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Compliance and Safety in Confined Spaces for the Windpower Industry
| Date post: | 06-May-2015 |
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Compliance and Safetyin Confined Spaces for the Windpower
Industry
Sponsored By:
Before We Start This webinar will be available at
www.windpowerengineering.com & via email
Q&A at the end of the presentation
Tweet with hashtag #WindWebinar
Moderator
Steven BushongWindpower Engineering &
Development
Presenters
Scott BramlettEDF Renewable Services
Rob Siegel ENSA North America
Confined / Enclosed Spaces in the Wind IndustryScott Bramlett – EDF Renewable
Services
Confined / Enclosed Spaces in the Wind Industry
• Introduction / Overview
• Employer Duties / OSHA
• Confined Space Assessment / Classification
• Written Program & Training
• Coordination
Occupational Safety & Health Administration
Under the Occupational
Safety and Health Act, the
Occupational Safety and
Health Administration
(OSHA) was created within
the Department of Labor
to:
Occupational Safety & Health Administration
• Encourage employers and employees to reduce
workplace hazards and to implement new or
improve existing safety and health programs;
• Innovation of H&S practices
• Develop rights / responsibilities
Occupational Safety & Health Administration
• Recordkeeping
• Training
• Develop / Enforce H&S Standards (29CFR)
• State programs
Employer Duties:
“General Duty Clause – Section 5(a)”
(a) Each employer
(1) shall furnish to each of his employees
employment and a place of employment which are
free from recognized hazards that are causing or are
likely to cause death or serious physical harm to his
employees;
(2) shall comply with occupational safety and health
standards promulgated under this Act.
Employee Duties:
29 USC 654
(b) Each employee shall comply with occupational
safety and health standards and all rules, regulations,
and orders issued pursuant to this Act which are
applicable to his own actions and conduct.
Confined / Enclosed Spaces
Enclosed vs Confined Space:
1910.269 – Enclosed Spaces
• Limited Entry / Egress
• Not designed for continuous occupancy
• Underground transmission areas or “vaults”
Enclosed vs Confined Space:
1910.146 – Confined Spaces
• Large enough for employee entry
• Limited Entry / Egress
• Not designed for continuous occupancy
Permit-Required Confined Spaces:
1910.146 – Permit-Required Confined Spaces
• Is a Confined or Enclosed Space
and…
• Contains or has the potential to contain a
hazardous atmosphere
• Contains material that could engulf an entrant
• Configuration is such that it could cause
entrapment
• Any other recognized safety or health hazard…
OSHA Regulation and the Wind Industry:
• PRCS Reclassification (1910.146(c)5-7)
• (if) The employer can demonstrate that the
only hazard posed by the permit space is an
actual or potential hazardous atmosphere;
• The employer can demonstrate that continuous
forced air ventilation alone is sufficient to
maintain that permit space safe for entry
• Develop and provide continuous monitoring…
OSHA and the Wind Industry
OSHA and the Wind Industry:
Electrical Power Generation, Transmission, and
Distribution (generally post-commissioning)
• 29CFR 1910.269 / 1910.146
• Enclosed / Permit-Required Confined Space
Employer Duties: Enclosed Spaces
• Evaluate potential hazards
• Safe practices – entry, work, rescue
• Training – hazards, entry & rescue procedures
• Rescue – Provide “prompt” rescue
• Based on the type of hazard / potential
Employer Duties: Permit-Required Confined Spaces
The Employer shall: (CFR1910.146(c)(1))
• Evaluate the workplace to determine if any spaces
are permit-required.
1910.146 Appendix A (flowchart)
• Inform Employees of the spaces and their location
Employer Duties: Permit-Required Confined Spaces
• Take effective measures to prevent its employees
from entering the permit spaces (if it decides not
to allow employees to enter prcs)
• Develop and implement a written permit space
program as applicable (employer decides to allow
prcs entry)
Enclosed / Permit Spaces in the Wind Industry
Turbine Sump or “Basement”
Turbine Sump or “Basement”
• Limited entry/exit
• Atmospheric Hazards
• Electrical• Environment
al
Rotor Hub Enclosure:
Rotor Hub Enclosure:
• Limited entry/exit
• Rotational Hazard
• Mechanical (pitching)
• Electrical• Pressurized fluid• Environmental
hazards
Blades:
• Inwardly converging walls
• Rotation• Narrow
configuration• Atmospheric
hazards• Limited
entry/exit• Environment
al hazards
Classification:
Start with the hazards in the space prior to entry
• Are they able to be eliminated?
• Are they controlled (Personal Protective
Equipment, ventilation etc.)
Classification:
What hazards will be present in the space once work
starts?
• Will the work create a hazardous atmosphere?
(Welding, painting etc)
• Does the work create any other significant
hazard?
Classification:
As a rule of thumb, if the hazard in the space is
significant enough to limit or prevent unassisted
evacuation of the space (because of configuration,
injury or exposure) the space should be considered
permit-required.
You must create safe working conditions inside the
space…
Written Program (1910.146):
• Identifies the spaces
• Prohibits unauthorized entry
• Specifies acceptable entry conditions
• Provide monitoring & access to monitoring
• Ensures hazard elimination
• Provides all necessary PPE
• Coordinates entry
• Ensures necessary training
Training:
• Authorized Entrant
• Authorized Attendant
• Entry Supervisor
• Rescue Team
• Annual Rescue training / evaluation
Coordination:
• Communicates status of the space / permit
• Ensures continuity of protection
• Shift changes
• Contractors
• Rescue services
In Summary
• Each employer must evaluate its enclosed or
confined spaces
• Develop a program addressing the hazards
associated with the space and potential hazards
• Provide the necessary equipment for safety /
rescue
• Provide adequate training for Entrants, Attendants,
Supervisors, Exposed Employees
• Coordinate entries with contractors as necessary
For more information…
• 29 CFR 1910.269 (e) Electrical Power Generation,
Transmission, and Distribution
• 29 CFR 1910.146 Permit Required Confined Spaces
• American Wind Energy Association
Confined Space Entry – Wind Energy
37
Wind Turbines contain spaces that are considered to be "confined" because their configurations hinder the activities of employees who must enter into, work in or exit from them. Employees who work in confined spaces face increased risk of exposure to serious physical injury from hazards such as:
Entrapment, Engulfment and Hazardous atmospheric conditions
Confinement itself may pose entrapment hazards and work in confined spaces exposes employees to hazards they would otherwise not be exposed to. For example,
Removal and reinstallation of heavy pitch pumps and motors Accumulator tanks Electrical cabinets and battery boxes
38
Many workers who enter into the narrow spaces of the blade to inspect lightning protection equipment or repair blades or fiberglass skin can be subjected to space penetration distances that are excessive without alternative means of access or escape. Consequently the workers are then further isolated from a rescuer.
A number of persons are killed or seriously injured in confined spaces each year in North America and the environment in which wind energy operates poses many confined space hazards to both technicians and those who would rescue them.
Discussion Objectives
• Locations of work vs. Determination• Hazards Identified• Hazard and Risk Assessments• Rescue Planning• Training Entry, Rescue and Company
Policies• Resources
Determination & Work Locations
Regardless of State or Province - Confined spaces are high risk locations to perform work in. (Countries with Mature Safety Standards)
o Same underlying theory exists for confined space work
• Determine if there is work in confinement
• Define those locations• Assess for hazards
WTG Anatomy - Basements
Confined Space Assessment
It is sufficiently large for a worker to enter and work
Yes
Its entrance and exit have size limitations Yes
Is designed for continuous occupancy No
Basements that meet the CS criteria:• Simple• Permit Required
IDENTIFYING HAZARDS
• Physical• Biological• Chemical
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Non-exhaustive Example
Written Assessment - Basement Survey
Non-exhaustive Example
Written Assessment - Basement Survey
Non-exhaustive Example
Written Assessment - Basement Survey
Non-exhaustive Example
Written Permit Entry
Case Study – Need for Training
• Employees who were required to enter the hub (a permit-required confined space) or act as attendants to employees entering the hub had not been trained in emergency rescue procedures from the hub.
August 2007 – Excerpt from News Source Oregon Electrical
During its investigation, Oregon OSHA found no structural problems with the tower. However, several violations of safety rules were discovered, including:
Resources• Confined Space and Structural Rope Rescue,
Michael Roop, Thomas Vines, and Richard Wright, Published by Mosby, Inc., 1998.
• Safe Work in Confined Space-Wind Industry, Published by Robert Siegel
ENSA Access and Rescue 2008
Questions?Windpower Engineering & Development Steven [email protected]: 440.234.4531Twitter: @WTWH_Renewables
ENSA North AmericaRob Siegel [email protected] Phone: 262.705.4558 Twitter:@ENSATraining
EDF Renewable ServicesScott [email protected] Phone: 858.521.3575
Thank You Tweet with hashtag #WindWebinar This webinar will be available at windpowerengineering.com
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