Confined Space Safety
April 25, 2007
- Worker dies inside sewage digester while attempting to restart a propane heater; coworker attempting a rescue also dies, both due to an oxygen-deficient atmosphere.
- Worker collapses and dies while cleaning a wastewater holding tank; coworker attempts rescue and also dies, both asphyxiated by methane gas.
- Sewer worker drowns when underground pumping station chamber is flooded with sewage. A would-be rescuer coworker also drowns, and a supervisor and policeman who attempt a rescue die of sewer gas asphyxiation.
Unfortunately, it’s an all too common occurrence. NIOSH and OSHA reports contain far too many examples of incidents involving multiple fatalities in permit spaces. Over half of them involve “Good Samaritan” individuals who rush to the aid of downed coworkers, only to become statistics themselves. And who knows how many “near misses” occur that never get recorded.
OSHA’s Permit-Required Confined Space standard is not new. It was published in January 1993. Yet, needless fatalities in these dangerous spaces continue to occur. If you have permit spaces, you are well aware that some level of training is required for everyone involved in permit space entries. But, does your confined space training stop there? As the tragic incidents noted above indicate, everyone in the workplace should be aware of your permit spaces and the reasons not to enter them.
Make everyone awareMost workplaces have many employees who don’t have a clue about the hazards lurking behind that locked door with the “Dangerâ€”Permit-Required Confined Space” sign posted on it. They’re the ones who need to know why there’s a danger sign, and about oxygen-deficient and toxic atmospheres â€” the hazards they can’t see with the naked eye; the hazards they’ll encounter if they enter that space unprepared.
Only those employees who are trained in confined space rescue should attempt such procedures. However, awareness-level training that focuses on the potential hazards associated with permit spaces particular to their workplace should be conducted for all employees. In addition to the specifics, awareness training should cover the following safety precautions:
Never trust your senses to determine if the air in a confined space is safe. You can’t see or smell many toxic gases or vapors, nor can you determine if sufficient oxygen is present.
Never enter a confined space to attempt an emergency rescue unless you have been trained in safe confined space entry and rescue procedures and have the proper tools and protective equipment.
Routine safety meetings are a good place to remind employees about confined space hazards, and to reinforce the safety policy and entry procedures, and procedures for emergency rescues.
Designated rescuersAs many confined space investigations report, unprepared rescuers often end up as fatalities. That’s why OSHA requires employers with permit spaces to have written procedures for safe entry into, and emergency rescue from, confined spaces.
When the host (site) employer decides to have an in-house rescue team, the responsibility to provide all the training falls on the host. However, when an outside rescue service is used, the obligation for providing the rescue-related training is placed on the rescue service employer. Because the host employer has greater knowledge about the inherent and unique hazards of the site spaces, the host is obligated to share this information with the outside rescue service.
Note: For non-entry rescues, OSHA expects all authorized entrants to wear retrieval devices until it is determined that a retrieval system presents a greater hazard to the entrant or won’t contribute to a successful rescue. If this is the case, the employer may choose not to use non-entry rescue procedures, relying instead on an emergency rescue team.
The provisions in the Permit-Required Confined Space standard at 1910.146(k) outline the steps an employer must take to ensure the rescue team is fully prepared prior to an attempted rescue. These requirements address both in-house rescue teams and outside emergency services.
In-house rescue teamCompanies deciding that the best response to a permit space emergency is an in-house rescue team will need to select team members and provide, at minimum:
- Personal protective equipment (PPE) needed to conduct permit space rescues safely and train members in its use;
- Training, at an authorized entrant level;
- Training to perform assigned rescue duties, and basic first-aid and cardiopulmonary resuscitation (CPR) (At least one member of the rescue team must have a current certification in first-aid and CPR.); and
- Practice training in making simulated permit space rescues at least once every 12 months.
Outside rescue servicesWhen relying on an outside rescue service, OSHA requires that the host employer ensures that the service:
- Is able to respond to a rescue in a timely manner (What is considered “timely” varies depending on the hazards involved.);
- Has appropriate and adequate equipment to complete a successful rescue;
- Has the capability to reach the victim within an appropriate time frame;
- Is proficient in performing the needed rescue services; and
- Has at least one member of the rescue service holding a current certification in first-aid and CPR.
OSHA has an excellent guideline to help employers evaluate and choose an appropriate rescue service. The guideline, in Appendix F of the permit space rule, covers how to do an initial evaluation and a performance evaluation. It can be used for evaluating the capabilities of both prospective and current rescue teams.
As previously mentioned, it is the host employer’s responsibility to inform each rescue team or service of the hazards they may confront and to provide them access to all permit spaces from which they may be called upon to perform a rescue. This will enable the service to develop appropriate rescue plans and practice rescue operations.
OSHA also requires annual refresher training. However, an actual rescue operation taking place during the year can be applied to this annual requirement, as long as a post-rescue critique is documented and remedial action is taken regarding any problems encountered.
Life and deathAn emergency confined space rescue situation is not the time to determine how to get a downed entrant out. Minutes spent in preparation can make the difference between life and death. It takes more than calling in the local fire department; it takes detailed planning, coordinating and training.
Prevent unnecessary permit space fatalities for all your employees by preparing before an emergency rescue attempt happens.