The High-Risk Nature of Confined Space Entry

Confined spaces pose a serious risk to worker safety, with a higher fatality rate than many other workplace incidents. The Occupational Safety and Health Administration (OSHA) defines a confined space and provides regulations for permit-required confined spaces, those with potential hazards such as hazardous atmospheres or engulfment. Due to these risks, OSHA has a permit-required confined space standard (29 CFR 1910.146) to protect workers. Following these regulations is essential for anyone working in or around confined spaces.

Identifying Confined Spaces and Their Hazards

Confined spaces are more common than many people realize. They exist in a wide range of industries and workplaces. Examples include:

• • Storage Tanks: Holding liquids, gases, or granular materials.
  • Silos: Storing grain, cement, or other bulk materials.
  • Manholes: Providing access to underground utilities.
  • Pipelines: Transporting fluids or gases.
  • Sewers: Carrying wastewater.
  • Vaults: Underground enclosures for electrical or communication equipment.
  • Digesters: Used in wastewater treatment.
  • Boilers: Generating steam.
  • Ducts: Part of ventilation systems.
  • Hoppers: Funnel-shaped containers.
  • Reaction Vessels: Used in chemical processing.
  • Excavations: (If they meet the definition of a confined space)
  • Ship Compartments: Various enclosed spaces on ships.

• Aircraft Fuel Tanks

• Tunnels

The hazards within these spaces can be categorized as follows:

Atmospheric Hazards: These are the most frequent cause of confined space fatalities.

• Oxygen Deficiency: Insufficient oxygen (below 19.5%) can lead to unconsciousness and death within minutes. This can be caused by displacement by other gases, consumption by chemical reactions, or poor ventilation.
• Oxygen Enrichment: Excessive oxygen (above 23.5%) significantly increases the risk of fire and explosion.
• Toxic Gases: Exposure to even small concentrations of gases like hydrogen sulfide (H2S), carbon monoxide (CO), methane (CH4), or various industrial chemicals can be deadly. These gases can be present due to the stored material, decomposition processes, or leakage.
• Flammable/Explosive Vapors: The presence of flammable gases or vapors, even at low concentrations, can create an explosive atmosphere if an ignition source is present.

Engulfment Hazards:

• Flowing Liquids or Solids: Workers can be trapped or suffocated by materials like grain, sand, coal, or water flowing into the confined space.

Mechanical Hazards:

• Moving Parts: Rotating equipment, agitators, or other machinery within the space can cause crushing injuries, amputations, or entanglement.

Other Hazards:

• Temperature Extremes: Exposure to excessive heat or cold can lead to heatstroke, hypothermia, or other health problems.
• Electrical Hazards: Contact with exposed wires or faulty equipment can cause electrocution.
• Falling Objects: Tools or materials falling from above can cause serious injuries.
• Noise: Excessive noise levels can damage hearing.
• Biological Hazards: Exposure to bacteria, viruses, or fungi.
• Poor Visibility: Lack of proper lighting.

Before any entry into a confined space, a thorough risk assessment is absolutely essential. This assessment must identify all potential hazards, evaluate the risks associated with each hazard, and determine the necessary control measures to ensure worker safety.

Permit-Required Confined Space Entry Procedures: A Step-by-Step Guide

OSHA’s permit-required confined space standard (29 CFR 1910.146) mandates a comprehensive, written program to ensure worker safety. The cornerstone of this program is the entry permit system.

Permit System Overview:

The entry permit is a written authorization that documents all aspects of the confined space entry. It serves as a checklist to ensure that all necessary precautions have been taken and that everyone involved understands the hazards, procedures, and responsibilities. The permit is not simply a piece of paper; it’s a critical safety tool.

Permit Content:

A properly completed permit must include the following information:

Authorized Entrants: The names of the workers who are authorized to enter the space.

Attendant(s): The names of the individuals who will remain outside the space to monitor the entrants and provide assistance.

Entry Supervisor: The name of the person responsible for overseeing the entire entry operation.

Hazard Identification: A detailed description of all potential hazards present in the space.

Hazard Control Measures: The specific steps taken to eliminate or control each identified hazard (e.g., ventilation, lockout/tagout, PPE).

Testing Results: The results of atmospheric testing, including the date, time, and initials of the person performing the tests. This includes pre-entry testing and continuous monitoring results.

Acceptable Entry Conditions: The specific atmospheric conditions (oxygen levels, toxic gas concentrations, flammable gas levels) that must be met before entry is allowed.

Emergency Procedures: A detailed plan for rescuing entrants in case of an emergency, including contact information for rescue services.

Rescue Plans: Specific details on how a rescue will be performed, including the equipment to be used and the roles of each member of the rescue team.

Equipment Required: A list of all equipment needed for the entry, including PPE, ventilation equipment, communication devices, and rescue equipment.

Entry Preparation:

• Isolation and Lockout/Tagout: Procedures to ensure that the space is isolated from all energy sources (electrical, mechanical, hydraulic, etc.) and that hazardous materials cannot enter the space. This involves physically locking and tagging out energy sources to prevent accidental activation.
• Ventilation: Establishing adequate ventilation to remove or dilute hazardous atmospheres. This may involve using mechanical fans, blowers, or ductwork.
• Atmospheric Testing: Using calibrated gas detectors to measure oxygen levels, flammable gas concentrations, and toxic gas levels. This testing must be performed before entry and continuously during the entry.
• Equipment Inspection and Calibration: Ensuring that all equipment, including gas detectors, PPE, and rescue equipment, is in good working order and properly calibrated.
• Creating a Safe Work Environment: Addressing any other hazards identified in the risk assessment, such as providing lighting, securing loose objects, or mitigating temperature extremes.

Entry and Work Execution:

• Continuous Atmospheric Monitoring: Continuously monitoring the atmosphere inside the confined space to ensure that it remains within acceptable limits.
• Communication Protocols: Maintaining constant communication between the entrants and the attendant outside the space. This may involve using radios, visual signals, or other communication methods.
• Use of Personal Protective Equipment (PPE): Ensuring that all entrants are wearing the appropriate PPE, including respirators, harnesses, protective clothing, and any other necessary equipment.
• Adherence to the Permit Conditions: Strictly following all procedures and requirements outlined in the entry permit.

Permit Closure:

After the work is completed, the permit must be formally closed. This involves:

• Ensuring that all entrants have exited the space.
• Removing all equipment.
• Verifying that the space is secured.
• Canceling the permit and returning it to the entry supervisor.
• Debriefing the entry team to identify any lessons learned.

Necessary Precautions to Protect Workers

Protecting workers in confined spaces requires a multi-faceted approach, addressing all potential hazards.

Atmospheric Monitoring and Control

Types of Gas Detectors: Various types of gas detectors are available, including:

• Single-Gas Detectors: Detect a specific gas (e.g., H2S, CO).
• Multi-Gas Detectors: Detect multiple gases simultaneously (typically oxygen, LEL, H2S, and CO).
• Photoionization Detectors (PIDs): Detect a wide range of volatile organic compounds (VOCs).
• Electrochemical Sensors: Used for oxygen and a variety of toxic gases.
• Infrared Sensors: For Combustibles, CO2

Proper Use of Gas Detectors

• Calibration: Gas detectors must be calibrated regularly according to the manufacturer’s instructions.
• Bump Testing: Performing a “bump test” before each use to verify that the sensors are responding to the target gases.
• Proper Sampling Techniques: Taking readings at various levels within the space (top, middle, bottom) to ensure accurate representation of the atmosphere.

Ventilation Systems

• Mechanical Ventilation: Using fans or blowers to provide forced-air ventilation.
• Natural Ventilation: Utilizing natural airflow, but this is often insufficient in confined spaces.
• Local Exhaust Ventilation: Capturing contaminants at their source.

Acceptable Entry Conditions and Action Levels

• Oxygen: 19.5% – 23.5%
• Flammable Gases: Less than 10% of the Lower Explosive Limit (LEL)
• Toxic Gases: Below the Permissible Exposure Limit (PEL) or Short-Term Exposure Limit (STEL) for the specific gas.

Personal Protective Equipment (PPE)

Respiratory Protection

• Self-Contained Breathing Apparatus (SCBA): Provides a supply of clean, breathable air from a tank carried by the user. Used in IDLH (Immediately Dangerous to Life or Health) atmospheres.
• Supplied-Air Respirators (SAR): Provide a continuous supply of air from a remote source through an air hose.

Harnesses and Retrieval Systems

• Full-body harnesses with retrieval lines are essential for rescue.
• Retrieval systems, such as tripods and winches, allow for non-entry rescue.

Protective Clothing and Footwear

• Chemical-resistant suits, gloves, and boots may be necessary.
• Flame-resistant clothing may be required in potentially flammable atmospheres.

Head and Eye Protection

• Hard hats and safety glasses or goggles protect against falling objects and other hazards.

Attendant Responsibilities:

The attendant plays a critical role in ensuring the safety of the entrants. Their responsibilities include:

• Monitoring Entrants: Continuously observing the entrants for any signs of distress.
• Monitoring Atmospheric Conditions: Monitoring the readings from gas detectors and ensuring that the atmosphere remains safe.
• Maintaining Communication: Maintaining constant communication with the entrants.
• Initiating Emergency Procedures: Summoning rescue services and initiating emergency procedures if necessary.
• Preventing Unauthorized Entry: Ensuring that only authorized personnel enter the space.
• Knowing the hazards: Being aware of the potential hazards, and signs of exposure.

Emergency Rescue and Retrieval:

• Developing and Practicing Rescue Plans: A detailed rescue plan must be in place, and all personnel must be trained on their roles in the plan. Regular rescue drills are essential.
• Use of Retrieval Systems: Retrieval systems allow for non-entry rescue, which is always the preferred method.
• First Aid and Medical Response: Trained personnel and first aid supplies must be readily available.
• Non-Entry Rescue: Whenever possible, rescue should be performed without requiring rescuers to enter the confined space. This minimizes the risk to rescuers.

Training and Competency:

• Comprehensive Training: All personnel involved in confined space entry (entrants, attendants, supervisors, rescue personnel) must receive thorough training on hazards, procedures, equipment, and emergency response.
• Regular Refresher Training: Refresher training should be provided at least annually, and more frequently if necessary.
• Competency Evaluations: Workers should be evaluated to ensure they have the knowledge and skills to perform their duties safely.

Prioritizing Safety in Confined Spaces

Confined space entry is inherently dangerous, but the risks can be significantly reduced, and accidents can be prevented, through meticulous planning, rigorous adherence to procedures, and a strong commitment to safety. Employers have a legal and moral obligation to protect their workers from these hazards. This means providing comprehensive training, appropriate equipment, and a robust confined space entry program that meets or exceeds OSHA regulations. Workers, in turn, must follow all safety procedures, use the provided equipment correctly, and report any unsafe conditions.

If you or a loved one has been injured in a confined space accident due to an employer’s negligence or an OSHA violation, don’t hesitate to seek legal counsel. Contact Our OSHA Injury Attorneys today for a free consultation. We have extensive experience in handling OSHA injury cases and are dedicated to fighting for the rights of injured workers. We can help you understand your legal options and pursue the compensation you deserve.