Confined Space (IET) Increased Exposure Training

To train on permit-required confined space definitions, hazards, and safety procedures. The result should be greater understanding of permit-required confined spaces' risks and safety rules.

Suggested Materials to Have on Hand:

• Sample confined space permit
• Air-testing instruments
• Confined space warning signs and barriers
• Any respirators used in confined spaces
• Communications and retrieval equipment used in permit-required confined spaces

Introduction/Overview

OSHA defines a confined space as one whose size and shape allows an employee to enter and perform assigned work. It's not designed to be occupied continuously and has limited or restricted means for getting in and out.

Many workplaces have confined spaces that meet this definition, such as tanks, storage bins, vessels, silos, hoppers, vaults, and pits. No one enjoys working in these areas, but it's sometimes necessary to perform repairs, maintenance, and other tasks.

Confined spaces can be awkward and uncomfortable work areas. Not only that hazards is generally more hazardous when they're in confined spaces. That's why OSHA requires special precautions and even permits for most confined space tasks. We'll review those today.

General Hazards

OSHA identifies several confined space hazards considered so serious they actually make up the definition of a permit-required confined space. To enter these spaces, you need a proper permit and specific precautions.

A permit-required confined space is one that has—or has the potential for—one or more of these hazards:

1. A hazardous atmosphere that could cause a person inside to become ill, incapacitated, unable to escape without aid, or even to die. The atmosphere may be hazardous due to:

• Flammable gas, vapor, or mist levels more than 10 percent above the substance's lower flammable limit.
• Airborne combustible dust at or above the substance's lower flammable limit, making it hard to see things less than five feet away.
• Atmospheric oxygen concentration below 19.5 percent or above 23.5 percent. Just 16 percent oxygen can make you drowsy, nauseated, and speed up breathing and heartbeat. At 12 percent, you'll lose consciousness; a 6 percent oxygen level will kill you.
• Any other atmospheric condition immediately dangerous to life or health (IDLH)a condition that threatens life, could cause irreversible health problems, or limit your ability to escape the space without help.

1. Engulfment potential applies to a space that contains a liquid or a flowing solid (such as sand or grain) that could immerse and bury or smother you.
2. Entrapping design refers to walls that converge inward or a floor that slopes and tapers down. In a space like that, you could slip or fall into an area too small to escape from or get pushed into machinery.
3. Any other recognized serious health or safety hazard. They could include:

• If something can burn or explode, it is more likely to do so, and do it instantly, in a confined space.
• If you fall in a confined space, you could get trapped or asphyxiated, especially if the space has too little oxygen or contains toxic gases.
• Heat can build up quickly in a confined space, making you tired, dizzy, and ill.
• Sounds reverberate in a confined space, and you could fail to hear important instructions or warnings.

OSHA Regulations

These definitions appear in OSHA's permit-required confined space regulation (29 CFR 1910.146), which also requires employers to:

• Identify and test the atmosphere in such spaces in their workplaces
• Allow work in such spaces only when they meet listed criteria and have a permit listing specific information about the space and the entry.
• Train employees to safely perform permit-required confined space tasks.
• Develop safety procedures, including rescue plans and personnel.

OSHA assigns several roles to employees for permit-required confined space jobs.

Authorized entrants are assigned and trained to work in a permit-required confined space.

Attendants stay outside the space to monitor, and maintain contact with, authorized entrants.

Entry supervisors decide if conditions are safe enough for workers to enter the space. They authorize and oversee the work. They also stop it and cancel the permit when the operations listed on the permit are done or when a condition not covered by the permit arises in or near the space.

Rescue and emergency services must be available.

We'll talk more about these roles shortly.

OSHA revised this standard in 1998 to give employees a chance to play a greater, more knowledgeable role in their own safety. The revisions specifically:

• Direct employers to "consult with affected employees and their authorized representatives" on developing and enacting all aspects of their permit-required confined space programs and make all OSHA-required information available to them.
• Allow employees or their authorized representatives to observe any testing or monitoring of the atmosphere in the permit-required confined space and provide them with information on the results.

The revisions also help employers evaluate potential rescue services to use for permit-required confined space situations.

Identifying Hazards:

Any confined space presents dangers, even if it doesn't require a permit. Always expect the unexpected in a confined space. And learn all you can about what is  expected.

Employers must identify their workplace's confined spaces that require permits and take actions to reduce the risks of working in these spaces. They must:

• Post signs or other warnings to alert employees to the specific space's dangers.
• Use barricades or other means to keep unauthorized employees out of permit-required spaces.
• Develop and follow a written confined space entry program in consultation with affected employees or their authorized representatives.
• Test the atmosphere in the space to identify and evaluate its hazards, observed, if desired, by authorized entrants or their representatives.
• Determine and state conditions that allow safe space entry and verify that those conditions will be maintained while anyone works in the space.
• Flush, ventilate, or otherwise eliminate or control atmospheric hazards before allowing anyone into the space.
• Retest the atmosphere in the space before workers enter it, with the authorized entrant or his or her authorized representative allowed to observe.
• Complete and post a permit that identifies the space's hazards and limitations on working there.

Protection Against Hazards:

The best protection against confined space hazards is the permit and the information it contains. A completed, signed, and posted or easily available permit is required before anyone can enter a permit-required confined space. Every authorized entrant, attendant, or entry supervisor should read the permit carefully before starting any task related to the space. It identifies:

• The specific space
• Date, purpose, and authorized length of entry
• Authorized entrants, attendant, and entry supervisor
• The space's hazards, including test results and measures used to control or eliminate the hazards.

• Acceptable conditions for entering the space
• Equipment to be used in the space (e.g., PPE, ladders to get in and out, lighting, ventilating, testing and monitoring, rescue or retrieval equipment)
• Rescue services and their phone number(s)
• Other special information or additional permits (e.g., hot work)

To protect employees, the atmosphere in the space is not only tested before they enter. It's tested periodically while they're working in the space and if any authorized entrant or his or her authorized representative expresses concern that a prior evaluation may have been inadequate.

OSHA even tells us the order in which the spaces possible hazards are tested, with a calibrated direct-reading instrument. We test first for oxygen content, then for flammable gases and vapors, and last for potential toxic air contaminants. And, of course, affected employees have access to all these test results.

In addition to these protections, OSHA requires employers to:

• Have at least one trained attendant outside an occupied permit space.
• Develop and implement a system for handling rescues or other emergencies in the space.
• Coordinate procedures with any contractors or other employers involved in the confined space task.
• Review the confined space program at least annually and after any injury, near miss, unauthorized entry, or other problem.

Safety Procedures:

OSHA also requires employers to train workers with confined space roles so they have the "understanding, knowledge, and skills necessary for the safe performance of the duties assigned." Training occurs when:

• A worker is assigned to confined space duties
• A new confined space hazard develops
• A trained employee isn't following safety procedures

 Employee Roles:

Authorized entrants don't go into a permit space until its air is tested and found safe. But once in, you have to stay alert for any change in conditions. Be familiar with the potential hazards listed on the permit and the signs and symptoms of lack of oxygen, fire risk, toxins, etc.

Authorized entrants also must know what equipment to use—and how to use it. That includes personal protective equipment, tools needed for the task, equipment to communicate with the attendant, and some kind of personal retrieval system.

OSHA says each authorized entrant has to use a chest or full body harness attached to a retrieval line. A wristlet system may be used only if the employer can demonstrate that the other systems are impractical or dangerous.

Even with all the protections, you should try to complete work inside a permit space as quickly and efficiently as possible. Notify the attendant immediately of any condition that's not permitted in the space, or if you have symptoms like dizziness, weakness, etc.

 If you think there's trouble—or if the attendant gives an order or alarm—leave the space immediately. If you can't get out yourself, say so and wait for rescue.

Attendants must be on duty outside any occupied permit space. An attendant must study the permit to understand the space's potential hazards and the signs and symptoms of trouble. If you're an attendant, your job is crucial. You:

• Monitor and count who's in and outside the space.
• Stay in contact with authorized entrants in the space.
• Keep unauthorized people away from an occupied space.
• Order immediate evacuation of the permit space if:

                        —The authorized entrant shows signs of hazardous exposure

                        —You can't perform the attendant duties safely

                        —A situation outside the space could endanger workers in it

• Summon authorized rescue and emergency services when needed to evacuate workers from the space.

The entry supervisor oversees the permit-required space operation. This person makes sure testing and other permit requirements are met, then signs the permit so workers can enter. The entry supervisor's other responsibilities are to:

• Be familiar with the hazards in the space.
• Make sure the rescue and emergency service is available.

• End work in the space and cancel the permit when the task is completed or when conditions develop that make the work unsafe.

The rescue and emergency service people are also key players, though everyone hopes they're not needed. They may work for the employer or an outside service. But it's up to the employer with the permit-required confined space to be sure the rescuers are ready, willing, and able to handle their vital responsibilities.

An employer that uses an outside service must:

• Be sure they can respond quickly and properly to a rescue summons.
• Explain the potential hazards.
• Check that they have and can properly use the necessary rescue equipment.
• Provide access to permit-required confined spaces so rescuers can develop and practice rescue plans.

An employer that uses its own employees for rescue should:

• Provide the necessary PPE and the training to use it properly.
• Provide training on how to perform rescue duties, including all the training required for authorized entrants.
• Assure that at least one rescuer is certified in first aid and CPR.
• Require practice rescues in actual permit spaces, using people or dummies or, if necessary, simulations.

Safety Tips:

You need knowledge and safety sense to perform tasks in and around permit-required confined spaces. Remember that you have the right and obligation to help develop and implement the permit space program. In other words, you're responsible for knowing the hazards, plus the procedures that keep you and your co-workers safe. Participate in training and apply what you learn. Also keep these basic safety precautions in mind:

• Plan your task and assemble your equipment so you can do your work in the space quickly and efficiently.
• Be sure any steam, water, heat, or power lines going into the space are cut off and locked and tagged.
• Don't enter the space if you aren't feeling well or have been using alcohol or any kind of drugs.

• Don't take food, drinks, or cigarettes into the space.
• Keep the space ventilated.
• Pay close attention to how you're feeling.
• Leave the space immediately if you have trouble breathing, feel tired, dizzy, nauseated, etc.

That last point is all-important. In a matter of moments, oxygen deficiency or asphyxiation can kill you. So if you have any hint of trouble, alert the attendant and get out. If you can't get out yourself, call the attendant to get help. But act quickly!

Suggested Discussion Questions

1. What are the characteristics of a permit-required confined space?
2. What are some examples of confined spaces here?
3. What information would you look for on a permit?
4. What preparations would you make before entering a confined space?
5. Why is it so important that confined space jobs always have trained rescue personnel available?
6. What are the purposes of having an attendant on duty when work is performed in a confined space?
7. What is the role of an entry supervisor?
8. What does an authorized entrant have to know?
9. What are the reasons for leaving a confined space before the task is completed?
10. Are there any other questions?

Wrap-up:

Sometimes we have to perform work in confined spaces that are potentially hazardous. OSHA's permit system gives us a way to identify the confined space hazards and to perform our jobs in ways that reduce the chance of harm.

As with all workplace hazards, however, a safety regulation isn't enough. Every person involved in a confined space task has to take the hazards, and their own responsibilities, seriously. We can't afford to skip any steps, ignore any hazards, or be less than fully alert.