The 2009 edition of ANSI Z117 Safety Requirements
for Confined Spaces has been published. The standard
contains numerous updates. If I had to sum up
the changes in one word it would be clarity. Most of the
changes are not substantial but clarify the intent of the
committee in several important areas.
Beyond OSHA requirements
ANSI Z117 was first published prior to the OSHA
1910.146 Confined Space Standard. OSHA used Z117 in
the development of their own standard. The ANSI standard
goes beyond OSHA though in a number of key areas.
All ANSI standards are consensus documents. A
balanced committee of representatives with expertise
in the topic debates the content of the standard until
consensus is reached. No one individual or group can
unfairly sway the final standard. Public comment is
also incorporated into the process. ANSI rules require
that the committee address all public comments.
The confined space standard uses a performance-based
approach. Guidelines are established on what must be
done but latitude is provided concerning how any particular
organization accomplishes the objectives. I believe this
approach is significantly better than a prescriptive standard
that requires things to be done in a specific way.
Z117 is laid out in a two-column format. The left column
contains the mandatory elements of the standard.
The right column provides explanatory material that can
assist the user with interpreting and applying the left column
items but does not create additional requirements. A
simpler way to look at this concept might be that “shall”
statements are in the left column and “should” comments
are in the right column. There are also appendicies that
contain useful but nonmandatory information.
Better hazard identification
A definition was added for “serious hazard” allowing
differentiation between serious hazards and less severe
issues considered hazards. A non-permit space may have
hazards. Any space that contains serious hazards must be
classified as a permit-required space. A serious hazard
is one capable of causing death, substantial injury, or of
incapacitating the entrant.
One specific clarification is that
hazard identification must be completed
prior to any entry of the space
and must be conducted by a qualified
person. This concept has been in
place but the wording was more open
to interpretation in the previous edition
of the standard.
Training: Beyond once and done
Another specific addition to
the standard is that both initial
and follow up training are required.
No fixed timing is specified for ongoing
training but the concept that once and done
is enough is clearly no longer permitted. The need for
supplemental training is driven by gaps in performance,
changes in spaces, procedures, equipment, or hazards.
The effectiveness of training must be assessed periodically
by a qualified person. One of the best ways
to complete this is with job site audits of confined
space entry operations. Evaluating actual performance
tends to provide the best view of whether knowledge
and skills are being appropriately applied.
Training must be provided as often as necessary to
insure competence. The frequency will vary depending
upon the nature of your entry operations. How
often your personnel engage in confined space work
will be one of the main influences. Organizations that
seldom conduct confined space entries may actually
require more refresher training than groups that use
their skills frequently. Where entries are routinely
made, one of the key issues to watch for is the introduction
of shortcuts or other bad habits.
The level of risk should also be part of the determination
on the frequency of supplemental training.
Where confined space entries involve relatively low
risk environments training may not be needed as often
as in those operations where hazards are more severe.
Atmospheric hazards are historically the leading cause
of death in confined space incidents. The standard places
a great deal of emphasis on identification
and assessment of atmospheric hazards,
atmospheric monitoring, appropriate training
for those who conduct the monitoring,
and elimination and control measures
for atmospheric hazards.
A process, not a program
The essence of the confined
space safety process laid out in
the standard includes identifying
spaces and their hazards;
developing a written process for
managing entry operations including
the use of a permit to authorize entry;
training personnel so that they are competent to
implement the process; preparing and using appropriate
hazard elimination and control processes and techniques;
preparing effectively for emergencies; and evaluating the
performance of the overall process.
Depending upon the nature of your confined spaces,
implementation may not always be easy. Effective
use of the standard will help prevent confined space
incidents that may lead to deaths and injuries.
Resource
Click on the ASSE Resource Center at www.ishn.com, click on “Standards,” and click on the description of ANSI/ASSE Z117.1-2009 Safety Requirements for Confined Spaces and ANSI/ASSE Z117.1-2009 Standard and the Z117 Comparison Document
CraigSchroll Craig is a Certified Safety Professional,
and a Professional Member of the American
Society of Safety Engineers. He has 37 years experience
in safety and loss control activities. Craig is a
frequent conference speaker, author, and seminar
leader. He founded FIRECON in 1980 with the mission
of helping clients prevent, plan for, and control
emergencies. He serves on a variety of NFPA and
ANSI committees including Z117. He may be contacted
at Craig@FIRECON.com.
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