1. Not monitoring the confined space prior to, and during, entry1910.146 (d)(5)(i) “Test conditions in the permit space to determine if acceptable entry conditions exist before entry is authorized to begin...” and (d)(5)(ii) “Test or monitor the permit space as necessary to determine if acceptable entry conditions are being maintained during the course of entry operations…”
Knowing the atmospheric conditions inside the confined space can mean the difference between life and death. No employee should go in until he is aware of the hazards that he faces on the inside, such as exposure to a toxic, oxygen-deficient or enriched, or flammable atmosphere. It is also important to monitor during entry because conditions can change. For even more protection, have the entrant positioned near a monitor with an alarm to warn them if conditions change.
2. Failure to remove hazards from the confined space1910.146 (f)(8) Entry permit. The entry permit that documents compliance with this section and authorizes entry to a permit space shall identify: …the measures used to isolate the permit space and to eliminate or control permit space hazards before entry; NOTE: Those measures can include the lockout or tagging of equipment and procedures for purging, inerting, ventilating, and flushing permit spaces.”
Before anyone enters a confined space, steps should be taken to lockout energy hazards, double block and bleed lines that run into the space, ventilate the confined space if it contains a hazardous atmosphere, and remove engulfment hazards. Confined spaces are dangerous enough without these additional hazards.
3. Bringing hazards into the confined space1910.146 (d)(3)(vi) “Verifying that conditions in the permit space are acceptable for entry throughout the duration of an authorized entry.”
Usually, confined spaces are entered because work needs to be done inside them. Oftentimes this work requires that tools be taken into the space. When this occurs, you should analyze the work to be performed to make sure that it will not create an unsafe environment for the entrant. Pay special attention to spark-producing tools (you do not want to use these in oxygen-rich environments or atmospheres above the LEL), anything that can produce carbon monoxide, and welding. Ventilation may be used and monitoring may need to be performed to ensure safety during these activities.
4. Failing to have trained rescue personnel onsite and standing by1910.146 (k)(1)(iii) “Select a rescue team or service from those evaluated that: Has the capability to reach the victim(s) within a time frame that is appropriate for the permit space hazard(s) identified; is equipped for and proficient in performing the needed rescue services; inform each rescue team or service of the hazards they may confront when called on to perform rescue at the site; and provide the rescue team or service selected with access to all permit spaces from which rescue may be necessary so that the rescue service can develop appropriate rescue plans and practice rescue operations.”
The confined space fatalities that I have investigated had one thing in common: reliance on an outside party for rescue. Generally, this would be a local fire department that had no idea that an entry was taking place — or that they were considered the rescue team. Inevitably, this ends in disaster. Survival for the entrant in an oxygen-deficient or toxic atmosphere depends on immediate rescue. Calling the outside party and notifying them once the entrant is in trouble usually means one of two things: Either the outside party arrives once it is too late, or an untrained fellow employee enters the confined space in an attempt to rescue the entrant. This often results in a second fatality.
5. Failing to use a mechanical means of rescue1910.146 (k)(3) “To facilitate non-entry rescue, retrieval systems or methods shall be used whenever an authorized entrant enters a permit space, unless the retrieval equipment would increase the overall risk of entry or would not contribute to the rescue of the entrant.”
Using a tripod and hoist, if the confined space configuration allows it to protect the entrant and rescue them, enables would-be entry rescuers to remove the entrant from outside the confined space. The other advantage is that rescue can be performed immediately, with the rescue team standing by.