Confined Space Training

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Confined Space Training

Regulations are changing

– New rule eliminates the distinction between a

required confined space (permit space) and a non permit-required confined space. q p

– Under this rule, a space with no actual or potential hazards is a confined space. A space with actual or potential hazards is

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a permit-required confined space.

– Also eliminated and combined the frequently confusing

language of alternate entry and permit space reclassification. g g y p p

Under the new regulations, a permit space is always a permit space, and can only be entered with a permit or under Alternate Entry Procedures.

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Who must comply?

All workplaces must be evaluated to

determine if there are any confined

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spaces on site, and if any of those spaces

are permit spaces.

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Biggest Change?

ALTERNATE ENTRY PROVISIONS

The space is still classified as permit required confined space but alternate methods are allowed for entry. y

Alternate entry is allowed when all hazards have been eliminated, or all physical hazards are eliminated and all

atmospheric hazards are controlled with constant ventilation and checked/verified with constant monitoring.

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ALSO REQUIRED

UNDER ALTERNATE ENTRY PROVISIONS:

The entrant must have an effective means to

communicate with others outside of the space to

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summon help if necessary

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Employee Training Required

Awareness training is required for all employees who g q p y work around permit spaces so they can:

 Readily identify permit spaces  Readily identify permit spaces

 Understand the process for how those spaces are entered, and

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Hazards of Confined Spaces

Basic Principlesp

• Confined spaces can be deadly

• Some confined spaces are more hazardous than othersp

• Confined space conditions can change rapidly from no hazards to life-threatening hazards

• Some confined spaces are so hazardous, a written permit

system is required for entry. These spaces are Permit Required Confined Spaces (PRCS)

Confined Spaces (PRCS)

• The hazards of confined spaces can often be controlled or eliminated before entering

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Examples of Confined Spaces

Compactor Tubes _{Utility Vaults & Manholes}

Truck Hopper

Some Pits Tanks &

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What is a Confined Space?

A confined space is a

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space that:

1. Is large enough to get

h

h l b d i id

the whole body inside,

AND

2 Has limited means of

2. Has limited means of

entry or exit, AND

3. Is not designed for

.

s o des g ed o

continuous employee

occupancy

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Confined Space

1. Is large enough and so configured that an employee

can get their whole body inside and perform work

NO

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Confined Space

2. Has limited or restricted entry or exit

Th bilit t il i The ability to easily escape is impeded by such obstacles as:

•a small door or opening •a small door or opening •a ladder

•a manhole •a long tunnel •Or…

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Confined Space

• a drop to a lower level

Yes

No Maybe

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What is a Permit Required Confined

Space (PRCS)?

A PRCS is a confined space PLUS it:

• Contains or has the potential to contain a hazardous atmosphere, and/or

• Contains a material that can engulf someone in the space, and/or

• Has an internal configuration that can trap

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or asphyxiate (inwardly converging walls or a floor which tapers to a smaller cross section) and/or

C t i th i f t h lth • Contains any other serious safety or health hazard such as moving parts or electricity.

Only one of these needs to be present for the space to be Only one of these needs to be present for the space to be classified as Permit Required Confined Space.

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Hazard Identification

Atmospheric hazards include:

• Oxygen deficient atmosphere (depletion by

rusting or replacement by other gases)

• Flammable atmospheres

• Carbon monoxide, hydrogen sulfide or other

toxic materials

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Hazard Identification

Hazardous Atmospheres – Carbon Monoxide (CO)

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•Carbon monoxide comes from operating internal combustion engines in or near confined space.

Propane-powered manlift in a large tank

•Propane-powered engines also emit carbon monoxide.

•Fatal levels of CO are quickly Fatal levels of CO are quickly reached in confined spaces.

Generators, heaters & vehicle exhaust & vehicle exhaust

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Hazard Identification

What are the Hazards of Engulfing Material?

Engulfing materials include liquids or loose solids such as grain, sand or

th l t i l

other granular material.

P l t h ht

People cannot escape when caught in moving loose solids and usually suffocate.

Workers often get engulfed when in-feed or out-feed lines are

in-feed or out-feed lines are

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Hazard Identification

What is Entrapment?

The space is configured in a way that can trap a worker The space is configured in a way that can trap a worker,

for example, sides sloping towards the center

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Hazard Identification

Other Recognized Hazards

Potential contact with live electrical or steam lines

Mechanical hazards Mechanical hazards (moving parts-blade)

Hazards caused by the work Hazards caused by the work (welding, painting etc.)

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What makes this a Permit Required

Confined Space?

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Employer Responsibilities

Actions we need to take to protect our employees and meet

l i d 1910 146 P i

regulatory requirements under 1910.146, Permit Required Confined Spaces:

1. Evaluate the workplace to identify PRCS (see form) 2 P t i t th PRCS

2. Post signs at the PRCS

3. Determine if your employees must enter the PRCS

• ALTERNATE ENTRY can be used if all hazardous energy can be controlled (lockout/tagout) and if there is no hazardous atmosphere. controlled (lockout/tagout) and if there is no hazardous atmosphere. NOTE: If hazards cannot be eliminated, a written Permit Required Confined Space Program is required and you should consult with an expert.

4 Ensure you have written procedures for locking out each piece of 4. Ensure you have written procedures for locking out each piece of

equipment as required by OSHA regulation 1910.147, The Control of Hazardous Energies.

5. Train your employees on your policy, identification of confined spaces, t l f h d i d Alt t E t

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Hazard Assessment of Truck Bodies

• For post-trip cleaning, under normal solid waste

For post trip cleaning, under normal solid waste

collection activities with daily truck emptying, we

have determined that there is no potential for a

hazardous atmosphere inside packer bodies after the

load has been removed.

• If the load has been emptied and all physical hazards

have been eliminated by following proper lockout,

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th

b

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i

Alt

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the truck body may then be entered using Alternate

Entry.

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Example Company Policy

We have surveyed our equipment and facilities and identified the following as Permit Required Confined Spaces:

following as Permit Required Confined Spaces:

• Hopper of Trucks

It is the policy of this Company to NOT ALLOW ENTRY into Permit-p y p y Required Confined Spaces by ANY employees.

Truck hoppers are considered PRCS until the load is emptied and lock out procedures are performed to remove the mechanical hazard

out procedures are performed to remove the mechanical hazard from the packer. When proper lockout is performed and

documented, the truck hopper can be entered under Alternate Entry. Employees must have an effective means to communicate with others outside of the space to summon help if necessary

with others outside of the space to summon help if necessary Before entry into a truck body for cleaning or maintenance, all

employees are required to follow Company Procedures for locking p y q p y g out (control of hazardous energies) and Alternate Entry to the

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Eliminating the Hazard from the Truck Hopper Before Entering for Cleaning

• Remove keys from

ignition

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• Place keys in your

pocket

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ff b

i h

• Turn off battery switch

• Apply unique lock to

battery switch if another

key to the vehicle is

available

R di i

k t

• Radio in pocket

• When finished cleaning,

complete and sign

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g

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Controlling the Space

Warning employees and controlling access

Post warning signs at the entrance of confined spaces

Limit employee access to confined confined spaces.

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spaces by using entry barriers or locks. Make sure that unauthorized workers do Make sure that unauthorized workers do not enter the confined space.

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Documentation

• Alternate Entry may be used to enter a confined

space if the space poses no actual or potential

atmospheric hazards and all hazards are

eliminated without entry into the space.

• Alternate Entry requires that the employee have

the ability to communicate with others outside of

the space (cell phone or radio).

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Sample of Alternate Entry Form

Alt t E t f D i Fill i th bl k i l th t

Alternate Entry for Drivers: Fill in the blanks or circle the correct answer

1. Today’s Date: ___________ Entry time: _________ Stop Time: ______ 2. Space to be entered: Truck #_______________ Hopper

3. Purpose of the entry Cleaning 4. Hazards of the space: Crushing

5. Acceptable Entry Conditions Met? Lock out Verified? __ Keys removed __battery switch off

6. Radio in pocket p _______

7. Any Issues? ________________________________________________ 8. Employee Signature ___________________________________

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Other Requirements

• Under 1910.147, Control of Hazardous

Under 1910.147, Control of Hazardous

Energies you must conduct periodic

inspections (at least annually) of your energy

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(

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gy

control procedures.

• The employer must train and certify that

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employees have been trained.

• Employees must be retrained and proficiency

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re-established when there are changes or

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Hazard Control

Controlling Hazardous Atmospheres

If h ith

If you have a space with a

potential atmospheric hazard -consult an expert!!! p

•Drain or pump out liquid contents, if any.

•Blank off all in-feeding lines. •Air test and ventilate.

C ti til ti t tl •Continue ventilating constantly.

•If possible, remove any sludge while staying outside the space.

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Confined Space Quiz

Question 1

Which of following are considered Permit Required Confined Spaces?

Confined Spaces?

a) The hopper of a front end loader

b) A b b t lt ith l dd b) A sub-basement vault with ladder access c) A 20 foot deep ditch

d) A 40 yard drop box d) A 40 yard drop box

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Confined Spaces Quiz

Question 2

Which of the following is PRCS?

a) The hopper of a front end loader a) The hopper of a front end loader

b) A sub-basement vault with ladder access c) A 20 foot deep ditch