PermitRequired Confined Space Best Practices Control v Isolation

Permit-Required Confined Space Best Practices: Control v. Isolation JOHN M MULROY, CSP, DIRECTOR, PENNSYLVANIA OSHA CONSULTATION INDIANA UNIVERSITY OF PENNSYLVANIA

Today’s Agenda: o Hazards Everywhere o Definitions (why they’re important!) o Capturing Best PRCS Practices: Photo source: ISHN. com • NFPA 350 -2016; ANSI Z 117 -2016; ANSI Z 10 -2012 o Control v. Isolation: Achieving Acceptable Operational Risk • Conducting Effective Hazard Assessments

PRCS “Hazards Everywhere” PRCS = HIGH DEGREE SERIOUS INJURY / FATALITY POTENTIAL & WORKERS ARE STILL DYING

PRCS have Serious Injury & Fatality (SIF) Potential. o Twenty-five years have passed since OSHA promulgated the permit-required confined space standard (PRCS) for general industry, and three years since the effective date for OSHA’s construction version. o Today’s news headlines too frequently include stories of workers needlessly dying inside permit-spaces following exposure to • atmospheres immediately dangerous to life or health (IDLH), • catastrophically injured during the unexpected start-up of mechanical equipment inside the permit-space, or • buried, • drowned or • crushed to death by flowable materials.

PRCS and SIF o According to the Bureau of Labor Statistics’ 2014 fatal occupational injury data, a “confined space” was attributed as the primary cause of death for twentytwo workers, and a secondary cause of death for an additional forty-five workers. o In addition, the BLS estimates between 2005 and 2011 an average two workers died inside confined spaces every week, and approximately 4, 700 disabling injuries occurred in confined spaces annually. o That essentially means nearly thirteen reported serious injuries occur per day. Imagine the actual number if minor injuries and near misses in permit spaces were captured in the BLS count.

PRCS and SIF o Permit-spaces by definition have a high degree of fatality potential. o Logic dictates that for each fatality in a PRCS as a result of exposure to a toxic or IDLH atmosphere, engulfment, or exposed to an unexpected start-up of electro-mechanical energy during the entry, then the victims, who were all once entrants, or attendants, entry supervisors, and their would-be rescuers identified on a written permit, were authorized to perform assigned work inside a space never correctly “isolated” as defined by 29 CFR 1910. 146(d)(3)(iii). o Instead these victims were needlessly exposed to a hazard that went without elimination. Without elimination a permit space cannot be reclassified to a non-permit space safe for entry (Rekus 1995).

“Hazards Everywhere” NFPA Journal (2017) o Recent examples of confined space fatalities: • WORKERS OVERCOME BY TOXIC FUMES IN A MANHOLE § A worker and would-be rescuer died while trying to repair a leak inside a manhole. One worker entered the manhole to seal the leak and was overcome by toxic fumes generated by the repair effort, collapsing into chest-deep water. The second worker entered the manhole to try to rescue the first victim and was also overcome by fumes. Both workers drowned.

“Hazards Everywhere” NFPA Journal (2017) o Recent examples of confined space fatalities: • WORKER DIES IN CONCRETE MIXER § In Illinois in 2014, a temporary worker entered a concrete mixer’s discharge mud hopper to free a pneumatically powered discharge gate stuck in the open position because of hardened concrete. The gate, which had not been isolated to prevent unintentional operation during maintenance activity, closed and crushed the worker.

“Hazards Everywhere” NFPA Journal (2017) o Recent examples of confined space fatalities: • WORKER SUFFOCATES IN HOPPER AT SUGAR PROCESSOR § In 2013, a worker at a Pennsylvania sugar processing facility climbed inside a large hopper to remove sugar clogs. The worker fell to the bottom of the hopper and his legs went through the chute; he was engulfed by sugar and suffocated. It was reported that a safety screen to prevent clogging had been removed from the chute since it slowed production.

“Hazards Everywhere” NFPA Journal (2017) o Recent examples of confined space fatalities: • FORMER FIRE CHIEF DIES IN GRAIN BIN § In Nebraska in 2014, a worker who was also a former fire chief climbed inside a bin containing corn. He carried a pole that he intended to use to clear a crust of kernels that was preventing corn from funneling out to be loaded into trucks. The corn collapsed beneath him, entrapping him in the grain where he suffocated. Rescuers searched for more than two hours until they located the man’s body, buried under 10 feet of corn.

“Hazards Everywhere” NFPA Journal (2017) Recent examples of confined space fatalities: o WORKER DIES WHILE CLEANING MOLASSES STORAGE TANK o In 2016 in Michigan, a 23 -year-old worker died while cleaning a molasses storage tank at work, likely the result of fermentation of the molasses that would create an oxygen-deficient atmosphere in the tank. Two teenagers died in a similar manner while cleaning a molasses tank in Michigan in 2010.

“Hazards Everywhere” NFPA Journal (2017) THREE WORKERS DIES WHILE INSPECTING UNDERGROUND PIPE • 2017, Key Largo, private contractor fixing a roadway climbed into a 15 foot-deep manhole to investigate complaints of sewage backups. Reportedly: ü First man enters, lost contact with coworkers above. ü Second worker climbed down in search of the first, also lost contact. ü Third man then went down in a desperate search to find his coworkers. ü Fearing the men unconscious, a volunteer Key Largo firefighter attempted to rescue the downed workers. ü He entered the hole without a self-contained breathing apparatus because the space was so narrow, and became incapacitated within seconds. § Firefighter eventually recovered, but the three workers perished. § Space was later tested and found to contain elevated levels of carbon monoxide and hydrogen sulfide as well as decreased oxygen levels, likely the result of decaying organic material and oxidation of mild steel. §

Gavilon Grain LCC, 2018 Photo source: confinedspaces. com • Two workers suffocated after being buried under 20 -25 feet of grain. • OSHA stated: “Moving grain acts like quick sand, and can bury a worker in seconds, ” said OSHA Regional Administrator Kimberly Stille. “This tragedy could have been prevented if the employer had provided workers with proper safety equipment, and followed required safety procedures to protect workers from grain bin hazards. ”

Death can take some time. Man dies at power station

Definitions DID YOU KNOW THERE ARE 27 SEPARATE DEFINITIONS IN 1910. 146? DOES YOUR ORGANIZATION KNOW THEM ALL?

Definitions: o What is the definition of “definition? ” • Webster defines definition as “a statement expressing the essential nature of something. ” • Are definitions important in OHS? § Definitions provide a common understanding of a word or subject. § Definitions ensure everyone in society, or from a perspective of subgroups, within our organization, is on the same page all the time. § Let me ask you… § Are you concerned about PRCS entries at 10: 00 am on any Tuesday? § Are you concerned about PRCS entry at 10: 00 am TODAY while you are sitting here? § Are you concerned about PRCS entries at 10: 00 pm on Christmas eve to address a breakdown repair? § Should you be more concerned about one than the other?

In Your Program – Standardize Definitions: Agreeing on standard definitions creates the foundation for safety performance. It is essential to defining, then achieving safety success. Using standard definitions in a PRCS program dictates: • • how a space is evaluated, entry is planned and executed, if operational risk is acceptable, what should or shouldn’t happen, what sequence steps will occur, who owns the process, and whether the process should continue, or stop.

Definitions germane to safe entry o 1910. 146(b): • Confined space: means a space that: 1. Is large enough and so configured an employee can bodily enter and perform assigned work; and 2. Has limited or restricted means for entry or exit (tanks, vessels, silos, storage bins, hoppers, vaults, and pits are spaces with limited means of entry); and 3. Is not designed for continuous occupancy.

Definitions germane to safe entry 1910. 146(b): o Permit-required Confined space: means a confined space that has one or more of the following characteristics: 1. Contains or has a potential to contain a hazardous atmosphere; 2. Contains a material that has the potential for engulfing an entrant; 3. Has an internal configuration such that an entrant could be trapped or asphyxiated by inwardly converging walls or by a floor which slopes downward and tapers to a smaller cross section; or 4. Contains any other recognized serious safety or health hazard.

Definitions germane to safe entry 1910. 146(b): o Acceptable entry conditions: means the conditions that must exist in a PRCS to allow entry and ensure employees involved can safely enter into and work within the space. o Blanking or blinding: means the absolute closure of a pipe, line, or duct by the fastening of a solid plate that completely covers the bore and capable of withstanding the maximum pressure of the pipe, line, or duct with no leakage beyond the plate.

Definitions germane to safe entry 1910. 146(b): o Double block and bleed: means the closure of a line, duct, or pipe by closing and locking or tagging in-line valves and by opening and locking or tagging a drain or vent valve in the line between the two closed vales.

Definitions germane to safe entry o 1910. 146(b): • Engulfment: means the surrounding and effective capture of a person by a liquid or finely divided (flowable) solid substance that can be aspirated to cause death by filling or plugging the respiratory system, or cane exert enough force on the body to cause death by strangulation, constriction, or crushing. • FLOWABLE SOLID ENGULFMENT DEMONSTRATION

Definitions germane to safe entry o 1910. 146(b): • Entry permit: means the written or printed document that is provided by the employer to allow and control entry into a permit space and contains the information specified in paragraph (f) of this section • Prohibited condition: means any condition in a permit space not allowed by the permit during the period when entry is authorized.

Definitions germane to safe entry 1910. 146(b): o Testing: means the process by which hazards that may confront entrants of a permit space are identified and evaluated. Testing includes specifying the tests performed in the permit space. NOTE: Testing enables employers both to devise and implement adequate control measures for the protection of authorized entrants and to determine in acceptable entry conditions are present immediately prior to, and during, entry.

National Consensus Standards Capturing Best Practices in NFPA 3502016; ANSI Z 117. 1 -2016; & ANSI Z 10 -2012

NFPA 350 -2016 “SAFETY CONFINED SPACE ENTRY & WORK” BRIDGES THE GAP BETWEEN PERFORMANCE-BASED MINIMUM PRCS STANDARDS BY PROVIDING THE “HOW-TO’ S ” AND BEST PRACTICES.

NFPA 350 -2016 Scope o Who is familiar with this new NFPA standard? o In the NFPA 350, the scope of this standard is: • Provide information to protect workers from confined space hazards; • Supplement existing confined space regulations, standards, and work practices by providing additional guidance for safe confined space entry and work. Existing regulations and standards are referenced throughout the guide and annex to direct reader to those regulations and standards that might be applicable.

NFPA 350 -2016 Scope o In the NFPA 350, the scope of this standard is: • Provide information on how to understand confined space safety and safeguard personnel from fire, explosion, and other health hazards uniquely associated with confined spaces • Provide information regarding training, qualifications, and competencies required for…confined space hazard identification, hazard evaluation, and hazard control for personnel who work in and around confined spaces.

NFPA 350 -2016 Scope o In the NFPA 350, the scope of this standard is: • Provide information about best practices for rescue. • Provide information concerning confined space hazards and safety practices applicable to all confined spaces. • Provide information regarding hazards adjacent to confined spaces that might affect the safe conditions necessary for entry and work inside. • Provide criteria for controlling, eliminating, or minimizing hazards in the confined space design phase.

NFPA 350 -2016 Definitions & Elements o In the NFPA 350, there are 82 separate definitions, many with subparts. OSHA had… • (remember, OSHA had… 27 definitions) o 3. 3. 31 Hazard: • Biological, chemical, mechanical, electrical, atmospheric, environmental, or physical agent that has or may have the potential to result in injury, illness, property damage, or interruption of a process or an activity in the absence of a control measure.

NFPA 350 -2016 Definitions & Elements o 3. 3. 31 Hazard: Further defined… • Adjacent Hazards: § Hazards that may exist in the area surrounding the space. • Inherent Hazards: § Hazards that exist as a permanent, essential characteristic or attribute of the space. • Introduced Hazards: § Hazards not normally associated with the space’s purpose or processes but are brought into the space or adjoining area(s) deliberately or inadvertently.

NFPA 350 -2016 Definitions & Elements 3. 3. 31 Isolation Specialist: § Person responsible for protecting the confined space from the unwanted release of energy (electrical, mechanical, or hydraulic), as well as liquids, gases, chemicals, and other materials impacting upon the space.

NFPA 350 -2016 Definitions & Elements o 3. 3. 38 Incident Management System • A system that defines the roles and responsibilities to be assumed by responders and the standard operating procedures to be used in the management and direction of emergency incidents and other functions. o 3. 3. 42 Job Hazard Analysis (JHA): • A safety management risk assessment technique that is used to define and control the actual or potential hazards associated with any process, job, or procedure.

NFPA 350 -2016 Definitions & Elements o 3. 3. 46 Management of Change: • A system used to evaluate and address the impacts of changes o 3. 3. 57 Prevention through Design (Pt. D) • A concept that studies the safety impacts during the initial design phase and seeks to eliminate hazards and reduce risks rather than relying on reactive hazard isolation and control approaches.

NFPA 350 -2016 Definitions & Elements o 3. 3. 68 Risk: • The probability a substance or situation will produce harm under specified conditions. Risk is a combination of two factors: 1. 2. The probability that an adverse event will occur The severity of the consequences of the adverse event o 3. 3. 69 Risk Assessment: • A process for systematically evaluating risk that considers the severity of consequences and the likelihood the adverse event will occur. o 3. 3. 80 Ventilation Specialist: • Person responsible for determining needs to comply with permit requirements.

BEST PRACTICES: How many attendees have Mo. C and Pt. D programs embedded in their PRCS or OHSMS?

ANSI Z 117 -2016 “SAFETY REQUIREMENTS FOR ENTERING CONFINED SPACES” PURPOSE IS TO ESTABLISH MINIMUM REQUIREMENTS AND PROCEDURES FOR THE SAFETY AND HEALTH OF EMPLOYEES WHO WORK IN, AND IN CONNECTION, WITH, CONFINED SPACES.

ANSI Z 117 -2016 Definitions & Elements o In ANSI Z 117, there are 37 separate definitions, many with subparts. OSHA had… • (remember, OSHA had… 27 definitions) o 2. 2 Atmospheric Tester: • A qualified person selected by the employer who tests or monitors a permit space as necessary to determine if acceptable limits are maintained and able to interpret the results.

ANSI Z 117 -2016 Definitions & Elements o 2. 3 Biological Hazards: • Microbial agents presenting a risk or potential risk to the well-being of humans through inhalation, ingestion, skin absorption, or injection o 2. 26 Qualified Person: • A person, who by reason of training, education and experience, is knowledgeable in the operation to be performed and is competent to judge the hazards involved and specify controls and/or protective measures.

ANSI Z 117 -2016 Definitions & Elements o 2. 3 Isolation: • A process of physically interrupting, disconnecting or removing pipes, lines, and energy sources such as electrical, pneumatic, and gravitational forces from entering the confined space. § E 2. 17: Disconnecting and separating pipes, blinding/blanking, double block and bleed pipe fluids and gases, lockout energy sources such as electrical, pneumatic, hydraulic, and gravitational. § Gravitational could be an elevator car in the raised position or a heavy portal lid. Isolation from engulfment could be blocking product from entering the space or completely removing by draining product.

Control v. Isolation: ACHIEVING ACCEPTABLE RISK

ISOLATION: Co ur tes y: ht tp s: / /w ww . he alt ha nd sa fet yh an db oo k. c om . au / o OSHA • The process by which a permit space is removed from service and completely protected against the release of energy and material into the space o Letter of Interpretation • (11 -6 -96) o Letter of Interpretation • (08 -6 -07)

Co ur tes y: ht tp s: / /w ww . he alt ha nd sa fet yh an db oo k. c om . au / ISOLATION: o NFPA: Isolation Specialist § Person responsible for protecting the confined space from the unwanted release of energy (electrical, mechanical, or hydraulic), as well as liquids, gases, chemicals, and other materials impacting upon the space.

ISOLATION: Co ur tes y: ht tp s: / /w ww . he alt ha nd sa fet yh an db oo k. c om . au / o ANSI • A process of physically interrupting, disconnecting, or removing pipes, lines, and energy sources such as electrical, pneumatic, and gravitational forces from entering the confined space.

ANSI Z 117 -2016 Hazard Evaluation o Paragraph 3. 2 “Hazard Identification” • Confined spaces shall be considered hazardous until determined to be otherwise. Hazards shall be identified for each confined space prior to entry. Hazard identification process shall be conducted by a qualified person and include, but not be limited to, a review of the following:

ANSI Z 117 -2016 Hazard Evaluation o Paragraph 3. 2 “Hazard Identification” • …conducted by a qualified person and include, but not be limited to, a review of the following: § Past and current uses of the CS which may adversely affect the atmosphere; § Physical characteristics, configuration and location of the CS; § Existing or potential atmospheric hazards (O 2, LEL/UEL, toxins); § Biological hazards; § Mechanical hazards; § Physical hazards; § Chemical hazards.

ANSI Z 117 -2016 Hazard Evaluation o Paragraph 3. 3 “Hazard Evaluation” • Hazards identified shall be evaluated by a qualified person. Each hazard shall be examined with respect to: § § § § Scope of hazard exposure Magnitude of the hazard Likelihood of hazard occurrence Consequences of the hazard occurrence Potential for changing conditions or activities Strategies for controlling hazards Impact on the need for emergency response

Effective Isolation and Control o To protect workers, employers should create a process to • Conduct thorough, detailed, effective and complete hazard identification for each confined space to be entered • Conduct a thorough, detailed, effective and complete hazard evaluation to reduce operational risk to organizationally acceptable level.

Hazard Evaluations / Risk Assessments ANSI Z 117 -2016: “SAFETY REQUIREMENTS FOR ENTERING CONFINED SPACES”

Why Risk Assessments? o Safety professionals must perform a risk assessment for each individual confined space which may be entered. o The ANSI Z 10 -2012 hierarchy of controls should be applied to achieve the most effective isolation technique that eliminates the recognized hazard before entry. o It is the presenter’s firsthand experience not all in the regulated community fully understand, nor make any distinction between OSHA’s means of isolation, which includes blank, blind, misaligning pipes, utilizing a double block and bleed, utilizing an effective LO/TO program to control electromechanical energy, and/or disconnecting mechanical linkages. • Unfortunately expediency (operational pressures) can trump effectiveness (isolation or elimination) often resulting in unnecessary residual risk to the entrant.

Hazard Evaluation / Risk Assessment o ANSI Z 10 -2012 provides guidance to conduct effective risk assessments o ANSI Z 117 -2016 Appendix C provides minimum performance criteria to conduct hazard evaluations o NFPA 350 -2016

Control v. Isolation o The difference between “isolation” and “control” of hazardous atmospheres or flowable materials is much more than semantics. Definitions matter! o Isolation and control are not synonymous; each result in two very different levels of worker protection, and should never be used interchangeably in the SHE professional’s lexicon. o Applying isolation achieves hazard elimination; hazard elimination achieves reclassification to nonpermit status. Control is just control. Control ≠ Elimination

Control Ventilation: Alternate entry o An employer need not comply with paragraphs (d) through (f) and (h) through (k) provided: o Employer can demonstrate only hazard posed is an actual or potential hazardous atmosphere o Employer can demonstrate continuous forced air ventilation alone is sufficient to maintain permit space safe for entry o Employer develops monitoring and inspection data supports demonstrations required above NFPA 350 -2016: Alternate Entry Guidance o Appendix C. 1 “Alternate Entry Procedures as Allowed in 29 CFR 1910. 146: o The use of alternate entry procedures should be carefully managed. History of confined space entry incidents indicates misuse, abuse, or misunderstanding of alternate entry procedures, which has resulted in injury or death to Entrants and other workers. Due to the increase in injuries, Owners/Operators and Entrant Employers may choose not to allow the use of alternate entry procedures.

Isolation: 1910. 146(b): o Isolation: means the process by which a permit space is removed from service and completely protected against the release of energy and material into the space by means as: o Blanking or blinding; o Misaligning or removing sections of pipes, or ducts; o A double block and bleed system; o Lockout or tagout of all sources of energy; or o Blocking or disconnecting all mechanical linkages.

Elimination: 29 CFR 1910. 146(c)(7)(i) o If the permit space poses no actual or potential atmospheric hazards and o If all hazards within the space are eliminated without entry into the space, o The permit space may be reclassified as a non-permit confined space for as long as the non-atmospheric hazards remain eliminated.

Elimination: 29 CFR 1910. 146(c)(7)(ii) o If it is necessary to enter the permit space to eliminate the hazards, such entry shall be performed under paragraphs (d) and (k) of this section. o If testing and inspection during that entry demonstrate the hazards within the permit space have been eliminated, the permit space may be reclassified as a non-permit confined space for as long as hazards remain eliminated. NOTE: Control of atmospheric hazards through forced air ventilation does not constitute elimination of the hazards.

Elimination: 29 CFR 1910. 146(c)(7)(iii) o The employer shall document the basis for determining all hazards in the permit space have been eliminated, through a certification containing the date, the location of the space, and the signature of the person making the determination. o The certification shall be made available to each employee entering the space or to that employee’s authorized representative.

Anion Process Close-Up