Confined Space Training Regulations are changing New rule eliminates the distinction between a permitrequired confined space (permit space) and a non permitrequired confined space. Under this rule, a space with no actual or potential hazards is a confined space. A space with actual or potential hazards is a permit-required i confined space. Also eliminated and combined the frequently confusing language g of alternate entry and permit space reclassification. Under the new regulations, a permit space is always a permit space, and can only be entered with a permit or under Alternate Entry Procedures.
Who must comply? All workplaces must be evaluated to determine if there are any confined spaces on site, and if any of those spaces are permit spaces.
Biggest Change? ALTERNATE ENTRY PROVISIONS The space is still classified as permit required confined space but alternate methods are allowed for entry. Alternate entry is allowed when all hazards have been eliminated, or all physical hazards are eliminated and all atmospheric hazards are controlled with constant ventilation and checked/verified with constant monitoring.
ALSO REQUIRED UNDER ALTERNATE ENTRY PROVISIONS: The entrant must have an effective means to communicate with others outside of the space to summon help if necessary Example: cell phone or radio
Employee Training Required Awareness training is required for all employees who work around permit spaces so they can: Readily identify permit spaces Understand the process for how those spaces are entered, and Understand their hazards.
Hazards of Confined Spaces Basic Principles Confined spaces can be deadly Some confined spaces are more hazardous than others Confined space conditions can change rapidly from no hazards to life-threatening hazards Some confined spaces are so hazardous, a written permit system is required for entry. These spaces are Permit Required Confined Spaces (PRCS) The hazards of confined spaces can often be controlled or eliminated before entering
Examples of Confined Spaces Compactor Tubes Utility Vaults & Manholes Truck Hopper Some Pits Tanks & Boilers
What is a Confined Space? A confined space is a space that: 1. Is large enough to get the whole body inside, id AND 2. Has limited means of entry or exit, AND 3. Is not designed edfor continuous employee occupancy It must have all three characteristics to be a confined space.
Confined Space 1. Is large enough and so configured that an employee can get their whole body inside and perform work NO YES
Confined Space 2. Has limited or restricted entry or exit The ability to easily escape is impeded by such obstacles as: a small door or opening a ladder a manhole a long tunnel Or
Confined Space a drop to a lower level Yes No Maybe
What is a Permit Required Confined Space (PRCS)? A PRCS is a confined space PLUS it: Contains or has the potential to contain a hazardous atmosphere, and/or Contains a material that can engulf someone in the space, and/or Has an internal configuration that can trap or asphyxiate (inwardly converging walls or a floor which tapers to a smaller cross section) and/or Contains any other serious safety or health hazard such as moving parts or electricity. Only one of these needs to be present for the space to be Only one of these needs to be present for the space to be classified as Permit Required Confined Space.
Hazard Identification Atmospheric hazards include: Oxygen deficient atmosphere (depletion by rusting or replacement by other gases) Flammable atmospheres Carbon monoxide, hydrogen sulfide or other toxic materials
Hazard Identification Hazardous Atmospheres Carbon Monoxide (CO) Carbon monoxide comes from operating internal combustion engines in or near confined space. Propane-powered engines also emit carbon monoxide. Fatal levels of CO are quickly reached in confined spaces. Generators, heaters & vehicle exhaust Propane-powered manlift in a large tank
Hazard Identification What are the Hazards of Engulfing Material? Engulfing materials include liquids or loose solids such as grain, sand or other granular material. People cannot escape when caught in moving loose solids and usually suffocate. Workers often get engulfed when in-feed or out-feed lines are inadvertently opened or activated.
Hazard Identification What is Entrapment? The space is configured in a way that can trap a worker, for example, sides sloping towards the center Gravel hopper Sawdust Cyclone
Hazard Identification Other Recognized Hazards Potential contact with live electrical or steam lines Mechanical hazards (moving parts-blade) Hazards caused by the work Hazards caused by the work (welding, painting etc.)
What makes this a Permit Required Confined Space?
What makes this a PRCS?
Is this a PRCS?
Employer Responsibilities Actions we need to take to protect our employees and meet regulatory requirements under 1910.146, 146 Permit Required Confined Spaces: 1. Evaluate the workplace to identify PRCS (see form) 2. Post signs at the PRCS 3. Determine if your employees must enter the PRCS ALTERNATE ENTRY can be used if all hazardous energy can be controlled (lockout/tagout) and if there is no hazardous atmosphere. NOTE: If hazards cannot be eliminated, a written Permit Required Confined Space Program is required and you should consult with an expert. 4. Ensure you have written procedures for locking out each piece of equipment as required by OSHA regulation 1910.147, The Control of Hazardous Energies. 5. Train your employees on your policy, identification of confined spaces, control of fhazardous energies, and your Alternate t Entry process.
Confined Space Survey
Hazard Assessment of Truck Bodies For post-trip trip cleaning, under normal solid waste collection activities with daily truck emptying, we have determined that there is no potential for a hazardous atmosphere inside packer bodies after the load has been removed. If the load has been emptied and all physical hazards have been eliminated by following proper lockout, the truck body may then be entered using Alternate t Entry.
Example Company Policy We have surveyed our equipment and facilities and identified the following as Permit Required Confined Spaces: Hopper of Trucks It is the policy of this Company to NOT ALLOW ENTRY into Permit- Required Confined Spaces by ANY employees. Truck hoppers are considered PRCS until the load is emptied and lock out procedures are performed to remove the mechanical hazard from the packer. When proper lockout is performed and documented, the truck hopper can be entered under Alternate Entry. Employees must have an effective means to communicate with others outside of the space to summon help if necessary Before entry into a truck body for cleaning or maintenance, all employees are required to follow Company Procedures for locking out (control of hazardous energies) and Alternate Entry to the Permit Required Confined Space.
Eliminating the Hazard from the Truck Hopper Before Entering for Cleaning Remove keys from ignition Place keys in your pocket Turn off battery switch Apply unique lock to battery switch if another key to the vehicle is available Rdi Radio in pocket kt When finished cleaning, complete and sign Alternate Entry form
Controlling the Space Warning employees and controlling access Post warning signs at the entrance of confined spaces. Limit employee access to confined spaces by using entry barriers or locks. Make sure that unauthorized workers do Make sure that unauthorized workers do not enter the confined space.
Documentation Alternate Entry may be used to enter a confined space if the space poses no actual or potential atmospheric hazards and all hazards are eliminated without entry into the space. Alternate Entry requires that the employee have the ability to communicate with others outside of the space (cell phone or radio).
Sample of Alternate Entry Form Alternate t Entry for Drivers: Fill in the blanks or circle the correct answer 1. Today s Date: Entry time: Stop Time: 2. Space to be entered: Truck # Hopper 3. Purpose of the entry Cleaning 4. Hazards of the space: Crushing 5. Acceptable Entry Conditions Met? Lock out Verified? Keys removed battery switch off 6. Radio in pocket 7. Any Issues? 8. Employee Signature
Other Requirements Under 1910.147, Control of Hazardous Energies you must conduct periodic inspections (at least annually) of your energy control procedures. The employer must train and certify that employees have been trained. Employees must be retrained and proficiency re-established when there are changes or inadequacies.
Hazard Control Controlling Hazardous Atmospheres If you have a space with a potential atmospheric hazard - consult an expert!!! Drain or pump out liquid contents, if any. Blank off all in-feeding lines. Air test and ventilate. Continue ventilating constantly. tl If possible, remove any sludge while staying outside the space. Exit space if conditions deteriorate.
Confined Space Quiz Question 1 Which of following are considered Permit Required Confined Spaces? a) The hopper of a front end loader b) A sub-basement b vault with ladder access c) A 20 foot deep ditch d) A 40 yard drop box
Confined Spaces Quiz Question 2 Which of the following is PRCS? a) The hopper of a front end loader b) A sub-basement vault with ladder access c) A 20 foot deep ditch d) A 40 yard drop box