Each year there are approximately 4.8 million confined space entries in the United States. There is a degree of risk with each entry that can be greatly decreased with proper confined space protocols in place. The accesses into tight crevices and poor egress work environments account for nearly two deaths a week and thousands of injuries each year in the United States.
What are Confined Spaces?
- Bins; boilers; pits
Concrete pier columns
Sewers; transformer vaults
Storm drains; water mains
Precast concrete and other pre-formed manhole units
Air receivers, preheaters, and chillers
COMMUNICATION IS KEY:
As the host employer, all details (e.g. entry employer’s entry program, known hazards, new hazards, and hazard elimination/isolation procedures) about confined spaces at the worksite will be communicated with the controlling contractor before and after entry. Where SoCal Removal has contracted with the property owner to manage it and transmit all confined space details, this company will be considered both the controlling contractor and the host employer.
As the controlling contractor, all details (e.g. employer’s entry program, known hazards, new hazards, and hazard elimination/isolation procedures) about confined spaces at the worksite will be communicated with the host employer and all entry employers (i.e. subcontractors) before and after entry, ensuring that information is transferred to the different entry employers before and during entry so they don’t create additional hazards for other entry employers’ workers. Details will be communicated with other non-entry employers so that their workers do not create hazards or go into the confined space.
As the entry employer, all details (e.g. entry program, known hazards, new hazards, and hazard elimination/isolation procedures) about confined spaces at the worksite will be communicated with the controlling contractor before and after entry.
As a non-entry employer, essential details about confined spaces will be communicated with the controlling contractor to determine where the confined spaces are and the necessary steps to prevent employees from accessing them or creating hazards for other workers. Employees will be instructed to not enter the identified confined spaces.
IDENTIFYING CONFINED SPACES AND HAZARDS
A confined space is an area a worker can enter, but isn’t designed for continuous occupancy and doesn’t have an unrestricted entry or exit. A permit required confined space (PRCS) has a serious health or safety hazard, such as the possibility for a hazardous atmosphere, material that can engulf a person, or is in a shape that can trap or asphyxiate a person (e.g. converging or sloping walls or floor).
To help provide an understanding for determinations CAL-OSHA has provided a limited list of work sites that could have a confined space: bins, boilers, pits, elevators, escalators, pumps, manholes, and tanks (containers).
SoCal Removal will ensure that a competent person will identify all confined spaces an employee might work in, before the work begins, and determine which require permits. Employees and the prime controlling contractor will be informed directly of the location and danger in each permit space. Signs that effectively warn of the danger and prohibit entry will be placed at permit space entrances.
As an entry employer, a competent person will reevaluate non-permit spaces and determine if it is a permit space whenever there is indication that the use or configuration changed increasing the danger, or the original evaluation is incorrect.
Work will be scheduled as much as reasonably possible to avoid confined spaces by finishing tasks in areas before they become confined spaces.
CONFINED SPACES WITH ONLY ATMOSPHERIC HAZARDS
The following procedures and conditions are for entering a confined space with only atmospheric hazards that can be made safe to enter through forced air ventilation during entry.
To be more specific, all physical hazards have to be eliminated or isolated through engineering controls, the forced air ventilation has to keep the space safe for entry, and entrants must be able to exit safely if ventilation stops working.
If the above can be proven and documented with monitoring and inspection where the data is available to each entrant, the space can be entered without a permit, attendant, or rescue and emergency equipment once the company certifies that
Entrance covers can be safely removed
Entrance openings are immediately guarded by a railing, temporary cover or barrier that prevents accidental falls into the opening and protects entrants from foreign objects falling into the space
The internal atmosphere is tested with a calibrated direct-reading instrument in the following order: oxygen content, flammable gases and vapors, and potential toxic air contaminants. The testing procedure is evaluated to ensure it is appropriate for the possible atmospheric hazards. This may mean identifying the possible toxic air contaminants and ensuring the gas detector can detect it, and testing at the top, middle, and bottom of the space to account for different gases’ density
Testing and continuous monitoring ensures there is no hazardous atmosphere
Continuous forced air ventilation from a clean source directed — to the lowest spot or furthest corner — so that it eliminates any hazardous atmosphere from the space while anyone is in there
Continuously monitoring the atmosphere in the space with monitoring equipment, unless necessary monitoring equipment isn’t commercially available, that will sound an alarm notifying all entrants if a hazard exceeds the atmospheric thresholds
Where the preferred continuous monitoring is not used because of equipment limitations, or that periodic monitoring is demonstrably sufficient, periodic monitoring will be often enough to detect a hazardous atmosphere is building up and that entrants have time to exit
Once a hazard is observed, everyone will immediately leave the space. The hazard source is then found — and the company will take steps that protect employees before they enter that space again
There is a safe way to enter and exit the space, including a personnel hoist made for that purpose, or a job hoist approved ahead of time in writing by a registered professional engineer
The written certificate must contain the date, location of the space and the signature of the person certifying the above conditions have been met. The certification must be made before anybody enters and be available to every employee entering the space. The employer will reevaluate the space if there is a change to the space that may increase hazards or there is indication the current evaluation is incorrect.
EVALUATING PERMIT SPACE CONDITIONS
The entry employer will take the following steps to check out the PRCS when conducting entry:
Test the conditions in the PRCS before entering or making any additional ventilation if the atmosphere can be isolated. Oxygen will be tested first, followed by combustible gases and vapors, and finally toxic gases and vapors.
If it is part of a larger continuous system and can’t be isolated, pre-entry testing will be done, and conditions will be continuously monitored unless necessary monitoring equipment isn’t commercially available. Work in large or continuous systems also requires a sufficient early-warning system continuously monitoring for engulfment hazards.
Continuously monitoring the atmosphere in space with monitoring equipment, unless necessary monitoring equipment isn’t commercially available, that will sound an alarm notifying all entrants if a hazard exceeds the atmospheric thresholds.
Authorized entrants will be allowed to observe the pre-entry and all other testing and monitoring, and the results will be posted with the permit at the entry to the confined space.
SoCal Removal and its subcontractors will ensure conditions are safe for entry in permit spaces through establishing, suspending, and cancelling entry permits. If there are multiple entry employers in a confined space during the same entry, then one permit will be completed by coordinating with the controlling contractor and all entry employers.
Through completing an entry permit, all measures needed to make the PRCS safe for entry will be documented. The entry supervisor on the permit will sign the entry permit authorizing that these necessary measures have been taken.
The permit’s duration will be the amount of time needed to complete the task as identified on the permit. Every entry permit will be kept for at least one year and addressed in the annual review.
The entry supervisor will terminate the permit when the task identified is completed, suspended, or will cancel the permit when necessary.
A permit will be suspended when a temporary condition not allowed in the permit occurs in or near the PRCS and doesn’t change its configuration or creates any new hazard. The entry supervisor needs to reevaluate the PRCS before lifting any suspension or cancelling the permit.
A permit will be canceled when a condition not allowed in the permit occurs in or near the PRCS and isn’t temporary or, changes its configuration or creates any new hazard.
ENTRY PERMIT REQUIREMENT
In order to identify everything needed to make a permit safe for entry the following items will be addressed:
The permit space’s location
The reason for entry
Date and duration of the entry
Authorized entrants identified so the attendant can easily track who is inside the PRCS
How any hazardous atmospheric levels will be tracked should ventilation stop:
The name of every attendant
The name of every entry supervisor and the signature of the one that authorized entry
Hazards in the PRCS
How the hazards will be isolated, eliminated or controlled before entry (e.g. lockout tagout, purging, inerting, ventilating, and flushing)
Acceptable entry conditions
Results and times of appropriate testing and monitoring, including the names or initials of who did the test
Rescue and emergency services and how they will be called
How entrants and attendants will communicate during entry
The necessary equipment
Additional permits needed to complete the task in the confined space
CONFINED SPACE ENTRY RESPONSIBILITIES
ENTRY EMPLOYER RESPONSIBILITES
As an entry employer, SoCal Removal or its project subcontractor will create and put into action the following measures to protect its and other employees both inside and outside confined spaces:
Prevent unauthorized entry. This can be accomplished using covers, signs, or an attendant at the entrance.
Ensure safe permit space entry operations
Provide the necessary equipment
Evaluate permit spaces during entry
Provide attendants outside permit spaces during entry
Describe how the attendant assigned to monitor multiple spaces will respond to emergencies.
Assign a role to every person in an entry, identify their duties and provide required training, rescue, and emergency services for PRCS
Coordinate entry operations
Review this policy annually and following any incidents or near misses
For every permit-required confined space entry, the entry employer will assign an entry supervisor who has the ability to complete the following responsibilities:
Knowing the hazards of the confined space
Verifying the permit is completed correctly
Ordering evacuation and cancelling or suspending the permit
Communicating with and verifying the availability of emergency and rescue services
Removing anyone unauthorized who tries to go into a permit space
Assessing the permit-confined space when taking over responsibility and periodically as needed
Entry supervisors will know and understand which potential hazards are in each confined space such as: how entrants could be exposed, signs, symptoms, and consequences. The entry supervisor will be someone who knows at least as much as the authorized entrants and attendants, and should be someone who knows even more about the space and hazards.
Before signing it, the appointed supervisor will check the completed permit to be sure everything identified in the permit is correct: tests completed, procedures followed, and equipment in place.
The entry supervisor is responsible for deciding when there are unsafe conditions for an ongoing permit entry, terminating the entry, and then cancelling or suspending a permit. A permit can be cancelled when the entry permit is completed or there is a new condition not addressed in the permit. The supervisor can also suspend a permit if a condition requires temporary evacuation, and the space soon returns to acceptable conditions in the permit. After reevaluating the permit space, the entry supervisor can remove the suspension but will record it on the permit.
The entry supervisor will check that needed emergency and rescue services are available, can be reached, and can themselves respond in a timely manner during the permit-required confined space entry.
An attendant’s primary responsibility is to evaluate and protect authorized entrants inside permit required confined spaces. These responsibilities include:
Knowing the hazards of the confined space
Keeping track of authorized entrants
Remaining outside permit spaces during entry and communicating with entrants. Assessing the confined space conditions
Ordering necessary evacuations
Calling emergency services
Keeping unauthorized entrants out
Focusing exclusively on primary responsibility
Attendants will know and understand which potential hazards are in each confined space such as: how entrants could be exposed, signs, symptoms, and consequences. This includes knowing how the hazard could affect entrants’ behavior.
Attendants will also continuously track authorized entrants in the permit space, and accurately document it on the permit.
An attendant must stay outside the permit space during an entry, even during emergencies regardless of whether entrants can escape, until relieved by another attendant. Once another attendant is on the scene, the attendant still can only try an entry rescue if they have the necessary equipment, are trained to do so, and the entry permit allows for it.
Communication includes working with the entrant to instill awareness of personal health in light of the potential hazards, the confined space conditions, and when to evacuate.
The attendant is responsible for determining when a confined space is no longer safe and ordering entrants to evacuate whenever: there is a prohibited condition, the entrant is showing behavioral effects of exposure, something outside the confined space could be dangerous to entrants, or if the attendant can’t focus on all required responsibilities.
As soon as the attendant assesses that entrants need help to evacuate the permit space, he/she will immediately call rescue and emergency services as described in the permit and start non-entry rescue established in the permit. When an unauthorized person approaches a confined space, the attendant will tell him/her to exit immediately. The attendant will tell the entrants and supervisor there is an unauthorized person in the permit space.
Attendants will not be assigned or allowed to do any work that takes their attention away from their focus on the confined space and the safety of people inside and outside it. This means attendants can do tasks that add to their knowledge of permit space conditions, like monitoring atmospheric conditions or passing tools to entrants from outside the space. Although this knowledge can be part of the job description, tasks that do not require continued attention away from or leaving the permit-required confined space are not included.
The entry supervisor is responsible for preventing unauthorized entry into a permit space and immediately removing from the worksite any unauthorized person who has entered a permit space.
When taking over responsibility of a permit space entry, the new entry supervisor will check the confined space conditions to make sure they are within safe levels and consistent with the permit. The entry supervisor is also responsible for periodically assessing the hazards and work within a confined space as often determined necessary according to the nature of the possible hazards and expected change of conditions.
SAFE PERMIT SPACE ENTRY OPERATIONS
A competent person will identify and evaluate permit space hazards before any employees enter it and establish all the elements to ensure safe work in the area, especially
Citing the acceptable entry conditions
Authorized entrants can observe space testing and monitoring
Isolating the space and its hazards
Controlling atmospheric hazards through purging, inerting, flushing, or ventilating
Reducing the atmosphere to below 10 percent of its Lower Flammable Limit (LFL) or inerting the atmosphere so that it is entirely non-combustible and addressing the other atmospheric hazards like oxygen deficiency through PPE
Ensuring monitoring procedures will detect atmospheric hazard level increases quickly enough for entrants to exit, in case ventilation stops working
Having necessary barriers to protect entrants from outside hazards, namely pedestrian and vehicle barriers
Conditions continue to allow safe entry the entire time
The necessary PPE effectively protects every employee, and that they have the PPE before entering a hazardous atmosphere
Conditions, like high pressure, that can make removing an entrance cover unsafe are eliminated
Authorized entrants will know and understand which potential hazards are in each confined space such as: how they could be exposed, signs, symptoms, and consequences.
Entrants are expected to properly use all equipment, communicate with attendant, and be ready to exit any permit space quickly.
Communication includes working with the attendant to instill awareness of personal health in light of the potential hazards. This awareness includes sharing information with the attendant about any symptoms, warning signs or prohibited conditions. The entrant must exit permit spaces when told to by the attendant or entry supervisor; if there is an exposure warning sign or symptom; if they detect a prohibited condition; or if an evacuation alarm is activated.
As an entry employer, the company will provide suitable equipment needed to safely enter, exit from, and conduct rescues in confined spaces. The equipment will also be properly maintained and all employees will know how to and be expected to use it correctly. Any equipment must also meet the regulations specific to it. For example, respiratory equipment must meet the respiratory regulations, 1926.103, and barriers are governed by the rules for guardrails, 1926.502(b).
The following equipment is specifically mentioned by CAL-OSHA:
Adequate testing and monitoring equipment
Ventilating equipment that makes entering possible
Communication equipment that allows attendant to talk to entrants, assess status, and tell them to evacuate
PPE that meets any other applicable regulations where engineering and administrative controls do not give enough protection
Lighting that meets construction’s minimum illumination in foot-candles (1926.56), that won’t ignite the specific gas, vapor, dust or fiber present, and that enables employees to work safely and exit during emergencies
Barriers and shields that effectively isolate the confined space
Ladders needed to enter and exit the confined space
Rescue and emergency equipment that is called for in the company’s emergency rescue policy