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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 Challenge1)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
The three conditions that define a confined space…
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…
Challenge #1Challenge #1Can your employees identify a Confined Space (CS)?
“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…
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”
Considered to be the most common and dangerous hazard
in a confined space…
“19.5% - 23.5%”
If a confined space has an oxygen atmosphere between
_____% and _____ %, it may be safe to enter.
“Lower Explosive Limit or LEL”
Atmospheric monitors display flammability as a percentage of
this measurement…
Challenge #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,….”
Other than atmosphere, name four other hazards may one face
in a confined space…..
“According to the manufacturer’s
recommendations”
The frequency with which gas monitors need to be
calibrated…
““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…
Gas Stratification in Confined Spaces
CHECKALL
LEVELSSinks
Drifts
Floats
“Mechanical Ventilation”
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”
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 #3Do your employees know how atmospheric control equipment works?
“Permit Required Entry”
“Alternate Procedure “C(5)” Entry “
“Declassified / Non-Permit Required Entry”
The three types of confined space entries that may be performed…
“ALL OF THEM!”
Which of the three types of confined spaces require
atmospheric testing prior to entry?
“Confined Space Permit”
The confined space regulation states that an entry supervisor must complete this document
before anyone enters a confined space…
Challenge #4Challenge #4Can your
employees determine the
proper classification of a confined space?
Entrant, Attendant,
Supervisor, Rescue
The four duty positions required by Cal/OSHA for a Permit-Required confined
space entry…
The hazards and how to control or eliminate them
What every confined space position must know prior to an
entry being made?
“Breaks the plane of a space”
Confined space entry has occurred when any part of
the body…
“Personnel must exit the space”
The action that must be taken if the attendant leaves the
space…
“Entry Supervisor”
The person who has overall responsibility for
the entry…
“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….
Challenge #5Challenge #5Is your staff
adequately trained for CSE operations?
“Would be rescuers”?
In the past, 50-60 % of fatalities in confined spaces were these
types of persons…
“Tripod, Harness, Winch, Gas Monitor, Ventilator,
SCBA, Annual Training….”
List at least five pieces of rescue equipment you would want to have
available…
“12 months”
Rescue teams must conduct a training drill at least once
every…
Challenge #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!!