035: Confined Spaces Pt 2 - Safety with Entry Permits

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This is part 2 in a series about confined space entry, the requirements including training and entry procedures and we will wrap the series up with some tips, interpretations and examples written programs. If you remember from the last episode I covered the basic definition of a confined space:

Is large enough and so configured that an employee can bodily enter and perform assigned work

Has limited or restricted means for entry or exit (for example, tanks, vessels, silos, storage bins, hoppers, vaults, and pits are spaces that may have limited means of entry.

AND (yes, it has to have all of these)

It is not designed for continuous employee occupancy. And we talked about what that means as well.

And a ”Permit-required confined space (permit space)" means a confined space that has one OR more of the following characteristics:

1. Contains or has a potential to contain a hazardous atmosphere 2. Contains a material that has the potential for engulfing an entrant 3. Has an internal configuration such that an entrant could be trapped or asphyxiated by inwardly converging walls or by a floor which slopes downward and tapers to a smaller cross-section OR 4. Contains any other recognized serious safety or health hazard

Okay, we touched on just some of the training requirements as well. Not too much detail there, but I will go into rescue teams including in-house rescue and the training requirements in the next episode, so be listening for Part 3. For now let’s move into the actual permit and entry procedures.

Let’s begin with the space itself. Any time you remove covers to openings, especially at ground level, it has to be guarded immediately by a railing, temporary cover, or other temporary barrier that will prevent an accidental fall through the opening.

You always want to address safety outside the space, before beginning work - addressing the space itself. This means identifying any potential hazards that may impact ground workers outside, but also those that may create hazards inside the space. For example, any generators or other combustion engines (like from service trucks) that may be running nearby and could create a carbon monoxide hazard entering the space.

And of course, before any employee can enter the space, the internal atmosphere has to be tested. You do this with a calibrated direct-reading instrument, for oxygen content, for flammable gases and vapors, and for potential toxic air contaminants, in that order. Most multi-gas meters will test for all of these simultaneously. So no need to worry about the order in that case.

Keep in mind, any employee who enters the space has to be provided an opportunity to observe the pre-entry testing directly. This avoids the whole “hey I checked, it’s fine in there” type of scenario.

A note on this one; anyone that witnesses the monitoring needs to be trained on monitoring as well. This means how to operate and read the results. This way they know what they are looking at. Plus, if continuous monitoring goes on, they know what the alarm sounds like and of course if they take one in with them, they know how to operate it as well.

If you plan to use forced air ventilation, be sure to set it up the right way. Notice I said “forced air”. You cannot use negative pressure. That is, a fan pulling air OUT of the space. Some folks may think pulling “bad air” out is a better idea. It is not. Forcing fresh air in is required. And testing has to be done with the forced air ventilation in place and operating. So what do you do with the test results?

Well, it is all part of the permit system. According to OSHA, the employer must verify the space is safe for entry by way of a written certification that contains the date, the location of the space, and the signature of the person providing the certification.

The certification must be made before entry and be made available to each employee entering the space. This is accomplished by using an entry permit. Let’s get into what the permit looks like.

Let’s talk about the permit itself for a bit. The actual permit has to contain the following information:

1. The permit space to be entered: This can be a site name such as vault 2B, or autoclave oven # 4, something like that.

2. The purpose of the entry: This can say PM check of tank welds, changing O-rings, stuff like that.

3. The date and the authorized duration of the entry permit: If there are issues with extreme heat or cold, you may have placed a 15 minute time-limit on the entry. Or if using breathing air, like SCBA, you could place a time limit for the entrants. These are examples of authorized durations, as I get asked about this one frequently. Essentially, the duration of the permit cannot exceed the time required to complete t