The city of Modesto, Calif., agreed to pay a $165,000 fine...
Following the proper safety precautions when entering or working
in confined spaces is an important function for anyone who subjects himself to
the hazards of this kind of vocation. We all know of the horror stories of
persons getting buried alive or of those who die from lack of oxygen in
confined spaces, and yet these accidents and deaths continue to occur; mostly
because people are in too much of a hurry or feel that they are not in any
danger when working in these situations. In some cases, people fail to read the
condition of excavations and think that they can work without the aid of a
trench box or proper shoring, only to become another statistic.
Before a person tries to learn any safety precautions he
must first know which conditions or circumstances constitute a confined space
and what sort of rules apply to working in these spaces. Once this is known, he
then can proceed to follow the regulations that relate to a particular
situation so he is working safely presuming, of course, that he knows the
proper safety regulations.
Knowing and understanding the proper safety precautions is
only a part of following safety procedures. Having the proper equipment
necessary to prevent accidents and save lives and practicing with this
equipment also is important.
Defining Confined Spaces
A confined space as defined by OSHA in Part 1910.146(b) of
the Federal Register (www.osha.gov) is any space that is large enough for an
employee to enter and perform work, has a restricted means of entry and exit
and is not designed for continuous occupancy. Additionally, the space may
contain a hazardous atmosphere that can result in employee injury or death. A
hazardous atmosphere is defined as one with a flammable gas, vapor or mist at
10 percent or more than the lower flammable limit as well as an atmospheric
oxygen concentration below 19.5 percent or above 23.5 percent or other gasses
such as hydrogen sulfide or carbon monoxide above 10 ppm or 35 ppm,
It is not relevent whether the space is a below-grade vault
or an above-ground building with a door. It is the interior space and
atmosphere that determines if it is a confined space. There are, however, some
considerations that can be taken into account in order to determine if the
space can be considered "confined."o:p>
For example, a chlorine room or other chemical feed/storage
room can be a confined space because of the possibility of chlorine or other
chemical fumes existing if the ventilation fan was not turned on to clear the
space before entering. At the same time, if chemical solutions or chlorine
tanks are being changed or handled, the atmosphere could have vapors or trace
gasses that would qualify the room as a confined space.
On the other hand, an open trench could be considered a
confined space if it was deep enough and had limited escape access ladders and
restricted movement in the bottom because of pipe structures and shoring
Another consideration that must be taken into account when
dealing with confined spaces is the determinaton of whether or not the space
may or may not require a permit for entry. Some spaces may be entered without a
permit and by anyone who has a need to enter the space. On the other hand, many
spaces cannot be entered by anyone (even those that are authorized) without a
permit that is signed by a responsible person.
Though this may seem like a complicated issue, there is some
guidance provided by the Federal Register under Section 1910.146—Appendix
A: Permit-required confined space decision flow chart (see left) and Appendix C: Examples of permit-required
confined space programs.
Appendix A (decision flow chart) begins with the utility as
a whole entity, asking the question, "Does the workplace contain confined
spaces as identified by 1910-146(b)?" If it does not, there is no problem.
However, if it does, then there are a series of checks and determinations that
must be made in order to determine if an entry permit is required. It also
requires that the employees be informed of the hazard and procedures necessary
to work in the space including safety equipment and evacuation or emergency
procedures. The appendix also covers outside contractors that may work in the
At this point, it is important to note that any outside
contractor working within your premises is under your responsibility, whether
he reports directly to you or not. You are responsible for his well-being even
though he is not on your payroll. If he enters a permit required space, he must
get a permit from you, and you must have someone around the job sites to make
sure that he follows all of the necessary work and safety procedures.
Addendix C uses examples to show when a permit is or is not
required. Basically, it states, "entry into a space can be made without a
permit or attendant, providing the space can be maintained in a safe condition
with the use of mechanical ventilation as provided in 1920-146(c)(5)." Of
course, a fully trained and qualifed employee must do a pre-check of the space
to check for any hazardous gasses or conditions. He also is required to fill
out a Confined Spaces Pre-Entry Check List to ensure that all of the necessary
procedures are being followed. This includes testing of the atmosphere in the
space, blocking off (where possible) of any lines that could bring contaminants
into the space and the surveillance of the surrounding area for drifting
Entering Confined Spaces
Whenever entering any confined space, it is important to
remember the need for safety and to follow recommended safety procedures that
correspond to each area. Although confined space entry may be briefly separated
into permit and non-permit entry, there are many circumstances listed in
1920-146 that provide flexibility in exactly how to define a confined space.
Therefore, any employer should thoroughly investigate the statute to ensure that
his employees are following the proper procedures when entering any sort of
For example, non-permit entry previously was described and
referenced as Appendix C of the code. Appendix E of 1910.146 goes one step
further to explain sewer entry and its requirements. It states that only
employees that are trained for this work should be used, and that the air
should be tested for specific substances (CO, ft, LLC and combustibles such as
LEL) before entry and at regular intervals while the employees are working.
Also, continuous ventilation should take place. Additionally, in large bore
sewers, employees should be equipped with audible alarm devices and an escape
self-contained breathing apparatus (ESCBA) with at least a 10-minute air supply
or some other NIOSH-approved self-rescuer and other emergency equipment such as
flashlights and radios.
Permit-required entry into confined spaces is more clearly
defined in 1910.146(c) of the Federal Register. It starts out with the
requirement that an employer must evaluate the workplace to determine if a
space is a permit-required area. If so, all employees should be notified and a
sign reading "Danger: Permit Required--Confined Space, Do Not Enter"
be posted. (There also are other sections of the OSHA Code that refer to other
vocations--mining, shipyard and meat packing--that have their own specific
regulations that define hazardous work environments.)
Once a space has been designated as a permit-required area,
the employer may or may not permit employees to enter the space. If entry is
permitted, then the employer must develop and implement a written space permit
program that complies with 1910.146(c) regulations. This regulation, however,
can be side-stepped if the space only has a potential hazardous atmosphere that
can be eliminated by forced air ventilation as defined in 1910.146(c)(S).
The details of implementing 1910.146(c) are further spelled
out in 1910.146(d). These include such items as identifying the hazard,
specifying acceptable entry conditions, providing protection barriers,
providing testing, communications, personal protection equipment, ladders and
emergency rescue equipment. It also includes the requirements that each
employee be able to observe and know the results of any tests that were made
prior to entering the space.
Additionally, the regulation requires that an entry
supervisor be present to determine if entry is allowable and then remain at the
site or have another person available as an attendant during the time when an
employee is working in the confined space. It also is suggested that a third
person be nearby in case an emergency arises. The regulation spells out the
procedures for calling for assistance as well as the actions to be taken by the
crew for extracting a worker from the confined space.
Most confined space safety procedures are just common sense.
You would not attempt to change a tire on a vehicle without setting the brakes
and blocking at least one wheel to prevent the vehicle from moving. The same rules
apply to the procedures that should be followed before entering a confined
space and are spelled out in the Federal Register 1910.146.
As previously mentioned, proper ventilation, sample air
testing and the use of protective safety equipment all are necessary before
entering a confined space. However, there are some specific items that should
be pointed out because their selection depends on the conditions within the
confined space. The following are examples of some of these selection
Ventilation equipment is available in both
"suction" and "blow-in" styles. If a suction style is used,
then the ventilator must be placed somewhere other than the work area in order
to provide fresh air at the work area and to eliminate other fumes from entering.
If a blow-in style is used, then the blower must be located away and downwind
of the work area. Also, the blower discharge hose must extend to the bottom of
the confined space to permit full purging of the atmosphere. The amount of time
for the air purge that is required can be calculated by dividing the manhole
volume (cubic feet) by the cfm of the blower. The air also must be tested for
C3 as detectors are available in a variety of styles.
However, those that most often are used measure specific gasses such as CO, O2,
H2S and combustibles (LEL). Additionally, there are audible warning devices
that can be worn by the worker as added protection against an unexpected surge
of hazardous gas.
Remember that the test equipment/device is only as good as
its calibration. Therefore, the device must be checked and calibrated at
regular intervals if it is to provide the required data. Also, the permit entry
form requires that the gas test equipment be identified as well as the person
performing the test.
The selection of hoisting equipment depends upon whether the
confined space is a ladder or ladderless entry and whether or not the hoist is
used for materials or personnel. Work winches should never be used to hoist
personnel. Various manufacturers have different stipulations on how their
winches should be used and are reflections of OSHA regulations published under
several different rulings.
For example, 1910.146(k)(3)(ii) requires a mechanical-type
device for rescue in vertical conditions more than 5 feet deep. On the other
hand, OSHA 1910 general industry and 1926 construction industry standards
stipulate specific requirements for the selection of a tripod/manually operated
winch system. Additionally, 1910.28 and 1926.451 require the use of a backup fall
arrest system for use when entering ladderless structures. Both regulations
also require that the tripods and winches be tested and listed by a nationally
recognized testing laboratory (Underwriters or Factory Mutual). The winches
also may require testing by the manufacturer after a period of use or
Backup fall systems are good ideas for any structure that is
deep and can be considered a hazard to enter even if they have
rungs—especially, if the structure is old and the ladder rungs are not in
the best condition. The backup fall system can be a rope grab kit or a
self-retracting lifeline but must be connected to the "D" ring of the
full body harness that the worker wears when entering the work space.
If the confined space contains a hazardous gas that cannot
be effectively purged or reduced to an acceptable level, then some sort of
breathing appartus will be required before the worker can be allowed to enter
the space. Again, the existing conditions will determine which kind of
breathing assistance/apparatus will be required.
For most conditions where the worker must enter and remain
for a period of time before he can complete his task, a 30- or 60-minute
self-contained breathing apparatus (SCBA) would be required. While some are
rated for fire-fighting situations, there are others that are rated for
industrial use. Both styles have similar features and are acceptable under OSHA
regulations. Keep in mind that the 30- or 60-minute air time cannot be fully
used by the wearer. Usually, a 5- or 10-minute warning system permits the
wearer to egress the space before the air runs out.
There also are other SCBA units available that have more
limited escape time from 5 to 15 minutes. These devices are not worn when
entering, and only are used to permit an emergency exit from the space. In
addition to these devices, some manufacturers have limited-use respirators that
can be used by workers in atmospheres that contain hazardous gasses at low
Regardless of how much and which kind of equipment you provide,
it is useless if the employees are not trained and proficient with it. Training
(not just talking about it but doing it) is the most important part of any
confined space entry program. It also is required as part of the OSHA
regulations and can be used to certify the employees performance of various
tasks that they will perform. There are many training programs available for
this purpose as well as OSHA compliance and accident-prevention manuals that
can help you determine how to understand and meet the regulations. WWD