Confined Space Safety 29 CFR 1926.1200 For Construction PPT-136-01

Confined Space Safety 29 CFR 1926.1200 For Construction PPT-136-01 Bureau of Workers’ Comp PA Training for Health & Safety (PATHS) 1

Reason for the Standard Why did OSHA develop a Confined Space standard? 122 confined space accidents each year led to 173 fatalities. 60% of the fatalities occurred during rescue attempts. PPT-136-01 2

The Standard Intended to protect workers from toxic, flammable, explosive, or asphyxiating atmospheres. Possible engulfment. Any other recognized serious hazard (example: hazardous energy). The standard focuses on areas with immediate health or safety risks, denoting them as “Permit Required Confined Space” (PRCS). PPT-136-01 3

Industry Standard All employees required to enter into confined or enclosed spaces shall be instructed as to: - Nature of the hazards involved. Necessary precautions to be taken. Use of protective emergency equipment. - The employer shall comply with any specific regulations that apply to work in dangerous or potentially dangerous areas. PPT-136-01 4

Exceptions to the Standard This standard does not apply to Construction work regulated by 1926 addressing the following areas: Subpart P – Excavations Subpart S – Underground Construction, Caissons, Cofferdams and Compressed Air Subpart Y - Diving PPT-136-01 5

Typical Confined Spaces o Tanks, incinerators, scrubbers o Concrete pier columns, transformer vaults, HVAC ducting o Drilling shafts, enclosed beams, vessels o Digesters, lift stations, step up transformers, turbines o Chillers, bag houses and mixers/reactors PPT-136-01 6

How to Identify Confined Spaces o Large enough/so configured for worker to enter. o Limited Openings for Entry and Exit. o Not Designed for Continuous Worker Occupancy. PPT-136-01 7

Limited Openings for Entry/Exit o Openings as small as 18 inches in diameter. o Difficult to enter with SCBA or other life-saving equipment. o Difficult to remove downed worker in folded up or bent over position. o Exit from large openings may be difficult due to presence of ladders, hoists, etc. PPT-136-01 8

Unfavorable Natural Ventilation o Lack of air movement in and out of the space can create an atmosphere much different than the outside atmosphere. o Deadly gases can be trapped inside. o Organic materials can decompose. o May not be enough oxygen due to presence of other gases or chemical reactions such as rusting. PPT-136-01 9

Characteristics Include Not Designed for Continuous Worker Occupancy: o Most confined spaces are not designed to enter and work in on a regular basis. o Designed to store a product. o Enclose materials or processes. o Transport products or substances. o Occasional worker entry for inspection, repair, cleanup, maintenance, etc. PPT-136-01 10

Hazards Physical hazard: an existing or potential hazard that can cause death or serious physical damage. Limited or restricted means for entry or exit: a condition that has a potential to impede an employee’s movement into or out of a confined space (e.g. trip hazards, slippery floors, poor illumination, etc.). PPT-136-01 11

Dangerous Combinations o Presence of all three confined space characteristics can complicate the situation. o Working in and around the space. o Rescue operations during emergencies. o Worsened conditions due to work activities: Welding and cutting, use of bonding agents. Cleaning with solvents, use of other chemicals. Use of gas-powered equipment. PPT-136-01 12

PRCS Permit-Required Confined Space 1. Contains or has a potential to contain a hazardous atmosphere. 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 crosssection. 4. Contains any other recognized serious safety or health hazard. PPT-136-01 13

Categorizing Work Space * Space large enough to enter &; * Limited or Restricted entry or exit &; * Not designed for continuous worker occupancy. YES NO Not a confined Space Confined Space Hazardous Atmosphere PermitRequired Confined Space Or YES Engulfment Hazard Or Configuration Hazard Or Any other recognized serious hazard PPT- NonNO Permit Required Space 14

Evaluation Employers are required to evaluate workplaces for permit required confined spaces. Employees must be informed of the existence of confined spaces through the use of signs, etc. UNAUTHORIZED ENTRY MUST BE PREVENTED PPT-136-01 15

Signs A sign reading: - DANGER PERMIT REQUIRED CONFINED SPACE DO NOT ENTER or other similar language would satisfy the requirement for a sign. PPT-136-01 16

Responsible Personnel Competent Person must identify and predict hazards in surroundings or in the space. Qualified persons will resolve problems found. PPT-136-01 17

Responsible Personnel Controlling contractor is the employer with overall responsibility for construction at the worksite. Entry Employer is any employer who decides an employee it directs will enter a permit space. Host employer is the employer that owns or manages the property where the construction work is taking place. PPT-136-01 18

Hazard Control Control is the action taken to reduce the level of any hazard inside a confined space using engineering methods (example, by ventilation), and then using these methods to maintain the reduced hazard level. Control also refers to the engineering methods used for this purpose. PPE is not a control. Control ensures persons do not enter Immediately Dangerous to Life or Health (IDLH) atmospheres. PPT-136-01 19

Hazard Control o Isolate or isolation: the process by which a permit space is removed from service and completely protected against the release of energy and material into the space; in 1926.1200 also includes “placement of barriers to eliminate the potential for employee contact with a physical hazard.” Line breaking Lockout Tagout Monitoring PPT-136-01 20

Hazard Control Protection against serious physical damage Ventilation may also be used PPE Lighting Barriers PPT-136-01 21

Hazards of Confined Spaces o Oxygen Deficient Atmospheres. o Oxygen Enriched Atmospheres. o Flammable Atmospheres. o Toxic Atmospheres. o Temperature Extremes. o Engulfment Hazards. o Noise, Slick/Wet Surfaces. o Falling Objects. PPT-136-01 22

Oxygen Deficient Atmospheres 19.5 % Minimum acceptable oxygen level. 15 - 19%Early symptoms: Decreased ability to work strenuously. Impaired coordination. 12-14% Respiration increases. Poor judgment. 10-12% Respiration increases. Lips blue. 8-10% Mental failure. Fainting. Nausea. Unconsciousness. Vomiting. 6-8% 8 minutes fatal, 6 minutes 50% fatal 4-5 minutes possible recovery. 4-6% Coma in 40 seconds. Death. PPT-136-01 23

Oxygen Enriched Atmospheres Oxygen level above 23.5%. o Causes flammable and combustible materials to burn violently when ignited. o Hair, clothing, materials, etc. o Oil soaked clothing and materials. Never use pure oxygen to ventilate. Never store or place compressed tanks in a confined space. PPT-136-01 24

Flammable Atmospheres 3 Critical Factors: o Presence of a flammable gas or vapor o Presence of Oxygen content in the air o Presence of dust (visibility of 5’ or less) Proper air/gas mixture can lead to explosion Typical Ignition Sources: o Sparking or electric tool o Welding/cutting operations o Smoking PPT-136-01 25

Toxic Atmospheres Product stored in a confined space: o Gases released when cleaning o Materials absorbed into walls of confined space o Decomposition of materials in o the confined space Work performed in a confined space: o Welding, cutting, brazing, soldering o Painting, scraping, sanding, o Degreasing o Sealing, bonding, melting Areas adjacent to a confined space. PPT-136-01 26

Hydrogen Sulfide o Decomposition of materials; human waste. o Rotten egg odor at low concentrations. o Possibly no warning at high concentrations. PPM Effect Time 10 Permissible Exposure Level 8 Hours 50 - 100 Mild Irritation - eyes, throat 1 Hour 200 - 300 Significant Irritation 1 Hour 500 - 700 Unconsciousness, Death 1/2-1 Hour 1000 Unconsciousness, Death Minutes PPT-136-01 27

Carbon Monoxide o Odorless, Colorless Gas. o Combustion By-Product. o Quickly collapse at high concentrations. PPM Effect Time 50 Permissible Exposure Level 8 Hours 200 Slight headache, discomfort 3 Hours 600 Headache, discomfort 1 Hour 1000-2000 Confusion, nausea, headache 2 Hours 1000-2000 Tendency to stagger 1 1/2 Hours 1000-2000 Slight heart palpitation 30 Min. 2000-2500 Unconsciousness 30 Min. PPT-136-01 28

Temperature Extremes o Extremely hot or cold temperatures. o Steam cleaning of confined spaces. o Humidity factors. o Extremely cold liquids. o Work processes inside the confined space can increase temperature extremes. o Personal protective equipment. PPT-136-01 29

Engulfment Hazards Loose, granular materials stored in bins and hoppers - grain, sand, coal, etc. Crusting and bridging below a worker. Flooding of confined space. Water or sewage flow. PPT-136-01 30

Testing the Atmosphere o Verify presence of safe work atmosphere. o Test in this order: oxygen, combustible gases and vapors, toxic gases and vapors o Test all areas of a confined space. Top, Middle, Bottom o Methane is lighter than air. o Carbon Monoxide is the same as air. o Hydrogen Sulfide is heavier than air. o Oxygen Deficiency. PPT-136-01 31

Entry Requirements o Continuously monitor entry conditions unless the employer can demonstrate that the equipment for continuously monitoring a hazard is not commercially available or that periodic monitoring is of sufficient frequency to ensure that the atmospheric hazard is being controlled at safe levels. o Provide an early-warning system that continuously monitors for non-isolated engulfment hazards. PPT-136-01 32

Ventilation o First option to correct problems. o Must be aware of hazards you are trying to correct in the confined space. o Air intake in a safe location to draw fresh air only. o Continuous ventilation whenever possible. o Retest the confined space before entry. PPT-136-01 33

Alternative Protection Procedures OSHA has specified alternative protection procedures that may be used for permit spaces where the only hazard is atmospheric and ventilation alone will control the hazard. PPT-136-01 34

Determination of Purge Time Purge times can be estimated by the following: T 7.5 V/C T purge time in minutes V the volume of the space in ft3 C effective blower capacity CFM PPT-136-01 35

Purging Time Example Situation: An estimation of purging time is needed for a 800 ft3 deep neck manhole. The effective blower capacity is 250 CFM. 800/250 x 7.5 24 minutes PPT-136-01 36

Isolation o Locking and tagging out electrical sources. o Blanking and bleeding pneumatic and hydraulic lines. o Disconnecting mechanical drives and shafts. o Securing mechanical parts. o Blanking sewer and water flow. o Locking and tagging out shutoff valves. PPT-136-01 37

Respirators Air-Purifying Respirators - Filter dangerous substances from the air. - Must know the type and amount of hazardous substance present in the confined space. - NEVER use where oxygen is deficient! Air-Supplying Respirators - Deliver a safe supply of breathing air from a cylinder or an uncontaminated area nearby. - Must be adequately monitored. PPT-136-01 38

Authorized Entrants Entrants must: o o o o o o Know the hazards they are facing. Be able to recognize signs and symptoms of exposure. Understand the consequences of exposure to hazards. Communicate with attendants as necessary. Alert attendants to warning signs or existence of a hazardous condition. Exit when ordered or alerted. PPT-136-01 39

Authorized Entrants o Chest or full body harness with a retrieval line attached at the center of entrant’s back near shoulder level, above the entrant’s head. o Wristlets or anklets may be used in lieu of chest or full body harness is employer can demonstrate the use of chest or full body harness is infeasible or creates a greater hazards. PPT-136-01 40

Attendants Could this be a safety issue for the attendant? Attendants must: o Be aware of behavioral effects of potential exposures. o Maintain count and identity of entrants. o Remain outside the space until relieved. o Communicate with entrants. o Monitor activities inside and outside the space and order exit if required. PPT-136-01 Yes, if a hazardous atmosphere is present. 41

Attendants o o o Summon rescuers if necessary. Prevent unauthorized entry. Perform non-entry rescue. Attendants may NOT perform other duties that interfere with their primary duty to monitor and protect! PPT-136-01 42

Entry Supervisors Entry Supervisors must: o Issue confined space permits. o Know hazards. o Verify that all tests have been conducted. o Verify that all procedures and equipment are in place before signing a permit. o Terminate entry if necessary and cancel permits. PPT-136-01 43

Entry Supervisors o Verify availability of rescue services & means for summoning. o Remove unauthorized individuals. o Terminate entry if necessary. o Cancel permits. o Coordinate shift change. PPT-136-01 44

Entry Permit Systems o Written permit signed by entry supervisor. o Verifies pre-entry precautions have been taken and the space is safe to enter. o Posted at entry to confined space. o Specifies apparent hazards and corrective actions taken prior to entry. o Requires termination of permit when task is completed or when new conditions exist. PPT-136-01 45

Entry Permit Requirements o Date, location, and name of confined space. o Purpose of entry and known hazards. o Duration of entry permit time. o Authorized entrants, attendants, supervisors. o Air testing results - signature of tester. o Protective measures to be taken. – Ventilation, Isolation, Flushing – Lockout/Tagout, Purging PPT-136-01 46

More Entry Permit Requirements o Name and phone numbers of rescue and emergency services. o Communication procedures. o Special equipment and procedures. – Personal protective equipment (PPE) – Alarm procedures – Rescue equipment – Respirators PPT-136-01 47

Entry without Permit When a confined space is opened: – The opening must be promptly guarded by a rail or temporary cover. – The atmosphere must be tested before entering using only direct reading instruments. – The atmosphere must be tested (in this order) for oxygen content, flammable gases/vapors, and toxic air contaminants. – Continuous forced air ventilation must be used. PPT-136-01 48

Entry without Permit When a confined space is opened: o The atmosphere must be tested periodically during work. o The employer must verify alternative procedure applicability and safe entry conditions by a written certification (not a permit) with the following information: Date Location Signature NOTE: The above certificate must be made available to entrant to review PPT-136-01 49

Entry without Permit If you meet the conditions stated in Section (C)(5)(i) of the OSHA standard 1910.146 o Employer can prove only hazard is actual or potential o o hazardous atmosphere Continuous forced air or ventilation alone sufficient for entry Employer develops monitoring and inspection data You may use the procedures specified in Section (C) (5)(ii) of the standard. This allows you to OMIT Paragraphs (d) through (f) and (h) through (k) of the standard. NOTE: Paragraph (g) Training still applies to all confined space activities PPT-136-01 50

Training and Education o All workers who must enter confined spaces. o All attendants and rescue team members. o Prior to initial work assignment. o Retraining when: – Job duties change – Change in permit-space program – New hazards are present – Job performance indicates deficiencies PPT-136-01 51

Training and Education Training and emergency drills should be conducted once a year or whenever the procedure or process changes. Records for training must include: Name of employee(s) Signature of trainer(s) Date(s) of training and Must be retained for 3 years PPT-136-01 52

Rescue Services May be provided by: On-site employees or “Off-site services” PPT-136-01 53

On-site Teams On-site teams must: o Be properly equipped. o Receive the same training as entrants. o Receive additional training in the use of PPE, rescue equipment, first aid and CPR. o Practice simulated rescues once each year. PPT-136-01 54

Off-site Teams Off-site teams must: o Be aware of confined space hazards. o Practice similar rescues in similar spaces. PPT-136-01 55

Local Fire/Rescue Service o Are all fire companies/departments in your county equipped and trained to handle Confined Space rescue? o Is your local fire company/department trained, equipped, and are they available every time you enter a PRCS? o Is your local fire company/department aware of the locations of your Confined Spaces? These are questions that need to be answered before allowing entry into a Permit Required Confined Space! PPT-136-01 56

1926 General Requirements (a) Before work, each employer must ensure a competent person: o Identifies all confined spaces in which one or more of the employees it directs may work, and o Identifies each space that is a permit space, through consideration and evaluation of the elements of that space, including testing as necessary. PPT-136-01 57

1926 General Requirements 1203(b) If the workplace contains one or more permit spaces, employer who identifies, or who receives notice of, a permit space must: (1) 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, each permit space; PPT-136-01 58

1926 General Requirements (2) Inform employees’ representatives and controlling contractor of the existence and location of, and the danger of each permit space. (c) Each employer who has not authorized employees entry must prevent those employees from entering that permit space. PPT-136-01 59

1926 General Requirements (d) Any employer deciding employees will enter a permit space, must have a written permit space program complying with §1926.1204 implemented at the construction site. Written program made available prior to and during entry for inspection. (e) An employer may use the alternate procedures specified in paragraph §1926.1203(e)(2) for entering a permit space only under the conditions set forth in paragraph §1926.1203(e)(1). PPT-136-01 60

1926 General Requirements (1) An employer whose employees enter a permit space need not comply with §1926.1204 through 1206 and §1926.1208 through 1211, provided all the following are met: (i) The employer can demonstrate that all physical hazards in the space are eliminated or isolated through engineering controls so that the only hazard posed by the permit space is an actual or potential hazardous PPT-136-01 atmosphere; 61

1926 General Requirements (ii) Employer can demonstrate continuous forced air ventilation alone is sufficient to maintain safe for entry, and that, in the event the ventilation system stops working, entrants can exit the space safely; (iii) Employer develops monitoring and inspection data supporting demonstrations required by paragraphs §1926.1203 (e)(1)(i) §1926.1203 (e)(1)(ii); PPT-136-01 and 62

1926 General Requirements (iv) If initial entry is necessary to obtain the data per §1926.1203(e) (1)(iii), entry is performed compliant with §1926.1204 through 1211 of this standard (v) The determinations and supporting data required by paragraphs§1926.1203(e)(1)(i), (e) (1)(ii), and (e)(1)(iii) are documented by the employer PPT-136-01 63

1926 General Requirements 1203. Continuous forced air ventilation must be used, as follows: o To eliminate the hazard o Ventilate immediate areas occupied by employees o Air source must be clean o Space continuously monitored *(see notes for more detailed information) PPT-136-01 64

1926 General Requirements (vii) If a hazard is detected during entry: (A) Each employee must leave the space immediately; (B) The space must be evaluated to determine how the hazard developed; and (C) The employer must implement measures to protect employees from the hazard before any subsequent entry takes place. PPT-136-01 65

1926 General Requirements (viii) The employer must ensure a safe method of entering and exiting the space: o If hoisting system used, must be designed and manufactured for personnel hoisting; o A job-made hoisting system is permissible if approved for personnel hoisting by a registered professional engineer, in writing, prior to use. PPT-136-01 66

1926 General Requirements (ix) The employer verifies the space is safe for entry and that the pre-entry measures per §1926.1203(e) (2) have been taken, through a written certification that contains the date, location of the space, and the signature of the person providing the certification. The certification must be made before entry and must be made available to each employee entering the space or to that employee’s authorized representative. PPT-136-01 67

1926 General Requirements (f) When changes occur in the use or configuration of a non-permit confined space possibly increasing the hazards to entrants, or some indication the initial evaluation of the space may not have been adequate: o Each entry employer must have a competent person reevaluate that space and, if necessary, reclassify it as a permit required confined space. PPT-136-01 68

1926 General Requirements (g) Spaces classified by an employer as a PRCS may only be reclassified as a non-permit confined space when a competent person determines that all of the applicable requirements in paragraphs §1926.1203(g)(1) through (g)(4) have been met: (h) Prior to entry, host employer provides o Locations o Hazards or potential hazards of each space o Precautions implemented by previous: Controlling contractor Entry contractor PPT-136-01 69

1926 General Requirements Before entry the controlling contractor must: o Obtain the host employer’s information o Provide information to entrants: Host information Additional information from controlling contractor Precautions which both have implemented PPT-136-01 70

1926 General Requirements Before entry each entry employer must: o Obtain all of the controlling contractor’s information o Inform the controlling contractor of the permit space program that the entry employer will follow o Include any hazards likely to be found or created in each space PPT-136-01 71

1926 General Requirements (4) Controlling contractor and entry employer(s) must coordinate entry operations when: (i) More than one entity performs permit space entry at the same time; or (ii) Permit space entry is performed at the same time that any activities that could foreseeably result in a hazard in the permit space are performed. PPT-136-01 72

1926 General Requirements 1203(5) After entry operations, controlling contractor: o Debriefs each entrant o Informed by entry employer of any hazards found o Apprises host employer of information exchanged with entrants per this subparagraph. PPT-136-01 73

1926.1204: PRCS Program (a) Prevent unauthorized entry; (b) Identify/evaluate hazards of permit spaces before entry (c) Develop/implement means, procedures, and practices for safe entry operations, including, (1) Acceptable entry conditions; (2) Allow entrants to observe any monitoring or testing (3) Isolate physical hazard(s) within the space; (4) Purging, inerting, flushing, or ventilating to eliminate or control atmospheric hazards; *(see notes for detailed information) PPT-136-01 74

1926.1204: PRCS Program (5) Determining that, in the event the ventilation system stops working, the monitoring procedures will detect an increase in atmospheric hazard levels in sufficient time for the entrants to safely exit the permit space; (6) Providing pedestrian, vehicle, or other barriers as necessary to protect entrants from external hazards; PPT-136-01 75

1926.1204: PRCS Program (7) * Verifying that conditions in the permit space are acceptable for entry throughout the duration of an authorized entry, and ensuring that employees are not allowed to enter into, or remain in, a permit space with a hazardous atmosphere unless the employer can demonstrate that personal protective equipment (PPE) will provide effective protection for each employee in the permit space and provides the appropriate PPE to each employee; and (8) Eliminating any conditions (for example, high pressure) that could make it unsafe to remove an entrance cover. * See notes for additional information PPT-136-01 76

1926.1212: Employee Participation (a) Employers must consult with affected employees and their authorized representatives on the development and implementation of all aspects of the permit space program required by §1926.1203 of this standard. (b) Employers must make available to each affected employee and his/her authorized representatives all information required to be developed by this standard. PPT-136-01 77

Bottom Line o Be aware of the location of all Confined Spaces in your facility. o Ensure you’re familiar with the hazards of these Confined Spaces. o Don’t enter a Permit Required Confined Space until all the safety conditions have been met and you’re wearing the proper PPE. o Before entering a PRCS, ensure reliable and trained personnel are available to perform rescue if the need arises. PPT-136-01 78

Contact Information Health & Safety Training Specialists 1171 South Cameron Street, Room 324 Harrisburg, PA 17104-2501 (717) 772-1635 [email protected] Like us on Facebook! https://www.facebook.com/BWCPATHS PPT-136-01 79

Questions PPT-136-01 80

Bibliography 29 CFR 1910.146 Permit-Required Confined Spaces for General Industry. 29 CFR 1926.1200 Confined Spaces for Construction. 29 CFR 1926.57-Ventilation. 29 CFR 1926.103-Respiratory protection. 29 CFR 1910.147-Lockout/Tagout PPT-136-01 81

Other Suggested Programs The following presentations are also available to supplement your in-house program: o o o o o Basic Air Monitoring Excavation & Trenching Lock-out/Tag-out Ventilation-Basic Work Zone Safety Please contact us for a full list of other programs available to you free of charge. PPT-136-01 82