Cal/OSHA Confined Space Emphasis Program Overview What is the 2012 Confined Space Emphasis Program? Every Cal/OSHA inspection will look for and identify potential confined spaces. Examples of Confined Spaces: Tanks Boilers Vats Kilns Vaults Silos Pipelines Sewers Compartments Manure pits Storage bins Double hulls Pumping stations Pits, sumps Vessels Manholes Water reservoirs Ducts 1
What is the 2012 Confined Space Emphasis Program? If there are confined spaces: Review written Confined Space Program. Review procedures / documentation / records. Review alternate entry and/or reclassification procedures if applicable. Review rescue procedures. Audit last 6 months permits for Permit Required Confined Space entry. Audit last 6 months certificates of reclassification. Two Different Confined Space Regulations 5156 Scope and Application (between 5157 and 5158) 5157 Permit Click to Required edit Master subtitle Confined style Space 5158 Other Confined Spaces 5156 Scope and Application 5158 Other Confined Spaces shall apply to: Construction 1502 Agriculture 3437 Marine terminal 3460 Telecommunication manholes/vaults 8616 Grain handling facilities 5178 Natural gas utility operation (within distribution and transmission facility vaults) Electric utility operations within underground vaults 2700 Confined and Enclosed Spaces and Other Dangerous Atmospheres for Ship Building, Repairing & Breaking 8355 2
Let s start with - Other Confined Spaces T8 CCR 5158 Other Confined Spaces T8 CCR 5158 (a) Implementing a permit required confined space program in accordance with section 5157 shall meet the requirements of this section. Other Confined Spaces 5158 (b) Definitions Confined Space Concurrent existence of : Existing ventilation insufficient to remove dangerous air contamination, oxygen enrichment and/or oxygen deficiency which may exist or develop; AND Ready access or egress for removal of suddenly disabled employee difficult due to location and/or size of opening(s). 3
Other Confined Spaces 5158 (b) Definitions Dangerous Air Contamination: Atmosphere presenting threat of causing death, injury, acute illness, or disablement due to presence of flammable and/or explosive, toxic, or otherwise injurious or incapacitating substances. >20% LFL flammables > 20% LFL combustible dusts IDLH concentration of toxics (not PEL, STEL or ceiling) < 19.5% Oxygen or > 23.5% Oxygen Other Confined Spaces 5158 (c) (c)(1)operating Procedures (A) Written, understandable operating and rescue procedures (B) Survey surrounding area for hazards such as drifting vapors from tanks, piping and sewers. (C) For multi-employer worksites, address how employers will coordinate their work activities (c)(2) Employee Training in operating and rescue procedures Other Confined Spaces 5158(e) Hazardous Atmosphere Present Confined spaces with side and top openings entered from side openings when practicable (within 3.5 ft of bottom) Appropriate respiratory protective equipment provided and worn. Approved safety belt with attached line used except where safety belt would endanger employee. At least one employee stand by on outside of confined space ready to give assistance in case of emergency. At least one additional employee who may have other duties be within sight or call of standby employees. 4
An Example: Grain Facilities 5178 Grain Facilities Oxygen, LEL, & combustible dust testing prior to entry Lockout energy sources prior to entry. Employees who walk on stored grain shall be equipped with harness & lifeline. With attendant and rescue equipment. End of 5158 Other Confined Spaces Any quick questions before we start 5157 Permit Confined Space? 5
And now - 5157 Permit-Required Confined Spaces 5157 (b) Definition Confined Space: 1. Is large enough to enter; and 2. Has limited/restricted means of entry or exit; and 3. Is not designed for continuous employee occupancy Interpretation of Restricted Entry / Exit Does person have to use hands to enter/exit space? Is person in awkward posture when entering or exiting space? Is person s entry into or exit from space slowed down/impeded by physical obstructions (pipes, ductwork, walls, holes in floor, flanges, etc.)? Would employee be forced to enter/exit in posture that might slow self-rescue or make rescue more difficult? Would rescuers need special equipment in order to reach or retrieve entrant? 6
5157 (b) Definition: Permit Required Confined Space A confined space that has one or more of following characteristics: Click to edit the Engulfment outline text format Hazardous Entrapment atmosphere Second Outline - <19.5% Oxygen Energy Levelsources - > 23.5% Oxygen - electrical - >10% LFL (G/V) Third Outline - mechanical Level ->LFL (Comb. Dust) - hydraulic Fourth - IDLH - pneumatic, Outline etc. - >PEL (Acute) Level Steam Fifth Corrosives, etc. Outline L l Or Any Other S&H Hazards... Energized Electrical Equipment HEAT STRESS! Unguarded Mechanical Equipment Biohazards Noise? Radiation 5157 (b) - Definition Non-Permit Confined Space does not contain or, with respect to atmospheric hazards, have potential to contain, any hazard capable of causing death or serious physical harm. 7
Causes of Hazardous Atmospheres Product stored in a confined space: Gases released when cleaning. Materials absorbed into walls of confined space. Decomposition of materials in the confined space. Work performed in a confined space: Welding, cutting, brazing, soldering. Painting, scraping, sanding, degreasing. Sealing, bonding, melting. Areas adjacent to a confined space. Piping connections. Leaks. Air Sampling Considerations Horizontal Entries Air monitoring at opening only is insufficient Suction Fans must be off during air monitoring Sampling Order: 1. Oxygen 2. Flammables/Explosives 3. Toxics 8
An Actual Refinery Fatality Exterior Welding O2 << 19.5 % Fans O2 normal Suspect O2 Deficiency When Space has been closed up, sealed or not ventilated before entry. Has contained inerted atmosphere or has been purged. Contains any amount of water or organic material. Metal Oxidation - rusting. Combustion processes. Displacement by other gases. Coatings, sludges, materials with cure and/or absorb oxygen - activated charcoal. Testing The Atmosphere Sampling Specific Gravity Methane: 0.55 Lighter than air gases Ammonia: 0.59 Carbon Monoxide: 0.96 Nitrogen: 0.97 Air: 1.0 Hydrogen Sulfide: 1.2 Carbon Dioxide: 1.5 Gasoline: 3-4 Jet Fuel, JP-8: 4.7 Heavier than air gases So...Must test at multiple levels within space! 9
5157 (b) Definition Entry Entry occurs as soon as any part of the entrant s body breaks the plane of opening into space including all extremities (hands or feet). 5157 (C) - GENERAL REQUIREMENTS FOR PERMIT REQUIRED CONFINED SPACES 5157(c)(1) Identify Confined Spaces in Workplace * Space large enough to enter &; NO * Limited or Restricted entry or exit &; * Not designed for continuous worker occupancy YES Confined Space Not a Confined Space Permit- Required Confined Space YES Hazardous Atmosphere Or Engulfment Hazard Or Configuration Hazard Or Any other recognized Serious Hazard NO Non Permit Required Space 10
5157(c)(2) & (3) - Inform Employees & Ensure No Entry By posting danger signs or by any other equally effective means, of the existence, location of and the danger posed by the permit spaces. If employer decides that nobody will enter permit spaces: (c)(1) Identify Confined Spaces (c)(2) Inform Employees (c)(6) Re-Evaluate Non-permit Confined Spaces as necessary (c)(8) Inform Contractors Options for Confined Space Entry 5157 (c)(4) Permit space entry (c)(5) Alternate entry procedures (c)(7) Reclassify permit space to non-permit space Alternate Entry Procedures 5157 (c)(5) Employees who enter permit space need not comply with subsections (d) through (f) and (h) through (k) (leaves only (g): training requirement) provided: Only hazard is actual/potential hazardous atmosphere ücontinuous forced air ventilation alone is sufficient to ensure safe atmosphere at all times üverification (comprehensive air testing, isolation, energy control measures, etc.) & Written Certification by employer that space is safe at all times üemployees observe pre-entry air testing ümany additional requirements 11
Reclassification as Non-Permit Required Confined Space 5157 (c)(7) If permit space poses no actual or potential atmospheric hazards and if all hazards within space are eliminated without entry into space, permit space may be reclassified as non-permit confined space. The employer shall document that all hazards in a permit space have been eliminated Documentation made available to employees Introduction of Hazards... permit spaces into which hazards (such as welding or toxic or flammable cleaning materials) are introduced during entry need protection afforded by a complete permit space program in order to assure that all measures, in addition to ventilation, necessary for protection of entrants are followed OSHA Interpretation Correct Lockout/Tagout acceptable for electro-mechanical hazards. Lockout/Tagout does not eliminate hazards from flowable materials such as steam, natural gas, and substances that can cause hazardous atmospheres or engulfment hazards. In a confined space these hazards can be eliminated only by isolation. Ex: blanking, blinding, misaligning or removing sections of lines or pipes and a double block and bleed system. 12
Blanking or Blinding Double Block and Bleed System close d close d ope n Requirements of 5157(d) Confined Space Program (1) Prevent unauthorized entry (2) Identify and evaluate hazards of permit spaces before EEs enter (3) Implement means, procedures & practices for safe entry (4) Provide, maintain, & ensure proper use of equipment (5) Testing of space (6) & (7) Attendant requirements (8) - Designate roles (9) Rescue & emergency procedures (10) & (12) - Permit system (11) Coordinating when more than one ER has EEs (13) - Review entry operations 13
5157 (e) & (f) - Permits 5157(f) - Entry Permit Entry permit to identify: ü Hazards ü Measures to isolate to eliminate or control hazards \ ü Acceptable entry conditions; ü Results of initial and periodic tests ü Rescue/emergency services provided on-site and additional service that can be summoned and numbers to call ü Communication procedures used by entrants and attendants to maintain contact; ü Equipment, such as PPE, testing equipment, communications equipment, alarm systems, and rescue equipment, to be provided 5157(g), (h), (i), (j) - Training 14
Training Requirements 5157 (g) - General Requirements 5157 (h) Authorized Entrants 5157 (i) Attendants 5157 (j) Entry Supervisors 5157 (k) - Rescue Rescue & Emergency Services 5157 (k) Employer shall ensure at least one standby person at the site is trained and immediately available to perform rescue and emergency services. Goal: 4 minute Rescue Response. Practice simulated rescue operations at least every 12 months in actual space or representative spaces based on opening size, configuration, and accessibility. A rescue plan that consists of call 911 or relies fi d i l i 15
Commonly Cited Sections Evaluate and Posting Spaces 5157(c)(1) --- Written Procedures 5157(c)(4) 5158(c)(1)(A) Atmospheric Testing 5157(d)(5) 5158(d)(3) Ventilation (if required) 5157(c)(5)(B) 5158(d)(6) (5) Rescue Procedures 5157(d)(9) 5158(c)(1) Training 5157(g)(1) 5158(c)(2) End of 5157 Permit Confined Spaces Any questions on 5157 Permit Confined Spaces or 5158 Other Confined Spaces? Not the End Just the beginning. 16