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IIPP (Section 3203)(a) “…every employer…”

(a) (4) Include procedures for identifying and evaluating work place hazards…

◦ (C) Whenever the employer is made aware of a new or previously unrecognized hazard.

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Construction 5%

Inspection 10%

Repair/Maintenance 40%

Rescue 36%

Retrieve Object 3%

Dislodge material 5%

Unknown 1%

In place February 2012 All Cal-OSHA units

◦ Enforcement◦ Consultation◦ Every inspection will include an evaluation of

confined spaces Goal: Zero confined space fatalities in 2012

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For ALL Inspections: Ask ER if they have any confined spaces Look for Confined Spaces during walk-

around◦ Identify hazards◦ Verify that spaces are labeled

Ask ER if anyone enters spaces and how spaces are maintained & cleaned

Interview employees entering spaces

Review written “Confined Space Program”, or procedures and documentation/records

Review alternate entry and/or reclassification procedures if applicable

Review rescue procedures Audit last 6 months’ permits for PRCS-entry

or certificates of reclassification

Confined spaces present very special work requirements and preparations

Safety incidents involving confined spaces may result in fatalities; many have multiple serious injuries

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If confined spaces exist in your workplace◦Post the space◦Warn employees of the hazard◦Prevent employees from entering until an effective and fully implemented confined space program is in place.

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Large enough and configured so that they can be entered, and

Have restricted means for entry or exit, and

Are not designed for continuous employee occupancy

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Manure pits Storage bins Double hulls Pumping stations Pits, sumps Vessels Manholes Water reservoirs

Tanks Boilers Vats Kilns Vaults Silos Pipelines Sewers

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Does the person have to use their hands to enter or exit the space?

Is the person in an awkward posture when entering or exiting the space?

Is a person’s entry into or exit from the space slowed down or impeded by physical obstructions (such as pipes, ductwork, walls, holes in the floor, flanges, etc.)?

Would an employee be forced to enter or exit in a posture that might slow self-rescue or make rescue more difficult?

Is an acutely hazardous atmosphere or physical hazard present?

If it’s not present now, can it become

present later?

Title 8, CCR

Sections 5156, 5157 & 5158

A “performance” standard: Every confined space is unique and must be treated on a case-by-case basis

Limited entrance and exit + potential atmospheric hazard or other hazards = “Permit Required Confined Space”

Applies to most workplaces such as:◦ Food production◦ Chemical manufacturing◦ Recycling operations◦ Sewer plants◦ Plating shops◦ Amusement parks

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Limited entrance and exit + hazardous atmosphere = “Confined Space”

Applies to:◦ Construction, ◦ Agriculture, ◦ Marine terminals ◦ Telecommunication manholes and unvented

vaults◦ Grain handling facilities, ◦ Natural gas utility operation within distribution

and transmission facility vaults,

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All Operations or Industries Except:

Construction

Agriculture

Marine Terminals

Telecommunication Manholes

Grain Handling Facilities

Natural Gas Utility

Electric Utility

5158 Applies

If a confined space has a hazardous atmosphere, or has the potential for a hazardous atmosphere, special confined space procedures must be taken

Hazardous atmosphere includes:◦ Oxygen deficiency or enrichment◦ Flammable atmosphere◦ Acutely toxic (Immediately Dangerous to Life or

Health, or impairs ability to self-rescue)

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CalibrationSample Locations

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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

So...Must test at multiple levels within space!

Specific Gravity

Use direct reading instruments with “real time” information on actual concentrations

“Alarm only” devices which do not provide readings, are not considered acceptable direct reading instruments

OxygenCombustible gases and vaporsToxic gases and vapors

When testing for atmospheric hazards, test in the following order:

OR, test for all simultaneously

Aviation fuelSensor poisoningCalibrationEmployee medical exposure records

Inerting of the space

Product stored in a confined space: Gases released when cleaning. Materials absorbed into walls of confined space, even if

space has been emptied or cleaned. Rotting organic materials and other decomposition

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Work performed in a confined space: Welding, cutting, brazing, soldering Painting, scraping, sanding, degreasing Sealing, bonding, melting

Connections or pipes to other spaces, or leakage from adjacent areas or soils.

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Water or other materials in the space, such as sand or sugar, are an “engulfment” hazard

A person may be trapped in the space due to sloping floor, converging walls, or piping or other obstacles

Any other recognized serious safety hazard such as energy sources, mechanical hazards, steam, or heat

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Hazardous atmosphere Energy sources

following characteristics:

electrical

mechanical

hydraulic

pneumatic, etc.

Other

One or more of the following:

<19.5% Oxygen

> 23.5% Oxygen

>10% LEL (G/V)

=/> 10% LEL (Dust)

IDLH

>PEL (Acute)

steam corrosives, etc.

Engulfment Entrapment

The action by which a person passes through an opening into a permit-required confined space, and includes ensuing work activities in that space

Considered to have occurred as soon as any part of the entrant’s body breaks the plane of an opening into the space

◦ Post the space and prevent unauthorized entry◦ Develop a program◦ Assess the space prior to and continually during

each entry, including atmospheric monitoring◦ Train employees in required roles – entrant,

attendant, supervisor, rescuers◦ Isolate the space from other energy sources &

materials◦ Have effective rescue procedures

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Non-entry rescue is preferred! You must utilize retrieval systems unless they would not be effective in the space

In addition to the attendant, there must be at least one standby person at the site who is trained and immediately available to perform rescue and emergency services.

Practice simulated rescue operations at least every 12 months in actual space or representative spaces based on opening size, configuration, and accessibility….

“CALL 911” IS NOT A RESCUE PLAN!!!

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Evaluate and Posting

§5157(c)(1) - - -

Written Procedures §5157(c)(4) §5158(c)(1)(A)

Atmospheric Testing

§5157(d)(5) §5158(d)(3)

Ventilation §5157(c)(5)(B)

§5158(d)(6)

Rescue Procedures §5157(d)(9) §5158(c)(1)Training §5157(g)(1) §5158(c)(2)

“Confined Spaces: Is it Safe to Enter?” [under revision]

OSHA “Advisor”

Federal Register Preamble

Your ChallengeYour ChallengeYour ChallengeYour Challenge

1)Use the SCORE CARD provided as a guide to the presentation.

2)Make an honest evaluation of your understanding of the topics discussed.

3)Focus your organization’s “improvements” on the issues scored “UNCOMFORTABLE”.

1. Large enough to enter,

2. Limited means of access

3. Not designed for continuous occupancy

1. Large enough to enter,

2. Limited means of access

3. Not designed for continuous occupancy

The three conditions that define a confined space…

The three conditions that define a confined space…

An inventory of all spaces including the hazards, space

classifications, equipment requirements, and rescue

procedures

An inventory of all spaces including the hazards, space

classifications, equipment requirements, and rescue

procedures

What must an employer develop as part of their Confined Space

Entry program…

What must an employer develop as part of their Confined Space

Entry program…

Challenge #1Challenge #1Challenge #1Challenge #1Can your employees identify a Confined Space (CS)?

“Labeling with a sign: “Confined Space – Entry by Permit Only – No Unauthorized Personnel (or

similar)”

“Labeling with a sign: “Confined Space – Entry by Permit Only – No Unauthorized Personnel (or

similar)”

Whenever possible confined spaces should be identified using this method…

Whenever possible confined spaces should be identified using this method…

P E R M IT R E Q U IR E D C O N F IN E D S PA C E

D O N O T E N T E R

“Atmosphere”“Atmosphere”

Considered to be the most common and dangerous hazard

in a confined space…

Considered to be the most common and dangerous hazard

in a confined space…

“19.5% - 23.5%”“19.5% - 23.5%”

If a confined space has an oxygen atmosphere between

_____% and _____ %, it may be safe to enter.

If a confined space has an oxygen atmosphere between

_____% and _____ %, it may be safe to enter.

“Lower Explosive Limit or LEL”

“Lower Explosive Limit or LEL”

Atmospheric monitors display flammability as a percentage of

this measurement…

Atmospheric monitors display flammability as a percentage of

this measurement…

Challenge #2Challenge #2Challenge #2Challenge #2Are there procedures and supervision in place to test the atmosphere prior to, and during, every Confined Space Entry (CSE)?

Lake Hemet Water District Lake Hemet Water District CSE FatalityCSE Fatality

“Engulfment, internal configuration, or job introduced

hazards such as electrical, moving parts, pressure piping, welding,

chemicals,….”

“Engulfment, internal configuration, or job introduced

hazards such as electrical, moving parts, pressure piping, welding,

chemicals,….”

Other than atmosphere, name four other hazards may one face

in a confined space…..

Other than atmosphere, name four other hazards may one face

in a confined space…..

“According to the manufacturer’s

recommendations”

“According to the manufacturer’s

recommendations”

The frequency with which gas monitors need to be

calibrated…

The frequency with which gas monitors need to be

calibrated…

““Stratification” or Stratification” or “Layering”“Layering”

““Stratification” or Stratification” or “Layering”“Layering”

Appendix B of the Cal/OSHA Appendix B of the Cal/OSHA confined space regulation confined space regulation states that the atmosphere states that the atmosphere

should be tested every 4 feet should be tested every 4 feet because the potential for…because the potential for…

Appendix B of the Cal/OSHA Appendix B of the Cal/OSHA confined space regulation confined space regulation states that the atmosphere states that the atmosphere

should be tested every 4 feet should be tested every 4 feet because the potential for…because the potential for…

Gas Stratification in Confined Spaces

CHECK

ALL

LEVELS

Sinks

Drifts

Floats

“Mechanical Ventilation”“Mechanical Ventilation”

The primary means of control used to maintain safe

atmospheric conditions…

The primary means of control used to maintain safe

atmospheric conditions…

Space Ventilation

One opening Lighter than air gases

One openingHeavier than air gases

WINDWIND

POSITIVE PRESSURE NEGATIVE PRESSURE

“ Short-Circuiting”“ Short-Circuiting”

This happens when ventilation air moves directly from the inlet to the exhaust outlet, without reaching the other areas of the space…

This happens when ventilation air moves directly from the inlet to the exhaust outlet, without reaching the other areas of the space…

Space Ventilation

Hose too short Air turns to path of least resistance

Fan intake in downwindHazardous air is drawn into fan

WIND

SHORT CIRCUTING RECIRCULATING

WIND

Challenge #3Challenge #3Challenge #3Challenge #3

Do your employees know how atmospheric control equipment works?

“Permit Required Entry”

“Alternate Procedure “C(5)” Entry “

“Declassified / Non-Permit Required Entry”

“Permit Required Entry”

“Alternate Procedure “C(5)” Entry “

“Declassified / Non-Permit Required Entry”

The three types of confined space entries that may be performed…

The three types of confined space entries that may be performed…

“ALL OF THEM!”“ALL OF THEM!”

Which of the three types of confined spaces require

atmospheric testing prior to entry?

Which of the three types of confined spaces require

atmospheric testing prior to entry?

“Confined Space Permit”“Confined Space Permit”

The confined space regulation states that an entry supervisor must complete this document

before anyone enters a confined space…

The confined space regulation states that an entry supervisor must complete this document

before anyone enters a confined space…

Challenge #4Challenge #4Challenge #4Challenge #4Can your

employees determine the

proper classification of a confined space?

Entrant, Attendant,

Supervisor, Rescue

Entrant, Attendant,

Supervisor, Rescue

The four duty positions required by Cal/OSHA for a Permit-Required confined

space entry…

The four duty positions required by Cal/OSHA for a Permit-Required confined

space entry…

The hazards and how to control or eliminate themThe hazards and how to

control or eliminate them

What every confined space position must know prior to an

entry being made?

What every confined space position must know prior to an

entry being made?

“Breaks the plane of a space”

“Breaks the plane of a space”

Confined space entry has occurred when any part of

the body…

Confined space entry has occurred when any part of

the body…

“Personnel must exit the space”

“Personnel must exit the space”

The action that must be taken if the attendant leaves the

space…

The action that must be taken if the attendant leaves the

space…

“Entry Supervisor”“Entry Supervisor”

The person who has overall responsibility for

the entry…

The person who has overall responsibility for

the entry…

“Host Contractor/Host Agency”

“Host Contractor/Host Agency”

Who has the obligation to inform outside contractors about all

known hazards and precautions normally taken when entering a

confined space….

Who has the obligation to inform outside contractors about all

known hazards and precautions normally taken when entering a

confined space….

Challenge #5Challenge #5Challenge #5Challenge #5Is your staff

adequately trained for CSE operations?

“Would be rescuers”?“Would be rescuers”?

In the past, 50-60 % of fatalities in confined spaces were these

types of persons…

In the past, 50-60 % of fatalities in confined spaces were these

types of persons…

“Tripod, Harness, Winch, Gas Monitor, Ventilator,

SCBA, Annual Training….”

“Tripod, Harness, Winch, Gas Monitor, Ventilator,

SCBA, Annual Training….”

List at least five pieces of rescue equipment you would want to have

available…

List at least five pieces of rescue equipment you would want to have

available…

“12 months”“12 months”

Rescue teams must conduct a training drill at least once

every…

Rescue teams must conduct a training drill at least once

every…

Challenge #6Challenge #6Challenge #6Challenge #6Do you, without a doubt, have a rescue capability for every CSE?

Thank you for taking the Thank you for taking the ChallengeChallenge

Rate your organization’s CSE Rate your organization’s CSE Program!Program!

INSTITUTE IMPROVEMENTS INSTITUTE IMPROVEMENTS NOWNOW!!