Confined Space Entry Training and Workshop

Confined Space Entry Training and Workshop Consultation Education & Training Division Michigan Occupational Safety & Health Administration Michigan Department of Licensing and Regulatory Affairs www.michigan.gov/miosha (517) 284-7720 SP #28 (Revised 04/04) TABLE OF CONTENTS Part 90 Confined Space Entry and Other Confined Space Related Safety & Health Standards Permit Required Confined Space Identify & Classify .24 Confined Space Hazards 62 Compliance Resources .76 Duties of Entry Supervisor, Attendant, Authorized Entrant 120 Help on the Internet .128 Part 90 Confined Space Entry And Other Confined Space Related Safety And Health Standards [Reserved for MIOSHA Standard Part 90 Confined Space Entry and Part 490 Permit-Required Confined Spaces] Pages 3-22 Permit Required Confined Space Identify & Classify [Reserved for Permit Required Confined Spaces: Identify and Classify slide/PowerPoint presentation] Pages 24-38 PART 90 - CONFINED SPACE ENTRY Samples of Confined Spaces for Evaluation and Classification Space #1 This space is a fresh-water, residential well 40-feet deep and 36 inches wide Usually it contains about 20 feet of water Concrete casings support the sides of the well, while the well floor is exposed soil to allow flow of groundwater, which is 35 - 40F General maintenance requires that the existing water be pumped out and the employee be lowered to the bottom to brush down the concrete casings using well water and shovel muck from the well floor Space #2 This space is a water meter pit, concrete lined, that is feet x 12 feet x 10 feet deep (about 960 sq ft.) It is accessed by a manhole cover leading to a vertical, fixed ladder Employees enter to take meter readings for the fire suppression water system The firm is located in Dearborn, an area known to have a lot of methane and hydrogen sulfide soil gases Space #3 This is a sulfuric acid storage tank made of stainless steel It measures 12 feet x 18 feet and 12 feet deep (about 2592 sq ft.) It is accessed by an 18 inch hatchway located on the top At the bottom of the tank is a small agitator blade near the drain pipe, which leads to a tank inside the plant for parts cleaning The acid is delivered by tanker trucks at which time the in-take valve cover is opened and the truck’s supply pipe is connected About once a year the tank is emptied and cleaned out, at which time the agitator is p.m.’d WORKPLACE EVALUATION FOR THE EXISTENCE OF PERMIT REQUIRED CONFINED SPACES Date of Survey and Signature of Surveyor Space Name / Location and Description Confined Space? YES / NO If answer YES to all 3, then this is a confined space Permit Required Confined Space? If #3 is Yes, and one of these conditions is Yes, then this is a Permit Required Confined Space (PRCS), so continue to #5 5A Indicate Actual or Potential Atmospheric Hazards 5B Indicate Physical Hazards and Identify Source 6A Can you Control Atmospheric Hazards Listed in 5A with Continuous Forced-Air Ventilation? YES / NO 6B Can you Eliminate Physical Hazards Listed in 5B without Entering the Space? YES / NO Circle to Indicate the Type of Space This is: (c5) (c7) (Full Permit) Is the space large enough and so configured that an employee can bodily enter and perform assigned work? YES / NO Does the space have limited or restricted means for entry or exit? YES / NO Is the space not designed for continuous employee occupancy? YES / NO Does it contain of have the potential to contain a hazardous atmosphere? YES / NO Does it contain a material that has the potential for engulfing an entrant? YES /NO Does it have an internal configuration such that an entrant could be trapped or asphyxiated by inwardly converging walls or by a floor that slopes downward and tapers to a smaller cross-section? YES / NO Does it contain any other recognized serious safety or health hazard? YES / NO _ Oxygen deficiency _ (19.5% to 23.5%) _ Flammable Substances _ (less than 10% of LFL) _ Toxic Materials _ (not to exceed PELs) _ Carbon Monoxide _ (CO 35 PPM) _ Hydrogen Sulfide _ (H2S 10 PPM) _ Other _ Flowable Substances Noise Inwardly Converging Walls Heat/Cold Floor Slopes Downward Radiation Mechanical Hazards Asbestos Electrical Hazards Wet/Slippery Conditions Hot Work Traffic Reduced Visibility Other If YES and there are no physical hazards in the space, then you may use the alternate procedures for entering the space by completing the steps defined in paragraph (c5) of the standard before each and every entry Written certification of each entry must be documented and maintained The steps required to control the atmosphere must be part of your written Confined Space Program Once the space is closed back up, this is a Permit Required Confined Space requiring that all of there steps be followed the next time employee enters If YES and there are no atmospheric hazards in space, then you may re-classify to a non-permit space and enter according to paragraph (c7) of the standard The steps required to eliminate the hazard (usually Lockout/Tagout procedures) must be part of, or referenced by, your written Confined Space Program Once the hazard has been reintroduced, this is a Permit Required Confined Space requiring that all steps be followed the next time employee enters If you cannot eliminate the hazards using c7 to Reclassify and/or control the atmospheric hazards by using the Alternate Procedures - c5, then a FULL PERMIT ENTRY PROCEDURE (paragraphs d-k) must be used to enter the space REMEMBER! IF CONDITIONS CHANGES, RE-EVALUATE! Part 90-Confined Space Entry Adopted from 1910.146 Permit Required Confined Spaces Top Violations-October 1, 1996-September 30, 1997 1) Rule (c)(1) Evaluate the workplace to determine if any spaces are permit-required confined spaces 2) Rule (c)(2) Develop and implement a permit-required confined space program that complies with this standard This program must be in writing and it must delineate whether each entry is going to be certified by use of the full permit system as detailed in paragraph (d), the alternate procedures in paragraph (c)(5), or reclassified in accordance with paragraph (c)(7) 3) Rule (c)(2) Inform exposed employees by posting danger signs, or by any other equally effective means, of the existence, locations, and dangers of the confined spaces 4) Rule (g)(1) Provide training so that all employees whose work is regulated by the permit-required confined space standard acquire the understanding, knowledge, and skills necessary for the safe performance of their assigned duties 5) Rule (c)(3) Take effective measures to prevent employees from entering permit-required confined spaces when it has been decided that employees will not enter the spaces 6) Rule (d)(4) Provide at no cost to the employee, maintain, and ensure proper use of all equipment necessary for the safe entry into and rescue from permit-required confined spaces 7) Rule (k)(1) Ensure that employees that enter permit-required confined spaces to perform rescue services are properly equipped and properly trained, and have practiced a rescue within the last 12 months 8) Rule (k)(2) Ensure that any outside employer that may be called upon to provide rescue services has been informed of the hazards and provided with access to all the permit required confined spaces in order to develop and practice rescue plans 9) Rule (g)(4) Maintain proper certification that all training required by paragraphs (g)(1), (g)(2), and (g)(3) has been accomplished Part 90-Confined Space Entry Top Violations Compliance Resources Rule (c)(1) Evaluation form OH-5310 “Confined Space Hazards” “Examples of Spaces Found in the Workplace” Rule (c)(4) Standard Outline Checklist Required Components OH-5330 “Guidelines…Written Program” OH-5310 “General Compliance Checklist” OH-5320 “Alternate Entry Procedure Action Agenda” Rule (c)(2) Sample sign “Confined Space” Additional Training for Employees Rule (g)(1) OH-5330, Section IX of the Written Program Rule (c)(3) Lock, bolt, screw, somehow secure it closed, post or train, etc Rule (d)(4) Testing equipment, harnesses, ropes, PPE, tri-pod, lights, respirators, all equipment deemed necessary by documented entry procedures Rule (k)(1) OH-5380 OH-5381 OH-5330, Section X of the Written Program Rule (k)(2) OH-5380 OH-5381 OH-5330, Section X of the Written Program Rule (g)(4) OH-9330, Appendix D *All referenced materials are included in this handout ITEM 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 56 DESCRIPTION Section D- continued (8) Persons with active roles designated? (entrants, attendants, testers, etc.) (9) Systems for summoning rescue and emergency services developed and implemented? (10) System for preparation, issuance and cancellation of permits developed and implemented? (11) Method of coordinating entry operations involving more than one employer developed and implemented? (12) Methods developed for closing of space and canceling permits? (13) Entry operations reviewed to assure that procedures protect employees in the confined space? (14) Program reviewed annually and revised when required? Section E - Permit System (1) Entry permit prepared prior to entry? (2) Permit signed by entry supervisor? (3) Permit available to all authorized entrants? (i.e post at entrance) (4) Duration of permit does not exceed time to complete the assigned job? (5) Entry terminated when: (i) Entry operations covered by permit are completed? (ii) A condition that is not allowed under the entry permit arises in or near the space? (6) Cancelled entry permits retained for at least one year? Problems encountered during entry noted on permit? Section F – Entry Permit Entry permit that documents compliance must identify: (1) The permit space to be entered? (2) The purpose of the entry? (3) The date and authorized duration of the entry permit? (4) Identification of entrants? (5) Name of attendant(s)? (6) Name of entry supervisor? (7) Hazard(s) of the permit space to be entered? (8) Measures used to isolate space? (9) Acceptable entry conditions? (10) Results of initial and periodic tests? YES NO N/A Part 90-Permit-Required CONFINED SPACE ENTRY (adopting Fed.Std.1910.146) Standard Outline Checklist – Page ITEM DESCRIPTION 57 (11) Emergency and rescue services that can be summoned, the means and telephone numbers? (12) Communication procedures used by entrants? (13) Equipment provided, such as PPE, testing equipment, communications equipment? (14) Information on special conditions that may affect safety of entrants? (15) Any additional permits that have been authorized for work in the space? Section G – Training (2) All affected employees received required training? (i) Before assigned duties in confined space? (ii) Before a change in assigned duties? (iii) Whenever a change occurs in the permit space that was not included in the original training? (iv)Whenever there are inadequacies in employee knowledge or use of these procedures? (3) Employee proficiency established by training? (4) Certification of training by employer? Section H – Duties of Authorized Entrants (1) Aware of all hazards faced during entry (mode, signs, symptoms & consequences of exposure? (2) Aware of how to use equipment properly as required by (d)(4)? (3) Communicate with Attendant (monitor status and alert need to evacuate)? (4) Alert the attendant if: (i) Entrant recognizes any warning sign or symptom of danger? (ii) Entrant detects a prohibited condition? (5) Entrant knows how to exit from the permit space as quickly as possible? (i) If an order to evacuate is given by the Attendant or Entry Supervisor? (ii) If the Entrant recognizes any warning signs or symptoms of danger? (iii) If the Entrant detects a prohibited condition> (iv) If the evacuation alarm is activated? 58 59 60 61 62 63 64 65 66 67 68 69 70 71 72 73 74 75 76 77 78 79 YES NO N/A Part 90-Permit-Required CONFINED SPACE ENTRY (adopting Fed.Std.1910.146) Standard Outline Checklist – Page ITEM 80 81 82 83 84 85 86 87 88 89 89 90 91 92 93 94 95 96 97 98 DESCRIPTION Section I – Duties of Attendants (1) Knows the hazards that will be faced? (2) Aware of behavioral effects of hazards exposure? (3) Maintains accurate count of Entrants & able to identify Authorized Entrants? (4) Remains outside of the permit space(s) until relieved? (5) Maintains communication with Entrants as necessary to monitor Entrants status? (6) Monitors activities inside and outside of space to determine if it’s safe to Entrants to remain? Evacuates permit space immediately under the following conditions: (i) If the Attendant detects a prohibited condition? (ii) If the Attendant detects the behavioral effects of hazard exposure in an Authorized Entrant? (iii) If the Attendant detects a situation outside the space that could endanger the authorized entrants? (iv) If the Attendant cannot effectively and safely perform all the duties? (7) Summons rescue and other emergency services as soon as danger is discovered? (8) Take the appropriate actions when unauthorized persons approach or enter a permit space while entry is underway? (9) Perform non-entry rescue as specified by employer’s procedures? (10) Perform no other duties that might interfere with Attendants primary duty to monitor and protect the entrants? Section J – Duties of Entry Supervisor (1) Knowledge of hazards that may be faced upon entry? (2) Verifies that proper entries have been made on the permit? (3) Terminates entry and cancels permit as required? (4) Verifies that rescue services are available and that means of summoning them are operable? (5) Removes unauthorized persons who enter or attempt to enter the permit space during entry operations? (6) Determines whenever permit entry operation is transferred, that entry operations remain constant and conditions remain acceptable? YES NO N/A Part 90-Permit-Required CONFINED SPACE ENTRY (adopting Fed.Std.1910.146) Standard Outline Checklist – Page ITEM 99 100 101 102 103 104 105 106 107 108 DESCRIPTION YES NO Section K – Rescue and Emergency Service (1) Employer has employees enter permit spaces to perform rescue services (i) Each member of rescue service is provided with and trained in the use of PPE and required rescue equipment? (ii) Each member of rescue service is trained to perform the assigned duties? (iv) Each member of rescue service is trained in basic first aid and CPR At least one member holding a current certification for first aid and CPR shall be available? (2) Employer (host) has off-site rescue service to perform rescue? (i) Inform rescue service of hazards they may confront? (ii) Provide access to all permit spaces from which rescue may be necessary to develop plans and practice? (3) Retrieval systems shall be used whenever possible to facilitate non-entry rescue? (i) Entrants use chest or full-body harness, retrieval line? (ii) Line attached to fixed point or mechanical device? Part 90-Permit-Required CONFINED SPACE ENTRY (adopting Fed.Std.1910.146) N/A Standard Outline Checklist – Page Answer these questions if you have chosen to use Alternate Procedures, C5, instead of a full permit entry ITEM DESCRIPTION Section C Subparagraph – Alternate Procedures (C5 Entry) (i) An employer need not comply with paragraphs d through f and h through k if: (A) Employer can demonstrate that the only hazard is an actual or potential hazardous atmosphere? (B) Employer can demonstrate that forced air ventilation alone is sufficient to maintain the space for entry? (C) Monitoring and inspection data developed to support A and B? 7 10 11 12 13 14 15 16 17 18 19 (D) Initial entry, if needed, is accomplished using the requirements of paragraphs d through k (E) Determinations and supporting documents are provided to each employee who enters the permit space? (F) Entry into the space is performed under the terms of paragraph c(5) (ii)? (5)(ii) Requirements to enter space under (c)(5)(ii) are: (A) Conditions that make it unsafe to remove cover are eliminated before cover is removed? (B) Opening promptly guarded by railing or temporary barrier? (C) Internal atmosphere tested prior to entry? In order of: (1) Oxygen content, (2) Flammable gases and vapors, and (3) Potential toxic air contaminants (D) Absence of any hazardous atmosphere in space when entered by employee? (E) Continuous forced air ventilation? (F) Periodic testing of air in space? (G) Evacuation if hazardous atmosphere is detected? (H) Employer verifies that space is safe for entry and that all requirements under this paragraph have been met in writing? (6) Employer reevaluates space when changes in use or configuration that might increase hazards? YES NO N/A Part 90-Permit-Required CONFINED SPACE ENTRY (adopting Fed.Std.1910.146) Standard Outline Checklist – Page Answer these questions if you have chosen to Reclassify as a Non-Permit Confined Space using C7, instead of a full permit entry ITEM DESCRIPTION YES NO N/A Section C Subparagraph 7– Alternate Procedures (C7Entry) (7) An employer may reclassify as a non-permit confined space under following procedures: (i) The permit space poses no actual or potential atmospheric hazards and all hazards are eliminated without entry into the space? (ii) Entry to eliminate hazards, if needed, is performed under paragraphs d through k? (iii) Employer documents basis for determining all hazards eliminated through written certification? (iv) Reevaluate space if hazards arise while declassified? Answer these questions if you (Host Employer) arrange to have employees of another employer (Contractor) perform work involving permit space entry C8 and C9 ITEM DESCRIPTION Section C Subparagraph – Host to Contractor (i) Informed contractor of permit spaces and of need to comply with permit program? (ii) Apprise contractor of hazards and host’s experience with space? (iii) Apprise contractor of implemented precautions or procedures in or near space? (iv) Debrief contractor of at conclusion of entry regarding hazards confronted or created? Section C Subparagraph – Contractor(s) to Host (i) Obtain information regarding permit space hazards from host? (ii) Coordinate entry with host when host and contractor personnel working in or near permit space, as required by paragraph (d)(11)? (iii) Inform host of permit space program to be followed, and debrief regarding any hazards confronted or created? YES NO N/A [Reserved for the following MIOSHA CET Publications] Permit Required Confined Space General Compliance Checklist For MIOSHA Permit Required Confined Space Entry Alternate Entry Procedure (C)(5) Action Agenda For MIOSHA Permit Required Confined Space Entry Guidelines for a Permit Required Confined Space Entry Written Program Rescue Service Decision Logic For MIOSHA Permit Required Confined Spaces Rescue Service Requirements For MIOSHA Permit Required Confined Spaces 5310 5320 5330 5380 5381 Duties Of Entry Supervisor Attendant Authorized Entrant [Reserved for the "Permit Required Confined Space: Duties of Supervisor, Attendant and Authorized Entrant" PowerPoint slide presentation] Help On The Internet Internet Sites of Interest The federal OSHA (and MIOSHA) Permit-Required Confined Space Standard – 29 CFR 1910.146: http://www.osha.gov/pls/oshaweb/owastand.display_standard_group? p_toc_level=1&p_part_number=1910 http://www.michigan.gov/documents/CIS_WSH_part490_55724_7.pdf 29 CFR Part 1915, Subpart B, Confined and Enclosed Spaces and Other Dangerous Atmospheres in Shipyard Employment CPL 02-01-042, (2005, September 7): http://www.osha.gov/pls/oshaweb/owadisp.show_document? p_table=DIRECTIVES&p_id=3308 MIOSHA’s Website: http://www.michigan.gov/miosha Michigan State University’s Confined Space Entry Program: http://www.orcbs.msu.edu/occupational/programs_guidelines/confined_space/cs_05responsi bilities.htm Miscellaneous Confined Space Entry Web Site Links: http://ehs.okstate.edu/links/conspace.htm Virginia Tech’s Confined Space Entry Program Environmental Health and Safety Service: http://www.ehss.vt.edu/programs/confined_spaces.php Vermont SIRI- Safety Information on the Internet (A great site for finding MSDSs!) http://www.siri.org Confined Spaces - Source USDOL website: http://www.osha.gov/SLTC/confinedspaces/index.html Compliance  The OSHA Unified Agenda (1997, October 29) has identified Confined Space standards for additional rulemaking Confined Spaces for Construction (Part 1926) (Construction: Preventing Suffocation/Explosions in Confined Spaces), page Permit Required Confined Spaces (General Industry: Preventing Suffocation/Explosions in Confined Spaces), page OSHA Standards General Industry http://www.osha.gov/pls/oshaweb/owasrch.search_form? p_doc_type=STANDARDS&p_toc_level=1&p_keyvalue=1910 Construction http://www.osha.gov/pls/oshaweb/owasrch.search_form? p_doc_type=STANDARDS&p_toc_level=1&p_keyvalue=Construction Maritime http://www.osha.gov/pls/oshaweb/owasrch.search_form? p_doc_type=STANDARDS&p_toc_level=1&p_keyvalue=Maritime [Reserved for "OSHA Hazard Information Bulletin Asphyxiation Hazard in Pits: Potential Confined Apace Problem" June 13, 1996] Michigan Department of Licensing and Regulatory Affairs Michigan Occupational Safety & Health Administration Consultation Education & Training Division 525 W Allegan Street, P.O Box 30643 Lansing, Michigan 48909-8143 For further information or to request consultation, education and training services call (517) 284-7720 or visit our website at www.michigan.gov/miosha www.michigan.gov/lara LARA is an equal opportunity employer/program Auxiliary aids, services and other reasonable accommodations are available upon request to individuals with disabilities ... CONTENTS Part 90 Confined Space Entry and Other Confined Space Related Safety & Health Standards Permit Required Confined Space Identify & Classify .24 Confined Space Hazards ... MIOSHA Standard Part 90 Confined Space Entry and Part 490 Permit-Required Confined Spaces] Pages 3-22 Permit Required Confined Space Identify & Classify [Reserved for Permit Required Confined Spaces:... (j) - Entry Supervisor (k) - Training This chart is a guideline, it does not take place of reading and understanding the standard: Part 90 -Confined Space Entry Part 90- CONFINED SPACE ENTRY