Gi confined space asse

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  • 1910.146(c)(1) The employer shall evaluate the workplace to determine if any spaces are permit-required confined spaces. 1910.146(c)(2) If the workplace contains permit spaces, the employer shall inform exposed employees, by posting danger signs or by any other equally effective means, of the existence and location of and the danger posed by the permit spaces. 1910.146(c)(4) If the employer decides that its employees will enter permit spaces, the employer shall develop and implement a written permit space program that complies with this section. The written program shall be available for inspection by employees and their authorized representatives. 1910.146(e)(1) Before entry is authorized, the employer shall document the completion of measures required by paragraph (d)(3) of this section by preparing an entry permit. 1910.146(g)(1) The employer shall provide training so that all employees whose work is regulated by this section acquire the understanding, knowledge, and skills necessary for the safe performance of the duties assigned under this section. 1910.146(d)(9) Develop and implement procedures for summoning rescue and emergency services, for rescuing entrants from permit spaces, for providing necessary emergency services to rescued employees, and for preventing unauthorized personnel from attempting a rescue 1910.146(d)(5)(i) Test conditions in the permit space to determine if acceptable entry conditions exist before entry is authorized to begin, except that, if isolation of the space is infeasible because the space is large or is part of a continuous system (such as a sewer), pre-entry testing shall be performed to the extent feasible before entry is authorized and, if entry is authorized, entry conditions shall be continuously monitored in the areas where authorized entrants are working; 1910.146(d)(3) Develop and implement the means, procedures, and practices necessary for safe permit space entry operations, including, but not limited to, the following: 1910.146(j)(2) Verifies, by checking that the appropriate entries have been made on the permit, that all tests specified by the permit have been conducted and that all procedures and equipment specified by the permit are in place before endorsing the permit and allowing entry to begin; 1910.146(k)(3) To facilitate non-entry rescue, retrieval systems or methods shall be used whenever an authorized entrant enters a permit space, unless the retrieval equipment would increase the overall risk of entry or would not contribute to the rescue of the entrant. Retrieval systems shall meet the following requirements.
  • The Film Recovery case involved a Polish worker in Illinois cleaning out a vat that had used film sludge containing cynanide.
  • Sample Permit.

Transcript

  • 1. Confined Spaces John Newquist September 20, 2011
  • 2. CSP Today
  • 3. Tina Williamson
    • Her 18 year old son Matthew died in a ship confined space on Dec. 1, 2005. 
    • “ So sad. One of the faults of the company is that it had no rescue plan in place. Well with my son, the only plan the company had was to call 911. This was deemed a good plan by OSHA. This is not a good plan for workers. Time is crucial. A trained rescue team needs to be close to the workers working in confined spaces.”
    • “ I ask you to conduct a review of your rescue provisions. Are contractors used for entry or rescue? Is there practice? Can they get the workers out in time?”
  • 4.
    • Draw Straws
    • DOL looking to ban teens doing this job
  • 5. Xcel Fire
    • 5 Died
    • Criminal Indictments
    • www.csp.gov
  • 6. Confined Space Most Cited
    • Not evaluating confined spaces
    • No Confined Space signs
    • No written Confined Space Program
    • No Permit before Entry
    • Employee Training
    • No Rescue Provisions
    • Not testing the Confined Space
    • Not developing safe permit entry operations
    • Entry Supervisor not verifying tests were conducted
    • No retrieval system where practical
  • 7. History
    • No standard for years - proposed 1976
    • Film Recovery – Hydrogen cyanide -1983
    • ANSI Z117
    • General Duty Clause
    • OSHA 1910.146 published in 1993
  • 8. Statistics
    • Over 224,000 worksites have permit spaces
    • Over 2.1 million workers enter permit spaces annually
    • Compliance with 1910.146 will save:
    • - at least 53 worker deaths
    • - 4,900 lost workday cases
    • - 5,700 non lost-time accidents ANNUALLY
  • 9. Idaho 2000
    • Allan Elias, 61, was ordered to serve 17 years in Jail
    • $6.3M in restitution
    • Told workers to clean cyanide tank without respirators
    • Employee suffered permanent brain damage
  • 10. Confined Space
    • A space that:
    • Is large enough and so configured that an employee can bodily enter and perform assigned work
    • Has limited or restricted entry/exit means
    • Is not designed for continuous worker occupancy
  • 11. Permit Space
    • a risk of death, incapacitation, injury or acute illness
    • flammable gases
    • oxygen deficient
    • toxic atmosphere
    • engulfment,
    • other serious physical hazards (ex. Augers)
  • 12. Permits
    • The following permit has been designed to assist in protecting persons entering confined spaces. It shall be completed before any employee enters a space designated as a "Permit-Required Confined Space". Only individuals that have received Confined Space Training shall be authorized to complete this permit. All questions that are not applicable to the entry are to be answered as "N/A". This section is to be completed by the confined space entry supervisor.
    • IDENTIFICATION Location_________________________________________________________________________ Date:                                       Expiration Date:                                   Time:                       am   pm 
    • Note: This Permit is valid for one entry team during a single entry. Maximum duration of the permit will be 8 hours . All copies shall remain at the job site until work has been completed. Description of Space: _______________________________________________________________________________ Reason for entry: (e.g., welding, cleaning, etc.)__________________________________________________________
    • AUTHORIZED PERSONNEL (list)
    • Entrants                                           Attendants                                                 Contractors                                         
    • EQUIPMENT REQUIRED
    • What type of communication equipment will be used to maintain contact with entrants? ( ) radio ( ) phone ( ) visual contact ( ) other ____________ What type of communication equipment will be available to contact emergency services? ( ) radio ( ) phone Is respiratory protective equipment required for this job? ( )Yes ( )No If yes, has each member of the entry team completed respirator training, physicals and fit testing?
    • ( )Yes ( )No     If yes, what type? ( ) SCBA ( ) supplied air ( ) PAPR ( ) full face ( ) half mask    cartridge used: _______ Is personal protective clothing required for this job? ( )Yes ( )No If yes, What type? ( ) coveralls        ( ) splash suit    ( ) leather gloves    ( ) chemical gloves    ( ) goggles        ( ) face shield    ( ) ear plugs ( ) ear muffs       ( ) hard hat        ( ) welding hood    ( ) welding gloves    ( ) welding jacket    ( ) safety boots    ( ) chemical boots ( ) other_______ What types of hazardous energy may be present? ( ) electrical        ( ) mechanical    ( ) hydraulic        ( )chemical         ( )pneumatic        ( ) thermal How will these hazards be eliminated or controlled? ___________________________________________________
    • What other hazards may the worker be exposed to? ___________________________________________________
    • Supervisor's Name (Print)_______________ Signature________________________ Date_____________
    • This section is to be completed by the attendant. ATMOSPHERIC TESTING
    • Type of gas monitor____________________ Date of last calibration ________________________________
    • Oxygen (between 19.5% and 23.5%) ____ Flammables/combustibles (less than 10% of L.E.L.) ____ 
    • TOXIC CONTAMINANTS
    • Chemical Name ______ (Is the MSDS present?) __________        PEL  #1 ____ #2 ____ #3 ____  #4 _____   
    • THIS PERMIT MUST BE POSTED NEAR THE ENTRANCE OF THE SPACE DURING ENTRY THIS ENTRY MUST BE REGISTERED WITH THE SAFETY DIRECTOR PRIOR TO ENTRY Check List(Initial the appropriate box)  All warning/caution signs, barricades, etc. are posted and in place.  _____
    • Hazardous energy has been locked and tagged.   _______
    • An emergency escape plan has been developed.   _______
    • Safety life lines and retrieval system are secured and in place,  _______
    • Space has been properly ventilated.   ______
    • Required personal protective equipment is available and in use. ______
  • 13. Signs
    • Required for permit confined spaces
  • 14. Non Permit Spaces
    • All other serious hazards have been controlled
    • Air monitoring data to show that the air quality is safe or
    • Continuous force air ventilation presents no hazards
    Underground storage vault
  • 15. Motel Fatality
    • 2002 - IL
    • Worker goes to restart pump
    • Passes out and dies
    • 5 feet deep
  • 16. Atmosphere
    • Atmosphere that is hazardous if:
    • Flammable gas, vapor or mist in excess of 10% of LEL
    • Airborne combustible dust at level equal or greater than LFL (or wherever dust obscures vision at 5 feet (1.52 m) or less
    • Oxygen concentration less than 19.5 OR
    • greater than 23.5
  • 17. Machine Pit
    • 1989 - IL
    • Pit measured 12 ' x 20' x 12' deep
    • Carbon Monoxide pulled into pit from heating operations
    • 2 rescuers hospitalized
    Typical Machine Pit
  • 18. Monitoring
    • Monitor for YOUR hazards
    • Calibrate your monitor – ensure the validity of your sensors
    • Calibration must occur in clean air
  • 19. Electric Vault Fire
    • 1992
    • Workers trying to dry water out of a vault with a propane heater
    • Left on overnight
    • Lit match to see and propane caused explosion
    • No monitoring performed
  • 20. Considerations
    • Identify your hazards
    • Refer to respirator standard 1910.134
    • Enforce the respiratory protection that in in the program
  • 21. Foundry
    • 2002
    • Workers sent into a large cupola to remove a plate
    • Wore SCBAs, but were never trained or used SCBA before
    • CO 200+ ppm
    Typical Small Cupola
  • 22. Entry
    • Action where the entrant passes through the opening into the permit space to perform work
    NOTE: Entry is considered to have occurred when any part of the entrant’s body breaks the plane of the opening.
  • 23. Chemical Plant
    • 1989
    • Worker went into vessel
    • Used 100% nitrogen to cool himself off
    • Passed out
  • 24. Supervisors
    • (35%) of the workers killed in confined spaces were supervisors
    • Acceptable entry conditions must be present
    • Authorizes entry and oversees entry operations
    • Initiates termination of entry
  • 25. Bastian Plating
    • June 26, 1988 - IN
    • Worker asphyxiated while using acid to clean out a tank.
    • The 5’ x 4’ x 5’ tank had been treated with zinc cyanide
    • Four coworkers, aged 19 to 25, were subsequently asphyxiated one by one as they tried to save their friends.
    Typical Plating Tank
  • 26. Attendant
    • Individual stationed outside the permit space who monitors entrants
    • Must have communication
    • Can alert rescue
  • 27. Water Vault
    • 1995 - IL
    • Two workers sent to turn on a water valve in a 22 foot deep dry well. Both died.
    • Ladders were rusty
    • Stagnant water at the bottom
    • No Attendant
    Example of a water pit
  • 28. Retrieval
    • Equipment for non-entry rescue of personnel from a permit space:
    • Full-body harness
    • Retrieval line
    • Wristlets
    • Lifting Device or Anchor
  • 29. Rescue
    • Sixty percent (60%) of all confined space deaths were the would-be-rescuers
    • Rescue equipment must be maintained
    • Run practice drills
    • Who enters???
  • 30. Grain Fire
    • 1995 - IL
    • Grain salvage
    • Employee passes out
    • Fire Chief died rescuing the employee
    • Criminal indictments for falsifying permits
  • 31. Training
    • Train before being assigned, when changes occur
    • Provide advisory training prior to entry of any space
  • 32. Manufacturing
    • 1995 - IL
    • Open pit 45’ x’ 60’
    • Argon gas had been used instead of compressed air to operate a pump that removed water from the pit.
    • Hose connections
    • 3 died
    Typical Machine Pit
  • 33. Let the Contractor Go In?
    • Blink!
    • You make the call…
    Bottom of a cupola. Contractor.
  • 34. Heat Stress new focus
    • Train the workforce
    • Perform the heaviest work in the coolest part of the day
    • Slowly build up tolerance to the heat and the work activity (usually takes up to two weeks)
    • Drink plenty of cool water (one cup every 15-20 minutes)
    • Wear light, loose-fitting, breathable (cotton) clothing
    • Take frequent short breaks in cool or shaded areas
    • Provide fans
  • 35. Quiz
    • ____% of confined space deaths are the rescuers.
    • What toxic chemical was in Film Recovery’s vats? ____________
    • What is the name of the individual stationed outside the permit space who monitors entrants? ______________
    • An Oxygen concentration less than ____ is hazardous.
    • Name one thing that could make a permit space classified as nonpermit. ___________________
    • Why is calibration of the confined space testing meter necessary? ________________________________________
  • 36. Secret?
    • Illinois Onsite 800-972-4216
    • INSAFE 317-234-4792
    • Large companies use insurance, consultants, outside eyes
    • CSP or CIH
  • 37. Inspections
    • Risk
    • Frequency Mapping
    • Fatals
    • Safety + Health
    • Sectors
    Confined Space ~120
  • 38. Where to Start?
    • Risk Management – Frequent Risks/High Severity
    • Job Hazard Analysis
    • Operating Procedures
    • Emergency Procedures
    • Training
    • Incident Investigations
    • Audits
  • 39. Job Safety Analysis Blank form - Copy for use at the workplace Date and signoff Who will make sure it happens? What can be done to make the job safe? What could harm someone? Break the job down into steps Number Completion Persons responsible Risk control Hazard Work activity Item
  • 40. Future
    • More Sector targeting vs. DART
    • More JHAs
    • More guidance documents
    • Business case for safety
    • OIS
    Ever see a large corporation have one secured single sign on with multiple devices at multiple locations using cloud emails and access to all its software platforms?
  • 41. Summary
    • Job hazard Analysis
    • Equipment for Rescue, Testing, Communication,
    • Heat (Pipe too much O2, N2 to cool off)
    • Training
    • Audits
  • 42. [email_address] Facebook….john newquist 312-353-5977 LinkedIn [email_address]
  • 43. Further
      • This was prepared as a collaborative effort several friends as a preliminary update evaluating confined spaces...
      • These are just some the issues. A comprehensive job hazard analysis should be conducted for any confined space.
      • This is not an official OSHA publication. Those will be on the OSHA.gov website.
      • Email me at [email_address] if you see any errors or call me at 312-353-5977.
      • I want to thank Tina Williamson and Janet S. for all their assistance in answering questions and providing insight to the many hazards in this sector.