1. Confined Space Hazards 1

2.  IIPP (Section 3203)(a) “…every employer…”  (a) (4) Include procedures for identifying and evaluating work place hazards… ◦ (C) Whenever the employer is made aware of a new or previously unrecognized hazard.

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4. Construction5% Inspection10% Repair/Maintenance40% Rescue36% Retrieve Object3% Dislodge material5% Unknown1%

5.  In place February 2012  All Cal-OSHA units ◦ Enforcement ◦ Consultation ◦ Every inspection will include an evaluation of confined spaces  Goal: Zero confined space fatalities in 2012 5

6. For ALL Inspections:  Ask ER if they have any confined spaces  Look for Confined Spaces during walk- around ◦ Identify hazards ◦ Verify that spaces are labeled  Ask ER if anyone enters spaces and how spaces are maintained & cleaned  Interview employees entering spaces

7.  Review written “Confined Space Program”, or procedures and documentation/records  Review alternate entry and/or reclassification procedures if applicable  Review rescue procedures  Audit last 6 months’ permits for PRCS-entry or certificates of reclassification

8.  Confined spaces present very special work requirements and preparations  Safety incidents involving confined spaces may result in fatalities; many have multiple serious injuries 8

9.  If confined spaces exist in your workplace ◦ Post the space ◦ Warn employees of the hazard ◦ Prevent employees from entering until an effective and fully implemented confined space program is in place. 9

10. Look for spaces that are…  Large enough and configured so that they can be entered, and  Have restricted means for entry or exit, and  Are not designed for continuous employee occupancy 10

11.  Manure pits  Storage bins  Double hulls  Pumping stations  Pits, sumps  Vessels  Manholes  Water reservoirs  Tanks  Boilers  Vats  Kilns  Vaults  Silos  Pipelines  Sewers 11

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16.  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?

17.  Is an acutely hazardous atmosphere or physical hazard present?  If it’s not present now, can it become present later?

18. Title 8, CCR Sections 5156, 5157 & 5158 A “performance” standard: Every confined space is unique and must be treated on a case-by-case basis

19.  Limited entrance and exit + potential atmospheric hazard or other hazards = “Permit Required Confined Space”  Applies to most workplaces such as: ◦ Food production ◦ Chemical manufacturing ◦ Recycling operations ◦ Sewer plants ◦ Plating shops ◦ Amusement parks 19

20.  Limited entrance and exit + hazardous atmosphere = “Confined Space”  Applies to: ◦ Construction, ◦ Agriculture, ◦ Marine terminals ◦ Telecommunication manholes and unvented vaults ◦ Grain handling facilities, ◦ Natural gas utility operation within distribution and transmission facility vaults, 20

21. All Operations or Industries Except: Construction Agriculture Marine Terminals Telecommunication Manholes Grain Handling Facilities Natural Gas Utility Electric Utility 5158 Applies

22.  If a confined space has a hazardous atmosphere, or has the potential for a hazardous atmosphere, special confined space procedures must be taken  Hazardous atmosphere includes: ◦ Oxygen deficiency or enrichment ◦ Flammable atmosphere ◦ Acutely toxic (Immediately Dangerous to Life or Health, or impairs ability to self-rescue) 22

23.  Calibration  Sample Locations 23

24. Methane: 0.55 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 Lighter than air gases Heavier than air gases So...Must test at multiple levels within space! Specific Gravity

25.  Use direct reading instruments with “real time” information on actual concentrations  “Alarm only” devices which do not provide readings, are not considered acceptable direct reading instruments

26.  Oxygen  Combustible gases and vapors  Toxic gases and vapors When testing for atmospheric hazards, test in the following order: OR, test for all simultaneously

27.  Aviation fuel  Sensor poisoning  Calibration  Employee medical exposure records

28.  Inerting of the space  Product stored in a confined space:  Gases released when cleaning.  Materials absorbed into walls of confined space, even if space has been emptied or cleaned.  Rotting organic materials and other decomposition 28

29.  Work performed in a confined space:  Welding, cutting, brazing, soldering  Painting, scraping, sanding, degreasing  Sealing, bonding, melting  Connections or pipes to other spaces, or leakage from adjacent areas or soils. 29

30.  Water or other materials in the space, such as sand or sugar, are an “engulfment” hazard  A person may be trapped in the space due to sloping floor, converging walls, or piping or other obstacles  Any other recognized serious safety hazard such as energy sources, mechanical hazards, steam, or heat 30

31.  Hazardous atmosphere  Energy sources following characteristics: electrical mechanical hydraulic pneumatic, etc. Other One or more of the following: <19.5% Oxygen > 23.5% Oxygen >10% LEL (G/V) =/> 10% LEL (Dust) IDLH >PEL (Acute) steam corrosives, etc. Engulfment Entrapment

32.  The action by which a person passes through an opening into a permit-required confined space, and includes ensuing work activities in that space  Considered to have occurred as soon as any part of the entrant’s body breaks the plane of an opening into the space

33. ◦ Post the space and prevent unauthorized entry ◦ Develop a program ◦ Assess the space prior to and continually during each entry, including atmospheric monitoring ◦ Train employees in required roles – entrant, attendant, supervisor, rescuers ◦ Isolate the space from other energy sources & materials ◦ Have effective rescue procedures 33

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35.  Non-entry rescue is preferred! You must utilize retrieval systems unless they would not be effective in the space  In addition to the attendant, there must be at least one standby person at the site who is trained and immediately available to perform rescue and emergency services.  Practice simulated rescue operations at least every 12 months in actual space or representative spaces based on opening size, configuration, and accessibility….  “CALL 911” IS NOT A RESCUE PLAN!!! 35

36. Evaluate and Posting§5157(c)(1) - - - Written Procedures§5157(c)(4)§5158(c)(1)(A) Atmospheric Testing§5157(d)(5)§5158(d)(3) Ventilation§5157(c)(5)(B)§5158(d)(6) Rescue Procedures§5157(d)(9)§5158(c)(1) Training§5157(g)(1)§5158(c)(2)

37.  “Confined Spaces: Is it Safe to Enter?” [under revision]  OSHA “Advisor”  Federal Register Preamble

39. Your Challenge 1)Use the SCORE CARD provided as a guide to the presentation. 2)Make an honest evaluation of your understanding of the topics discussed. 3)Focus your organization’s “improvements” on the issues scored “UNCOMFORTABLE”.

40. 1. Large enough to enter, 2. Limited means of access 3. Not designed for continuous occupancy 1. Large enough to enter, 2. Limited means of access 3. Not designed for continuous occupancy The three conditions that define a confined space…

41. An inventory of all spaces including the hazards, space classifications, equipment requirements, and rescue procedures What must an employer develop as part of their Confined Space Entry program…

42. Challenge #1 Can your employees identify a Confined Space (CS)?

43. “Labeling with a sign: “Confined Space – Entry by Permit Only – No Unauthorized Personnel (or similar)” Whenever possible confined spaces should be identified using this method…

44. “Atmosphere” Considered to be the most common and dangerous hazard in a confined space…

45. “19.5% - 23.5%” If a confined space has an oxygen atmosphere between _____% and _____ %, it may be safe to enter.

46. “Lower Explosive Limit or LEL” Atmospheric monitors display flammability as a percentage of this measurement…

47. Challenge #2 Are there procedures and supervision in place to test the atmosphere prior to, and during, every Confined Space Entry (CSE)?

48. Lake Hemet Water District CSE Fatality

49. “Engulfment, internal configuration, or job introduced hazards such as electrical, moving parts, pressure piping, welding, chemicals,….” Other than atmosphere, name four other hazards may one face in a confined space…..

50. “According to the manufacturer’s recommendations” The frequency with which gas monitors need to be calibrated…

51. “Stratification” or “Layering” Appendix B of the Cal/OSHA confined space regulation states that the atmosphere should be tested every 4 feet because the potential for…

53. “Mechanical Ventilation” The primary means of control used to maintain safe atmospheric conditions…

55. “ Short-Circuiting” This happens when ventilation air moves directly from the inlet to the exhaust outlet, without reaching the other areas of the space…

57. Challenge #3 Do your employees know how atmospheric control equipment works?

58. “Permit Required Entry” “Alternate Procedure “C(5)” Entry “ “Declassified / Non-Permit Required Entry” “Permit Required Entry” “Alternate Procedure “C(5)” Entry “ “Declassified / Non-Permit Required Entry” The three types of confined space entries that may be performed…

59. “ALL OF THEM!” Which of the three types of confined spaces require atmospheric testing prior to entry?

60. “Confined Space Permit” The confined space regulation states that an entry supervisor must complete this document before anyone enters a confined space…

61. Challenge #4 Can your employees determine the proper classification of a confined space?

62. Entrant, Attendant, Supervisor, Rescue Entrant, Attendant, Supervisor, Rescue The four duty positions required by Cal/OSHA for a Permit-Required confined space entry…

63. The hazards and how to control or eliminate them What every confined space position must know prior to an entry being made?

64. “Breaks the plane of a space” Confined space entry has occurred when any part of the body…

65. “Personnel must exit the space” The action that must be taken if the attendant leaves the space…

66. “Entry Supervisor” The person who has overall responsibility for the entry…

67. “Host Contractor/Host Agency” Who has the obligation to inform outside contractors about all known hazards and precautions normally taken when entering a confined space….

68. Challenge #5 Is your staff adequately trained for CSE operations?

69. “Would be rescuers”? In the past, 50-60 % of fatalities in confined spaces were these types of persons…

70. “Tripod, Harness, Winch, Gas Monitor, Ventilator, SCBA, Annual Training….” List at least five pieces of rescue equipment you would want to have available…

71. “12 months” Rescue teams must conduct a training drill at least once every…

72. Challenge #6 Do you, without a doubt, have a rescue capability for every CSE?

73. Thank you for taking the Challenge Rate your organization’s CSE Program! INSTITUTE IMPROVEMENTS NOW!