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Subpart J Confined Spaces 29 CFR 1910.146 Background OSHA estimates 239,000 general industry establishments employing over 12 million workers have confined.

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Presentation on theme: "Subpart J Confined Spaces 29 CFR 1910.146 Background OSHA estimates 239,000 general industry establishments employing over 12 million workers have confined."— Presentation transcript:


2 Subpart J Confined Spaces 29 CFR 1910.146

3 Background OSHA estimates 239,000 general industry establishments employing over 12 million workers have confined spaces More than 4.8 million Permit Required Confined Spaces and millions more non-permit confined spaces Over 30 different industries are affected by the hazards of confined space entry BLS(2002) reports an average of 20 fatalities per year from confined space hazards

4 What kills people in confined spaces? They _________ from lack of oxygen. They are exposed to _________ chemicals. They are killed by ______ or ________. They are __________ by cave-ins. They are __________ by unstable material. They sustain _______ injuries from falls. They are ______ __ objects or equipment.

5 What kills people in confined spaces? They suffocate from lack of oxygen. They are exposed to toxic chemicals. They are killed by fire or explosions. They are crushed by cave-ins. They are engulfed by unstable material. They sustain fatal injuries from falls. They are struck by objects or equipment.

6 Why do we have a confined space standard? –122 confined space accidents each year lead to 173 fatalities Why? –60% of the fatalities occurred during rescue attempts

7 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” Why? (continued)

8 Chronology of 29 CFR 1910.146 Advanced Notice of Proposed Rulemaking (ANPR) for General Industry July 24, 1975 and Oct 19, 1979 ANPR for Construction Industry March 25, 1980 Public Meetings held May, 1980 in Houston, Denver and Washington, D.C. General Industry Proposed Standard June 5, 1989 Hearings held Nov 14 & 15, 1989 in Washington, D.C., Dec 5 & 6, 1989 in Houston and Jan 30 - Feb 1, 1990 in Chicago Public Record closed November 9, 1990 Final Rule published Jan 14, 1993; effective April 15, 1993 Final Rule changes published December 1, 1998; effective February 1, 1999

9 General Industry Standard 29 CFR 1910.146 –(a) Scope –(b) Definitions –(c) General Requirements –(d) Permit-Required confined space program –(e) Permit system –(f) Entry permit –(g) Training

10 General Industry Standard 29 CFR 1910.146 –(h) Duties of authorized entrants –(i) Duties of attendants –(j) Duties of entry supervisors –(k) Rescue and emergency services –(l) Employee participation

11 General Industry Standard 29 CFR 1910.146 Appendices –Appendix A – Permit-required confined space decision flow chart –Appendix B – Procedures for atmospheric testing –Appendix C – Examples of permit-required confined space programs –Appendix D – Confined space pre-entry checklist

12 General Industry Standard 29 CFR 1910.146 Appendices –Appendix E – Sewer system entry –Appendix F – Rescue team or rescue service evaluation criteria (non-mandatory)

13 December 1, 1998 Changes Authorized representatives Observation of testing Clarified paragraph (k) Added paragraph (l) Added Appendix F

14 Scope and application - (a) 29 CFR 1910.146 does not apply to: –Agriculture –Construction –Shipyards

15 Degreaser, Furnace Pit, Pumping Station Septic Tanks, Sewage Digestors Silos, Barges Manholes Trenches, Shafts Common Confined Spaces

16 How to Identify Confined Spaces 1. Limited Openings for Entry and Exit; and 2. Is large enough and so configured that an employee can bodily enter and perform assigned work; and 3. Not Designed for Continuous Worker Occupancy


18 Federal Register Jan 14, 1993 (p. 4477) “While OSHA is concerned that spaces that are too small for complete bodily entry may pose hazards for employees, the Agency did not intend to cover such spaces under the permit space standard.”

19 “Limited - when an employee would be forced to enter or exit in a posture that might slow self- rescue or make rescue more difficult.” Federal Register Nov. 4, 1994 (p. 55208) Standard Safety Requirements for Confined Spaces (ANSI Z117.1-1995) “Restricted entry and exit means physical impediment of the body, e.g., use of the hands or a contortion of the body to enter into or exit from the confined space”.




23 Federal Register Nov. 4, 1994 (p. 55208) “For example, even if the door or portal of a space is of sufficient size, obstructions could make entry into or exit from the space difficult. The Agency intended that spaces which otherwise meet the definition of confined spaces, and which have obstructed entry or exits even though the portal is a standard size doorway, be classified as confined spaces.”

24 Questions to Ask Does the person have to use their hands to enter or exit the space? Is the person in an awkward posture when entering or exiting the space? Is a person’s entry into or exit from the space slowed down or impeded by physical obstructions (such as pipes, ductwork, walls, holes in the floor, flanges, etc.)? Would an employee be forced to enter or exit in a posture that might slow self-rescue or make rescue more difficult?

25 Federal Register Jan 14, 1993 (p. 4478) OSHA believes that the final rule’s definition properly places the focus on the design of the space, which is the key to whether a human can occupy the space under normal operating conditions.

26 Worker entered by ladder – is this a C/S?



29 Dust Collector



32 To Underground Tunnel

33 Presence of all three confined space characteristics can complicate the situation. Working in and around the space. Rescue operations during emergencies. 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 Dangerous Combinations

34 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 an 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. Permit Required Confined Space

35 1.Hazardous atmospheres 2.Engulfment 3.trapped or asphyxiated by an inwardly converging walls or by a floor 4.Contains any other recognized serious safety or health hazard Confined Space Permit Required Confined Space VS 1.Limited Openings for Entry & Egress 2.Large enough to bodily enter and perform work 3.Not designed for continuous worker occupancy

36 Hazardous Atmosphere Means an atmosphere that may expose employees to the risk of death, incapacitation, impairment of ability to self-rescue (escape from a permit space), injury, or acute illness from one or more of the following causes:

37 Hazardous Atmosphere 1.Flammable gas, vapor, or mist in excess of 10% of its lower flammable limit (LFL); 2.Airborne combustible dust at a concentration that meets or exceeds its LFL; 3.Atmospheric oxygen concentration below 19.5% or above 23.5%; 4.Atmospheric concentrations of any substance for which a dose or PEL is published in Subpart G or Z of this Part and which could result in employee exposure in excess of its dose or PEL; 5.Any other atmospheric condition that is IDLH


39 Employers are required to evaluate workplaces to determine if any spaces are PRCS * Proper application of the decision flow chart in Appendix A would facilitate compliance with this requirement Evaluation – (c)(1)

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

41 Signs - (c)(2) Employees must be informed of the existence of confined spaces through the use of signs, etc. UNAUTHORIZED ENTRY MUST BE PREVENTED

42 Signs – (c)(2) A sign reading: - DANGER - PERMIT REQUIRED CONFINED SPACE “DO NOT ENTER” or other similar language would satisfy the requirement for a sign.

43 Ensure No Entry – (c)(3) If employees will not enter permit spaces, the employer will take effective measures to prevent them from entering Required to Still comply with paragraphs (c)(1), (c)(2), (c (6), and (c)(8)

44 Entering Permit Spaces – (c)(4) If employees will enter permit spaces, the employer shall develop and implement a written permit space program The written program shall be available for inspection by employee and their authorized representatives

45 “Changes” - (c)(6) When there are changes in the use or configuration of a non-permit confined space that might increase the hazards to entrants, the employer shall reevaluate that space and, if necessary, reclassify it as a permit-required confined space.

46 Host Employers – (c)(8) (i) Inform contractor workplace contains permit spaces and that entry is only allowed through compliance with a permit system (ii) Appraise the contractor of the elements, including hazards identified and employer’s experience with the space (iii) Appraise the contractor of any precautions or procedures that have been implemented for the protection of employees in or near the spaces where the contractor will be working

47 Host Employers – (c)(8) (iv) Coordinate entry operations with contractor, when both host employer personnel and contract personnel will be working in or near permit spaces (v) Debrief contactor at conclusion of the entry operations regarding the program followed and any hazards confronted or created in the permit spaces during entry operations

48 Contractor – (c)(9) (i) Obtain any available information regarding permit space hazards and entry operaitons (ii) Coordinate entry operations with host employer (iii) Inform the host employer of any hazards confronted or created in permit spaces, either through debriefing or during entry operations

49 Hazards of Confined Spaces Oxygen Deficient Atmospheres Oxygen Enriched Atmospheres Flammable Atmospheres Toxic Atmospheres Temperature Extremes Engulfment Hazards Noise, Slick/Wet Surfaces, Falling Objects

50 Oxygen Deficient Atmospheres 19.5 %Minimum acceptable oxygen level. 15 - 19%Decreased ability to work strenuously. Impair coordination. Early symptoms. 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

51 Oxygen Deficient Atmospheres Exposure to atmospheres containing 12% or less oxygen will bring about unconsciousness without warning and so quickly that individuals cannot help or protect themselves. (Source: Compressed Gas Association Bulletin SB-2)

52 Primary Constituents of Normal Air (Permanent Gases) Constituent Chemical Formula Molecular Weight Percent by Volume Nitrogen Oxygen Argon N2N2 O2O2 Ar 28 32 40 78.1 20.9 0.9 Water vapor content varies, but is usually the third largest constituent by volume in air.

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

54 The byproducts of work procedures can generate flammable or explosive conditions within a confined space. Flammable Atmospheres

55 Flammable Hazards Definitions Lower Flammable Limit –Minimum concentration of vapor or gas in air below which propagation of flame does not occur on contact with a source of ignition (below the LFL there is too little combustible fuel to sustain a flammable mixture)

56 Flammable Hazards Definitions Upper Flammable Limit –Maximum concentration of vapor or gas in air above which propagation of flame does not occur on contact with a source of ignition (above the UFL there is too little oxygen to sustain a flammable mixture)

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

58 Toxic 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.

59 Simple Asphyxiants Nitrogen (N 2 ) Argon (Ar) Methane (CH 4 ) - also - gases that causes suffocation by dilution of oxygen.

60 Inerting The displacement of the atmosphere in a permit space by a noncombustible gas (such as nitrogen) to such an extent that the resulting atmosphere is noncombustible. NOTE: This procedure produces an IDLH oxygen-deficient atmosphere IDLH oxygen-deficient atmosphere

61 Nitrogen (N 2 ) Colorless, odorless inert gas Slightly lighter than air Used for inerting Non flammable Non reactive Simple asphyxiant

62 Argon (Ar) Colorless, odorless inert gas Heavier than air Used for inerting Simple asphyxiant Used as a shielding gas in welding

63 Methane (CH 4 ) Natural, marsh, swamp gas Colorless, odorless gas Lighter than air Flammable gas (LEL = 5%; UEL = 15%) Simple asphyxiant Product of organic decay

64 Chemical Asphyxiants - materials that render the body incapable of utilizing an adequate supply of oxygen. Examples include: Carbon monoxide Hydrogen sulfide

65 Hydrogen Sulfide Decomposition of materials. Human waste. Rotten egg odor at low concentrations. Causes olfactory fatigue Odor threshold: 0.02 - 0.2 ppm PPMEffectTime 10 ppmPermissible Exposure Level8 Hours 50 - 100Mild Irritation - eyes, throat1 Hour 200 - 300Significant Irritation1 Hour 500 -700Unconsciousness, Death1/2 - 1 Hour >1000Unconsciousness, DeathMinutes

66 Carbon Monoxide Odorless, Colorless Gas. Combustion By-Product. Quickly collapse at high concentrations. PPMEffectTime 50Permissible Exposure Level8 Hours 200Slight headache, discomfort3 Hours 600Headache, discomfort1 Hour 1000-2000Confusion, nausea, headache2 Hours 1000-2000Tendency to stagger1 1/2 Hours 1000-2000Slight heart palpitation30 Min. 2000-2500Unconsciousness30 Min.

67 Confined space testing FOUR-GAS DETECTOR Oxygen content Flammability / explosion potential Carbon monoxide Hydrogen sulfide CRITICAL ISSUES Training Procedures Calibration

68 Testing The Atmosphere Verify presence of safe work atmosphere. Test all areas of a confined space. –Top, Middle, Bottom Methane is lighter than air. Carbon Monoxide is the same as air. Hydrogen Sulfide is heavier than air. Oxygen Deficiency.

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

70 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 ft 3 C = effective blower capacity CFM

71 Purging Time Example Situation: An estimation of purging time is needed for a 800 ft 3 deep neck manhole. The effective blower capacity is 250 CFM 800/250 x 7.5 = 24 minutes

72 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 with oxygen deficiency! Air-Supplying Respirators –Deliver a safe supply of breathing air from a tank or an uncontaminated area nearby. –Must be adequately monitored.

73 Respirators for IDLH Atmospheres Full Facepiece Pressure Demand SCBA Combination Full Facepiece Pressure Demand SAR with Auxiliary Self-Contained Air Supply

74 Isolation Locking and tagging out electrical sources. Blanking and bleeding pneumatic and hydraulic lines. Disconnecting mechanical drives and shafts. Securing mechanical parts. Blanking sewer and water flow. Locking and tagging out shutoff valves.

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

76 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.

77 Other Hazards Noise –Amplified due to acoustics within the space. –Damaged hearing, affect communication. Slick / Wet Surfaces –Slips and falls. –Increased chance of electric shock. Falling Objects –Topside openings expose workers inside confined space to falling objects.

78 Authorized Entrants Entrants must: 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 oar alerted

79 Attendants Attendants must: be aware of behavioral effects of potential exposures maintain count and identity of entrants remain outside the space until relieved communicate with entrants monitor activities inside and outside the space and order exit if required

80 Attendants (cont) Attendants must: Summon rescuers is necessary prevent unauthorized entry perform non-entry rescue Attendants may NOT perform other duties that interfere with their primary duty to monitor and protect!

81 Entry Supervisors Entry Supervisors must: issue confined space permits know hazards verify that all tests have been conducted verify that all procedures and equipment are in place before signing a permit terminate entry if necessary and cancel permits

82 Entry Supervisors (cont) Verify availability of rescue services and means for summoning them remove unauthorized individuals, terminate entry if necessary, and cancel permits coordinate shift change

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

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

85 Entry Permit Requirements Name and phone numbers of rescue and emergency services. Communication procedures. Special equipment and procedures. –Personal protective equipment. –Alarm procedures. –Rescue equipment. –Respirators.

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

87 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

88 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.

89 Entry Without Permit (continued) 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 gasses/vapors, and toxic air contaminants –continuous forced air ventilation must be used

90 Entry Without Permit (continued) When a confined space is opened –the atmosphere must be tested periodically during work –the employer must verify alternative procedure applicability and safe entry conditions by a written certification (not a permit) with the following information: 2.location 3.signature NOTE: The above certificate must be made available to entrant to review.

91 Entry Without Permit (continued) If you meet the conditions stated in Section (C)(5)(I) of the OSHA standard, 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


93 The Necessity of Rescue Entrants are in spaces that could quickly render them unconscious Over 60% of fatalities in confined spaces are would-be rescuers A pre-planned and effectively executed rescue saves lives Entry programs that by-pass safeguards will eventually end up requiring rescue

94 Types of Rescue Self-Rescue Non-Entry Rescue Entry Rescue

95 Self Rescue Initiated by entrant or attendant Worker removes self No rescuer entry required Entrant must know reasons for self rescue

96 Non-Entry Rescue Entrant must wear full body harness and be attached to a retrieval system Usually initiated by attendant Difficult when equipment entangles lines Difficult when entrant is not directly in line of sight or is around obstacles

97 Entry Rescue Most difficult and risky Requires training, equipment and coordination of efforts

98 Rescue Members are Trained: To perform assigned duties As entrants In first aid and CPR (at least one member holds current certification) To be proficient in use of personal protective equipment To practice rescue at least once every 12 months

99 Rescue Equipment Components Body Support Connecting Component Anchorage Component Anchorage

100 Tripod with Hoist and Rope

101 Davit Arm

102 Vehicle-Mounted Davit

103 Wall Mount Support

104 Structure Mounted Rope and Pulley System

105 Horizontal Retrieval Support

106 Employer Responsibilities Evaluate prospective rescue team abilities to respond in a timely manner. Ensure the rescue team is trained and equipped to execute a rescue Provide the rescue team access to the permit spaces Ensure rescue is practiced at least once every 12 months Non-mandatory Appendix F may be used as a guide to evaluate rescue teams

107 May be provided by –“on-site” employees –“off-site” services Rescue Services

108 On-site Teams On-site teams must –be properly equipped –receive the same training as entrants –receive additional training in the use of PPE and rescue equipment and in first aid and CPR –practice simulated rescues once each year

109 Off-site Teams Off-site teams must –be aware of confined space hazards –practice similar rescues in similar spaces

110 Questions?

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