Feb 25, 2018
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This is part 2 in a series about confined space entry, the requirements including training and entry procedures and we will wrap the series up with some tips, interpretations, and examples written programs. If you remember from the last episode I covered the basic definition of a confined space:
* Is large enough and so configured that an employee can bodily enter and perform assigned work
* Has limited or restricted means for entry or exit (for example, tanks, vessels, silos, storage bins, hoppers, vaults, and pits are spaces that may have limited means of entry.
AND (yes, it has to have all of these)
* It is not designed for continuous employee occupancy. And we talked about what that means as well.
And a ”Permit-required confined space (permit space)" means a confined space that has one OR more of the following characteristics:
1. Contains or has a potential to contain a hazardous
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
Okay, we touched on just some of the training requirements as well. Not too much detail there, but I will go into rescue teams including in-house rescue and the training requirements in the next episode, so be listening for Part 3. For now, let’s move into the actual permit and entry procedures.
Let’s begin with the actual space. Any time you remove covers to openings, especially at ground level, it has to be guarded immediately by a railing, temporary cover, or another temporary barrier that will prevent an accidental fall through the opening.
You always want to address safety outside the space, before beginning work - addressing the space itself. This means identifying any potential hazards that may impact ground workers outside, but also those that may create hazards inside the space. For example, any generators or other combustion engines (like from service trucks) that may be running nearby and could create a carbon monoxide hazard entering the space.
And of course, before any employee can enter the space, the internal atmosphere has to be tested. You do this with a calibrated direct-reading instrument, for oxygen content, for flammable gases and vapors, and for potential toxic air contaminants, in that order. Most multi-gas meters will test for all of these simultaneously. So no need to worry about the order in that case.
Keep in mind, any employee who enters the space has to be provided an opportunity to observe the pre-entry testing directly. This avoids the whole “hey I checked, it’s fine in there” type of scenario.
A note on this one; anyone that witnesses the monitoring needs to be trained on monitoring as well. This means how to operate and read the results. This way they know what they are looking at. Plus, if continuous monitoring goes on, they know what the alarm sounds like and of course, if they take one in with them, they know how to operate it as well.
If you plan to use forced air ventilation, be sure to set it up
the right way. Notice I said “forced air”. You cannot use negative
pressure. That is, a fan pulling air OUT of the space. Some folks
may think pulling “bad air” out is a better idea. It is not.
Forcing fresh air is required.
And testing has to be done with the forced air ventilation in place and operating. So what do you do with the test results?
Well, it is all part of the permit system. According to OSHA, the employer must verify the space is safe for entry by way of a written certification that contains the date, the location of the space, and the signature of the person providing the certification.
The certification must be made before entry and be made available to each employee entering the space. This is accomplished by using an entry permit. Let’s get into what the permit looks like.
Let’s talk about the permit itself for a bit. The actual permit has to contain the following information:
1. The permit space to be entered: This can be a site name such as vault 2B, or autoclave oven # 4, something like that.
2. The purpose of the entry: This can say PM check of tank welds, changing O-rings, stuff like that.
3. The date and the authorized duration of the entry permit: If there are issues with extreme heat or cold, you may have placed a 15-minute time-limit on the entry. Or if using breathing air, like SCBA, you could place a time limit for the entrants. These are examples of authorized durations, as I get asked about this one frequently. Essentially, the duration of the permit cannot exceed the time required to complete the assigned task or job identified on the permit.
4. The authorized entrants: This can be done by listing their names or by using a roster or accountability log - For example, entrants check-in and out moving names on and off the log. The goal is that attendants can know who is inside at any given time.
5. The name of the attendant(s): This is needed especially if you will be rotating attendants, you can see who is authorized to do so.
6. The name of the entry supervisor: Remember, this is just the person supervising the entry process, not necessarily a work supervisor. The permit also has to have a space for the entry supervisor’s signature. This authorizes the entry.
7. The permit has to also list the hazards of the space: These should be spelled out. I am not a fan of the checklist, that is, a list of typical hazards and a box next to it for you to check. It just adds to the length and visual clutter of the permit itself. I prefer to list the hazards that are present or likely to be present so those involved fully understand what they are protecting themselves from and what to look out for. This helps when communicating with entrants, looking for signs and symptoms of exposure. This requires that all involved be trained on such symptoms of different hazards as well.
8. This gets us to listing the measures taken to eliminate or control those hazards. Like blanking, purging, LOTO, etc. It also gives all involved something to check during the entire process. If you indicated a forced air blower, that is plugged into a generator, you know that you have to check the fuel level periodically, or you may have indicated CO as a potential hazard. Again, all this stuff is useful when you think about how you can use it to protect yourself and your co-workers.
9. You have to list acceptable entry procedures as well. This is key because you then have to continuously check conditions against this list. If there are any differences, that is a red flag. You may determine a condition improved, not worsened. But you still have to flag it and determine whether or not to evacuate the space and cancel the entry permit.
10. This also means you need a section for the initial and periodic test results. This helps us document ongoing monitoring activities.
11. A section for the rescue and emergency services that can be called and you have to detail HOW they will be called; such as the equipment to use and the numbers to call.
12. The communication procedures that are to be used by authorized entrants and attendants to maintain contact during the entry. Constant audible or vial contact must be maintained during the entire entry process. If at any time a specified communication device goes down, you have to pull entrants out until you establish another acceptable, an agreed-upon way of communicating, note this change on the permit, retest, and proceed again.
13. You also have to list all the equipment to be used, such as PPE, testing equipment, (again, communications equipment), alarm systems, and rescue equipment as well. This also tells us what types of pre-entry inspections are needed, based on what will be used.
14. Any additional info that would be pertinent especially additional permits like hot work, that you will rely on for the entry.
I have a permit template available here as well as a written program template in case you want to compare it to the one you have, or if you are looking to create one altogether. Some points to consider in your program:
The entry supervisor must terminate the entry (in writing on the permit) once operations have been completed and all personnel, materials, tools, etc have been accounted for and are out of the space.
They also have to terminate the entry when a condition that is not allowed under the entry permit arises in or near the permit space. Again, not just the entry supervisor, but the attendant and any entrant can terminate the entry for this reason. But only the entry supervisor of record should sign and terminate the entry permit itself.
OSHA requires that you keep each entry permit for at least 1 year to facilitate the review of the permit-required confined space program. So at least annually, go over all the entries that were made, look for issues discovered, reasons entries were terminated prematurely, hazards encountered that were not noted on the permit originally, etc. This is so you can improve the written permit-required confined space entry program, improve training, and so on.
Not just for confined space entry, but all of your written safety programs; conduct an annual review to verify they are still adequate and do not need updating. This is a requirement! It is also a great way to use a safety committee; have the group go through a program and talk about how it applies, what needs to be added, what needs to be removed, and so on.
This is a perfect place to stop and tease the next episode; we will get into training specifics and rescue teams; both in-house and external services. Then wrap it all up with some best practices and a template you can use to get started writing your own program.
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