This document discusses confined spaces and permit-required confined spaces. It defines a confined space as a space large enough for entry, with limited entry/exit, and not designed for continuous occupancy. A permit space requires a permit due to hazards like toxic gases, oxygen deficiency, engulfment, or other physical hazards. The duties of a host employer to inform contractors about permit space hazards and coordinate entry are also outlined. Several case studies of accidents in confined spaces resulting in injuries and fatalities are presented.

1. Confined Space
johnanewquist@gmail.com
Draft 9 19 2019

2. 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 Employee
occupancy

3. Permit Space
• a risk of death,
incapacitation, injury or
acute illness
• flammable gases
• oxygen deficient
• toxic atmosphere
• engulfment,
• other serious physical
hazards

4. Duty of Host Employer
• 1910.146(c)(8)
• Inform the contractor that
the workplace contains
permit spaces
• Apprise the contractor of
the elements, including the
hazards identified and the
host employer's experience
with the space
• Apprise the contractor of
any precautions or
procedures that the host
employer has implemented
4

5. Duty of Host Employer
• 1910.146(c)(8)
• Coordinate entry operations with
the contractor, when both host
employer personnel and
contractor personnel will be
working in or near permit spaces
5

6. Duty of Host Employers
• 1910.146(c)(8) When an
employer (host employer)
arranges to have employees of
another employer (contractor)
perform work that involves
permit space entry, the host
employer shall: …
• 1910.146(c)(8)(v) Debrief the
contractor at the conclusion of
the entry operations regarding
the permit space program
followed and regarding any
hazards confronted or created in
permit spaces during entry
operations.
6

7. Host Employers
• Include the debrief in your "Permit
Termination" procedures, as well as
on the actual entry permit or the
“reclassification” form.
• Have the contractor supervisor sign-
off on the terminated contractor and
answer two yes/no questions:
• Do you have any questions or
concerns regarding the permit space
program followed?
• Do you have any questions or
concerns regarding any hazards
confronted or created during entry?
• Provide a space for them to make
comments
7

8. 2010 IL
• Mt. Carroll, IL
• Haasbach LLC sent Will Piper 16,
Alex Pacas 19, and Wyatt
Whitebread 14, into the grain
bin.
• 300+ grain entrapment deaths
since 1984

9. 2010 IL
• Mt. Carroll, IL
• Haasbach LLC sent Will Piper 16,
Alex Pacas 19, and Wyatt
Whitebread 14, into the grain
bin.
• 300+ grain entrapment deaths
since 1984

10. Standard
Permit-Required Confined Spaces
– 29 CFR 1910.146
– Four revisions since was made law by
OSHA
– 29 CFR 1926.1200
10
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.

11. Sign
11

12. Aftermath

13. March 2016
13

14. March 2016
14

15. March 2016
15

16. March 2016
16

17. Non Permit
• 1910.146(c)(7) A space
classified by the employer as a
permit-required confined space
may be reclassified as a non-
permit confined space under
the following (4) procedures:
• 1) 1910.146(c)(7)(i) - If the
permit space poses no actual or
potential atmospheric hazards
and if ALL HAZARDS within the
space are eliminated without
entry into the space, the permit
space may be reclassified as a
non-permit confined space for
as long as the non-atmospheric
hazards remain eliminated.
17

18. Non Permit
• 1910.146(c)(7) A space classified by the
employer as a permit-required confined
space may be reclassified as a non-permit
confined space under the following (4)
procedures:
• 2) 1910.146(c)(7)(ii) - If it is necessary to
enter the permit space to eliminate
hazards, such entry shall be performed
under paragraphs (d) through (k) of this
section.
• If testing and inspection during that entry
demonstrate that 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 the
hazards remain eliminated
18

19. Non Permit
• 3) 1910.146(c)(7)(iii) - The
employer shall document the
basis for determining that all
hazards in a permit space have
been eliminated, through a
certification that contains the
date, the location of the space,
and the signature of the person
making the determination.
• The certification shall be made
available to each employee
entering the space or to that
employee's authorized
representative
19
This document certifies that the
___________________________
(location) has been cleared for a
change in status from a Permit
Confined Space to a Non-Permit
Confined Space provided that the
below conditions are met.
All entrants/attendants involved in
any entry have completed the
Confined Space Entry training.
All hazards other than atmospheric
(e.g., lockout/tag out) can be
completed without entry. Any
conditions making it unsafe have
been eliminated.

20. Non Permit
• 1910.146(c)(7) A space classified by
the employer as a permit-required
confined space may be reclassified
as a non-permit confined space
under the following (4) procedures:
• 4) 1910.146(c)(7)(iv) - If hazards
arise within a permit space that has
been declassified to a non-permit
space under paragraph (c)(7) of this
section, each employee in the
space shall exit the space.
• The employer shall then reevaluate
the space and determine whether it
must be reclassified as a permit
space, in accordance with other
applicable provisions of this section.
20

21. Non Permit
• From an
interpretation in 1996
• Question 2: May
mechanical hazards
be eliminated by
compliance with §
1910.147?
• Answer: Yes
21

22. Non Permit
• ANSI Z117.1
• The employer shall develop and implement
safe work procedures for entry in NPCS.
Examples include:
• Tasks that be performed the space
• The equipment needs for entry
• PPE
• Preparations to make space safe for entry
• Lockout
• Proper ventilation
• Hot Works
• Rescue equipment requirements
22

23. Non Permit
• ANSI Z117.1
Examples of Safe Work Practices
• Use of a buddy system
• Use gas monitor to tes
• Take 5 minute escape pack
• Tell area supervisor when in and out
• Take a communication device
23

24. Oct 2019
• Odessa Tx.
• A $600 gas detector
installed would have
saved husband and wife.
• A 44-year-old Texas oil
company worker died
after being overcome by
hydrogen sulfide gas at a
pump house.
• His 37-year-old wife also
was killed by the fumes
when she went to check
on him.
24
Typical Pump House

25. Nov 2018
• 3 Dead in cryogenic cooler room.
• Alberta Canada
• Liquid Nitrogen
• Cited - written code of practice
for working in the confined space
of the cryogenic coolers,
• establish an emergency response
plan for responding to an
emergency that may require
rescue or evacuation and
• designate a competent worker to
conduct hazard assessments
related to working in confined
spaces.
25

26. July 2018
• CONCORD, MASS.
• The Occupational Safety and
Health Administration is
investigating a fatal industrial
accident at a Massachusetts
hospital.
• Authorities say a 46-year-old
worker died Wednesday at
Emerson Hospital in Concord
while working in the crawl space
of a boiler system.
26

27. Dec 2017
• Two workers burned in
confined space in NY.
• The two workers were
using solvent-based
cement in a confined
space at the time.
• Fire officials said the
space lacked proper
ventilation, which may
have led to the
explosion. 27

28. Sep 2017
28
Wakefield, NE
Worker crushed in
dock leveler accident
at food company.

29. Oven
• Bumble Bee Foods and two
managers were charged by Los
Angeles prosecutors Monday
with violating safety regulations
in the death of a worker who
was cooked in an industrial
oven with tons of tuna.
• Bumble Bee Foods will pay
$6 million for “willfully
violating worker safety
rules,” according to the
Los Angeles County
District Attorney’s office.
• $1.5 Million to the
worker’s family

30. Aug 2017
30

31. April 2017
• Utility crews spent
hours in downtown
Boston Sunday where
multiple manholes
exploded.
• Officials say an old,
blackened, and
corroded wire caused
the explosion.

32. Aug
2017
• Shippingport PA
• Two dead
• Enerfab workers were doing contract
work with Penn Energy at the plant.
• They were working in a well-type area
to remove an elbow joint from a pipe.
• Two men were in a pit below, one was
on a ladder and the other two were
about 20 to 50 feet on a wall above.
• When they removed the elbow joint, it
released hydrogen sulfide gas.
• “The line was not supposed to be
charged, obviously. They got to the last
bolt to crack it open and when they did
so, this nauseous gas…hydrogen sulfide
type mixture immediately incapacitates
you,” State Police Lt. Eric Hermick said.

33. Jan 2017
• Key Largo FL
• Three dead in
manhole
• Firefighter critical
• 10 “serious” violations
totaling $119,507 in
penalties for the
deaths of three
workers, Robert
Wilson, 24, Elway
Gray, 34, and Louis
O’Keefe, 49
33

34. 2016

35. December 2016
• Lytle TX
• Two brothers dead
entering a tanker
containing naptha
35

36. Aug 2016
• Rochester NY
• Police say the contract worker
was doing some underground
work when another co-worker
looked down into the manhole to
discover that the man was
unresponsive.
• Co-workers pulled him out of the
manhole and performed CPR until
first responders arrived.
• Investigators say the victim's
heart stopped and they had to
use a defibrillator on him.
• He was breathing again as he was
being transported to Strong
Hospital.
36

37. March 2016
• Placid LA
• “Trouard and another
contract worker were
working near the
storage tank at the
Placid refining facility
and were exposed to
argon instead of the
fresh air supply.”
37

38. June 2015
• Washington Township OH
• The sheriff says 20-year-
old James Bradley Brown
and another plumber
were working on a septic
system at a home on
Township Road 254
around 2:30 p.m.
Tuesday.
• The office says Brown
crawled into the septic
tank and lost
consciousness.
38

39. Aug 2016
39
DUBLIN, Ohio — Neighbors credit a teen girl for
rescuing a toddler who had fallen head-first into a
septic tank full of sludge.
But Madison Williams, 13, said there was no way she
was going to let a two-year old boy die. Williams is
about 5 feet, 4 inches tall and the hole is more than
8 feet deep and only 11 inches wide. Once she could
reach the toddler, she pulled the small child out of
the tank.
The septic tank cover has now been bolted down. It
was not the evening of the accident.

40. April 2015
• OSHA - Nebraska Railcar Cleaning
Services sent two employees into
the rail car to work without
monitoring the air continuously for
explosive hazards as required, nor
providing the employees with
emergency retrieval equipment or
properly fitted respirators
• The explosion blew the rail car’s
escape ladder off and killed the two
men, trapping one inside and
hurling the other off the top of the
car. A third employee was injured.
• The workers who died were Dallas
Foulk, 40, and Adrian LaPour, 44.
• $963,000.
40

41. June 2014
• A specially trained Pekin
Fire Department rescue
team, which arrived
within several minutes
of the accident report
about noon, entered
the tanker with oxygen
tanks and masks to pull
the victims out by
winch and rope.
41
A railroad tank car containing
300 gallons of Toluene would be
a permit confined space

42. 2013 NC
• Autopsy: Catawba plant worker
died of hydrogen sulfide
intoxication
Samir Storey, 39 and others were
cleaning a 10-by-40-foot tank
• “clear, cloudy smoke” entered the
tank, triggering emergency
alarms, which trapped Samir in
the tank.
• Hydrogen sulfide affects the body
in two ways, she said. It blocks
oxygen from binding with blood
cells, and it interrupts the central
nervous system, which, in turn,
affects the respiratory system.

43. Nov 2012 IL
• Tank 16 feet high
• 28 inch opening
• Methylene chloride
• Contracted a cleaning
company to do the
work.
Fall protection should be provided on
tanks 4 feet high.

44. 2012
• Worker engulfed in a sand
bin at precast plant.
• Plant employees attempted
to rescue the worker for
more than an hour before
the company summoned
emergency assistance.
• Worker suffered serious
crushing injuries.
• Proposed fines total
$70,000.

45. Grain Fire
• Jan. 13, 1996
• Seward IL
• The Stickle employee collapsed
and died due to carbon monoxide
inhalation.
• After entering the bin, Pecatonica
Fire Department Chief Dale
Zimmerman became lethargic
and was physically unable to
climb the ladder to exit the bin.
• William J. Kirchner, 54, of Leaf
River, IL, manager of Fasco's
Seward elevator, pleaded guilty
to a misdemeanor charge of
making false statements on a
document
Victor A. Randolph, 42, of Cedar
Rapids, a vice president of Stickle,
indicted for obstructing an OSHA
investigation and making a false
document concerning workplace
safety violations. Three years
probation. $10,000 fine.

46. Examples
• Manholes
• Grain Bins
• Tanks
• Vaults

47. History
• No standard for years -
proposed 1976
• Film Recovery – Hydrogen
cyanide -1983
• ANSI Z117
• General Duty Clause
• OSHA 1910.146 published
in 1993

48. 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

49. Motel Fatality
• 2002 - IL
• Worker goes to restart
pump
• Passes out and dies
• 5 feet deep

50. Atmosphere
Atmosphere that is hazardous if:
1) Oxygen concentration less
than 19.5% OR greater than
23.5%
2) Flammable gas, vapor or mist
in excess of 10% of LEL/LFL
3) Airborne combustible dust at
level equal or greater than
LFL (or wherever dust
obscures vision at 5 feet (1.52
m) or less
Lower flammable limit of a flammable gas or
vapor is the: Lowest concentration of the gas
or vapor in air, expressed as a percentage, that
can be ignited

51. 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

52. Monitoring
• Monitor for YOUR
hazards
• Calibrate your monitor
– ensure the validity of
your sensors
• Calibration must occur
in clean air

53. Respirators Considerations
• Identify your hazards
• Refer to respirator
standard 1910.134
• Enforce the respiratory
protection that in in the
program

54. 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.

55. Chemical Plant
• 1989
• Worker went into vessel
• Used 100% nitrogen to
cool himself off
• Passed out

56. 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

57. Bastian Plating
• June 26, 1988 - IN
• Worker asphyxiated while
acid cleaning 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
friend.
Typical Plating Tank

58. Attendant
• Individual stationed
outside the permit
space who monitors
entrants
• Must have
communication
• Can alert rescue
• Does not enter

59. Training
• For employees,
confined space training
must be before being
assigned to enter the
space.
 Provide advisory
training prior to entry of
any space

60. Manufacturing
• 1995 - IL
• Open pit 45’ x’ 60’
• Argon gas had been
used instead of
compressed air to
operate an air hammer
in pit.
• 3 died including a
firefighter.
Typical Machine Pit

61. Retrival
Equipment for non-entry
rescue of personnel
from a permit space:
• Full-body harness
• Retrieval line
• Wristlets
• Lifting Device or Anchor

62. Rescue
• Sixty percent (60%) of all
confined space deaths were
the would-be-rescuers
• Rescue equipment must be
maintained
• Run practice drills

63. Summary
• Carbon Dioxide,
Carbon Monoxide
and Argon are
colorless, odorless
gases.
• Constant Monitoring
• Constant Ventilation
• Train
• Rescue

64. Questions?