OSHA Confined Space Rule versus Petroleum RetailConfined Spaces
Petroleum Retail
Why Are We Here?
they are large enough for workers to enter and perform certain
tasks
have limited or
not designed for
continuous human occupancy
tanks, vessels, silos, storage bins, hoppers, vaults, pits, sumps,
manholes, tunnels, equipment housings, ductwork, pipelines,
etc.
What is a Confined Space?
contains or has the potential to contain a hazardous atmosphere
contains material that has the potential to engulf an entrant has
walls that converge inward or floors that slope downward and taper
into a smaller area which could trap or asphyxiate an entrant or
contains any other recognized safety or health hazard known as
“permit space”
What is a “Permit- Required Confined Space”?
Petroleum Retail “Permit Spaces”
Storage Tanks STP Sumps Dispenser Sumps Don’t forget about the
other examples!
FEDERAL REGULATIONS
29 CFR 1910.146 – General Industry 29 CFR 1926 Subpart AA –
Construction
STATE REGULATIONS
own OSHA-approved State Plans
Alaska Arizona California Connecticut* Hawaii Illinois* Indiana
Iowa Kentucky Maine Maryland Michigan Minnesota Nevada New Mexico
New Jersey* New York*
North Carolina Oregon Puerto Rico South Carolina Tennessee Utah
Vermont Virgin Islands* Washington Wyoming
* State Plan covers state & local government workers
only.
State Plan States
OSHA says: If you are doing construction work - such as building a
new structure or upgrading an old one - then you must follow the
construction confined space rule. Helpful?
What regulation do I follow? General Industry? Construction? State
vs. Federal
What are you doing? Construction? Maintenance? Service? Repair? Why
do we care?
Construction”
OSHA's regulations define "construction work" as "construction,
alteration, and/or repair, including painting and decorating." They
further provide that OSHA's construction industry standards apply
"to every employment and place of employment of every employee
engaged in construction work." The terms "building" and "work"
generally include construction activity as distinguished from
manufacturing, furnishing of materials, or servicing and
maintenance work.
Further, construction work is not limited to new construction. It
includes the repair of existing facilities. The replacement of
structures and their components is also considered construction
work.
There is no specified definition for "maintenance", nor a clear
distinction between terms such as "maintenance", "repair", or
"refurbishment." "Maintenance activities" can be defined as making
or keeping a structure, fixture or foundation (substrates) in
proper condition in a routine, scheduled, or anticipated fashion.
This definition implies "keeping equipment working in its existing
state, i.e., preventing its failure or decline." However, this
definition, (taken from the directive on confined spaces) is not
dispositive; and, consequently, determinations of whether a
contractor is engaged in maintenance operations rather than
construction activities must be made on a case-by-case basis,
taking into account all information available at a particular
site.
“Maintenance”
An employer whose workers are engaged in both construction and
general industry work in confined spaces will meet OSHA
requirements if that employer meets the requirements of 29 CFR 1926
Subpart AA - Confined Spaces in Construction. Don’t forget to check
your
state requirements.
Interpretation
There are 5 key differences from the construction rule, and several
areas where OSHA has clarified existing requirements.
General Industry vs. Construction
1. More detailed provisions requiring coordinated activities when
there are multiple employers at the worksite. This will ensure
hazards are not introduced into a confined space by workers
performing tasks outside the space. An example would be a generator
running near the entrance of a confined space causing a buildup of
carbon monoxide within the space.
General Industry vs. Construction
2. Requiring a competent person to evaluate the work site and
identify confined spaces, including permit spaces. "Competent
person" means one who is capable of identifying existing and
predictable hazards in the surroundings or working conditions which
are unsanitary, hazardous, or dangerous to employees, and who has
authorization to take prompt corrective measures to eliminate
them.
General Industry vs. Construction
General Industry vs. Construction
4. Requiring continuous monitoring of engulfment hazards. For
example, when workers are performing work in a storm sewer, a storm
upstream from the workers could cause flash flooding. An electronic
sensor or observer posted upstream from the work site could alert
workers in the space at the first sign of the hazard, giving the
workers time to evacuate the space safely.
General Industry vs. Construction
5. Allowing for the suspension of a permit, instead of
cancellation, in the event of changes from the entry conditions
list on the permit or an unexpected event requiring evacuation of
the space. The space must be returned to the entry conditions
listed on the permit before re-entry.
General Industry vs. Construction
Clarifies exposure to physical hazards and requires elimination or
isolation.
If using local emergency services for rescue, ensure they are
available.
Provide training in a language that your employees understand.
Definitions added.
General Industry vs. Construction
An entry employer is an employer who decides that an employee it
directs will enter a permit space.
A controlling contractor is the
employer with overall responsibility for construction at the
worksite.
A host employer is the
employer that owns or manages the property where the construction
work is taking place.
Category of Employer
Employer Responsibilities
All Employers • Identify all confined spaces in which their workers
may work and determine whether any are permit spaces. If its
workers are supposed to enter permit spaces, the employer is an
“entry employer.” • Employers who are not “entry employers” must
make sure their workers stay out of any permit spaces present on
the site, unless the workers are authorized for entry.
Entry Employer • Protect workers against permit space hazards by
complying with the standard. • Inform controlling contractor of the
program followed and hazards encountered in permit spaces.
Controlling Contractors
Share information it has about permit space hazards with entry
employers and other employers whose activities may create hazards
in the permit space. • Coordinate entry operations when there is
more than one entry employer. • Coordinate operations when permit
space entry occurs during other activities at the site that might
create a hazard in the space.
Host Employers
Share information it has about permit space hazards with the
controlling contractor.
Have a competent person identify all confined spaces in which its
employees may work. If confined spaces are
present, the employer must have the competent person determine
whether the confined spaces are “permit spaces.” If the workplace
contains
a permit space, the entry employer must protect its workers against
the hazards in the permit space. STP Sumps, Dispenser
Sumps and Storage Tanks are always “permit spaces.”
Overview
Protective Action
Permit spaces that do not qualify for one of the following two
exceptions.
If the employer’s workers will enter the space, develop and follow
a written permit space program. The permit space program specifies,
among other things, how the employer will (1) regulate worker entry
into permit spaces; and (2) control permit space hazards. All
employers must inform their workers about the locations and dangers
of each permit space (e.g., post signs), and take additional steps
to ensure that workers do not enter permit spaces if they are not
authorized to do so.
Exception 1: Spaces that contain only physical hazards(non-
atmospheric).
If the physical hazards are eliminated or isolated so that they no
longer present a hazard, the space may be reclassified as a
non-permit space, with no further precautions required.
Exception 2: Spaces containing an atmospheric hazard that can be
controlled by continuous forced air ventilation.
As long as the atmospheric hazard is controlled by continuous
forced air ventilation and any physical hazards are eliminated or
isolated, alternate procedures may be used instead of full permit
space procedures, although the space is still classified as a
permit space.
A permit space program must: Implement measures to prevent
unauthorized entry; Identify and evaluate permit space hazards
before allowing employee entry; Provide for the atmospheric
conditions in the permit space to be tested before entry operations
and for the space to be monitored during entry; Require appropriate
testing for the following atmospheric hazards in this sequence:
oxygen, combustible gases or vapors, and toxic gases or vapors;
Establish and implement the means, procedures and practices to
eliminate or control hazards necessary for safe permit space entry
operations; Identify employee job duties; Provide and maintain, at
no cost to the employee, personal protective equipment and any
other equipment necessary for safe entry, and require employees to
use the equipment properly;
A permit space program must: Ensure that at least one attendant is
stationed outside the permit space during entry operations;
Implement the procedures that any attendant who is required to
monitor multiple spaces will follow during an emergency in one or
more of those spaces; Coordinate entry operations (in consultation
with the controlling contractor) when employees of more than one
employer are working in the permit space; and Establish procedures
for summoning rescue and emergency services and preventing
unauthorized personnel from attempting rescue.
Entry Permit Requirements Name of the permit space to be entered,
authorized entrant(s), current attendants, and current entry
supervisors; Purpose of entry; Date and authorized duration of
entry; Means of detecting an increase in atmospheric hazard levels;
Name and signature of supervisor who authorizes entry; Known
hazards in the space; Measures to be taken to isolate permit spaces
and to eliminate or control space hazards; Acceptable entry
conditions; Test results, date and time of test(s), and tester’s
initials or signature; Name and telephone numbers of rescue and
emergency services and means to be used to contact them;
Communication procedures and equipment to maintain contact during
entry; Special equipment and procedures, including personal
protective equipment and alarm systems; Any other information
needed to ensure employee safety; and Additional permits, such as
for hot work, that have been issued authorizing work in the permit
space.
Confined Space Entry Permit
In the event of an emergency call 9-1-1
SECTION 1 Permit Issued: Is this a permit-required space? Yes No
(If no permit required skip section #4)
ion of Confined Space (What area, floor, etc.):
iption of confined space:
iption of work to be performed:
Material or Chemicals located and/ or brought into the confined
spaces MSDS Yes No MSDS Yes No MSDS Yes No MSDS Yes No MSDS Yes No
MSDS Yes No
Air monitoring device information / Model: Date of
Calibration:
Pre-entry Atmospheric monitoring results en (19.5%-23%)
% Carbon monoxide (< 35PPM) PPM
Flammables (<10% of LEL) %
Yes Chemical exposures Corrosive Substances Carbon Monoxide
Potential Flammable/ Explosive Dust O2 Deficient O2 Enriched
Flammable Gas Temperature Extremes Slip/ Trip/ Fall Vermin/ Animal
Limited Egress Noise/ Vibration Structural Collapse Small Internal
Size Visual/ Lighting Plumbing Lines HVAC (Heating, Ventilation and
Air conditioning) Radiation (ionizing or non ionizing) Pressurized
Equipment Mechanical Equipment Electrical Hazards Biohazards
Asbestos other:
Controls needed for hazards N/A Yes
Barricade/ Signs Lock out/ Tag out Double block and bleed Lighting
Air purifying respirator Supplied Air Respirator/ SCBA Hearing
Protection Mechanical fresh air ventilation Natural Ventilation
Protective clothing Safety Glasses/ Face shield Hard hat/ head
protection Ground fault interrupter (GFCI) Harness/ Life lines/
Tripod Gloves/ Hand Protection Continuous air monitoring Fire
extinguisher. Type: Two way communication equipment Eye wash/
Emergency Shower Hot work Permit First Aid kit other: other:
other:
ional Information:
SECTION 1
Date Permit Issued:
Is this a permit-required space? Yes FORMCHECKBOX No FORMCHECKBOX
(If no permit required skip section #4)
Location of Confined Space (What area, floor, etc.):
Description of confined space:
Description of work to be performed:
Material or Chemicals located and/ or brought into the confined
spaces
MSDS Yes FORMCHECKBOX No FORMCHECKBOX
MSDS Yes FORMCHECKBOX No FORMCHECKBOX
MSDS Yes FORMCHECKBOX No FORMCHECKBOX
MSDS Yes FORMCHECKBOX No FORMCHECKBOX
MSDS Yes FORMCHECKBOX No FORMCHECKBOX
MSDS Yes FORMCHECKBOX No FORMCHECKBOX
Air monitoring device information
FORMCHECKBOX FORMCHECKBOX O2 Deficient
FORMCHECKBOX FORMCHECKBOX O2 Enriched
FORMCHECKBOX FORMCHECKBOX Flammable Gas
FORMCHECKBOX FORMCHECKBOX Temperature Extremes
FORMCHECKBOX FORMCHECKBOX Vermin/ Animal
FORMCHECKBOX FORMCHECKBOX Limited Egress
FORMCHECKBOX FORMCHECKBOX Noise/ Vibration
FORMCHECKBOX FORMCHECKBOX Structural Collapse
FORMCHECKBOX FORMCHECKBOX Visual/ Lighting
FORMCHECKBOX FORMCHECKBOX Plumbing Lines
FORMCHECKBOX FORMCHECKBOX Radiation (ionizing or non
ionizing)
FORMCHECKBOX FORMCHECKBOX Pressurized Equipment
FORMCHECKBOX FORMCHECKBOX Mechanical Equipment
FORMCHECKBOX FORMCHECKBOX Electrical Hazards
FORMCHECKBOX FORMCHECKBOX Lighting
FORMCHECKBOX FORMCHECKBOX Supplied Air Respirator/ SCBA
FORMCHECKBOX FORMCHECKBOX Hearing Protection
FORMCHECKBOX FORMCHECKBOX Natural Ventilation
FORMCHECKBOX FORMCHECKBOX Protective clothing
FORMCHECKBOX FORMCHECKBOX Gloves/ Hand Protection
FORMCHECKBOX FORMCHECKBOX Continuous air monitoring
FORMCHECKBOX FORMCHECKBOX Fire extinguisher. Type:
FORMCHECKBOX FORMCHECKBOX Two way communication equipment
FORMCHECKBOX FORMCHECKBOX Eye wash/ Emergency Shower
FORMCHECKBOX FORMCHECKBOX Hot work Permit
FORMCHECKBOX FORMCHECKBOX First Aid kit
FORMCHECKBOX FORMCHECKBOX other:
FORMCHECKBOX FORMCHECKBOX other:
FORMCHECKBOX FORMCHECKBOX other:
Additional Information:
SECTION 3
Continuous Atmospheric monitoring results (Tests must be recorded
at least once per hour)
Remember to test at different levels (e.g. low, medium, and
high)
Time
(Please Print Neatly)
Post authorized permit at job site until completed.
Qualified Entry Supervisor.
I certify that all of the requirements of the confined space entry
program have been met. I have ensured that all applicable hazards
have been identified and sufficiently controlled.
Permit authorization
Name:
Signature:
Permit Cancellation
Time Canceled
In the event of an emergency Call 9-1-1
The Entry Supervisor is required to submit the completed permits to
the Safety Administrator for 3 years.
Page 1 of 2
A permit space that contains only physical hazards may be
reclassified as a non-permit space if (1) the physical hazards are
eliminated or isolated without entering the space; or (2) the
physical hazards are eliminated or isolated by entering the space
using permit space procedures. Examples; mechanical,
electrical,
hydraulic and pneumatic energy; radiation; temperature extremes;
engulfment; noise; inwardly converging surfaces; and chemicals that
can cause death or serious physical harm through skin or eye
contact (rather than through inhalation).
A space containing an atmospheric hazard cannot be reclassified as
a non- permit space. However, if the atmospheric hazard in a permit
space can be controlled by forced air ventilation, the employer may
use less stringent procedures instead of full permit space
procedures when workers enter the space. The alternate procedures
may be used if the employer can show that: All physical hazards are
eliminated or isolated; The only hazard is an actual or potential
hazardous atmosphere that can be and is made safe for entry using
continuous forced air ventilation; and In the event the ventilation
system stops working, entrants can exit the space safely.
Entry and Exit Any conditions making it unsafe to remove an
entrance cover must be eliminated before the cover is removed. When
entrance covers are removed, the opening must be immediately
guarded by a railing, temporary cover, or other temporary barrier
that will prevent an accidental fall through the opening and that
will protect each employee working in the space from foreign
objects entering the space. Before a worker enters the space, the
internal atmosphere must be tested, with calibrated direct-reading
instruments, for oxygen content, for flammable gases and vapors,
and for potential toxic air contaminants, in that order.
Entry and Exit The employer must verify that the space is safe for
entry and that the pre-entry measures discussed above have been
taken, through a written certification that contains the date, the
location of the space, and the signature of the person providing
the certification. The certification must be made before entry and
must be made available to each worker entering the space or to that
worker’s authorized representative. The employer must provide
workers with a safe method of entering and exiting the space. Any
hoisting system that is used must either (1) be designed and
manufactured for personnel hoisting; or (2) be approved for
personnel hoisting by a registered professional engineer prior to
use.
Ventilation Requirements: Continuous forced air ventilation must be
used. (Exhaust ventilation is not an acceptable substitute for
forced air ventilation.) If the forced air ventilation stops for
any reason, the entrant(s) must immediately leave the space. The
forced air ventilation must be directed to ventilate the immediate
areas where each entrant is or will be located within the space and
must continue until all employees have left the space. The air
supply for the forced air ventilation must be from a clean source
and must not increase the hazards in the space.
During Entry: The atmosphere within the space must be monitored to
ensure that the forced air ventilation is preventing the
accumulation of a hazardous atmosphere. Monitoring must be
conducted continuously unless the entry employer can demonstrate
that equipment for continuous monitoring is not commercially
available or that periodic monitoring is sufficient to ensure that
the atmosphere remains nonhazardous. Employers must provide any
worker who enters the space, or that worker’s authorized
representative, with an opportunity to observe the testing required
by this paragraph. If a hazard is detected during entry: (A)
Employers must make sure each worker leaves the space immediately;
(B) The space must be evaluated to determine how the hazard
developed; and (C) The employer must implement measures to protect
workers from the hazard before any subsequent entry takes
place.
Tank Entry – Written “permit space” Program Training Entry Permit
System Rescue Information Exchange Signage/Barricades
Monitoring/Ventilation
Sump Entry (non-atmospheric)– Reclassification Training Information
Exchange
Sump Entry (atmospheric) – Alternate “permit space” procedure
Training Monitoring/Ventilation Amended permit
Signage/Barricades
Art Sodermark, MS (352) 267-8440 www.platinumengineers.com
Confined Spaces Petroleum Retail
What is a “Permit- Required Confined Space”?
Petroleum Retail “Permit Spaces”
What regulation do I follow?General Industry?Construction?State vs.
Federal
What are you doing?Construction?Maintenance? Service? Repair?Why do
we care?
“Construction”
“Maintenance”
Interpretation
Slide Number 22
Alternate “Permit Space”(atmospheric)
Alternate “Permit Space”(atmospheric)
Alternate “Permit Space”(atmospheric)
Alternate “Permit Space”(atmospheric)
Alternate “Permit Space”(atmospheric)
Summary