OSHA Confined Space Rule versus Petroleum RetailConfined Spaces Petroleum Retail
Why Are We Here?
they are large enough for workers to enter and perform certain tasks
have limited or
not designed for
continuous human occupancy
tanks, vessels, silos, storage bins, hoppers, vaults, pits, sumps, manholes, tunnels, equipment housings, ductwork, pipelines, etc.
What is a Confined Space?
contains or has the potential to contain a hazardous atmosphere contains material that has the potential to engulf an entrant has walls that converge inward or floors that slope downward and taper into a smaller area which could trap or asphyxiate an entrant or contains any other recognized safety or health hazard known as “permit space”
What is a “Permit- Required Confined Space”?
Petroleum Retail “Permit Spaces”
Storage Tanks STP Sumps Dispenser Sumps Don’t forget about the other examples!
FEDERAL REGULATIONS
29 CFR 1910.146 – General Industry 29 CFR 1926 Subpart AA – Construction
STATE REGULATIONS
own OSHA-approved State Plans
Alaska Arizona California Connecticut* Hawaii Illinois* Indiana Iowa Kentucky Maine Maryland Michigan Minnesota Nevada New Mexico New Jersey* New York*
North Carolina Oregon Puerto Rico South Carolina Tennessee Utah Vermont Virgin Islands* Washington Wyoming
* State Plan covers state & local government workers only.
State Plan States
OSHA says: If you are doing construction work - such as building a new structure or upgrading an old one - then you must follow the construction confined space rule. Helpful?
What regulation do I follow? General Industry? Construction? State vs. Federal
What are you doing? Construction? Maintenance? Service? Repair? Why do we care?
Construction”
OSHA's regulations define "construction work" as "construction, alteration, and/or repair, including painting and decorating." They further provide that OSHA's construction industry standards apply "to every employment and place of employment of every employee engaged in construction work." The terms "building" and "work" generally include construction activity as distinguished from manufacturing, furnishing of materials, or servicing and maintenance work.
Further, construction work is not limited to new construction. It includes the repair of existing facilities. The replacement of structures and their components is also considered construction work.
There is no specified definition for "maintenance", nor a clear distinction between terms such as "maintenance", "repair", or "refurbishment." "Maintenance activities" can be defined as making or keeping a structure, fixture or foundation (substrates) in proper condition in a routine, scheduled, or anticipated fashion. This definition implies "keeping equipment working in its existing state, i.e., preventing its failure or decline." However, this definition, (taken from the directive on confined spaces) is not dispositive; and, consequently, determinations of whether a contractor is engaged in maintenance operations rather than construction activities must be made on a case-by-case basis, taking into account all information available at a particular site.
“Maintenance”
An employer whose workers are engaged in both construction and general industry work in confined spaces will meet OSHA requirements if that employer meets the requirements of 29 CFR 1926 Subpart AA - Confined Spaces in Construction. Don’t forget to check your
state requirements.
Interpretation
There are 5 key differences from the construction rule, and several areas where OSHA has clarified existing requirements.
General Industry vs. Construction
1. More detailed provisions requiring coordinated activities when there are multiple employers at the worksite. This will ensure hazards are not introduced into a confined space by workers performing tasks outside the space. An example would be a generator running near the entrance of a confined space causing a buildup of carbon monoxide within the space.
General Industry vs. Construction
2. Requiring a competent person to evaluate the work site and identify confined spaces, including permit spaces. "Competent person" means one who is capable of identifying existing and predictable hazards in the surroundings or working conditions which are unsanitary, hazardous, or dangerous to employees, and who has authorization to take prompt corrective measures to eliminate them.
General Industry vs. Construction
General Industry vs. Construction
4. Requiring continuous monitoring of engulfment hazards. For example, when workers are performing work in a storm sewer, a storm upstream from the workers could cause flash flooding. An electronic sensor or observer posted upstream from the work site could alert workers in the space at the first sign of the hazard, giving the workers time to evacuate the space safely.
General Industry vs. Construction
5. Allowing for the suspension of a permit, instead of cancellation, in the event of changes from the entry conditions list on the permit or an unexpected event requiring evacuation of the space. The space must be returned to the entry conditions listed on the permit before re-entry.
General Industry vs. Construction
Clarifies exposure to physical hazards and requires elimination or isolation.
If using local emergency services for rescue, ensure they are available.
Provide training in a language that your employees understand. Definitions added.
General Industry vs. Construction
An entry employer is an employer who decides that an employee it directs will enter a permit space.
A controlling contractor is the
employer with overall responsibility for construction at the worksite.
A host employer is the
employer that owns or manages the property where the construction work is taking place.
Category of Employer
Employer Responsibilities
All Employers • Identify all confined spaces in which their workers may work and determine whether any are permit spaces. If its workers are supposed to enter permit spaces, the employer is an “entry employer.” • Employers who are not “entry employers” must make sure their workers stay out of any permit spaces present on the site, unless the workers are authorized for entry.
Entry Employer • Protect workers against permit space hazards by complying with the standard. • Inform controlling contractor of the program followed and hazards encountered in permit spaces.
Controlling Contractors
Share information it has about permit space hazards with entry employers and other employers whose activities may create hazards in the permit space. • Coordinate entry operations when there is more than one entry employer. • Coordinate operations when permit space entry occurs during other activities at the site that might create a hazard in the space.
Host Employers
Share information it has about permit space hazards with the controlling contractor.
Have a competent person identify all confined spaces in which its employees may work. If confined spaces are
present, the employer must have the competent person determine whether the confined spaces are “permit spaces.” If the workplace contains
a permit space, the entry employer must protect its workers against the hazards in the permit space. STP Sumps, Dispenser
Sumps and Storage Tanks are always “permit spaces.”
Overview
Protective Action
Permit spaces that do not qualify for one of the following two exceptions.
If the employer’s workers will enter the space, develop and follow a written permit space program. The permit space program specifies, among other things, how the employer will (1) regulate worker entry into permit spaces; and (2) control permit space hazards. All employers must inform their workers about the locations and dangers of each permit space (e.g., post signs), and take additional steps to ensure that workers do not enter permit spaces if they are not authorized to do so.
Exception 1: Spaces that contain only physical hazards(non- atmospheric).
If the physical hazards are eliminated or isolated so that they no longer present a hazard, the space may be reclassified as a non-permit space, with no further precautions required.
Exception 2: Spaces containing an atmospheric hazard that can be controlled by continuous forced air ventilation.
As long as the atmospheric hazard is controlled by continuous forced air ventilation and any physical hazards are eliminated or isolated, alternate procedures may be used instead of full permit space procedures, although the space is still classified as a permit space.
A permit space program must: Implement measures to prevent unauthorized entry; Identify and evaluate permit space hazards before allowing employee entry; Provide for the atmospheric conditions in the permit space to be tested before entry operations and for the space to be monitored during entry; Require appropriate testing for the following atmospheric hazards in this sequence: oxygen, combustible gases or vapors, and toxic gases or vapors; Establish and implement the means, procedures and practices to eliminate or control hazards necessary for safe permit space entry operations; Identify employee job duties; Provide and maintain, at no cost to the employee, personal protective equipment and any other equipment necessary for safe entry, and require employees to use the equipment properly;
A permit space program must: Ensure that at least one attendant is stationed outside the permit space during entry operations; Implement the procedures that any attendant who is required to monitor multiple spaces will follow during an emergency in one or more of those spaces; Coordinate entry operations (in consultation with the controlling contractor) when employees of more than one employer are working in the permit space; and Establish procedures for summoning rescue and emergency services and preventing unauthorized personnel from attempting rescue.
Entry Permit Requirements Name of the permit space to be entered, authorized entrant(s), current attendants, and current entry supervisors; Purpose of entry; Date and authorized duration of entry; Means of detecting an increase in atmospheric hazard levels; Name and signature of supervisor who authorizes entry; Known hazards in the space; Measures to be taken to isolate permit spaces and to eliminate or control space hazards; Acceptable entry conditions; Test results, date and time of test(s), and tester’s initials or signature; Name and telephone numbers of rescue and emergency services and means to be used to contact them; Communication procedures and equipment to maintain contact during entry; Special equipment and procedures, including personal protective equipment and alarm systems; Any other information needed to ensure employee safety; and Additional permits, such as for hot work, that have been issued authorizing work in the permit space.
Confined Space Entry Permit
In the event of an emergency call 9-1-1
SECTION 1 Permit Issued: Is this a permit-required space? Yes No (If no permit required skip section #4)
ion of Confined Space (What area, floor, etc.):
iption of confined space:
iption of work to be performed:
Material or Chemicals located and/ or brought into the confined spaces MSDS Yes No MSDS Yes No MSDS Yes No MSDS Yes No MSDS Yes No MSDS Yes No
Air monitoring device information / Model: Date of Calibration:
Pre-entry Atmospheric monitoring results en (19.5%-23%)
% Carbon monoxide (< 35PPM) PPM
Flammables (<10% of LEL) %
Yes Chemical exposures Corrosive Substances Carbon Monoxide Potential Flammable/ Explosive Dust O2 Deficient O2 Enriched Flammable Gas Temperature Extremes Slip/ Trip/ Fall Vermin/ Animal Limited Egress Noise/ Vibration Structural Collapse Small Internal Size Visual/ Lighting Plumbing Lines HVAC (Heating, Ventilation and Air conditioning) Radiation (ionizing or non ionizing) Pressurized Equipment Mechanical Equipment Electrical Hazards Biohazards Asbestos other:
Controls needed for hazards N/A Yes
Barricade/ Signs Lock out/ Tag out Double block and bleed Lighting Air purifying respirator Supplied Air Respirator/ SCBA Hearing Protection Mechanical fresh air ventilation Natural Ventilation Protective clothing Safety Glasses/ Face shield Hard hat/ head protection Ground fault interrupter (GFCI) Harness/ Life lines/ Tripod Gloves/ Hand Protection Continuous air monitoring Fire extinguisher. Type: Two way communication equipment Eye wash/ Emergency Shower Hot work Permit First Aid kit other: other: other:
ional Information:
SECTION 1
Date Permit Issued:
Is this a permit-required space? Yes FORMCHECKBOX No FORMCHECKBOX (If no permit required skip section #4)
Location of Confined Space (What area, floor, etc.):
Description of confined space:
Description of work to be performed:
Material or Chemicals located and/ or brought into the confined spaces
MSDS Yes FORMCHECKBOX No FORMCHECKBOX
MSDS Yes FORMCHECKBOX No FORMCHECKBOX
MSDS Yes FORMCHECKBOX No FORMCHECKBOX
MSDS Yes FORMCHECKBOX No FORMCHECKBOX
MSDS Yes FORMCHECKBOX No FORMCHECKBOX
MSDS Yes FORMCHECKBOX No FORMCHECKBOX
Air monitoring device information
FORMCHECKBOX FORMCHECKBOX O2 Deficient
FORMCHECKBOX FORMCHECKBOX O2 Enriched
FORMCHECKBOX FORMCHECKBOX Flammable Gas
FORMCHECKBOX FORMCHECKBOX Temperature Extremes
FORMCHECKBOX FORMCHECKBOX Vermin/ Animal
FORMCHECKBOX FORMCHECKBOX Limited Egress
FORMCHECKBOX FORMCHECKBOX Noise/ Vibration
FORMCHECKBOX FORMCHECKBOX Structural Collapse
FORMCHECKBOX FORMCHECKBOX Visual/ Lighting
FORMCHECKBOX FORMCHECKBOX Plumbing Lines
FORMCHECKBOX FORMCHECKBOX Radiation (ionizing or non ionizing)
FORMCHECKBOX FORMCHECKBOX Pressurized Equipment
FORMCHECKBOX FORMCHECKBOX Mechanical Equipment
FORMCHECKBOX FORMCHECKBOX Electrical Hazards
FORMCHECKBOX FORMCHECKBOX Lighting
FORMCHECKBOX FORMCHECKBOX Supplied Air Respirator/ SCBA
FORMCHECKBOX FORMCHECKBOX Hearing Protection
FORMCHECKBOX FORMCHECKBOX Natural Ventilation
FORMCHECKBOX FORMCHECKBOX Protective clothing
FORMCHECKBOX FORMCHECKBOX Gloves/ Hand Protection
FORMCHECKBOX FORMCHECKBOX Continuous air monitoring
FORMCHECKBOX FORMCHECKBOX Fire extinguisher. Type:
FORMCHECKBOX FORMCHECKBOX Two way communication equipment
FORMCHECKBOX FORMCHECKBOX Eye wash/ Emergency Shower
FORMCHECKBOX FORMCHECKBOX Hot work Permit
FORMCHECKBOX FORMCHECKBOX First Aid kit
FORMCHECKBOX FORMCHECKBOX other:
FORMCHECKBOX FORMCHECKBOX other:
FORMCHECKBOX FORMCHECKBOX other:
Additional Information:
SECTION 3
Continuous Atmospheric monitoring results (Tests must be recorded at least once per hour)
Remember to test at different levels (e.g. low, medium, and high)
Time
(Please Print Neatly)
Post authorized permit at job site until completed.
Qualified Entry Supervisor.
I certify that all of the requirements of the confined space entry program have been met. I have ensured that all applicable hazards have been identified and sufficiently controlled.
Permit authorization
Name:
Signature:
Permit Cancellation
Time Canceled
In the event of an emergency Call 9-1-1
The Entry Supervisor is required to submit the completed permits to the Safety Administrator for 3 years.
Page 1 of 2
A permit space that contains only physical hazards may be reclassified as a non-permit space if (1) the physical hazards are eliminated or isolated without entering the space; or (2) the physical hazards are eliminated or isolated by entering the space using permit space procedures. Examples; mechanical, electrical,
hydraulic and pneumatic energy; radiation; temperature extremes; engulfment; noise; inwardly converging surfaces; and chemicals that can cause death or serious physical harm through skin or eye contact (rather than through inhalation).
A space containing an atmospheric hazard cannot be reclassified as a non- permit space. However, if the atmospheric hazard in a permit space can be controlled by forced air ventilation, the employer may use less stringent procedures instead of full permit space procedures when workers enter the space. The alternate procedures may be used if the employer can show that: All physical hazards are eliminated or isolated; The only hazard is an actual or potential hazardous atmosphere that can be and is made safe for entry using continuous forced air ventilation; and In the event the ventilation system stops working, entrants can exit the space safely.
Entry and Exit Any conditions making it unsafe to remove an entrance cover must be eliminated before the cover is removed. When entrance covers are removed, the opening must be immediately guarded by a railing, temporary cover, or other temporary barrier that will prevent an accidental fall through the opening and that will protect each employee working in the space from foreign objects entering the space. Before a worker enters the space, the internal atmosphere must be tested, with calibrated direct-reading instruments, for oxygen content, for flammable gases and vapors, and for potential toxic air contaminants, in that order.
Entry and Exit The employer must verify that the space is safe for entry and that the pre-entry measures discussed above have been taken, through a written certification that contains the date, the location of the space, and the signature of the person providing the certification. The certification must be made before entry and must be made available to each worker entering the space or to that worker’s authorized representative. The employer must provide workers with a safe method of entering and exiting the space. Any hoisting system that is used must either (1) be designed and manufactured for personnel hoisting; or (2) be approved for personnel hoisting by a registered professional engineer prior to use.
Ventilation Requirements: Continuous forced air ventilation must be used. (Exhaust ventilation is not an acceptable substitute for forced air ventilation.) If the forced air ventilation stops for any reason, the entrant(s) must immediately leave the space. The forced air ventilation must be directed to ventilate the immediate areas where each entrant is or will be located within the space and must continue until all employees have left the space. The air supply for the forced air ventilation must be from a clean source and must not increase the hazards in the space.
During Entry: The atmosphere within the space must be monitored to ensure that the forced air ventilation is preventing the accumulation of a hazardous atmosphere. Monitoring must be conducted continuously unless the entry employer can demonstrate that equipment for continuous monitoring is not commercially available or that periodic monitoring is sufficient to ensure that the atmosphere remains nonhazardous. Employers must provide any worker who enters the space, or that worker’s authorized representative, with an opportunity to observe the testing required by this paragraph. If a hazard is detected during entry: (A) Employers must make sure each worker leaves the space immediately; (B) The space must be evaluated to determine how the hazard developed; and (C) The employer must implement measures to protect workers from the hazard before any subsequent entry takes place.
Tank Entry – Written “permit space” Program Training Entry Permit System Rescue Information Exchange Signage/Barricades Monitoring/Ventilation
Sump Entry (non-atmospheric)– Reclassification Training Information Exchange
Sump Entry (atmospheric) – Alternate “permit space” procedure Training Monitoring/Ventilation Amended permit Signage/Barricades
Art Sodermark, MS (352) 267-8440 www.platinumengineers.com
Confined Spaces Petroleum Retail
What is a “Permit- Required Confined Space”?
Petroleum Retail “Permit Spaces”
What regulation do I follow?General Industry?Construction?State vs. Federal
What are you doing?Construction?Maintenance? Service? Repair?Why do we care?
“Construction”
“Maintenance”
Interpretation
Slide Number 22
Alternate “Permit Space”(atmospheric)
Alternate “Permit Space”(atmospheric)
Alternate “Permit Space”(atmospheric)
Alternate “Permit Space”(atmospheric)
Alternate “Permit Space”(atmospheric)
Summary