1

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.

3

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

5

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

8

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.

9

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

10

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

Tanks Boilers Vats Kilns Vaults Silos Pipelines Sewers

11

12

13

14

15

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

19

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,

20

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)

22

CalibrationSample Locations

23

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

28

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.

29

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

30

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

33

34

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!!!

35

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