Confined Space Safety Management
Greg Daugherty, CSP, OHST, CHST
Confined spaces represent a major hazard at many operations. Managing confined spaces and entry is required to reduce the risk and ensure employee safety.
The confined space standard (29 CFR 1910.146) is confusing to understand, but the first step is to understand what a confined space is.
A confined space is defined as an area that meets all three of the following:
- Is large enough for an employee to bodily enter and perform work. Keep in mind that entry means breaking the plane of the opening, i.e. reaching in.
- Has limited or restricted means of entry or exit.
- Is not designed for continuous employee occupancy.
In most cases a confined space is easy to identify based on the three criteria. But identifying the space as a Permit Required Confined Space (PRCS) is not so easy in all cases. The best rule of thumb is to consider all confined spaces as a PRCS until you prove it is not via testing and evaluation.
A PRCS is a confined space that has one or more of the following:
- Contains, or has the known potential to contain, a hazardous atmosphere. This includes explosive, toxic and/or oxygen deficient or oxygen enriched.
- Contains material with engulfment potential. This means being buried by a solid or liquid.
- Has an internal configuration such that entrants could be trapped or asphyxiated by inwardly converging walls, or a floor which slopes and tapers to a smaller cross-section. Think of a V-shaped bottom vessel like a silo or hopper.
- Contains any other recognized serious safety or health hazard. The first one that should be considered is hazardous energy sources (lockout, tagout hazards). Are there any flow lines, mechanical movements, electrical hazards, rotating drums, etc?
Once the space is identified as a PRCS, you must inform exposed employees by posting signs, labeling it at the opening, or by other effective means. A sign or label reading Danger, Permit Required Confined Space, Do Not Enter at or near the entry is most effective.
The next step in managing your confined spaces is to make a decision on whether employees will be authorized to enter these spaces to perform necessary tasks, such as inspection, maintenance, or cleaning.
If the decision is to allow employees to enter, a policy and procedures for entry should be developed. The policy must describe when entry is allowed, the training required, the safety measures that must be in place prior to and during entry, roles and responsibilities, rescue resources and the permit process. All of these are required by the OSHA standard.
The permitting process is a must. It is a documented safety checklist and approval form that each affected member of the entry team (supervisor, entrant, and attendant) must review, and based on the information provided on the permit, agree that the PRCS is safe to enter.
In addition, the qualified confined space supervisor must sign the permit indicating that they have reviewed the confined space and the permit and that the employees are qualified to be on the entry team and that it is safe to enter. Identifying how to safely enter the PRCS is different for each space and depends on the space configuration, any hazardous materials, atmospheric hazards, flow line lockout, etc. As a best management practice, a job safety analysis should be developed, followed, for each space as part of the policy and procedure.
Once the entry is complete, the permit must be closed out and kept on file for at least 12 months. Compliant confined space management takes substantial time, but the consequences of not managing them properly by ensuring the safety of the employees and compliance with the standards can be devastating.
Greg Daugherty, CSP, OHST, CHST
Greg is a Sr. Safety Consultant at J. J. Keller & Associates. With over 30 years of health and safety and OSHA and MSHA compliance experience, he combines regulatory knowledge with extensive industry experience to provide guidance for achieving and maintaining safety compliance. Meet Greg.
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