November/December 2012
Permit-required confined spaces can house invisible threats to workers. Entry takes planning, preparation, and strict adherence to proper procedures to keep employees safe.
By Diana Mota
ISRI Safety Outreach Manager Joe Bateman still recalls one of the first deaths at a scrapyard he helped investigate when he joined the ReMA staff four years ago. Working alone, an employee at a recycling facility had climbed down into the pit of a truck scale to clean it out. Fifteen minutes later, co-workers who came to check on him found him dead at the bottom of the pit. The investigation revealed that a forklift with an undetected propane gas leak had been sitting on the scale for nearly three hours earlier in the day. During that time, the propane—which weighs more than air—had leaked down into the pit, displacing the oxygen in the space. The young man most likely died within eight minutes of entering the pit, says Bateman, who shares that story every time he conducts confined-space safety training for ReMA members. The spaces can be deceiving, Bateman says, which is why recyclers need to take certain precautions when working in confined areas.
“Confined space is the No. 2 safety issue for our members—second only to lock-out/tag-out,” Bateman says. In safety terms, a confined space is one that hinders workers’ ability to move freely and potentially exposes them to situations that are immediately dangerous to life and health. Even when such spaces appear safe, the atmosphere inside them could be explosive or toxic. “Hundreds of workers in our industry go inside these spaces every day to perform maintenance or repair equipment,” Bateman says. “Sometimes they do the right thing before they go in, and sometimes they don’t.” When it’s the latter, workers and employers often find out the hard way these spaces hold life-threatening hazards, says John Gilstrap, ReMA director of safety. “When something goes wrong, it’s almost always a fatality or serious injury,” says Eric Berg, a senior safety engineer with California’s Division of Occupational Safety and Health (Oakland, Calif.), better known as Cal/OSHA.
In 1989, when the Occupational Safety and Health Administration (Washington, D.C.) proposed the confined-space standard that took effect in April 1993, more than 300 confined-space fatalities were occurring each year, says Sherman Williamson, an OSHA safety and health specialist. “That number has come down some,” Williamson says. In fact, the U.S. Bureau of Labor Statistics (Washington, D.C.) estimates there were an average of 101 deaths a year in the past eight years. The OSHA standard focuses on confined spaces with immediate health or safety risks, classifying them as permit-required confined spaces, Bateman says. Not all confined spaces are hazardous, Gilstrap points out. Employers should know how to locate, identify, and secure permit-required confined spaces in their facilities to comply with the law and keep their workers safe. In addition to facing hazards from toxic, flammable, explosive, or asphyxiating atmospheres, workers in confined spaces risk potential engulfment by material and or other serious hazards, such as electrocution.
Identifying Confined Spaces
Confined spaces come in a multitude of shapes, sizes, and configurations, which can make them difficult to identify. They can be above ground, below ground, and inside buildings or equipment. Even when employers recognize a confined space, “they sometimes are confused about whether it’s a permit-required space or a nonpermit space,” says Tony Samento of Samento Industrial Training Systems (Dillsburg, Pa.). For many, “it’s an unrecognized issue because going into the spaces is not an everyday occurrence,” says Alan Mesh, environmental health and safety director at General Iron Industries (Chicago). That’s part of the reason they can pose such great risks, says Jerry Heitman, safety director and environmental coordinator for Sadoff & Rudoy Industries (Fond du Lac, Wis.). “If you’re only [entering them] once or twice a year, that’s when problems happen.”
According to OSHA’s standard (available at www.osha.gov/SLTC/confinedspaces), a confined space is large enough for an employee to enter and perform assigned work; has limited or restricted means for entry or exit, such as a ladder; and is not designed for continuous employee occupancy. A permit-required confined space meets the above three requirements and has one or more of the following characteristics: It contains or has the potential to contain a hazardous atmosphere; it has material that could engulf an entrant; its internal configuration could trap or asphyxiate an entrant due to inwardly converging walls or a floor that slopes downward and tapers to a smaller cross-section; or it has other serious safety or health hazards. Typical permit-required confined spaces at recycling facilities include storage bins, shredders, trommels, cyclones, Z-boxes, bag houses, and oil-water separator systems for stormwater management, Bateman says.
The OSHA confined-space website has several tools to help employers identify confined spaces. The standard’s Appendix A contains a flow chart that asks a series of yes/no questions to identify spaces, says Art Buchanan, OSHA’s director of general industry and agricultural enforcement. OSHA’s Confined Spaces Advisor online software also can help (www.osha.gov/dts/osta/oshasoft/csa.html). Samento suggests that at least one employee at a facility take an advanced confined-space training course, which should help that person identify such spaces on a walk-through of his or her facility. OSHA consultation services also can address this issue, Berg says. Cal/OSHA made confined spaces a special emphasis program in 2012, after the state’s confined-space deaths increased from two each in 2008, 2009, and 2010 to seven in 2011.
Once you identify permit-required spaces, secure them to prevent unauthorized entry. Many companies lock the spaces and identify them with signs in applicable languages so exposed employees are aware of the dangers they pose, Williamson says. Even if you tell employees not to enter the space, you must take additional steps to prevent entry, he notes.
Identifying Hazards
Because the extent and types of hazards in confined spaces vary, it’s important to evaluate each space individually, Williamson says. Atmospheric hazards are the leading cause of confined-space deaths, Gilstrap says. An OSHA safety consultant, certified industrial hygienist, or other qualified safety professional can use atmospheric testing to either verify that acceptable conditions exist for entry into the space or evaluate the hazards and decide how the company will eliminate or control them.
“In our industry, the hazard is often oxygen deficiency,” Bateman says. Oxygen levels in a confined space should not fall below 19.5 percent or rise above 23.5 percent, he says. Exposure to atmospheres that are less than 8 to 10 percent oxygen “will bring about unconsciousness without warning and so quickly that the [exposed] individuals cannot help or protect themselves,” according to a bulletin from the Compressed Gas Association (Chantilly, Va.). “It’s not like you say, ‘Uh-oh, I’d better get out,’” Heitman says. “It’s more like [the lack of oxygen] paralyzes you, you can’t breathe, and you pass out.” The opposite condition is a hazard as well, however. Oxygen-enriched atmospheres put employees at risk by creating explosive or fire hazards, Bateman says.
Work an employee does in a confined space also can introduce or exacerbate hazards. “Spaces that typically would not require permits can become permit-required spaces by virtue of the work performed [in them],” Gilstrap says. For example, cleaning agents, chemicals, or solvents a worker uses, as well as welding or torching, could affect the atmosphere, Buchanan says. “Any confined space in which you are doing hot work [like welding or torching] by default becomes a permit-required confined space,” says Scott Jacoby, national health and safety director for Schnitzer Steel Industries (Portland, Ore.). Further, confined spaces can contain the same types of physical hazards as the rest of the scrapyard: those related to unguarded equipment, electrical sources, stored material, temperature extremes, falling objects, or slippery surfaces, Bateman says.
Other safety standards will address most of the hazards you’ll uncover in confined spaces, Williamson says, but the confined space might require giving the hazard special consideration because in the space, “a lot of the hazards become more dangerous.” For example, a toxic or explosive gas released on a plant floor could dissipate quickly, whereas a confined space will contain and concentrate the gas, Williamson says. Review work processes or material safety data sheets for substances workers use in and near confined spaces to further identify hazards, he says, and take note of spaces that currently don’t require permits in case conditions within them change.
Eliminating and Controlling Hazards
“The easiest and safest way to handle [the hazards of] a permit-required confined space is by not entering it,” Williamson says, so ask whether employees can perform the work without doing so. If that’s not possible, the next-safest approach is to remove hazards so the space doesn’t require an entry permit, the safety professionals say. The hazards must be eliminated, not just controlled, however. The assumption is that every permit-required confined space is hazardous, Gilstrap says. “Employers must document the affirmative process they followed to prove that it’s safe.”
Physical hazards often are easier to address, Williamson says. Sometimes lock-out/tag-out of equipment is all a space needs to be made safe, Bateman says, but Jacoby adds this caution: “Don’t think, just because you have isolated a confined space through lock-out/tag-out, it now absolves you from the requirements of your permit.” Lock-out/tag-out does not eliminate hazards created by flowable materials such as steam, natural gas, and other substances that can cause hazardous atmospheres or engulfment hazards. The OSHA confined-space website points out that you must isolate those hazards by blanking, blinding, misaligning or removing sections of lines or pipes, or using a double block and bleed system.
For atmospheric hazards, OSHA considers continuous ventilation a method for controlling, not eliminating, the hazard because if the ventilation system fails, the hazard could immediately return. “Atmospheric conditions can change very quickly in a confined space,” Williamson says. Blowers or fans must draw in clean air, ventilate the immediate area where the employee is working, and be compatible with the space and its hazards, Jacoby says. It’s not just a matter of setting up a fan and entering the space, however. Employees shouldn’t enter the space until the ventilation system removes the hazard and the air is retested, Heitman says. The tests should evaluate the space’s oxygen content, flammable gases and vapors, and toxic air contaminants, drawing air from the top, middle, and bottom of the space because the atmosphere might be layered, Bateman says. Leave enough time for the air to enter the testing equipment and for the sensor to react, Berg says, and even more time if you’re using a hose or probe. Also, make sure the equipment is properly calibrated and maintained. “We calibrate prior to entry and monthly if it’s not used,” Heitman says. Testing should continue periodically while the worker is in the space, Williamson says, with the stability of the space, the results of the initial test, and the work being performed determining the frequency of testing. “Confined space atmospheres are dynamic,” Samento says.
As is the case with the aforementioned atmospheric hazards, you can’t engineer out every hazard, Bateman says, so you must control those that remain with a written program that spells out the procedures for operating in permit-required confined spaces. At a minimum, the program should specify how the company will
--identify spaces;
--prevent unauthorized entry;
--identify, evaluate, and control hazards;
--test and monitor atmospheres;
--prepare, issue, use, and cancel permits;
--train and educate employees;
--identify roles and responsibilities;
--equip workers with PPE and other required equipment;
--monitor contractors;
--implement rescue and emergency procedures; and
--review and evaluate procedures.
The document should identify and describe the roles of the employees who are authorized to—and must—play a role in confined-space work, including the person who tests the atmosphere, entry supervisors, the space entrants, and attendants. All of these participants must understand their responsibilities and the hazards so they can safely perform their duties, Williamson says. Entry supervisors issue confined-space permits; determine whether acceptable entry conditions exist; ensure that all tests were conducted, procedures and equipment are in place, and rescue services are available; and certify—with date, location, and signature—that the space is safe for entry, Bateman says. Entry supervisors must know and understand the potential hazards as well as remove unauthorized individuals from the space, coordinate shift changes, terminate entry, if necessary, and cancel permits.
Entrants and attendants should recognize the signs and symptoms of hazard exposures, understand the consequences of such exposures, communicate with each other as necessary, and alert one another to warning signs or hazardous conditions. “Communication and training is critical,” Jacoby says. Entrants should wear a monitor that vibrates as well as sends off a visual and audible alarm, as well as a harness with a retrieval line attached to a mechanical device or a fixed point outside the permit space. (A mechanical device must be available for retrieving workers from vertical permit-requiring confined spaces more than 5 feet deep.) Wristlets can substitute for the harness if the latter would create a greater hazard. The attendant’s job is to watch the entrants. “Attendants may not perform other duties that would interfere with their primary duty—to monitor and protect the entrant,” Bateman says. Entrants must exit the space when the attendant alerts or orders them to do so. If necessary, an attendant calls rescuers and keeps unauthorized people from entering the space.
Training is essential, these safety professionals say. “Do not enter permit-required confined spaces without being trained,” Jacoby warns. “Make sure you review, understand, and follow your employer’s procedures before entering.” Training should take place at least once a year or whenever duties change, new hazards are present, the program changes, or performance suffers, Bateman says. At Schnitzer Steel, “we have confined-space entry and attendant training, and then we have a separate class for all employees on confined-space general awareness,” Jacoby says.
If the training, testing, and preparation seem daunting, you have another option: If your permit-required spaces do not require frequent entry, you can outsource any work that needs to be done in them, Samento says. “Decide whether it’s cost-effective to have a full-blown, permit-required confined space program,” he says. “Depending on the space, [the program] could get pretty elaborate.” Air monitors alone can cost a couple of thousand dollars, he says. Gilstrap recommends that scrapyards use contractors for this work whenever possible. They “specialize in this type of entry [and] have the necessary equipment and training.”
Even when using contractors, you have some responsibility for confined-space work, however. Employers must inform contractors about the space-entry requirements of the permit, Heitman says. “It’s important to talk with [the contractors] about the space and the type of work they plan to do inside it.” Samento also suggests conducting spot audits to ensure the contractor is following proper procedures. In the end, “the hazards still belong to the employers,” Bateman says.
Creating a Permit
Before anyone enters a permit-required confined space, the entry supervisor must fill out a permit specific to that space and that planned entry to ensure the company has met all pre-entry requirements and controlled or eliminated all hazards, Williamson says. What does “entering the space” really mean? Samento puts it this way: Whenever any part of a person’s body breaks the plane of the opening in a permit-required confined space, a permit had better be in place. Even authorized entrants should never enter a permit-required space without a permit, Jacoby says. The entry permit must identify
--the permit-requiring space to be entered;
--the purpose of the entry;
--the date and authorized duration of the permit;
--the names of authorized entrants, attendants, and entry supervisors;
--the signature of the entry supervisor to verify entry conditions were met;
--the hazards of the permit-requiring space;
--the measures taken to isolate the space and eliminate or control hazards;
--acceptable entry conditions;
--initial and periodic test results and test times, along with the tester’s signature;
--the name and phone number of rescue and emergency services;
--the communication procedures for entrants and attendants;
--equipment to be used, including PPE, alarm systems, and testing, monitoring, communication, ventilating, and rescue equipment;
--other information relevant to the space to keep employees safe; and
--additional permits—such as hot-work permits—issued to authorize work in the space.
The permit expires when the work is complete or when new conditions exist, Bateman says. If the job extends from one shift to another, employers can use the same permit as long as the entry supervisor signs off that conditions haven’t changed, Williamson says, and the permit must include the names of the workers on each shift. He emphasizes, however, that an employee must never enter a space—or re-enter a space he or she has exited—until it’s tested using the steps described on the permit. This ensures that conditions for safe entry on the permit are met.
Employers must keep permits for a year and should use them to evaluate their confined-space program periodically, Williamson says. If workers were exposed to certain chemicals while in the space, the employer might need to keep the permits longer or transfer certain information to employees’ records, he adds. You can use a prior permit to create a new one for the same space unless you have modified the space, Samento says, “but you can’t have a standing permit for the space.”
Emergency Preparedness
Preparing for emergency rescue is an essential part of a confined-space program. Only trained rescuers should attempt a rescue, Jacoby says. Samento concurs, noting that ill-conceived, ill-prepared, and ill-equipped rescue efforts often result in multiple deaths. About 60 percent of the fatalities associated with confined spaces are would-be rescuers, Gilstrap adds. People react to the situation instinctively instead of preparing for it, Samento says, which is a natural response. “People aren’t stupid. They’re concerned for their co-workers, friends, or family members.”
Many employers assume they can just call 911 in a confined-space emergency, but that’s often not the best rescue option. (See “911 to the Rescue—or Not” on page 112.) Find out if the emergency responders who would come to the facility are trained in confined-space rescue and can respond in a timely manner, Jacoby says. “Different fire departments have different capabilities,” Gilstrap says. “Small, local fire departments are less likely to have the necessary training
or equipment.” If local emergency services don’t have the needed skills, equipment, or training, it’s the scrap company’s responsibility to train and equip a team of employees or hire a firm that provides the rescue services, Williamson says. Each rescue-team member should have first aid and CPR training, and at least one must be certified in both. Appendix F of the OSHA confined-space standard can guide employers in choosing rescue services.
Rescuers should practice at least once a year to develop proficiency, Gilstrap says. Employers must make on-site confined spaces available for practice, Williamson says, though outside services can choose to practice elsewhere in similar spaces. Although Sadoff relies on local rescue services, a company comes to its headquarters annually for training that includes hands-on training using a tripod and harness, Heitman says. “We also do a separate rope and rescue class for employees who work with the shredders to practice self-rescue techniques.”
Other Considerations
With confined spaces, “complacency is one of the biggest hurdles,” Gilstrap says. When employees enter these spaces over and over again without incident, it lulls them into a false sense of security. Bateman says he tries to counter those attitudes in the safety training he conducts. “In every 10-hour OSHA class, I spend an hour on confined spaces and an hour on lock-out/tag-out because those are the two main [sources of accidents] that cause death in our industry. If I can fill [the attendees] with real stories, I can scare them into doing the right thing.”
The ReMA board recently approved recommended industry safety practices for confined spaces, which are available in the ReMA Safety Manual (www.isrisafety.org/products). The RISP is based on the OSHA standard, Gilstrap says. “The point of the regulation and the RISP is to make it clear that recyclers need to evaluate these spaces for potential hazards. There’s no room for assumption. Take [these spaces] seriously.”
Diana Mota is associate editor of Scrap.
911 to the Rescue--Or Not
Removing an incapacitated worker from a confined space that contains an atmosphere “immediately dangerous to life and health” is time-sensitive and technically complicated, says Michael Wilson, lead researcher on a University of California, Berkeley, study on California’s confined space emergency responses. The worker must be removed from the space and resuscitated in a matter of minutes, Wilson says. The study gives a blunt assessment of whether employers can rely on calling 911 for confined space emergency response, concluding that “a worker who experiences cardiac arrest, deprivation of cerebral oxygen, or some other highly time-critical, life-threatening emergency during a confined space entry will almost certainly die if the employer’s emergency response plan relies solely on the fire department for rescue services.”
The study found that local fire departments might not have the resources or specialized training required for confined space rescue—especially when response and rescue times are critical, Wilson says. Further, though urban fire-rescue teams typically arrive within 10 minutes from the time of dispatch, the average time required to perform the rescue, according to estimates made by fire officers, varied from 48 minutes to more than two hours when no hazardous materials were present and 70 minutes to nearly three hours when hazardous materials were present, Wilson says. “These findings are best-case scenarios with full-time, professional fire departments,” he adds. The total response time reflects the steps emergency responders must take once they arrive to assemble a rescue platform as well as access and extricate the victim, he explains. “Under the best of conditions, it will be one hour from the time an employer calls 911, and three hours if hazardous materials are present” until the rescue is completed. “Four to six minutes is the survival window to resuscitate someone who is not breathing. If they haven’t stopped breathing, you have a longer window, but you don’t have an hour.” He recommends that employers call 911 only to support a properly trained and equipped on-site rescue team and to provide advanced life support.
The study, “Confined Space Emergency Response: Assessing Employer and Fire Department Practices,” was funded by a legal settlement following the death of two workers in a confined space incident in California. It appeared in the February 2012 Journal of Occupational and Environmental Hygiene. The abstract is available at www.ncbi.nlm.nih.gov/pubmed/22300305. For copies of the article, contact Sheela Jhaveri at the UC Berkeley Labor Occupational Health Program: sheelaj@berkeley.edu or 510/642-5507.
Permit-required confined spaces can house invisible threats to workers. Entry takes planning, preparation, and strict adherence to proper procedures to keep employees safe.