Managing Confined Spaces Safely

1

INTRODUCTIONS

• George Rex (Certified CSE Trainer)

• Patrick Burke (Certified OSHA General Industry Trainer)

This is not a training session but more so how to handle the dynamic task of working within Confined Spaces properly

• Have you ever worked a confined space project that:

• Permit requirements changed?

• Facilitated a rescue?

• Did the thought of bidding confined space ever sway your go/no go decision?

• Was adequate, reliable, and timely rescue available?

• Was it the local 1st responders?

• If so, did you verify they had the training, equipment and knowledge of your project?

PURPOSE

• What we (HHS and SENDREX) do to support Confined Space Entry

• Initial review of the CSE and its configuration from photos, drawings and any other pre-job details

• Emergency Services location and how can we get them onsite

• Is MEDEVAC available?

• What's the worst thing that could happen

Inspection and Isolation

• LOTO

• Double block and bleed (prefer disconnecting the space from the balance of process)

• Safety systems (fire or deluge) consideration

• Ventilation of the space well before the entry is to take place

• Traffic and traffic control

• Other contractor activities that could affect confined space

Double

Isolation

Double

Isolation

with skillet

(blank)

installed

Unforeseen Potential Concerns

• Fire mitigation systems (deluge)

• Connectivity to other areas (Sewers, conduit, vaults)

• Low point collection for fluids

• Vehicle exhaust

• Traffic

• Other Contractors activities

• Temperatures within the space

• Fumes from activities within the space (welding, solvents, cleaners)

Impact of Toxics or Flammables

• Engulfment (grain, water)

• Entrapment (trayed tower work) on entrants and associated mitigation

• Continuous air monitoring of the space to confirm absence of a hazardous environment prior to entry

• Dynamic nature of a confined space during work activities

Permit Process and Notifications

• Employees (entrants)

• Contractors

• Supervisor

• Attendant

• Rescue services

• Define the permit and entry process

• Are the employees up to the task that day, that moment?

• Is anyone sick or not 100%?

• Have entrants, permit-issuer (CS supervisor), and/or attendant undergone training?

Pre-entry Process (rescuer)

• Inspection of access

• Inspection of anchor points and rescue path

• Lighting

• PPE (Air delivery system, SKA-Paks)

• Atmosphere and temperatures

• Configuration for extraction (trays, weirs, manway location)

Managing Confined Spaces

• Continuous air monitoring

• Track personnel

• Observe entrants' behaviors

• Stress levels

• Heat and cold tolerance

• Personnel monitors

• Use of supplied air or air-purifying respirators – air management if supplied air

• Define changes that occur while task is ongoing;

• Tank cleaning and exposing materials that change the atmosphere within the space

• Employee, material, and waste ingress and egress and how that is handled

LAWS AND MANDATES

1926.32(f) Competent person.

Someone who is designated in writing and 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.

LAWS AND MANDATES

• This training must result in an understanding of the hazards in the permit space and the methods used to isolate, control or in other ways protect employees from these hazards…

§1926.1207 Training

LAWS AND MANDATES

• (c) The training must establish employee proficiency in the duties required by this standard and must introduce new or revised procedures, as necessary, for compliance with this standard.

NFPA 1006 & 1670

§1926.1207 Training

LAWS AND MANDATES

OSHA 1910.146

&

OSHA 1926.1200

LAWS AND MANDATES

What constitutes a permit required confined space?

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.

LAWS AND MANDATES

• “Rescue service" means the personnel designated to rescue employees from permit spaces.

• In section (k), OSHA requires employers to evaluate the prospective rescue service to determine proficiency in terms of rescue-related tasks and proper equipment

• Otherwise, if an incident occurs and the “rescuers” you’re depending on are not capable of safely performing a rescue, your company is culpable.

LAWS AND MANDATES

The NFPA 1670 Standard outlines the level of “functional capability” for

organizations

At the Awareness level, personnel are expected to perform an assessment,

recognize hazards, make resource decisions, keep themselves and others

safe,

and perhaps perform a non-entry rescue.

It does not, however, allow Awareness personnel to make any entries or do

atmospheric monitoring or other skills needed to perform an entry.

Training is now required to be based on performance standards such as;

NFPA 1006, NFPA 1670 and NFPA 1981.

LAWS AND MANDATES

NFPA 1670 Confined Space Awareness Level

7.2.4 Organizations operating at the awareness level shall implement procedures for the following:

(1) Recognizing the need for confined space search and rescue

(2) Initiating contact and establishing communications with victims

(3)* Recognizing and identifying the hazards associated with non entry confined space emergencies

(4)* Recognizing confined spaces

(5)* Performing a non entry retrieval

(6)* Implementing the emergency response for confined space

(7)* Implementing site control and scene management

MANAGING THE RESPONSE

PRE-PLAN THE RESCUE

PRE-RIG YOUR EQUIPMENT

TIME IS OF THE ESSENCE !

SORT SET SHINE STANDARDIZE SUSTAIN

Risk little for a rescue, risk nothing for a recovery

MANAGING THE RESPONSE

ZERO RISK IS A FANTASY

MANAGING THE RESPONSE

• CONFINED SPACE RESCUE

• Confined Space Rescues can be technically challenging due to the environment in which they occur.

• 7 Steps of Confined Space Rescue

1) Conduct rescue drills

2) Understand that rescue fall into 2 categories

3) Make every entrant wear a full body harness

4) Survey confined spaces for rescue

5) Survey openings

6) Meet with local authorities about rescue capabilities

7) Have a rescue team

MANAGING THE RESPONSE

• EACH RESCUE IS UNIQUE!

• SOMETIMES IT’S ABOUT THE PLAN,

• SOMETIMES ITS ABOUT THE RESULTS,

• IT’S YOUR TASK TO ADJUST ACCORDINGLY!

MANAGING THE RESPONSE

• Training doesn’t end here !

• An investment has been made in you, as a professional it is your responsibility to maintain a regular regiment of training or you will lose this knowledge and these skill sets.

Skill decay is problematic in rescue!

CONTINUOUS IMPROVEMENT

OPPORTUNITYISNOWHERE

COMMON MISTAKES AND MISINTERPRETATION

• Language barriers (OSHA mandates an employee be trained and understand his/her responsibilities tied to Confined Space Entry)

• Relying on local 1st responders, assuming they can find your location, arrive in a timely manner, have the equipment and training on hand

• Reluctance to consider a confined space a permitted confined space due to requirements that mandate rescue standby (Downplaying hazard within the space such as trays, levels, weirs, and difficult configurations for a rescue situation)

• Failure to consider connectivity to other systems such as sewers, vaults and conduits leading from unattended or un-characterized areas

• Faulty or non-calibrated atmospheric monitoring equipment

• Lack of planning for entry and rescue, undeveloped rescue plan that lacks details and the “what if” scenarios from other factors involved with confined space

• Unfamiliarity with rescue equipment and techniques (high angle rope, tripod, and structures used during rescue)

• Lack of communication from entrant to attendant and vice versa

• Not considering LOTO, double block and bleed and systems that could affect the confined space

• Poor management of entry documentation for atmospheric testing, entrants’ names and times, and general conditions of the space

• Lack of recognizing that activity within a confined space can severely change the hazards (Tank cleaning and exposing VOC’s below tank heal)

EXECUTION

• INDUSTRIAL HYGIENE

• Planning the entry

• Initial atmospheric testing

• Recommendations for ventilation, flushing and/or opening of manways

• Day of entry testing and setting up continuous monitoring

• Backup atmospheric monitoring equipment in case of failure

• Brief personnel on personal 4 gas monitor functions, alarms and recognition

• Review lighting for OSHA minimum standard of 5 ftC

• Documentation of results from testing and continuous monitoring

EXECUTION

• ON-SITE RESCUE

• Planning the entry and rescue with CS supervisor, attendant and entrants

• Develop rescue plan (sometimes this will occur after rescuer initial entry so the space can be evaluated for rescue encumbrances)

• Rescue equipment set-up adjacent to confined space, review structural points for tie-off and integrity

• Brief entrants and provide instructions regarding how a rescue would be achieved

• Full-time at the hole coverage

• Communication with entrants either directly or through attendant as to their well-being

SPECIALIZED EQUIPMENT

• Atmospheric testing equipment

• Area RAE with remote tubing and occasionally outside of confined space

• BW MaxGas XT with probe

• Personnel monitors

• CSE Rescue Equipment

• Crash Bag

• Sked

• Victim lift assist

• Certified (Rated) rescue ropes and throw bags

• Carabiners (Rated)

• 3 way and 4 way descenders

• Tripod

• Body Harness

OPEN FORUM (QUESTIONS)

THANK YOU FOR WHAT YOU DO EVERYDAY