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Have you recently checked on your permit-required confined space compliance? Risks can go well beyond hefty Occupational Safety and Health Administration (OSHA) fines. Potential outcomes of confined space entry can be serious, even fatal, and include asphyxiation, engulfed or trapped workers, explosions or fires, and electrical and struck-by hazards.

There are confined spaces in workplaces across many industries that include ductwork, equipment housings, hoppers, manholes, pipelines, pits, silos, storage bins, tanks, tunnels, vaults, and vessels. These are spaces that are not designed for occupancy but that workers may need to enter, and the means of entry or exit may be limited or restricted.

A permit-required confined space is one that contains or can contain a hazardous atmosphere; contain material that may engulf a worker; has walls that converge inward or floors that slope downward and taper into a smaller area where a worker can become trapped or asphyxiate; or contain a recognized safety or health hazard, such as excessive heat, exposed live wires, or unguarded machinery.

You must identify such spaces in your facility or at your worksites and inform affected employees of permit-required spaces and their associated hazards.

An oversight in your compliance with the federal permit-required confined space standard (29 Code of Federal Regulations (CFR) §1910.146) or the comparable state standard can have catastrophic results.

Hazardous atmospheres in confined spaces can include gases like carbon monoxide, hydrogen sulfide, and nitrogen. However, a recent fatality involved argon, an odorless gas.

On November 12, 2021, a worker at the Valero Refinery in Benicia, California, descended into a regenerator overflow well to evaluate the condition of the well interior and perform cleaning operations in advance of a welding crew.

The worker lost consciousness and was later found inside the regenerator, suspended by his fall protection equipment. Rescuers from the Benicia Fire Department and Valero Refinery Fire Department performed medical treatment on-site but could not resuscitate the worker.

Investigators with the California Division of Occupational Safety and Health (Cal/OSHA) determined that a welding torch left in the well was leaking argon that displaced oxygen inside the well. Cal/OSHA cited Valero and its contractors with willful, serious, and other violations, seeking a combined $1,753,375 in proposed penalties.

During a shutdown for maintenance and capital improvement projects at the Evergreen Packaging paper mill in Canton, North Carolina, two separate crews were working in connected process vessels—the upflow and downflow towers of one of Evergreen’s pulp bleaching units. The crew in the upflow tower were applying flammable epoxy vinyl ester resin and sheets of fiberglass to the inside walls of the vessel. Cooler nighttime temperatures caused the resin to harden more slowly than the workers anticipated, leading to newly applied resin and fiberglass sliding down the walls of the vessel.

The workers resorted to using a portable, electric heat gun to warm the resin, enabling it to harden quicker. The heat gun fell into a 5-gallon bucket of flammable resin, igniting it.

The workers in the upflow tower escaped and evacuated the vessel, but flames and smoke spread to the connected vessel, fatally injuring two workers in the downflow tower.

The U.S. Chemical Safety and Hazard Investigation Board (CSB) investigated the incident, identifying four safety issues that contributed to the fatal incident: combustible materials, confined space safety, hot work safety, and pre-job planning. Workers in the upflow tower failed to recognize the electric heat gun as an ignition source requiring a hot work permit. Evergreen and its two contract firms treated the connected vessels as separate confined spaces.

On January 28, 2021, at a Gainesville, Georgia, poultry processing facility, a freezer malfunctioned, releasing colorless, odorless liquid nitrogen into the plant’s air.  

Six workers died from nitrogen exposure caused by the malfunctioning freezer.

OSHA investigators determined that the host employer failed to implement a permit-required confined space program for workers who entered the liquid nitrogen freezer or notify contractors required to work inside the freezer that it was a permit-required confined space.

The four employers at the poultry processing facility found themselves facing nearly $1 million in OSHA penalties for a total of 59 violations.

Dangerous atmospheres are also a frequent, sometimes fatal hazard in cleaning and servicing rail tank cars. Two workers at a Hugo, Oklahoma, facility sent into a natural gasoline tank car died from inhaling toxic fumes. OSHA determined that Dallas-based Trinity Rail Maintenance and Services failed to follow permit-required confined space entry procedures, monitor hazards inside a confined space, and properly ventilate it.

Specifically, OSHA cited Trinity with two willful, serious violations of the permit-required confined space standard for failing to test conditions in a confined space before allowing employees to enter where they would be exposed to a hazardous atmosphere and failing the prepare an entry permit, leading to employees’ exposures to corn oil, methanol, and natural gasoline respiratory hazards inside tank cars.

Trinity also failed to assign an attendant outside a permit-required confined space who was informed of the hazards of the confined space and knew the mode, signs and symptoms, and consequences of exposures inside tank cars. Additionally, the company failed to provide initial, follow-up, or refresher training for permit-required confined space entry when employees were exposed to a new hazard.

OSHA investigators also concluded that the company failed to:

Confined space hazards are so common in the industry that two OSHA regional offices last year launched regional emphasis programs (REPs) focused on enforcement of the permit-required confined spaces standard in the industry. The REPs for Transportation Tank Cleaning Operations remain in effect in Region 5 (Illinois, Indiana, Michigan, Minnesota, Ohio, and Wisconsin) and Region 6 (Arkansas, Louisiana, New Mexico, Oklahoma, and Texas).

Understanding how OSHA enforces the standard can help. You will better understand your compliance duties if you consult the agency’s detailed instructions (CPL 2.100) for applying and enforcing the permit-required confined space standard.

You first need to identify confined spaces in your facility or at your worksites and develop confined space entry permit and training programs. In a nutshell, compliance involves ensuring those who are not trained and equipped do not enter permit-required confined spaces and that those who do are trained, equipped, and monitored. You also need the means and personnel to rescue them if something goes wrong.

During an inspection, an OSHA compliance safety and health officer (CSHO) will want to know how you identify permit-required spaces, as well as whether you review non-permit-required spaces for hazards that would make them permit-required spaces.

Before allowing any of your employees to enter a confined space, you must identify any physical hazards of the space. You also need to test the atmosphere and monitor for explosive hazards, flammability, oxygen content, and toxicity before and during employee entry.

A CSHO will want to know if the sampling equipment you use is being maintained and calibrated in accordance with the manufacturer’s recommendations and will ask if air sampling, monitoring plans, and procedures take sampling equipment limitations into consideration. Additionally, an OSHA inspector will want to know whether sampling plans include measuring the exposure at employee locations and other locations within the space.

Personnel permitted to enter a confined space must be provided with properly maintained personal protective equipment (PPE) and other equipment necessary for safe entry, such as air-monitoring and communications devices, and fall protection equipment.

You must always station a trained attendant outside the confined space who maintains contact with confined space entrants either visually, via phone, or by two-way radio. Monitoring enables the attendant and entry supervisor to order confined space entrants to evacuate or alert trained rescue personnel to rescue entrants if necessary.

Each time employees or contractors enter a permit-required confined space, a written entry permit must be prepared that includes the following information:

All employers at a multiemployer worksite have responsibilities for compliance with confined space requirements.

If you exclusively rely on a third-party rescue service, you must ensure that the rescue service can protect its own employees.

When looking at third-party rescue services, you want a provider that has adequate equipment for possible rescues at your facility or worksites, such as atmospheric monitors, extraction equipment, fall protection gear, and self-contained breathing apparatus (SCBA) appropriate for your particular permit-required confined spaces.

A prospective rescue service provider should also have the ability to respond and conduct a rescue in a timely manner based on your site conditions, managing the potential hazards specific to your confined spaces. You also will want a provider that will notify you when the rescue team becomes unavailable.

Your compliance begins with identifying permit-required confined spaces and their hazards. You need to ensure that only properly trained, equipped, and permitted entrants are allowed to enter a confined space, and conditions in the space must be monitored before and during entry. Moreover, an attendant must maintain contact with entrants, and you must have planned rescue procedures and rescue personnel available in case something goes wrong.

The Hazard Communication Standard (HCS) requires pictograms on labels to alert users of the chemical hazards to which they may be exposed. Each pictogram consists of a symbol on a white background framed within a red border and represents a distinct hazard(s). The pictogram on the label is determined by the chemical hazard classification.

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