only can this help when you review yourtraining records for improvement reasons but it can also help when somebody newcomes in and takes on the training responsibilities. You will have a training planalready created.
Important language here Training must establish worker proficiency andinclude new or revised procedures to ensure compliance with permit spacestandards. Be sure to include a demonstration!
What more can be included?
Your specific spaces
Company-specific procedures/expectationsWorking with contractorsUse of company-provided air monitorCommunicationsPPEVentilation equipmentIsolation methods (e.g. lockout)
Your specific spaces
Company-specific procedures/expectationsWorking with contractorsUse of company-provided air monitorCommunicationsPPEVentilation equipmentIsolation methods (e.g. lockout)
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1. Arrange for rescue service from an outside source.
Evaluate their ability to respond in a timely manner considering thehazard(s) evaluated and proficiency with rescue-related tasks andequipment.
Rescue and Emergency Services
Three Options to Permit-Required Confined Space Rescue
3. Provide for non-entry rescue.
Provide necessary retrieval equipment such as a full bodyharness and a mechanical device when permit space depthsare more than five feet.
2. Arrange for your own employees toprovide rescue.
Provide necessary PPE and training in thePPE; training in their assigned rescue duties;training in first aid & CPR; practice simulatedpermit space rescues at least annually inrespective spaces using manikins or actualpersons.
If a chemical is involved during an emergency, provide the necessary MSDS immediately!
timely will vary according to the specific hazards involved provide the rescue service with access to all permit spaces from
which rescue may be necessary so they can develop appropriate
rescue plans and practice rescue operations
unless the retrieval equipment would increase theoverall risk of entry or would not contribute to therescue of the entrant
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If a chemical is involved during an emergency, provide the necessary MSDS immediately!
The rescue-related rules and Appendix F in the reference section of this workbookhelp here.
Availability and being equipped are the biggies here. Several organizations donot have the resources to man their own rescue team. If this is the case and theyalso do not have an outside source available to them that leaves them with non-entry rescue as their only option. And if this is not practical to their entryoperation, reclassifying or using the alternative (c)5 procedures could be asolution here.
And dont assume the local fire department is your outside service option. Manyfire departments are not equipped or trained for confined space rescue. If youhavent already contacted them but plan on using them please call them!
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Reference
Rescue and Emergency Services
OR-OSHA Div 2/Sub J 29 CFR 1910.146(k)
Rescue and Emergency ServicesOR-OSHA Div 2/Sub J 29 CFR 1910.146
Appendix F Rescue Team or RescueService Evaluation Criteria (Non-Mandatory)
Confined Space and PRCS Recognition
Checklist
Sample Entry Permit
Quick Reference Flow Chart
Why Is This Important?
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OR-OSHA Div 2/Sub J 29 CFR 1910.146(k) Rescue and emergency services.
(1) An employer who designates rescue and emergency services, pursuant to paragraph (d)(9)of this section, shall:
(i) Evaluate a prospective rescuer's ability to respond to a rescue summons in a timely manner,considering the hazard(s) identified;Note to paragraph (k)(1)(i): What will be considered timely will vary according to thespecific hazards involved in each entry. For example, 1910.134, Respiratory Protection,requires that employers provide a standby person or persons capable of immediate action torescue employee(s) wearing respiratory protection while in work areas defined as IDLHatmospheres.
(ii)Evaluate a prospective rescue service's ability, in terms of proficiency with rescue-relatedtasks and equipment, to function appropriately while rescuing entrants from the particularpermit space or types of permit spaces identified;
(iii) Select a rescue team or service from those evaluated that:(A) Has the capability to reach the victim(s) within a time frame that is appropriate for the
permit space hazard(s) identified;(B) Is equipped for and proficient in performing the needed rescue services;
(iv) Inform each rescue team or service of the hazards they may confront when called on toperform rescue at the site; and
(v) Provide the rescue team or service selected with access to all permit spaces from whichrescue may be necessary so that the rescue service can develop appropriate rescue plans andpractice rescue operations.Note to paragraph (k)(1): Non-mandatory Appendix F contains examples of criteria whichemployers can use in evaluating prospective rescuers as required by paragraph (k)(l) of thissection.
(2) An employer whose employees have been designated to provide permit space rescue andemergency services shall take the following measures:
(i) Provide affected employees with the personal protective equipment (PPE) needed toconduct permit space rescues safely and train affected employees so they are proficient in
the use of that PPE, at no cost to those employees;
(ii) Train affected employees to perform assigned rescue duties. The employer must ensure thatsuch employees successfully complete the training required to establish proficiency as anauthorized entrant, as provided by paragraphs (g) and (h) of this section;
(iii) Train affected employees in basic first-aid and cardiopulmonary resuscitation (CPR). Theemployer shall ensure that at least one member of the rescue team or service holding acurrent certification in first aid and CPR is available; and
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OR-OSHA Div 2/Sub J 29 CFR 1910.146(k) Rescue and emergency services (cont).
(iv) Ensure that affected employees practice making permit space rescues at least once every 12months, by means of simulated rescue operations in which they remove dummies,manikins, or actual persons from the actual permit spaces or from representative permitspaces. Representative permit spaces shall, with respect to opening size, configuration, andaccessibility, simulate the types of permit spaces from which rescue is to be performed.
(3) To facilitate non-entry rescue, retrieval systems or methods shall be used whenever an authorizedentrant enters a permit space, unless the retrieval equipment would increase the overall risk ofentry or would not contribute to the rescue of the entrant. Retrieval systems shall meet thefollowing requirements.
(i) Each authorized entrant shall use a chest or full body harness, with a retrieval line attached atthe center of the entrant's back near shoulder level, above the entrant's head , or at anotherpoint which the employer can establish presents a profile small enough for the successfulremoval of the entrant. Wristlets may be used in lieu of the chest or full body harness if theemployer can demonstrate that the use of a chest or full body harness is infeasible orcreates a greater hazard and that the use of wristlets is the safest and most effectivealternative.
(ii) The other end of the retrieval line shall be attached to a mechanical device or fixed pointoutside the permit space in such a manner that rescue can begin as soon as the rescuerbecomes aware that rescue is necessary. A mechanical device shall be available to retrievepersonnel from vertical type permit spaces more than 5 feet (1.52 m) deep.
(4) If an injured entrant is exposed to a substance for which a Material Safety Data Sheet (MSDS) orother similar written information is required to be kept at the worksite, that MSDS or writteninformation shall be made available to the medical facility treating the exposed entrant.
Rescue and Emergency Services
Non-mandatory Appendix Fcontains examples of criteria which
employers can use in evaluatingprospective rescuers as required by
paragraph (k)(l) of this section.
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OR-OSHA Div 2/Sub J 29 CFR 1910.146 Appendix F Rescue Team or Rescue ServiceEvaluation Criteria (Non-Mandatory)
(1) This appendix provides guidance to employers in choosing an appropriate rescue service. Itcontains criteria that may be used to evaluate the capabilities both of prospective and currentrescue teams. Before a rescue team can be trained or chosen, however, a satisfactory permitprogram, including an analysis of all permit-required confined spaces to identify all potentialhazards in those spaces, must be completed. OSHA believes that compliance with all theprovisions of 1910.146 will enable employers to conduct permit space operations withoutrecourse to rescue services in nearly all cases. However, experience indicates thatcircumstances will arise where entrants will need to be rescued from permit spaces. It istherefore important for employers to select rescue services or teams, either on-site or off-site,that are equipped and capable of minimizing harm to both entrants and rescuers if the need
arises.
(2) For all rescue teams or services, the employer's evaluation should consist of two components:an initial evaluation, in which employers decide whether a potential rescue service or team isadequately trained and equipped to perform permit space rescues of the kind needed at thefacility and whether such rescuers can respond in a timely manner, and a performanceevaluation, in which employers measure the performance of the team or service during anactual or practice rescue. For example, based on the initial evaluation, an employer maydetermine that maintaining an on-site rescue team will be more expensive than obtaining theservices of an off-site team, without being significantly more effective, and decide to hire arescue service. During a performance evaluation, the employer could decide, after observingthe rescue service perform a practice rescue, that the service's training or preparedness was not
adequate to effect a timely or effective rescue at his or her facility and decide to select anotherrescue service, or to form an internal rescue team.
A. Initial Evaluation
I. The employer should meet with the prospective rescue service to facilitate the evaluationsrequired by 1910.146(k)(1)(i) and 1910.146(k)(1)(ii). At a minimum, if an off-site rescueservice is being considered, the employer must contact the service to plan and coordinate theevaluations required by the standard. Merely posting the service's number or planning to relyon the 911 emergency phone number to obtain these services at the time of a permit spaceemergency would not comply with paragraph (k)(1) of the standard.
II.The capabilities required of a rescue service vary with the type of permit spaces from whichrescue may be necessary and the hazards likely to be encountered in those spaces.Answering the questions below will assist employers in determining whether the rescueservice is capable of performing rescues in the permit spaces present at the employer'sworkplace.
1. What are the needs of the employer with regard to response time (time for the rescueservice to receive notification, arrive at the scene, and set up and be ready for entry)?
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OR-OSHA Div 2/Sub J 29 CFR 1910.146 Appendix F Rescue Team or Rescue ServiceEvaluation Criteria (Non-Mandatory)
For example, if entry is to be made into an IDLH atmosphere, or into a space that canquickly develop an IDLH atmosphere (if ventilation fails or for other reasons), therescue team or service would need to be standing by at the permit space. On theother hand, if the danger to entrants is restricted to mechanical hazards that wouldcause injuries (e.g., broken bones, abrasions) a response time of 10 or 15 minutesmight be adequate.
2. How quickly can the rescue team or service get from its location to the permit spacesfrom which rescue may be necessary? Relevant factors to consider would include:the location of the rescue team or service relative to the employer's workplace, the
quality of roads and highways to be traveled, potential bottlenecks or trafficcongestion that might be encountered in transit, the reliability of the rescuer'svehicles, and the training and skill of its drivers.
3. What is the availability of the rescue service? Is it unavailable at certain times of theday or in certain situations? What is the likelihood that key personnel of the rescueservice might be unavailable at times? If the rescue service becomes unavailablewhile an entry is underway, does it have the capability of notifying the employer sothat the employer can instruct the attendant to abort the entry immediately?
4. Does the rescue service meet all the requirements of paragraph (k)(2) of thestandard? If not, has it developed a plan that will enable it to meet those
requirements in the future? If so, how soon can the plan be implemented?
5. For off-site services, is the service willing to perform rescues at the employer'sworkplace? (An employer may not rely on a rescuer who declines, for whateverreason, to provide rescue services.)
6. Is an adequate method for communications between the attendant, employer andprospective rescuer available so that a rescue request can be transmitted to therescuer without delay? How soon after notification can a prospective rescuerdispatch a rescue team to the entry site?
7. For rescues into spaces that may pose significant atmospheric hazards and from
which rescue entry, patient packaging and retrieval cannot be safely accomplished ina relatively short time (15-20 minutes), employers should consider using airlinerespirators (with escape bottles) for the rescuers and to supply rescue air to thepatient. If the employer decides to use SCBA, does the prospective rescue servicehave an ample supply of replacement cylinders and procedures for rescuers to enterand exit (or be retrieved) well within the SCBA's air supply limits?
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OR-OSHA Div 2/Sub J 29 CFR 1910.146 Appendix F Rescue Team or Rescue ServiceEvaluation Criteria (Non-Mandatory)
8. If the space has a vertical entry over 5 feet in depth, can the prospective rescueservice properly perform entry rescues? Does the service have the technicalknowledge and equipment to perform rope work or elevated rescue, if needed?
9. Does the rescue service have the necessary skills in medical evaluation, patientpackaging and emergency response?
10. Does the rescue service have the necessary equipment to perform rescues, or mustthe equipment be provided by the employer or another source?
B. Performance Evaluation
Rescue services are required by paragraph (k)(2)(iv) of the standard to practice rescues at leastonce every 12 months, provided that the team or service has not successfully performed a permitspace rescue within that time. As part of each practice session, the service should perform acritique of the practice rescue, or have another qualified party perform the critique, so thatdeficiencies in procedures, equipment, training, or number of personnel can be identified andcorrected. The results of the critique, and the corrections made to respond to the deficienciesidentified, should be given to the employer to enable it to determine whether the rescue servicecan quickly be upgraded to meet the employer's rescue needs or whether another service must beselected. The following questions will assist employers and rescue teams and services evaluatetheir performance.
1. Have all members of the service been trained as permit space entrants, at a minimum,including training in the potential hazards of all permit spaces, or of representativepermit spaces, from which rescue may be needed? Can team members recognize thesigns, symptoms, and consequences of exposure to any hazardous atmospheres that maybe present in those permit spaces?
2. Is every team member provided with, and properly trained in, the use and need for PPE,such as SCBA or fall arrest equipment, which may be required to perform permit spacerescues in the facility? Is every team member properly trained to perform his or herfunctions and make rescues, and to use any rescue equipment, such as ropes andbackboards, that may be needed in a rescue attempt?
3. Are team members trained in the first aid and medical skills needed to treat victimsovercome or injured by the types of hazards that may be encountered in the permitspaces at the facility?
4. Do all team members perform their functions safely and efficiently? Do rescue servicepersonnel focus on their own safety before considering the safety of the victim?
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OR-OSHA Div 2/Sub J 29 CFR 1910.146 Appendix F Rescue Team or Rescue ServiceEvaluation Criteria (Non-Mandatory)
5. If necessary, can the rescue service properly test the atmosphere to determineif it is IDLH?
6. Can the rescue personnel identify information pertinent to the rescue from entrypermits, hot work permits, and MSDSs?
7. Has the rescue service been informed of any hazards to personnel that may arise fromoutside the space, such as those that may be caused by future work near the space?
8. If necessary, can the rescue service properly package and retrieve victims from a permit
space that has a limited size opening (less than 24 inches (60.9 cm) in diameter),limited internal space, or internal obstacles or hazards?
9. If necessary, can the rescue service safely perform an elevated (high angle) rescue?
10. Does the rescue service have a plan for each of the kinds of permit space rescueoperations at the facility? Is the plan adequate for all types of rescue operations thatmay be needed at the facility? Teams may practice in representative spaces, or inspaces that are worst-case or most restrictive with respect to internal configuration,elevation, and portal size. The following characteristics of a practice space should beconsidered when deciding whether a space is truly representative of an actual permitspace:
(1) Internal configuration.(a) Open there are no obstacles, barriers, or obstructions within the space. One
example is a water tank.(b) Obstructed the permit space contains some type of obstruction that a rescuer
would need to maneuver around. An example would be a baffle or mixingblade. Large equipment, such as a ladder or scaffold, brought into a space forwork purposes would be considered an obstruction if the positioning or size ofthe equipment would make rescue more difficult.
(2) Elevation.(a) Elevated a permit space where the entrance portal or opening is above grade
by 4 feet or more. This type of space usually requires knowledge of high anglerescue procedures because of the difficulty in packaging and transporting apatient to the ground from the portal.
(b) Non-elevated a permit space with the entrance portal located less than 4 feetabove grade. This type of space will allow the rescue team to transport aninjured employee normally.
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OR-OSHA Div 2/Sub J 29 CFR 1910.146 Appendix F Rescue Team or Rescue ServiceEvaluation Criteria (Non-Mandatory)
(3) Portal size.(a) Restricted A portal of 24 inches or less in the least dimension. Portals of this
size are too small to allow a rescuer to simply enter the space while usingSCBA. The portal size is also too small to allow normal spinal immobilizationof an injured employee.
(b) Unrestricted A portal of greater than 24 inches in the least dimension. Theseportals allow relatively free movement into and out of the permit space.
(4) Space access.(a) Horizontal The portal is located on the side of the permit space. Use of
retrieval lines could be difficult.(b) Vertical The portal is located on the top of the permit space, so that rescuersmust climb down, or the bottom of the permit space, so that rescuers mustclimb up to enter the space. Vertical portals may require knowledge of ropetechniques, or special patient packaging to safely retrieve a downed entrant.
Rescue and Emergency Services
Teams may practice inrepresentative spaces, or in
spaces that are worst-case ormost restrictive with respect to
internal configuration,elevation, and portal size.
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CONFINED SPACE AND PRCS RECOGNITION CHECKLIST
PART I
____ 1. Is the space large enough so an employee can bodily enter and performwork?
____ 2. Does the space have limited or restricted means of entry and exit?
____ 3. Is the space not designed for continuous occupancy?
If the answer is yes to all items in Part I, continue to Part II. If the answer is no to any ofthe items in Part I, the space is not considered a confined space.
PART II
____ 1. Does the space contain or potentially contain a hazardous atmosphere?
____ 2. Does the space contain any chemicals or chemical residues?
____ 3. Does the space contain any flammable/combustible substances?
____ 4. Does the space contain or potentially contain any decomposing organicmatter?
____ 5. Does the space have any pipes which bring chemicals into it?
____ 6. Does the space have any materials that can trap or potentially trap, engulf,or drown an entrant?
____ 7. Is vision obscured by dust at 5 feet or less?
____ 8. Does the space contain any mechanical equipment servicing the space?
____ 9. Does the space have converging walls, sloped floors or tapered floor tosmaller cross-sections which could trap or asphyxiate an entrant?
____ 10. Does the tank or vessel contain rusted interior surfaces?
____ 11. Does the space contain thermal hazards (e.g. cold, hot)?
____ 12. Does the space contain excessive noise levels which could interfere withcommunication with an attendant?
____ 13. Does the space present any slip, trip, or fall hazards?
____ 14. Are there any operations conducted near the space opening which couldpresent a hazard to the entrant?
____ 15. Are there any hazards from falling objects?
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____ 16. Are there lines under pressure servicing the space?
____ 17. Are cleaning solvents or paints going to be used in the space?
____ 18. Is welding, cutting, brazing, riveting, scraping, or sanding goingto be performed in the space?
____ 19. Is electrical equipment located in or required to be used in thespace?
____ 20. Does the space have poor natural ventilation which would allowan atmospheric hazard to develop?
____ 21. Are there any corrosives which could irritate the eyes in thespace?
____ 22. Are there any conditions which could prevent any entrants selfrescue from the space?
____ 23. Are there any substances used in the space which have acutehazards?
____ 24. Is mechanical ventilation needed to maintain a safe environment?
____ 25. Is air monitoring necessary to ensure the space is safe for entry dueto a potential hazardous atmosphere?
____ 26. Will entry be made into a diked area where the dike is 5 feet or morein height?
____ 27. Are residues going to be scraped off the interior surfaces of thevessel?
____ 28. Are non-sparking tools required to remove residues?
____ 29. Does the space restrict mobility to the extent that it could trap anirritant?
____ 30. Is respiratory protection required because of a hazardousatmosphere?
____ 31. Does the space present a hazard other than those noted abovewhich would make it a permit space?
If any other questions in PART II have been checked yes, the confined space is likelya Permit-Required Confined Space (PRCS). As such, entry into these spaces mustbe performed under the protection of your PRCS program. Note: In some situations,alternative procedures or reclassifying to a non-PRCS may be possible in lieu of a fullPRCS program.
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XYZ Inc., Confined Space Entry Permit (Example)Date & Time Issued _______________ Date & Time Expires ____________________Job site/space I.D. _______________ Job Supervisor ____________________Equipment to be worked on _______________ Work to be performed ____________________Entrants __________________________ _____________________ _______________________Stand-by personnel _________________ _____________________ _______________________
1. Atmospheric checks Time _______Oxygen _______%Explosive _______% LFLToxic _______ PPM
2. Testers signature _______________________
3. Source isolation (No Entry) NA Yes NoPumps or lines blinded, ___ ___ ___disconnected or blocked
4. Ventilation ModificationMechanical ___ ___ ___ Natural Ventilation only ___ ___ ___
5. Atmospheric check afterisolation and ventilation
Time _______ Oxygen _______% > 19.5%Explosive _______%LFL < 10%
Toxic _______PPM < 10 PPM H2STesters signature ______________________
6. Communication procedures _______________________________________________________
7. Rescue procedures: _____________________________________________________________________________________________________
8. Entry, standby, backup personsTraining completed? Yes ___ No ___Training current? Yes ___ No ___
9. Equipment NA Yes NoDirect reading gas monitor
tested? ___ ___ ___Safety harnesses/lifelinesfor entrants/standby crew? ___ ___ ___
Hoists ___ ___ ___Powered communications? ___ ___ ___SCBAs for entrants and
standby crew? ___ ___ ___Protective clothing? ___ ___ ___All electric equipment listedClass I, Div I, Group Dand non-spark producing? ___ ___ ___
10. Periodic atmospheric tests
Time ____O2___% Explosive ___% Toxic ___%Time ____O2___% Explosive ___% Toxic ___%Time ____O2___% Explosive ___% Toxic ___%Time ____O2___% Explosive ___% Toxic ___%Time ____O2___% Explosive ___% Toxic ___%Time ____O2___% Explosive ___% Toxic ___%Time ____O2___% Explosive ___% Toxic ___%Time ____O2___% Explosive ___% Toxic ___%Time ____O2___% Explosive ___% Toxic ___%
We have reviewed the work authorized by this permit and the information contained herein. Writteninstructions and safety procedures have been received and are understood. Entry cannot be approved ifany column is marked no. This permit is not valid unless all appropriate items are completed.
Permit prepared by: (Supervisor) ________________________ ___________________________
Approved by: (Unit Supervisor) ________________________ ___________________________
Reviewed by: (CS Ops Personnel) ________________________ ___________________________(Printed Name) (Signature)
A Sample Permit
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Does workplace contain PRCS? (b)
Inform Employees. (c)(2)
Will PRCS be entered?
Will Contractors enter?
Will host employees enter?
Does space have known orpotential hazards?
Can hazards be eliminated?
Can space be maintained safeusing continuous forced air only?
Prepare for entry using permit procedures.
Verify acceptable entry conditions.
Issue permit. Maintain acceptable
entry conditions throughout entry.
Entry tasks completed. Return andcancel permit.
Audit permit program
A quick reference to the Permit-Required Confined Space Standard
Consult other OSHAStandards.
Prevent employee entry. (c)(3)Do task from outside of space.
Inform contractor. (c)(8)Contractor obtains information. (c)(9)
Both contractor and host employees enter.
Coordinate entry operations. (c)(8), (d)(11)Prevent unauthorized entry.
Prevent unauthorized entry.
May reclassify space as non-PRCS. (c)(7)
Space may be entered under (c)(5).
Permit not valid until conditionsmeet permit specifications.
Emergency exists (prohibited condition).Entrants evacuated, entry aborted. Callrescuers if needed. Permit is void.Reevaluate program to correct/preventprohibited condition. No entry until programcorrections completed. May require a new program.
Not a PRCS. Consult other OSHA standards.
No
Yes
No
Yes
Yes
No
Yes No
No
Yes
No
No
Yes
Yes
No
No
Yes
Yes
Stop1
Stop1
Stop
Yes
No
Stop
1 Spaces may have to be evacuated and re-evaluated if hazards arise during entry.
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Why is this important?
Menominee, Mich. - Five farmers who died trying to save one another in a manure pit
were buried Saturday as the family grappled with running the 100-year-old dairy.The five were overcome by methane fumes Wednesday morning trying to save eachother at the Theuerkauf family dairy barn in Menominee County. Sheriff's officialsbelieve Hofer, a farm employee, went into the pit first - perhaps to clear a drain - andcollapsed after breathing the fumes, which are produced by manure. Each onefollowed to rescue the man before, until all had died. There was about a foot ofmanure in the 12-foot deep pit.
In Oklahoma, a three-person work crew ruptured a water line while boring through astreet to prepare the way for extended water service. The workers were instructed to
close off three valves in order to cut off water flow to the damaged pipe. The workmenhad no personal protective equipment or training for confined space entry. They wereaware of a company policy which required atmospheric testing before entry, but theydecided that shutting off the water was more important. They had no trouble with thefirst valve pit. However, the employee who entered the second pit, which had not beenopened in three years, soon called for help. The crew leader entered the pit to assistthe initial entrant but was overcome. The third crewman realized that entering thepit was unsafe and went for help. Firefighters equipped with self-contained breathingapparatus were on the scene within a few minutes. They entered the second valve pit,discharged oxygen from cylinders to increase the oxygen level and retrieved thevictims. Both victims died shortly afterward, asphyxiated due to oxygen deprivation.The accident report noted that the oxygen level at a valve pit two miles downstream
from the scene of the accident was only three percent.
Workers at a refinery in Puerto Rico were cleaning a large storage tank. Since it hadlast been cleaned, the tank had been used at various times to store gasoline, gas oil,and light and heavy crude oils. The employer expected that the tank would containresidues from these liquids. The procedures, tools, and all other equipment to be usedfor entry were prepared by the parent company, not by the refinery. Under the termsof the entry permit, workers were required to use air-supplying respirators, lifelines,explosive-proof lighting, and were also required to test the atmosphere for flammableconditions before and during entry. However, no one at the refinery had been madeaccountable for compliance with the permit. Employee accounts indicate that
refinery management originally followed permit procedures but largely ignored themthe day of the incident. For example, even though it was known that the work couldgenerate a flammable atmosphere and that only explosion-proof lighting was allowedwhere a flammable atmosphere could exist, only two of the twelve lamps illuminatingthe inside of the tank were explosion-proof; no lifelines were available; and noatmospheric monitoring was done. Five employees were in the tank when itexploded and burned briefly. The workers outside the tank were unable to help them.The fire burned out in just seconds, but by then four of the workers were dead. Thefifth entrant died of massive respiratory injuries several days later.
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