OSHA Regulations on Confined Space Entry can seem complicated and difficult to understand why they are necessary. The following overview is an attempt to provide context to the rules and procedures. Be aware that the next time you read about a confined space fatality, at least one of these general rules was probably violated. So, do your best to ensure that it won’t ever happen at your city.
Atmospheric monitoring is the first and most critical rule as most fatalities in confined spaces are the result of atmospheric problems. Remember your nose is not a gas detector! Some hazards will have characteristic odors, but others will not. Use a properly calibrated 4-gas meter continuously during the confined space entry.
1. Monitor the atmosphere
All hazards identified during the hazard assessment must be eliminated or controlled prior to entering the space. Elimination, the preferred method for dealing with hazards, means that a hazard has been handled in a way that it cannot possibly have an impact on the operation.
2. Eliminate or control hazards
For example, a properly installed blank eliminates the hazard of material being introduced through a pipe. Ventilation can also control the build-up of a dangerous atmosphere during an entry.
Your approach to atmospheric problems should be to correct the condition prior to entry, and ventilation and related activities are the best options for correcting these problems. Forced-air ventilation is generally the most effective approach for confined space entry operations.
3. Ventilate the space
Proper personal protective equipment (PPE) should be the last line of defense. Elimination and control of hazards should be done whenever possible, but PPE is essential when the hazards present cannot be eliminated or controlled through other means.
4. Use proper personal protective equipment
Isolation of the space should eliminate the opportunity for introducing additional hazards through external connections. This includes lockout of all powered devices associated with the space, such as electrical, pneumatic, hydraulic, and gaseous agent fire control systems.
5. Isolate the space
An outside attendant must be present to monitor the safety of the entry operation, to help during an emergency, and to call for assistance from outside if that becomes necessary. The attendant’s role is primarily to help ensure that problems do not escalate to the point where rescue is needed.
6. Know the attendant’s role
Any equipment required for rescue must be available to those who are designated to use it. External retrieval equipment that may be used by the attendant must be in place when appropriate. More advanced rescue equipment for entry-type rescues must be available to the designated rescue crew.
7. Be prepared for rescues
Lighting is important for two primary reasons: You cannot safely perform in environments where you cannot see adequately, and lighting failure can cause fear. Anyone who is uncomfortable inside a well-lit confined space may become afraid if the lighting fails, and fear can cause people to behave irrationally and injure themselves or others.
8. Use effective lighting
Effective communications are critical to safe operation and are the string that ties all the other activities together. Communication must be maintained between entrants and the attendant. The attendant must also be able to contact the entry supervisor and call for emergency help.
9. Emphasize constant communication
The safest way to reduce the hazard of confined space entry is to not do it. Developing an alternative method where employee do not enter confined spaces at all, or as often, such as: lifting pumps out of confined space, remote grease fitting, remote meters, vacuum extractors, etc. can all help in achieving this goal.
10. Eliminate the entry
LMCIT Model Permit Required Confined Space Entry Policy
By: Joe Ingebrand
Editor's Note: Don't forget that OSHA's new crystalline silica rule is set to go into effect soon. It was originally slated to go into effect at the end of June, however enforcement was delayed to provide for employee education. It is now set to start being enforced starting September 23, 2017.
We previously published a blog back in May on the rule change should you need a brief reminder of what the new standard entails.