Confined Spaces Confined Space Entry Construction Industry Standard

Confined Spaces

Confined Space Entry • Construction Industry Standard 1926. 21(b)(6) • General Industry Standard 1910. 146 • Best Practices for all Industries

Typical Confined Spaces • Boiler, Degreaser, Furnace • Pipeline, Pit, Pumping Station • Reaction or Process Vessel, Mills • Septic Tank, Sewage Digestor • Silo, Storage Tank, Barges • Sewer, Utility Vault, Manhole • Trenches, Shafts, Caissons

The Three Elements of a Confined Space • Is large enough and so configured that an employee can bodily enter and perform assigned work; and • Has limited openings for entry and exit, and • Is not designed for continuous worker occupancy

Categorizing Work Space * Space large enough to enter &; * Limited or Restricted entry or exit &; * Not designed for continuous worker occupancy. YES Permit. Required Confined Space NO Not a confined Space Confined Space Non Hazardous Atmosphere YES Or Engulfment Hazard Or Configuration Hazard Or Any other recognized serious hazard NO Permit Required Space

Limited Openings for Entry/Exit • Openings as small as 18 inches in diameter. • Difficult to enter with SCBA or other life- saving equipment. • Difficult to remove downed worker in folded up or bent over position. • Exit from large openings may be difficult due to presence of ladders, hoists, etc.

Unfavorable Natural Ventilation • Lack of air movement in and out of the space can create an atmosphere much different than the outside atmosphere. • Deadly gases can be trapped inside. • Organic materials can decompose. • May not be enough oxygen due to presence of other gases or chemical reactions such as rusting.

Not Designed for Continuous Worker Occupancy • Most confined spaces are not designed to enter and work in on a regular basis. • Designed to store a product. • Enclose materials or processes. • Transport products or substances. • Occasional worker entry for inspection, repair, cleanup, maintenance, etc.

Dangerous Combinations 1. Presence of all three confined space characteristics can complicate the situation. 2. Working in and around the space. 3. Rescue operations during emergencies. 4. Worsened conditions due to work activities: n n n Welding and cutting, use of bonding agents Cleaning with solvents, use of other chemicals Use of gas-powered equipment

Hazards of Confined Spaces • Oxygen Deficient Atmospheres • Oxygen Enriched Atmospheres • Flammable Atmospheres • Toxic Atmospheres • Temperature Extremes • Engulfment Hazards • Noise, Slick/Wet Surfaces, Falling Objects

Oxygen Deficient Atmospheres 19. 5 % Minimum acceptable oxygen level. 15 - 19% Decreased ability to work strenuously. Impair coordination. Early symptoms. 12 -14% Respiration increases. Poor judgment. 10 -12% Respiration increases. Lips blue. 8 -10% Mental failure. Fainting. Nausea Unconsciousness. Vomiting. 6 -8% 8 minutes - fatal, 6 minutes - 50% fatal 4 -5 minutes - possible recovery. 4 -6% Coma in 40 seconds. Death

Oxygen Enriched Atmospheres 1. Oxygen level above 21%. 2. Causes flammable and combustible materials to burn violently when ignited. 3. Hair, clothing, materials, etc. 4. Oil soaked clothing and materials. 5. Never use pure oxygen to ventilate. 6. Never store or place compressed tanks in a confined space.

Flammable Atmospheres • 2 Critical Factors: n n n Oxygen content in the air. Presence of a flammable gas, or vapor Presence of dust (visibility of 5’ or less) • Proper air/gas mixture can lead to explosion • Typical Ignition Sources: n n n Sparking or electric tool. Welding / cutting operations. Smoking

Toxic Atmospheres • Product stored in a confined space: w Gases released when cleaning. w Materials absorbed into walls of confined space. w Decomposition of materials in the confined space. • Work performed in a confined space: w Welding, cutting, brazing, soldering. w Painting, scraping, sanding, degreasing. w Sealing, bonding, melting. • Areas adjacent to a confined space.

Hydrogen Sulfide 1. Decomposition of materials. Human waste. 2. Rotten egg odor at low concentrations. 3. Possibly no warning at high concentrations. PPM Effect Time 10 ppm 50 - 100 200 - 300 500 -700 Hour >1000 Permissible Exposure Level Mild Irritation - eyes, throat Significant Irritation Unconsciousness, Death 8 Hours 1 Hour 1/2 - 1 Minutes

Carbon Monoxide • Odorless, Colorless Gas. • Combustion By-Product. • Quickly collapse at high concentrations. PPM Effect 50 200 600 1000 -2000 2000 -2500 Permissible Exposure Level Slight headache, discomfort Headache, discomfort Confusion, nausea, headache Tendency to stagger Slight heart palpitation Unconsciousness Time 8 Hours 3 Hours 1 Hour 2 Hours 1 1/2 Hours 30 Min.

Temperature Extremes • Extremely hot or cold temperatures. • Steam cleaning of confined spaces. • Humidity factors. • Extremely cold liquids. • Work processes inside the confined space can increase temperature extremes. • Personal protective equipment.

Engulfment Hazards • Loose, granular materials stored in bins and hoppers - grain, sand, coal, etc. • Crusting and bridging below a worker. • Flooding of confined space. • Water or sewage flow.

Other Hazards • Noise w Amplified due to acoustics within the space. w Damaged hearing, affect communication. • Slick / Wet Surfaces w Slips and falls. w Increased chance of electric shock. • Falling Objects w Topside openings expose workers inside confined space to falling objects.

Internal Configuration 11/5/2020 Roco Rescue 20

Testing The Atmosphere • Verify presence of safe work atmosphere. • Test all areas of a confined space. n Top, Middle, Bottom • Methane is lighter than air. • Carbon Monoxide is the same as air. • Hydrogen Sulfide is heavier than air. • Oxygen Deficiency.

Ventilation • First option to correct problems. • Must be aware of hazards you are trying to correct in the confined space. • Air intake in a safe location to draw fresh air only. • Continuous ventilation whenever possible. • Retest the confined space before entry.

Isolation • Locking and tagging out electrical sources. • Blanking and bleeding pneumatic and hydraulic lines. • Disconnecting mechanical drives and shafts. • Securing mechanical parts. • Blanking sewer and water flow. • Locking and tagging out shutoff valves.

Respirators • Air-Purifying Respirators n n n Filter dangerous substances from the air. Must know the type and amount of hazardous substance present in the confined space. NEVER use with oxygen deficiency! • Air-Supplying Respirators n n Deliver a safe supply of breathing air from a tank or an uncontaminated area nearby. Must be adequately monitored.

Permit Entry Systems 1. Written permit signed by entry supervisor. 2. Verifies pre-entry precautions have been taken and the space is safe to enter. 3. Posted at entry to confined space. 4. Specifies apparent hazards and corrective actions taken prior to entry. 5. Requires termination of permit when task is completed or when new conditions exist.

Entry Permit Requirements • Date, location, and name of confined space. • Purpose of entry and known hazards. • Duration of entry permit time. • Authorized entrants, attendants, supervisors. • Air testing results - signature of tester. • Protective measures to be taken. w Ventilation, Isolation, Flushing w Lockout / Tagout, Purging

Entry Permit Requirements • Name and phone numbers of rescue and emergency services. • Communication procedures. • Special equipment and procedures. n n Personal protective equipment. Alarm procedures. Rescue equipment. Respirators.

Standby / Rescue • Worker assigned to remain outside the confined space and be in constant contact with the workers inside. • Know emergency rescue procedures. • 50% of workers who die in confined spaces are would-be rescuers. • Trained in use of emergency rescue equipment and PPE.

Training and Education • All workers who must enter confined spaces • All attendants and rescue team members. • Prior to initial work assignment. • Retraining: w w Job duties change. Change in permit-space program. New hazards are present. Job performance indicates deficiencies.

Confined Space Rescue Training Compliance Issues 11/5/2020 Roco Rescue 30

Most confined space fatalities are poorly trained rescuers… Many of these heroes died because their employer unintentionally broke the law. OSHA regulations! 11/5/2020 Roco Rescue 31

OSHA’s 3 levels of protection for confined space entrants: 1) Permitting procedure identifies hazards and addresses protective measures 2) Retrieval equipment required for quick external rescue 3) Rescue services required to be available to perform internal rescue 11/5/2020 Roco Rescue 32

Employer shall ensure. . . (i) The outside rescuer can effectively respond in a timely manner to rescue summons. (ii) The outside rescuer is equipped, trained, and capable of functioning appropriately to perform permit space rescues… (iii) …rescuer is aware of the hazards… (iv) …provide access. . . 11/5/2020 Roco Rescue 33

Response Vs Rescue Time. . . (1) React Time: Attendant recognizes that the Entrant has a problem. (2) Contact Time: Attendant contacts the Rescue Service. (3) Response Time: Rescue Service arrives at the scene. 11/5/2020 Roco Rescue 34

Rescue Vs Response Time. . . (4) Assessment Time: Size-up and strategy determination. (5) Preparation Time: Rescue equipment set-up. (6) Rescue Time: Reaching, treating, packaging, and evacuation of the victim. 11/5/2020 Roco Rescue 35

Rescue Stand-by Goal: 4 -Minute Rescue Response Possible only if rescuers are rigged and ready while the entry is taking place. This is defined as Rescue Stand-by. 11/5/2020 Roco Rescue 36

Rescue Available Appropriate (and Approximate!) Goals: Respond To CS Scene / 10 Minutes Reach The Victim(s) / 5 -10 Minutes Later Case law update…. 10 minute response held to be not timely in a Nov. 1997 case! 11/5/2020 Roco Rescue 37

Choosing the Appropriate Response Decision: Stand-by Vs. Available Each entry must be evaluated to determine the appropriate response mode. The evaluation must be done by a qualified person (rescuer and/or entry supervisor). Factors to be considered include the severity of the hazard, required PPE, and the ability of the entrant to self-rescue. 11/5/2020 Roco Rescue 38

Timely Response, Training, and Equipment Rescue Retrieval Ventilation & Atmospheric Monitoring Barriers Access/Egress (ladders, etc. . . ) Lighting Communication 11/5/2020 Roco Rescue 39

Timely Response, Equipment Training, and Documented training by each team member via simulated rescues in every type of confined space (Rescue training) Authorized Entrant/Attendant First Aid & CPR (Blood-borne pathogens) Haz Com, PPE, Respiratory, Lockout, PSM Equipment training (Fall Protection) 11/5/2020 Roco Rescue 40

CSR Training: - Each rescue team member must be trained to safely perform all assigned rescue duties. Rigging Entry (claustrophobia) PPE utilized outside the space Equipment maintenance Individual skills (IPE) 11/5/2020 Roco Rescue 41

Hands-on Rescue Training: Each member must practice simulated rescue operations at least once every 12 months in the actual PRCS or representative spaces that simulate the types of spaces based on opening size, configuration, and accessibility…. 11/5/2020 Roco Rescue 42

Rescue in Confined Space

What are the requirements for practice rescue exercises? 1. Practice exercise must involve the actual removal of dummies or persons from the actual permit spaces or from representative spaces. 2. Representative spaces need to simulate the types of permit spaces from which rescues may be performed with respect to: · Opening size · Configuration · Accessibility 11/5/2020 Roco Rescue 44

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Ventilation of Confined Spaces

Confined Space Ventilation Confined spaces are not normally designed for convenient ventilation Must take steps to: n n ensure air is breathable before entering confined space maintain acceptable air quality in the confined space during entry

Hotwork in Confined Spaces Presents additional ventilation challenges in confined spaces Includes torch cutting, welding, brazing and soldering, arch gouging

Hotwork in Confined Spaces Remember… confined spaces concentrate hazards! Hotwork can create atmospheric hazards in confined spaces from fumes, gasses and vapors Effective ventilation sometimes may only be accomplished by mechanical ventilation

Natural Ventilation in Confined Spaces “Chimney Effect” n convection process created by temperature changes Occurs by sunlight heating vessel walls and air within If there is an opening in bottom and top of vessel, upward draft created

Natural Ventilation Problems Confined spaces rarely experience uniform thermal conditions Various sources of heat in confined spaces n n n human bodies lighting hotwork processes

Natural Ventilation Problems Factors such as sunlight, body heat, lighting and hotwork are usually not sufficient to move enough air to provide an acceptable atmosphere

Use of Mechanical Ventilation Properly installed, can reduce or eliminate respiratory protection requirements Effective engineering controls usually less dependent on worker attention than respiratory protection

When is ventilation necessary? If atmosphere: n n n contains insufficient oxygen or is oxygen rich contains flammable dusts or vapors contains hazardous or toxic vapors, mists, fumes, gases, or fibers

When is ventilation necessary? If atmosphere: n n is subject to activities that may generate hazardous mists, vapors, fumes or gases, or may create either an oxygen deficiency or oxygen excess, and increases heat stress on workers to unacceptable levels

CAUTIONS Many people resist wearing PPE, including respiratory protection Tangle of supplied air hoses in vessel with many welders can present a hazard

Ventilation- 29 CFR 1910. 252(c) Spaces that require ventilation n work space less than 16 feet high volume less than 10, 000 cubic feet per welder work areas with partitions, structural barriers, or other barriers that significantly obstruct airflow

Ventilation- 29 CFR 1910. 252 Ventilation options: n n provide at least 2000 cfm of airflow for each active welder; or provide each welder with a local exhaust device w local exhaust devices must be capable of maintaining a velocity of 100 fpm toward the air intake

Ventilation Requirements 29 CFR 1910. 252 and 29 CFR 1926. 353 require use of local exhaust ventilation or supplied air respiratory protection when performing hotwork using certain substances

Air Moving Devices Two types: n n Fans Venturi-type eductors Can be air, steam or electrically driven

Eductors Sometimes called “air horns” Air powered and rely on venturi effects to move air

Criteria for Rating Air Movers Free Air Delivery Effective Blower Capacity Quantity of air and air pressure required (air-driven devices) Electrical power requirements (electrically driven devices)

Factors Reducing Performance Equipment components in confined space Maintenance/construction materials erected in space Obstructions in make-up air manway Insufficient number of make-up air manways

Factors Reducing Performance More restrictions to overcome = less air moved Air moving into space equals amount of air leaving the space

Air Driven Devices. Poor Performance Reduced pressure and volume to air driven devices from multiple users Excessively long air hoses

Increasing Performance Supplemental air compressors dedicated to air mover use (air driven devices) Supplemental air compressors connected directly to plant air system Eliminate “short-circuiting” of airflow

Designing Ventilation Systems Configuration, contents and tasks determine type of ventilation n opening configuration properties of expected atmospheric hazards type of work being performed

Electrically Driven Centrifugal Fans Designed to overcome higher static pressures Usually heavier than air-driven equipment Can be used remotely to reduce noise Due to power, can suck up debris

Local Exhaust Single manway vessels Interior obstructions that create “dead spots” Lack of feasible way to attach airmoving device Work with toxic metals

Local Exhaust Effective only when it captures and removes welding fumes and gasses at the source as they are emitted 100 fpm capture velocity at the source of fumes or gasses

Local Exhaust- Considerations Long runs reduce airflow Airflow loss minimized by use of smooth ducting with large radius bends Run flexible ducting as straight as possible Consider using plenums for multiple welders Field test flow/personal air monitors

Make-up air quality Mechanical ventilation uses surrounding air Make sure the make-up air is not a source of airborne contaminants

Confined Spaces

Pre Entry Consider the following: Piping systems Electrical hazards Illumination Ventilation Means of access Fall protection

Pre Entry Visual Inspection (Competent Person) Employee Training Exchanging Information Atmospheric Testing n n Shipyard Competent Person Certified Marine Chemist Certified Industrial Hygienist Coast Guard Authorized Person Rescue Teams

Entry Atmospheric Testing Warning Signs and Labels Visual Inspection Ventilation PPE for Entry Rescue Teams

Work Hot Work Cleaning