Covering the Basics
Five Components of Confined Space Entry
BY JIMI MICHALSCHECK

It was a regular day at Tom’s Dairy Farm when two family workers were tasked with cleaning out a drain inside a water retention pit. The pit was about eight feet deep, and the task required both workers to lift an entry gate.

Because this family was keen on safety, they developed a confined space program that they felt protected them from the potential hazards that existed on their farm. The two trained authorized entrants named Tom Jr. and Phil opened the entry point, made sure their radios were working, and then put on their four-gas meters to enter.

Their written procedure for the space instructed them to ventilate the space for 15 minutes prior to entry and throughout the duration of the service; however their exhaust fan wasn’t working that day, so they decided to just proceed cautiously with the tools they had on hand.

Tom was the first to enter the space and noticed a foul odor from the buildup of methane that leached in from the dairy cow floor drains above. He’s smelled this before when working around the cattle and didn’t think much of it.

Then he felt light-headed and heard his gas meter going off. He looked down to check it and fainted. His brother Phil heard Tom’s meter go off and against his better judgment proceeded down the ladder to rescue his brother. With the surge of adrenaline and desperation for the situation, Phil was taking even more breaths than usual and became unconscious before reaching Tom.

It wasn’t until later that day that the father realized both boys were missing and started looking around. He saw the open hatch and looked down. He heard their gas meters going off and realized that something was definitely wrong. Instead of going down to try to rescue them, he called 911 and trained rescue teams with proper PPE performed the task.

Unfortunately both Phil and Tom Jr. died that day; however, even more unfortunate was that it was easily avoidable. What did they do wrong? They had a confined space program, training and procedures. Was it because they didn’t ventilate the space that caused the deaths? Actually that was part of it. However, ultimately what ended both of their lives was not following proper emergency rescue procedures.

Had the attendant just called 911, or donned proper PPE such as a SCBA, he would have been able to save his brother’s life and his own.

So what is needed to fully protect your workers at your facility from potential confined space catastrophes like this one?

There are five main components to a complete confined space program:
• Inventory;
• Labeling;
• Policy;
• Procedures; and
• Training.

 Part 1:5 Confined Space Inventory: One of the first steps to constructing a confined space procedure program is to establish a clear list of all confined spaces on your site. For some sites this will be very easy. For instance a hotel or casino may have elevator service pits, large air handler units, or water tanks on site totaling 10-15 spaces, where as a large factory, hospital, or pharmaceutical company may have 30- 100 confined spaces ranging from chemical tanks, underground storage containers, drop pits and more.

The reason taking inventory is a crucial first step is because it will tell you how much work the next steps will be so you can properly prepare and get help from outside firms if needed.

Part 2:5 Confined Space Labeling: Part of OSHA regulation 1910.146 states that all points of entry into a permit required confined space must be clearly labeled. We recommend sticking with the basic confined space signs available from most sign manufacturers as stock items, the most common: “Danger: Permit Required Confined Space.”

We also recommend investing a little more money in the quality of signage to ensure you get a product that will last in your environment. If you are mounting these confined space signs indoors in a clean environment then just about any sign will suffice. However if you are mounting signage with any of the following elements: outdoor UV, harsh chemicals, oils or greases, or frequent physical abuse, then we recommend going with signage designed to last in those elements such as in-mold signage.

Ensure you mount all signs clearly at the main points of entry. Sometimes this will be difficult, such as man-hole entry points. There are special products for these circumstances that allow you to mount the signage below the man-hole cover. Quick tip: Ensure your signage is not mounted on a swinging or removable door because when the door is opened or removed the sign will not be displayed and you may be in violation at that point.

Part 3:5 Confined Space Policy: The policy is perhaps the most important element of your entire confined space program because it brings all the other elements together. OSHA is flexible about what it includes, however we recommend including the following elements to keep you compliant with the regulation’s entirety:

• Entry Permits and where to file the completed forms;
• Annual training requirements and testing;
• Emergency rescue procedures;
• Atmospheric testing procedures and proper equipment use;
• PPE available at the site;
• Common hazards at the site that they might encounter (this will be redundant with what is found in your procedures, but that’s okay); and
• Company confined space rules and means of enforcement if the rules are broken.

Part 4:5 Confined Space Procedures: This is the heart of your program because it’s the segment most commonly used by the authorized entrants. OSHA requires that all permit required confined spaces must have a documented procedure available for the authorized entrants. The intent of the procedure is to explain the hazards of the space they are about to enter and let them know what the proper steps to take to ensure they stay safe while entering and working inside the space.

A good confined space procedure should clearly outline the hazards in an easy-to-read grid layout along with the means of protection and verification steps. The easier a procedure is to read, the more likely it will be to follow. Two other important elements to include in a confined space procedure are references to any associated lockout- tagout procedures along with proper entry and exit procedures.

Many companies choose to just create their confined space procedures on the fly when they are needed. This is out of compliance and unsafe. In an emergency, authorized entrants must be able to reference a clearly written procedure to ensure they're using the proper PPE and understand all the hazards before they enter or attempt to rescue an entrant.

Part 5:5 Confined Space Training: As with other safety programs, training is the catch-all program element that if implemented well enough may make up for any other deficient element. It will also help with employee buy-in and overall program maintenance. We recommend training and testing on the essential elements of the company policy, PPE, confined space tools, and proper procedure usage. It’s also a good idea to train the entrants to identify deficiencies in the system and how to report them so they can help keep it up to date as systems change or need maintenance.

Confined Space is not a new concept, and neither are the horrific stories of the dozens of avoidable deaths that occur every year as a result of non-compliance with the standard. With a few basic steps initiated from the employer, all authorized entrants can be guaranteed safety while they work in potentially hostile confined spaces. Be safe out there. FSM

Jimi Michalscheck is vice-president and co-owner of ESC Services, Inc., an engineering firm that specializes in lockouttagout and confined space compliance. They have helped more than 250 companies around the U.S. achieve and maintain compliance. To contact ESC, visit their website at www.escservices.com or call 262.939.4825.