Permit-Required Confined Spaces

Identify and Classify

Presented By: Consultation Education and Training Division

Michigan Occupational Safety & Health AdministrationMichigan Department of Licensing and Regulatory Affairs

www.michigan.gov/miosha(517) 322-1809

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This Door Leads to a Room

If You Never Enter the Room, IS IT STILL A ROOM?

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“We never go in there.”

Evaluate a space Evaluate a space based on based on definitions, not definitions, not on whether you on whether you enter the space.enter the space.

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Why Identify and Classify?

Performance standard Analysis of hazards is open for

discussion between you and MIOSHA If you have permit spaces and have

done nothing you are assumed to be in violation

Therefore, employers must establish criteria and make judgements

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Benefits of Identifying and Classifying

Puts employees on notice not to enter or how to enter safely

Enables employer to use “alternate entry” and/or reclassification to “non-permit” status, both of which are less resource intensive (i.e., no attendant, no rescue service, no entry supervisor, etc.)

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Horizontal vs VerticalStandards

VERTICAL - if a particular standard is specifically applicable... it shall prevail over any different general standard which might otherwise be applicable.

HORIZONTAL - any general standard shall apply according to its terms to any employment and place of employment in any industry, even though particular standards are also prescribed for the industry, to the extent that none of such particular standards applies.

Part 90-Confined Space Entry

Next…..

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GI Standards - Vertical

Health Rule 3240 Welding, Cutting & Brazing Rule 3303 (1) Entry of Open Surface Tanks Rule 3303 (2) Welding in Confined Spaces Rule 3303 (3) Vessel Entry in Pulp, Paper

and Paperboard Mills Safety

Part 1. General Rules Part 12. Welding and Cutting Part 63. Pulp, Paper, and Paperboard Mills Part 77. Grain Handling Facilities Part 81. Baking Operations Part 86. Electric Power Generation

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Construction Standards-Vertical

Health Rule 6310 Health Hazard Control for

Specific Equipment and Operations

Rule 6402 Control Measures for Hazardous Atmospheres in Confined Spaces

Safety Part 1. General Rules Part 7. Welding and Cutting Part 30. Telecommunications

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It is a CONFINED SPACEif all three are true

1. Is large enough and so configured that an employee can bodily enter and perform assigned work (average person, full body entry); AND

2. Has limited or restricted means for entry or exit (ladders, climb, be lowered); AND

3. Is not designed for continuous employee occupancy.

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1. Large Enough to Bodily Enter

Average Person

Capable of Full Body Entry

…bodily enter and Perform Assigned Work

There Must be a Means of Entry This could be pre-existing opening or one

the employer has mandated be created

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2. Restricted Entry or Exit

Porthole, portable ladder, vertical fixed ladder, hatchway, etc.

Internal configuration which makes movement in space difficult

KEY PHRASE: “Route/Method of Exit Creates an Impediment to Self Rescue”

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3. Not Meant for Continuous Human Occupancy

Not a workstation Employees may have assigned

tasks which put them in those spaces on a routine basis as an excursion to flip a switch, check a reading, clean a filter or trap, etc.

Does include longer excursions like maintenance, service, or repair

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Not a Confined Space?

Can still have hazards regulated by other standards

JOURNEY FROM

AN IDENTIFIED

CONFINED SPACE

TO A

PERMIT REQUIRED CONFINED SPACE

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Is the CONFINED SPACE permit required?

Yes, if the CONFINED SPACE has one or more hazards:

1. Actual/potential atmospheric hazards

2. Materials that could engulf entrant3. Internal configuration that could

trap or asphyxiate entrant4. Any other serious safety or health

hazard

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Analysis for Hazards

Immediately Dangerous to Life and Health-IDLH

Capable of Causing Death Capable of Causing Incapacitation Conditions Cause Inability to Self Rescue

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1. Hazardous Atmosphere

Lack of Oxygen - 19.5% - 23.5% Displacement by other gases Consumption from rust, organic materials,

electrical sparking, chemical process, other Flammable Atmosphere - <10% LEL

O2 enriched atmosphere, flammable vapors, chemical reactions, combustible dusts, other

Carbon Monoxide - 35PPM/8hr. Other Toxic Air Contaminants Corrosive Atmosphere

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Analysis for Explosivity

H2S and CH4 are naturally occurring and are flammable

Standard requires such airborne hazards to be controlled to below 10% of the LEL. (Refer to MSDS) Remember to consult conversion sheet

which comes with air monitor - some flammables can require adjustments of +/- 30%

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2. Engulfment

Powders, beads, grains, pellets, coal, dust, sludge, etc.

Breakthrough bridging

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Analysis for Engulfment

Flowable materials in containers which are intact can be assumed to keep their integrity

The volume of the material in the space must be sufficient to cause death or impediment to self rescue

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3. Internal Configuration

Sloping Floors and Walls Bottoms of Feed Hoppers or Silos Drainage areas Sluice ways Baffles High and Low Pipes Low Ceiling

EspeciallyHazardous

when combined with

engulfmenthazards

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4. Other Serious Hazards

Exposed, Live Electrical Circuits Unguarded Mechanical Hazards Critters Slippery Surface Noise Vibration Heat Poor Visibility Others

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JOURNEY FROM

IDENTIFICATION

TO

CLASSIFICATION

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Dynamics of Classification

The space must be identified and classified as a PRCS if it contains a hazard(s)

However, you may never enter it as a PRCS Because you will always reclassify it by

performing certain tasks prior to entry (i.e. emptying, locking out, cooling, blanking, etc.)

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Classifications - There are 3

ALTERNATE PROCEDURE The atmospheric hazard(s) can be

CONTROLLED creating a “temporary” C5 space?

RECLASSIFICATION - NON-PERMIT SPACE The hazard(s) can be ELIMINATED creating a

“temporary” C7 space FULL PERMIT-ENTRY

The hazard(s) cannot be evaluated, eliminated and/or controlled

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Alternate Entry Space - (C)(5)

A confined space in which the only hazard is atmospheric (actual or potential)

The employer can show through monitoring data that the atmospheric hazard can be controlled through ventilation If any non-atmospheric hazards exist but

they can be eliminated from outside the space (C7) or by an initial full permit entry, you can use this method

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Necessary Proofs - (C)(5)

MSDS including an appraisal of the use of the product and its status in the space

Air monitoring data to prove elimination, control, or non-existence of atmospheric hazards (esp. of unintended contaminants) certification of non-existence of

atmospheric hazards lasts for as long as the conditions certified remain

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C5-Alternate Entry

A. Eliminate hazards, remove cover

B. Guard opening

C. Test w/calibrated, direct-reading meter

D. Start continuous, forced-air ventilation If test shows hazard, wait, test until good

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E. Ventilate as follows: Any hazardous atmosphere

eliminated Continuous and directed to

immediate area where employees work

From a clean air source

F. Test periodically

C5-Alternate Entry Cont…

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G. If hazard detected: Leave, evaluate, additional measures

before next entry

H. Verify through written certification Date Location Signature

C5-Alternate Entry Cont…

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Non-Permit Space - (C)(7)

A permit space which has no actual or potential atmospheric hazards

All hazards within the space are eliminated without entry into the space If it is necessary to enter the space to

eliminate hazards, do a full-permit entry. Document basis for determining

elimination: date, location, signature

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Full Permit Entry When…

Hazard cannot be evaluated from outside the space

You are taking the hazard in with you The employer cannot guarantee an

ability to control the hazard during the operation Remember: you must be able to state

the pre-entry “Acceptable Entry Conditions” under which the entry will be made.

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Full Permit Entry Requires...

(d) PRCS Program Develop, implement, review

(e) Permit system(f) Entry permit(g) Training(h) Duties of authorized entrants(i) Duties of attendants(j) Duties of entry supervisor(k) Rescue and emergency

services

1910.146

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Prohibited Conditions

Are changes in the space which were not a part of the original or current classification scheme. They require exiting or not entering the space until re-evaluation is performed.

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In Conclusion

IDENTIFY based on space meeting all 3 portions of the confined space definition

CLASSIFY based on the hazards present and potentially present in the space

ENTER based on your ability to eliminate and/or control the hazards, preferably from outside the space, which defines your reclassification options

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Need Assistance?

CET Division (517) 322-1809

GI Safety & Health Division (517) 322-1831