Implementing OSHA’s Confined Spaces Standard

Q. I have always struggled to understand the applicability of the OSHA’s Permit-Required Confined Spaces standard and how best to go about properly implementing a program. Please shed some light on an approach someone like myself may follow to make certain we achieve compliance with this standard and protect my employees. G.W.

A. The Permit-Required Confined Space standard is found in OSHA’s general industry standards at 29CFR1910.146, which can be accessed from the OSHA web site, www.osha.gov.

From our experience, we find that many facilities not only struggle with implementing a program, but maintaining it once it is in place due to frequent line and tank changes to meet customer demands. As process changes occur, the program needs to be re-evaluated.

Some of the typical permit-required confined spaces in the metal finishing industry include process tanks, chemical storage tanks, wastewater treatment tanks and sumps/lift stations.

In meeting the intent of the standard, the following approach may prove useful:

I. Site Evaluation

1. Determine what confined spaces exist at the facility. Although the standard’s definition of confined space is quite vague, for open-top tanks and vats, we use a rule-of-thumb of four feet or greater in depth, but this may not be the case for manholes, sumps and pits.

2. Determine if the identified confined spaces should be considered permit- required confined spaces. These are spaces that could potentially contain a hazard (i.e., oxygen deficient, flam- mable vapor or toxic vapor) during an entry operation. Most metal finishing plants have tanks and vats that accumulate sludges in the bottom that may be cor- rosive or toxic in nature or liberate potentially hazardous gases when disturbed. Also, keep in mind that weld- ing and thermal cutting in a tank could cause an oxygen deficient atmosphere quite rapidly. We have evaluated rinse tanks greater than four feet in depth and determined that they were NOT a permit- required confined space.

3. Document your findings of the site evalu- ation. If it is determined that permit- required confined spaces do exist, then the standard is applicable and a program must be implemented.

II. Program Implementation

1. Develop a plant specific written pro- gram that specifies the actions your facility is taking to achieve compli- ance with the standard and protection of your employees. There is a sample program located in Appendix C of the above OSHA standard that may help.

2. Create an entry permit system that will serve as documentation for the entry operation to be safety per- formed. There is a sample permit located in Appendix D of the above OSHA standard.

3. Place warning signs on or near the entry point of each permit-required confined space.

4. Obtain the proper safety equipment. In making this determination, each permit-required confined space must be evaluated for its particular needs. At a minimum, the typical safety equipment includes a safety harness, life line/rope, safety glasses and/or goggles, rubber boots and gloves, Tyvek® suit and atmospheric meter. Depending upon the space, an injured person may not be able to be removed from the space without some sort of a wrench mechanism.

5. Make a determination whether to use employees for rescue or an outside service, such as a local fire depart- ment. If facility employees are to be used, then extensive training and refresher training must be provided in accordance with 29CFR 1910.120(q). If outside rescue ser- vices are to be used, then you need to review them in accordance with 29CFR1910.146(k) and document that they are able to perform. In an effort to minimize, if not eliminate the need for rescue services, try to retrofit those hard to remove spaces with mechanism that will allow a downed employee to be removed by someone located outside the space.

6. Provide initial and refresher employee training for those employees designated to perform permit-required confined space duties and provide general aware- ness training for all employees.

III. Program Evaluation

1. Maintain canceled entry permits for one year as to allow for an annual review of the program. If discrepancies are noted, the written program must be updated to reflect such changes.

In summary, there is not one fit for every facility.