Bruce DelGrasso

Principal

Confined Spaces

Permit Required Program

Regulations
Definitions
Hazards of Confined Spaces
How to Categorize Work Spaces
Permit System
Training
Responsibilities and Duties

Alternate Procedures
Reclassification
Recap
Questions

26-Dec-14

What confined spaces exist on your site?

storage tanks, mud pits, reserve pits excavated areas, sand

storage containers, manholes, culverts, signs, box girders, pump

vaults

Which confined spaces on your site may be

Permit Required Confined Spaces?

What hazards may exist in these confined

spaces?

29 CFR 1910.146

General industry only does not apply to

construction operations

29 CFR 1926.21- safety training & education,

Subpart S- underground construction,
1926.956- underground electric transmission
and distribution work, Subpart P- excavations,
and Subpart J- welding and cutting

Govern construction activities

The requirements are basically the same, TSA follows
the most stringent governing regulations

26-Dec-14

 Employer shall evaluate workplace

If workplace contains permit spaces, signs shall
be posted
Give notice of Existence
Location
Danger

Effective measures shall be taken to prevent

unauthorized entry
If entry is allowed, a permit space program must
be:
Written
Implemented
Made available to employees/representatives

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 Engulfment

Configuration
Oxygen Deficient Atmospheres
Oxygen Enriched Atmospheres

Flammable Atmospheres
Toxic Atmospheres
Temperature Extremes
Equipment (machinery, electrical)

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Confined Space

Large Enough to Enter and Work

Limited Openings for Entry and Exit
Not Designed for Continuous Worker Occupancy

Entry

26-Dec-14

Passing through opening (any part of entrants body

breaks its plane)
Includes ensuing work activities

Hazardous Atmosphere
Flammable gas, vapor, or mist in excess of 10% of its

LFL (lower flammable limit)

Airborne dust at a concentration that meets or

exceeds its LFL (Rule of thumb: vision at <5)

Oxygen <19.5% or >23.5%

Atmospheric concentrations of substances above PEL

(permissible exposure limit)

Other atmospheric conditions: IDLH (immediately

dangerous to life or health)

26-Dec-14

Engulfment
The surrounding & effective capture of a
person by a liquid or finely divided (flowable)

solid substance that can:

Be aspirated to cause death by filling or plugging the

respiratory system
Exert enough force on the
body to cause death by
strangulation, constriction,
or crushing

26-Dec-14

 Loose, granular materials stored

in bins and hoppers such as grain,

sand, coal, etc.
Crusting and bridging below a
worker
Flooding of confined space
Water

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Mud
Sewage flow

10

Has an internal configuration such that an entrant

could be trapped or asphyxiated

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Inwardly converging walls, or

A floor which slopes downward & tapers to a smaller
cross-section

11

19.5 %
15 -19%
12-14%
10-12%
8-10%
6-8%

4-6%

26-Dec-14

Minimum acceptable oxygen level.

Decreased ability to work strenuously.
Impaired coordination Early symptoms
Respiration increases. Poor judgment.
Respiration increases. Lips blue.
Mental failure.
Fainting. Nausea.
Unconsciousness.
Vomiting.
8 minutes Fatal
6 minutes 50% fatal
4-5 minutes Iffy
Coma in 40 seconds. Death.

12

 Oxygen level above 23.5%

Causes flammable and combustible materials to
burn violently when ignited
Hair, clothing, materials, etc.
Oil soaked clothing and materials

Never use pure oxygen to ventilate

Never store or place compressed tanks in a
confined space

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13

 Critical Factors:

Oxygen content in the air

Presence of a flammable gas, or vapor
Presence of dust (visibility of 5 or less)
Critical air/gas/dust mixture can lead to explosion

Typical Ignition Sources:

26-Dec-14

Sparking or electric tool

Welding / cutting operations
Smoking

14

 Product stored in a confined space:

Gases released when cleaning

Materials absorbed into walls of confined space
Decomposition of materials in the confined space

Work performed in a confined space:

Welding, cutting, brazing, soldering

Painting, scraping, sanding, degreasing
Sealing, bonding, melting

Areas adjacent to a confined space

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Decomposition of materials, human waste

Naturally present in some oil/gas reservoirs
Rotten egg odor at low concentrations
Possibly no warning at high concentrations

PPM

Effect

Time

10
50 - 100
200 - 300
500 - 700
>1000

Permissible Exposure Level

Mild Irritation - eyes, throat
Significant Irritation
Unconsciousness, Death
Unconsciousness, Death

8 Hours
1 Hour
1 Hour
1/2 - 1 Hour
Minutes

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16

Odorless, colorless gas

Combustion by-product
Quickly collapse at high concentrations
PPM
50
200
600
1000-2000
1000-2000
1000-2000
2000-2500

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Effect
Permissible Exposure Level
Slight headache, discomfort
Headache, discomfort
Confusion, nausea, headache
Tendency to stagger
Slight heart palpitation
Unconsciousness

Time
8 Hours
3 Hours
1 Hour
2 Hours
1 1/2 Hours
30 Min.
30 Min.

17

Extreme heat & cold

Steam cleaning
Humidity factors
Extremely cold liquids
Work processes inside the confined space can
increase temperature extremes
Personal protective equipment

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18

 Noise

Amplified due to acoustics within the space

Damages hearing; affect communication

Slick / Wet Surfaces

Slips and falls

Increased chance of electric shock

Falling Objects

26-Dec-14

Topside openings expose workers in confined space

to falling objects

19

Space large enough to enter and

Limited or restricted entry or exit and
Not designed for continuous worker occupancy.

YES

PermitRequired
Confined
Space

YES

NO

Not a Confined Space

Confined Space

Hazardous Atmosphere
or
Engulfment Hazard
or
Configuration Hazard
or
Any other recognized serious
hazard

Non

NO

PermitRequired
Space

1.

2.

Implement measures to prevent unauthorized

entry
Identify & evaluate
hazards prior to entry

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21

3.

Develop & implement means, procedures &

practices for safe entry:

Specify acceptable entry conditions

Let entrant/rep observe monitoring/testing
Isolate the permit space
Purge, inert, flush or ventilate as necessary
Provide barriers
Verify acceptable conditions throughout entry

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4.

Provide the following equipment at no cost to

the employee:

26-Dec-14

Testing & monitoring equipment

Ventilation equipment
Communication equipment
PPE
Lighting equipment
Barriers & shields
Ingress/egress equipment (ladders, etc.)
Rescue & emergency equipment
Other needed entry/rescue equipment

23

5.

6.
7.

8.

Evaluate permit space to ensure acceptable

conditions
Provide at least one attendant
Provide means & procedures for emergency
response to two spaces if monitored by one
attendant Recommend: do not allow this
practice, One entry, One attendant.
Designate program personnel & duties and
provide training

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9.

10.

Develop & implement procedures for rescue

and emergency services
Develop & implement a system for entry
permits
Preparation
Issuance
Use
Cancellation
Retention

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25

13.

14.

15.

16.

Develop & implement procedures to coordinate

multi-employer entry operations
Develop procedures for concluding entry
operations
Review entry operations when protective
measures appear insufficient
Program shall be reviewed at least annually
(your canceled permits are an excellent
resource for this)

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26

1.

2.
3.

4.

Entry permit completed by employer designee

Supervisor must sign to authorize entry
Permit must be posted at entry for inspection
by all entrants
Permit shall be valid for time needed to
complete to task or length of shift

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27

5.

Supervisor shall terminate entry & cancel

permit when:
The entry operation covered by the permit has been

completed or
A condition that is not allowed under the entry permit
arises in or near the permit space.
6.

Cancelled permits are retained for at least 1

year
Note any problems, evaluations, corrections

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28

Space to be
entered, purpose,
date & duration
Names of
attendants and
supervisor
Hazards of space
Measures to isolate
space & control
hazards
Acceptable entry
conditions

26-Dec-14

Test results, initial

and periodic
Rescue and
emergency services
Communication
procedures
Equipment
Intrinsically Safe
Tools
Lock Out / Tag Out
Other information
Other permits, such
as hot work
29

Training shall be provided:

26-Dec-14

Before first assigned duties

Before change in duties
When permit space requirements change
When employee seems not to have retained
previous training

30

Know hazards and symptoms

Use equipment properly
Communicate with attendant
Alert attendants of symptoms or prohibited
condition
Exit as quickly as possible after:

26-Dec-14

Attendant or supervisor give order to evacuate

Recognizing sign or symptom of exposure
Detecting prohibited condition
Evacuation alarm is activated

31

 Know hazards, symptoms & behavioral effects

Count, monitor, communicate with & protect
personnel
Stay posted outside space until released
Order employees out if dangerous conditions
noticed
Summon rescue/emergency services
Warn unauthorized persons to stay away or exit;
inform others if present in space
Non-entry rescue
No other interfering duties
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32

26-Dec-14

Know hazards, symptoms & behavioral effects

Verify permit conditions
Authorize & terminate entries
Verify rescue availability
Remove unauthorized persons
Ensure compliance with terms of entry permits

33

1.

Employer shall:
Evaluate a prospective rescuers timely response
according to hazards
Evaluate prospective rescue services ability for
pertinent types of rescue
Select a rescue service based on those criteria
Inform rescue service of potential hazards
Provide rescue service with access to permit spaces
to
develop appropriate plans
practice rescue operations

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34

2.

Rescue service employer shall:

Provide PPE at no cost to employees
Train affected employees to perform assigned
rescue duties
Train in First Aid/CPR
Practice making permit required rescue at
least every 12 months

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3.

Retrieval systems for non-entry rescue

Authorized entrant shall use a
chest or full body harness
Other end of line connected to
make quick rescue possible

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36

Compliance may be simplified if:

Can demonstrate that the only hazard is atmospheric
Can demonstrate that continuous forced air
ventilation can control the hazard
Supportive monitoring & inspection data is
developed
and

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Compliance may be simplified if:

Entry to obtain initial supportive data is made in full
compliance
Qualifying info above is shared with each entrant
Further entries are made in compliance with (c)(5)(ii)

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Simplified compliance requirements:

It must be safe to remove the entrance cover
Open entrance covers must be promptly guarded

A.
B.

Railing or temporary cover/ barrier

and
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Simplified compliance requirements:

Prior to entry, the internal atmosphere shall be
tested for:

C.

Oxygen content
Flammable gases & vapors
Potential toxic air contaminants
In that order!
Entrant/representative must be allowed to observe
pre-entry testing
and

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Simplified compliance requirements:

D.

E.

F.

No hazardous atmosphere allowed whenever any

employee is inside the space
Continuous forced air ventilation
Periodic testing as necessary, observable by
entrant/representative

and

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Simplified compliance requirements:

G.

If hazardous atmosphere is detected during entry:

1. Employees out immediately
2.

3.

Hazard evaluated
Protective measures implemented

and

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Simplified compliance requirements:

Certification requirements:

H.

26-Dec-14

Written
Space safe to enter (verified)
Pre-entry measures taken (verified)
Date
Location of the space
Signature of certifier
Available to entrant/representative

43

Always test the

air at various levels to
be sure that the entire
space is safe.
Good air near the
opening does NOT
mean there is good
air at the bottom!

26-Dec-14

Good Air

Poor Air

Deadly Air

44

Reclassification: non-permit to permit

Where changes in use or configuration might

increase the hazards

Reclassification: permit to non-permit

26-Dec-14

When atmospheric hazards are not present, or while

they remain eliminated
Entry to determine this must be made in full
compliance

45

A host employer arranging for employees of a

contractor employer to perform work shall inform
about:

26-Dec-14

Permit spaces & program

Identified hazards
Precautions/procedures
Entry operations & coordinate
Entries completed & hazards found

46

Contractor employer shall interact with host

employer to:
Obtain info about hazards & entry operations
Coordinate entry operations
Inform about program followed & any hazards
confronted or created

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Identify and evaluate confined spaces

Provide training on confined space recognition and dangers
Provide atmospheric testing equipment
If necessary, provide ventilation equipment and/or
respiratory protection
Provide training on confined space permits and the written
program
Develop, train, and rehearse emergency action and rescue
plans
Respond to and correct hazards pointed out by the worker

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 Understand and Follow permit procedures

Test the atmosphere prior to entry
Periodically monitor the atmosphere for possible
changes
Ensure that there is at least one authorized
attendant present at all times
Correct the hazards you are able to correct
Report to your supervisor the hazards you are
unable to correct
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49

Questions?

DelGrasso Safety Consulting, llc 2014.

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to any third party without the written authority from DSC, llc.