1. Confined or Enclosed Spaces [29 CFR 1926.21(6)(i & ii)
Per Safety training and education
(b) Employer responsibility
Welcome to the session on Permit Required Confined Space Entry

2. Permit Required Confined Spaces [29 CFR 1910.146]
Welcome to the session on Permit Required Confined Space Entry

3. Please take a Deep Breath & Hold It…..
Class Exercise
Please take a Deep Breath & Hold It…..

4. CONFINED SPACE ENTRY (CSE)
Confined Spaces come in all shapes and sizes!
Confined Spaces are all around us. They come in all shapes and sizes, from the grain silos shown here you can see that workers on the inside face some unique challenges. Every few years you read in the newspaper about a silo that exploded.

5. CONFINED SPACE ENTRY
Manholes are always a threat. See the rust on the sides of this shaft? That is an indication that the oxygen has been leached out of the enclosed air and mixed with the iron to form rust. Remember, rust is oxidation, so if you see rust, there is less oxygen there than there was at one time. And if the area is enclosed no fresh air can get into that area.

6. FATAL ACCIDENTS 35% Supervisor or Higher 64% Did not need to enter
66% Water / Wastewater / Sewer / Manhole Construction
78% Oxygen deficient / IDLH / toxic
95% Had no confined space training
100% No (or inadequate) powered ventilation
100% No instrument at site (to measure hazardous atmosphere)
When we analyzed the number of deaths that resulted from confined space accidents, we found that 35% of the people that died in confined spaces were supervisors. 64% of the people didn’t have to go into the confined space. 66% of the deaths involved sewer pipes or manhole covers or construction, and the OSHA rule didn’t apply to the construction industry at all!
78% of the people died because of a poisonous atmosphere or not enough air and in 95% of the cases the people had not received any training on confined space entry!
In every single case there was no air monitor on site nor was there any ventilation equipment on site. These people didn’t stand a chance!

7. CSE Fatalities Happen…
Excavations
Manholes
Foundations
Underground utility vaults
Sewer lines
Bins
Boilers
Storage tanks
Process vessels
People are dying in excavations, manholes, building foundations, underground vault. Grain elevators and sewer pipes are all examples of deadly areas!

8. ‘Confined Space’ Defined
SPACE LARGE ENOUGH TO BODILY ENTER & DO ASSIGNED WORK AND
LIMITED OR RESTRICTED ENTRY OR EXIT AND
NOT DESIGNED FOR CONTINUOUS OCCUPANCY
The American National Standards Institute (ANSI) defines a confined space as an area that is large enough to physically get into, one that has restricted entry or exit, and that is not designed for continuous occupancy. In order to be a confined space all three of those criteria must be met.
Let’s examine this classroom. Is it large enough to enter? Yes. It meets the first criteria. Does it have restricted entry or exit? (If there are two doors on the classroom, point that out, if not, point out that the single entry door is sufficient for a small classroom of less than 50 people, according to the NFPA)
Because the entry/exit is not restricted, this classroom is NOT a confined space.
Now, let’s think about those stainless steel milk trucks that haul dairy milk to the plant. They have a hatch on the top that workers may enter for cleaning or servicing. So…
Is it large enough to enter? Yes
Restricted entry and exit? Yes
Not designed for continuous occupancy? There is no heating or ventilation system there, so it wasn’t designed for people. So it meets the final criteria. A milk truck container is a confined space.
You have to go through that analysis for every possible confined space you may enter.
This classroom?
A concrete truck?

9. CONFINED SPACE ENTRY Overview Types of Confined Spaces by Definition
Permit-required means….
Non-permit means…..
Typical Citations
No testing of confined space atmosphere
No rescue provisions
No retrieval device for confined spaces greater than 5 feet deep
Procedures to enter confined spaces were developed by industry and the American National Standards Institute has a standard that applies to construction AND general industry. That standard breaks confined spaces into two types, permit required and NON permit required.
OSHA issues citations on a regular basis to companies that do not test the atmosphere or have established procedures for rescuing workers in a confined space. In addition, any time a worker is more than 5 feet in a permit required confined space a retrieval device must be present at the site.

10. Confined Space Decision Flowchart
SPACE LARGE ENOUGH TO ENTER AND;
LIMITED OR RESTRICTED ENTRY OR EXIT;
NOT DESIGNED FOR CONTINUOUS OCCUPANCY
NOT A
CONFINED
SPACE NO
YES
CONFINED SPACE
HAZARDOUS ATMOSPHERE?
CONFIGURATION HAZARD?
ENGULFMENT HAZARD?
ANY OTHER RECOGNIZED
SERIOUS HAZARD? OR
PERMIT
REQUIRED
NON
This is an example of how to examine your work place to determine if you need a permit system. You can use this flowchart to analyze your confined spaces to see if you need any special permits or requirements.
(Walk the students through the flowchart and let them provide some examples that they have in their work area and determine if they are non-permit required or permit required confined spaces) OR

11. Requirements of Standards
Evaluate workplace for permit-required spaces
Employees informed of existence, location, & danger signs
Develop written program (if entry is permitted)
Train and educate employees
Re-evaluation & reclassification
Contractor confined space interface
The OSHA regulations require that employers evaluate their workplace to determine if they have any permit required confined spaces. If any are found, the employees must be informed of where they are and the dangers that lurk within.
Companies must develop a written program for their employees who will be entering those spaces and those employees must be trained on how to safety enter, work inside and exit permit required confined spaces.

12. Confined Space Is it a confined space?
Is it a permit required confined space?
Adds a new meaning to Special Delivery!
(Give the students a moment to read the new clipping, or read it to them)
What do you think of this workers predicament? Clearly it’s a puzzle as to how he got in there in the first place. The burning question for safety people is:
Is it a confined space?
Is it a permit required confined space?
It does add new meaning to the phrase, special delivery!

13. CONFINED SPACE ENTRY
The tragic loss of life occurred when confined space rules were not enforced by the employer.
This is a true case of a permit-required confined space incident. The man in the picture is dead, the woman is now a widow. At G. Heileman Brewery in La Crosse Wisconsin they usually made Old Style Beer in the vats, which were cleaned with a solution of mild soapy water. The victim had a job in which he would open the top of the hatch and peer in during the midnight shift to ensure that the vat was cleaned.
Production was low, so the company was brewing Tea in those vats and the solution to clean the vats is a more caustic, dangerous solution. The victim was not informed of the hazard, and when he opened the vat and placed his face into it, he was overcome by the vapors. His body was found several hours later, hanging half inside the vat.
This is an example of how a non-permit required confined space became a permit-required confined space overnight!

14. CONFINED SPACE ENTRY Lack of oxygen in sewer Ideas?
This article demonstrates how easy it is to get into trouble in a permit required confined space. Two city workers died when they didn’t follow the rules.
Lack of oxygen in sewer Ideas?
Rusty hand rails might have tipped them off!!
What did they do wrong or not do correctly?

15. Categorizing Work Spaces
REQUIRES A PERMIT IF:
Contains or has potential to contain a hazardous atmosphere
Engulfment hazard potential
Internal configuration hazard
Contains any recognized serious hazard
But just because it’s a confined space doesn’t make it dangerous! It merely makes it a confined space by definition. The next step is to classify it as a non-permit required confined space or a permit required confined space. If there is no hazard that would injure a worker, it is just a non-permit confined space. Get in there, get the job done and get out.
However… if there is an atmosphere that could be hazardous, or the chance of the worker being engulfed by the contents of the confined space it would be a Permit Required Confined Space. If there is a chance that the worker could get stuck due to sloping walls or crawling through tubes that bend in ways that the human body doesn’t bend, that would be considered a permit required confined space. Finally, OSHA added the last bullet because they couldn’t think of every possibility. So if there is a serious hazard inside the confined space, such as whirling ventilation fans on top of skyscrapers, that would be considered a permit required confined space.

16. Permit-Required CSE Hazards
Falling Objects
Excavations
Temperature Extremes
Falls / Slick/wet surfaces
Toxic / Corrosive chemicals
Moving parts/ equipment
These are some examples of hazards that you need to be on the lookout for when entering confined spaces. Naturally, Hazardous Atmospheres top the list of dangers, but other hazards on the right side of the slide also need to be considered any time you get into a permit required confined space.

17. SIGNAGE
A simple sign like this one can serve as a barrier to a well trained work force. The workers must be trained that when they see this type of sign, they do not enter the area.
May say additional things like:
Respirator Required for Entry
Lifeline Required for Entry

18. WRITTEN PROGRAM (d) Identify & evaluate space hazards
Test for atmospheric hazards
Continuously monitor
Prevent unauthorized entry
Establish procedures & practices
Identify employee duties
Require, provide & maintain PPE
One Attendant minimum
Rescue & emergency procedures established
Permit system
Periodic review
Owners of facilities whose workers enter permit-required confined spaces must develop a written program to control those entry activities. If they make the decision that none of their workers will go into a permit-required confined space, they only have to identify the spaces, label them and develop a means to keep their workers out of them.
The written program must contain these items to be effective. The plan should be in writing and OSHA will ask for a copy when they come on your site.

19. CONFINED SPACE ENTRY NEEDS
Air Testing Monitor
Full Body Harness
Communication Equipment
Protective Eyewear
Protective Helmet
Protective Boots
This man is well dressed for permit required confined space work. He has an air monitor on the ground on the left by the manhole cover that is monitoring the air inside. He is wearing a full harness so that in case he enters and gets in trouble someone can pull him out. He also has a method of communication with some one else to let them know that he is in trouble and he is wearing the correct PPE. (Eyewear, head protection, boots)
So what is missing?

20. Hazardous Atmospheres
Too much Oxygen over 23.5%
Too little Oxygen under 19.5%
Flammable atmosphere 10% LEL
Carbon Monoxide ppm
Hydrogen Sulfide ppm Ceiling
See
Subpart Z
Air Contaminants
Let’s talk about the atmosphere, since that seems to be what is killing most people in the confined space business. Right now you are breathing air that has an oxygen content of probably percent oxygen. If the oxygen level went up to 23.5% we would say that the atmosphere is oxygen enriched. Things burn very, very easily in oxygen enriched atmospheres, so that’s a bad thing. On the other hand, if the oxygen level drops to 19.5%, the human body can’t get enough oxygen to function and the brain shuts down.
If there is 10% fumes of anything that can burn, alcohol, methane, etc, you have reached the Lower Explosive Limit of the flammable material and things might blow up on you inside a confined space.
Finally, Carbon Monoxide is a deadly killer. If you get 35 parts per million it will get you. Your home fire alarm/carbon monoxide detector (and I know that you all have one in your home since you are all safety conscious) is set to go off at 35 ppm.

21. PERMIT REQUIRED CONFINED SPACE PROGRAM Atmosphere Testing
Oxygen level
Flammability / explosion potential
Carbon monoxide
Hydrogen sulfide
You probably don’t have a canary in a cage to stick into the permit required confined space before you enter it, so you should have one of these nifty little gas monitors. It will test the atmosphere and let you know if it is safe to enter the permit required confined space. This is a four gas monitor. In addition to testing for the basics of oxygen, flammability and carbon monoxide, this one also tests for hydrogen sulfide.
This is a 4-gas monitor

22. Atmosphere Testing Draw samples without entering the space!
Then wear it while in the space
This is a typical air monitor that is used for permit required confined space entry. It consists of an air monitor, the square box on the right. It also has an air line with a hand pump attached so that you can put the end of a hose into the confined space and draw some air into the monitor to test it. This monitor tests for three gases, oxygen, carbon monoxide and a flammable gas test.

23. Atmosphere Testing CRITICAL ISSUES Training Procedures
Calibration prior to use
Air monitors come in all shapes and sizes and they require different training and procedures when using them. Always check the manual to make sure that your system is calibrated correctly and that it is being used correctly.

24. Atmosphere Testing Normal Readings
This is what your readings may look like when entering a permit required confined space. The air level is between 19.5 and 23 percent, so that’s all right. The LEL (the flammable limit) is at 4 and as long as it doesn’t go higher than 10 we’re ok. There is no carbon monoxide, so it’s all right to enter the permit-required confined space.

25. Atmosphere Testing DANGER Reading! Oxygen level too low!
Alarm is going off!!
This reading shows that the oxygen level has dropped below the safe level of 19.5 percent. As you can see by the red light at the top of the monitor an alarm is going off. The light is flashing and an audible alarm can be heard. When this happens, you have to get out of the space immediately!!

26. CONFINED SPACE ENTRY
A simple fan may ventilate the PRCS enough to eliminate the hazard
Fan nomographs
Use them
Follow Mfg. recommendations
Eliminate the hazard and the space may be considered a non permit required space!

27. CONFINED SPACE ENTRY
These signs are available by many sign shops and safety equipment companies, such as Lab Safety in Janesville, Wisconsin.

29. CONFINED SPACE ENTRY
Entry into Permit Required Space areas takes teamwork and planning!
It takes a well trained team to enter and exit a permit required confined space!

30. Entry Permit System Signed by Supervisor Includes:
Test results & tester’s initials or signature
Supervisor’s name & signature
Identification of space and personnel (by assigned duty)
Purpose & control measures are in place
All specified equipment is in place
Name & number of rescue/emergency service
Acceptable entry conditions
Any special equipment & communication procedures
Remember that a permit system must be developed if your workers go into a permit required confined space.
In order to safely enter a permit-required confined space a permit must be issued that is signed by the site supervisor. This permit is only valid for a specific time period and lists all of the equipment needed to get into and out of the permit-required confined space safely, as well as the results of the air monitoring.
When the time is expired, all personnel must leave the danger area. If work has not been completed a new permit must be developed. Permits cannot be extended. An example of a permit is in the regulation.

31. CSE: Ventilator Room Example
In some cases, a permit required confined space can become a non-permit required space. Some buildings have ventilator rooms with revolving fans at the top of the skyscrapers. These rooms are permit required confined spaces because of the dangerous fans. However, if lock-out rules are engaged, the hazard is eliminated and the room can be reclassified as a non-permit confined space.
If you eliminate the hazard you could save a life.
WHAT type of confined space is this & WHY?

32. Training and Education
Knowledge & skills for safe performance
Additional training is required when:
Job duties change
Change in program
New hazard(s) are identified
Employee’s job performance is found deficient
Emergency training (CPR / First Aid)
Certification of training
When Job duties change or a new hazard is introduced the workers who enter the permit-required confined spaces must be retrained on those hazards. Retraining is also required whenever a worker shows that their job performance is deficient. CPR and first aid training must be included for at least one member of the rescue team that will respond. Always document your training!

33. Entry Supervisor’s Duties
Know the space’s hazards & consequences
Verify emergency plans, test procedures, and proper equipment are in place
Terminate/cancel permits (upon completion or change in conditions)
Remove unauthorized personnel
Ensure operation remains consistent with entry permit conditions
The Supervisor has specific duties as spelled out in the regulation.

34. Authorized Entrant Responsibilities
Know the space hazards & consequences
Alert to exposure symptoms & prohibited conditions
Use appropriate PPE
Begin self rescue w hazards /symptoms
Evacuate immediately on order of Attendant
The Entrant is what we call the lucky person who gets to go into the confined space. That person must know what they are getting into, what kind of hazards exist and how bad those hazards are. They must be made aware of any prohibited conditions that would cause them to exit the confined space. They should use Personal Protective Equipment to protect themselves. In this picture the entrant is wearing his body harness which is required for all entries more than 5 feet, but is a recommended item in all other permit required confined spaces as well.
In the event of an emergency the entrant must try to get out of the space and whenever the attendant issues an order to vacate, the entrant must exit immediately. Don’t let you entrants get into the habit of “turning one more bolt” or saying “I’m almost done here, another minute..” When the attendant says leave, the entrant leaves immediately!
Communicate w Attendant re: prohibited conditions

35. Attendant Duties Recognize existing & potential hazards
Aware of behavioral effects to Entrant
Remain outside to monitor space & headcount
Maintain effective contact with Entrant
Monitor activities in & out of space.
Order evacuation in any hazardous situation
Summon emergency rescue
Perform “non-entry rescue”
Perform no other duties
The attendant remains outside of the permit required confined space to monitor the activity and locate hazards that could injure the workers inside. They must be trained on those hazards and must be in constant contact with the person inside. The Attendant will order an evacuation whenever a hazardous situation arises.

36. Communication Entrant and Attendant must maintain verbal contact
Have backup communication system
Methods
Simple voice
Radios
Telephone
“Tug Signals” on the cable
Communication is critical in permit required confined spaces. You may only have seconds to get the word to the entrant that there is a deadly problem sneaking up on him. You can communicate by talking, radios or telephones or even a system of tugs on the rope. One tug means the attendant is checking the entrants status. The entrant should respond with two tugs. If two tugs don’t come back, the attendant immediately winches the entrant out.

37. Entrant Self-Rescue
At first sign or trouble, notify Attendant and begin evacuation
Attendant notifies other workers to evacuate
Rescue team notified, if necessary
Unlike mine safety procedures where the workers are told to remain still and conserve their air, in permit required confined space incidents, we WANT the entrant to try to get out. When the attendant gives the evacuation order the entrants leave.

38. Non-Entry Rescue Entrant is wearing a harness
Cable is attached to the harness
Use a hand crank!
vs a powered winch
Wristlets may be used
The entrant should wear a harness all the time, and it is required if he is going in deeper than 5 feet. When rescuing workers a cable should be attached to the harness and then attached to a hand crank to pull the worker out. Don’t use a powered crank attached to the winch on the front of your jeep!
Instead of attaching the cable to the center of the back, OSHA allows rescue operators to attach the cable at any point where the body will present the smallest profile during the rescue operation. Often this is the wrists, and the cable is attached to wristlets to pull the straight lined body out of the tube.

39. Plan for Emergencies MSDS requirements
Chest or full body harness requirement and mechanical device
Employer responsibilities:
Rescuers provided with & trained on PPE
Trained to perform rescue duties
Rescuers have Authorized Entrant’s training
Practice rescue exercises completed yearly
Emergency rescue from a permit required confined space can be tricky. Don’t assume that the local fire department will come and rescue you, since rescue providers are now required to practice their rescue in the permit-required confined space annually. So always check with your rescue service.
If you have your own rescue service at your company, make sure that they are trained and have the correct equipment to perform their rescue tasks.

40. CSE RESCUE Confined Space Rescue teams must practice annually
At the actual or representative confined spaces in which they may be required to perform Entrant rescue
Once a year the rescue team must practice rescuing a worker from a permit required confined space. The worker in this picture is in the orange plastic shroud that is designed to be used to pull workers out of the tubes of a manhole. There is lots and lots of specialized equipment to help you do your job.

41. The Domino Effect One worker gets into trouble
The next worker goes in to help
A third worker goes in to help...
Newspapers reveal a lot of dangerous area. Let’s analyze this case and see what happened. (Have them analyze the news clipping to determine if the area is a confined space or a permit-required confined space. What happened to the rescuers? The final word is that the chicken survived!!)

42. ‘Cause I put the hard ones on the Post Test!!!
Questions?
Just keep them simple, please.
‘Cause I put the hard ones on the Post Test!!!

43. CSE Major Points Written plan of action for rescue is required.
Ventilation is necessary if there is the potential for the atmosphere to move out of the acceptable range.
When working with Permit Required Confined Spaces you must have a written plan for rescuing trapped workers. Ventilation must be available if the air in the chamber can go bad.
OSHA has a section on confined spaces in their industrial manuals, and construction workers have to comply with the ANSI standard. OSHA will cite the ANSI standard to enforce safe permit required confined space entry procedures in construction.
On all Federal projects the Army Corps of Engineer Manual must be obeyed and it has special provisions for entry into permit required confined spaces. So if your contract is on Federal property you need to obey all the rules for entry as well, since the Federal Government writes the need to comply with the Army Corps of Engineer Manual into every construction contract that they issue.