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Lesson: 1 – Introduction & Regulations
This training is designed to meet the requirements of OSHA regulation 29CFR1910.146. Hello, and welcome to the Safety Moment’s training on Confined Space Entry for Entrants & Attendants. This course is designed to give you the basics you need to become qualified on being an Entrant, or Attendant for permit required confined spaces. This training does not complete the requirements for Entry Supervisor or Emergency Rescue as outline in OSHA Part 1910.146. On April 15, 1993, OSHA regulation 1910.146 became effective. This regulation, known as “Permit‐required confined spaces,” deals with the identification of confined spaces that pose health hazards to anyone entering them and the protection of employees from the hazards of these confined spaces. The regulation also specifies requirements for employers. The regulation requires that employers do the following: 1. Evaluate the workplace to identify all permit‐ required spaces. 2. Develop a permit space entry program that specifies proper entry procedures and permit contents. 3. Train employees involved in permit entry. These employees may actually enter the space, act as “watches” from outside the space, supervise the entry, or be a part of a rescue team. 4. Comply with requirements pertaining to contractors entering a permit space.
Let’s begin by defining a few terms.
Confined Space ‐ A confined space is any space that is large enough and so configured that an employee can bodily enter and perform assigned work. It also has limited or restricted means for entry and exit and is not designed for continuous employee occupancy.
Examples of confined space include: storage tanks, process vessels, columns, manholes, valve pits, culverts, or excavations measuring five feet deep or more at any point. Spaces that fall into these categories of confined spaces are common in most industrial facilities. The regulation goes on to define a “permit‐required confined space.” This is any confined space that also has one or more of the following characteristics:
It has the potential to contain a hazardous atmosphere, It has material that has the potential for engulfing someone who enters it, It has an internal configuration such that someone could be trapped or asphyxiated by inwardly converging walls or by a floor which slopes downward to a smaller cross‐section, or It contains any other recognized serious safety or health hazard.
Many industrial facilities have chosen to treat all confined spaces in their facility as “permit‐required confined spaces.” PERMIT REQUIRED CONFINED SPACE
1. 29 CFR 1910.146 is the OSHA regulation known as ____________________. (check one answer) Confined Space Entry Permit‐required Confined Spaces OSHA Rule 146 Confined Space Health and Safety 2. The Permit‐Required Confined Spaces rule requires that employers: (check all that apply) Train employees involved in permit entry. Develop a permit space entry program. Evaluate the workplace to identify all permit‐required space. Comply with requirements pertaining to contractors. 3. A confined space is any space that: (check all that apply) Has the potential for containing a hazardous atmosphere. Has limited entry and exit. Is large enough that an employee can bodily enter it and perform work. Is not designed for continuous occupancy. 4. Which of the following are examples of confined spaces? (check all that apply) Excavations more than 5 feet deep A unit control room Storage tanks Valve pits 5. A permit‐required confined space is a confined space that: Contains material that has the potential for engulfing a person. Could trap or asphyxiate someone. Is to be occupied by more than one person. Has the potential for containing a hazardous atmosphere. 6. Many industrial plants have chosen to treat all confined spaces as permit‐required confined spaces. True False
Lesson: 2 – Entrant Duties
Let’s define the people involved in the permit‐required confined space entry procedure.
Authorized Entrant ‐ Anyone authorized to enter a permit‐ required confined space is called an Authorized Entrant, frequently shortened to Entrant. Entry is defined as the action by which a person passes through an opening into a permit‐required space. Entry includes any subsequent work in that space and occurs as soon as any part of the person’s body crosses the plane of an opening into the space.
The duties of the Authorized Entrant are as follows: 1. Know the hazards that may be faced during entry, including the information on the mode, signs or symptoms, and consequences of exposure, 2. Properly use equipment, Communicate with the Attendant as necessary to enable the Attendant to monitor the Entrant’s status and to enable the Attendant to alert Entrants of the need to evacuate the space, 3. Alert the Attendant whenever the Entrant recognizes any warning sign or symptom of danger, or if the Entrant detects a prohibited condition, 4. Entrants must exit the permit space as quickly as possible whenever an order to evacuate is given by the Attendant or the Entry Supervisor, the Entrant recognizes any warning sign or symptom of exposure to a dangerous situation, the Entrant detects a prohibited condition, or an evacuation alarm is activated. 1. Entry is considered to have occurred when: (check one answer) The Entrant's head crosses the plane of the confined space opening. The Entrant is completely inside the confined space. The Entrant is no longer visible from outside the space. Any part of the Entrant's body crosses the plane of the confined space opening. 2. During entry, the Entrants must: (check all that apply) Keep in contact with the Attendant. Wear impervious clothing. Exit if an evacuation alarm is activated. Wear full‐face respiratory equipment.
Lesson: 3 – Attendant Duties
Whenever someone enters a permit‐required space, another person must be stationed outside the space at a point where the entrants can be watched in case trouble develops. This person is referred to as an Attendant.
Let’s take a look at the Attendant’s duties:
1. Know the hazards that may be faced during entry, including the information on the mode, signs or symptoms, and consequences of exposure, 2. Be aware of possible behavioral effects of hazard exposure on Authorized Entrants, 3. Continuously maintain an accurate count of Authorized Entrants and be able to identify each one, 4. Remain outside the permit space during entry operations until relieved by another Attendant, 5. Communicate with the Entrants as necessary to monitor Entrant status and to alert Entrants of the need to evacuate the space, 6. Monitor activities inside and outside the space to determine if it is safe for Entrants to remain in the space and to order evacuation of the space if these conditions arise: a. If a prohibited condition is detected, b. If the behavioral effects of hazard exposure are detected in an Authorized Entrant, c. If a situation outside the space that could endanger the Authorized Entrants is detected, d. The Attendant cannot perform all the duties required.
7. Summon rescue and other emergency services as soon as the Attendant determines that the Entrants may need assistance to escape from the space hazards, 8. Warn unauthorized personnel that they must stay away from the permit space, advise unauthorized persons that they must exit immediately if they have entered the permit space, and inform Authorized Entrants and the Entry Supervisor if an unauthorized person has entered the permit space. 9. Does not perform any duties that might interfere with the Attendant’s primary duty to monitor and protect the Authorized Entrants from outside the confined space.
1. Whenever someone enters a permit‐required space: (check one answer) A Supervisor is to stand watch. An Attendant must be present. The Safety Supervisor must be present. Two people must be placed outside the space as "watches."
2. The Attendant must: (check all that apply) Monitor activities outside the space. Sign the entry permit. Monitor activities inside the space. Keep track of who is in the space. Lesson: 4 – Entry Supervisor Duties Let’s look at the duties of an Entry Supervisor: 1. Know the hazards that may be faced during entry, including the information on the mode, signs or symptoms, and consequences of exposure, 2. Verify that appropriate entries have been made in the entry permit, that all tests have been conducted, and that all procedures and equipment specified by the permit are in place before endorsing the permit and allowing entry to begin, 3. Terminate the entry and cancel the permit when necessary, 4. Verify that rescue services are available and that the means for summoning them are operable, 5. Remove unauthorized individuals who enter or attempt to enter the permit space during entry operations, 6. Make sure that acceptable entry conditions are maintained during the entry. This may mean re‐ testing the atmosphere and making sure that if the responsibility for the entry changes hands, the new Supervisor is fully aware of the situation.
1. Who has responsibility for an entry? (check one answer) The Entry Supervisor The Safety Department The Attendant The Unit Foreman 2. Who is responsible for issuing an entry permit? (check one answer) The Entry Supervisor The Unit Manager The Attendant The Safety Department 3. The regulation defines duties for which of the following people? (check all that apply) Program Administrator Authorized Entrant Entry Supervisor Attendant
Lesson: 5 ‐ Entry
The procedure for entering a permit‐required confined space begins with an evaluation of the confined space to be entered. That is, a determination of the extent of the hazards is made. At this time the entry team makes an announcement over the Public Address system (PA) before a Confined Entry starts and when it is concluded.
Prior to anyone entering a permit‐required confined space, the space must be drained of its contents and thoroughly cleaned to remove all traces of any harmful materials. Pumps, piping, exchangers or other equipment associated with the work to be done must also be drained and cleaned prior to entry.
The space must then be isolated. Isolation is the process by which a permit space is removed from service and completely protected against the release of energy and material into the space. Methods of isolation include: blanking or blinding, misaligning or removing sections of pipes, a double block and bleed system, lockout of all sources of energy, and blocking or disconnecting of all mechanical linkages.
Most industrial facilities require that all connected piping be blinded at the flange closest to the vessel. Or in case of threaded piping, the line must be physically separated as close to the vessel as practical. Instrument lines using nitrogen as a backup and level transmitters using nitrogen must also be disconnected.
Block & Bleed
Double block and bleed means the closure of a line, duct, or pipe by closing two in–line valves and by opening and locking or tagging a drain or vent valve in the line between the two valves.
Isolation also includes locking out energy sources. Electrically operated devices must be locked out and tagged according to an approved procedure.
Once the space is cleaned and isolated, it must be ventilated in order to create and maintain a suitable atmosphere for entry. If adequate natural ventilation cannot be achieved, then mechanical ventilation must be used. Either explosion‐ proof electric or pneumatic air movers may be used. The correct method of ventilation is to place the air mover such that it draws fresh air into the space and exits through the air mover. When using pneumatically driven air movers, be sure to use plant air and not nitrogen as the source of energy. It is also important to be sure that plant air is used to power pneumatic tools ‐ not nitrogen.
Now that we have the space opened, cleaned, and ventilated, we can begin testing the atmosphere inside the space. Tests are run for the following (Tests must be run in the sequence given): oxygen content, flammable gases and vapors, and potential toxic air contaminants. Qualified individuals using direct‐reading instruments must run tests. Additional Testing is required when: 10 minutes of ventilation has been completed (if ventilation is necessary); At least hourly for permit‐required confined spaces. More frequently, if conditions or suspicions warrant. Always test the air at various levels to be sure that the entire space is safe. Know your air testing equipment. Monitors can have air pumps that run at different rates so the time required to get a accurate reading will vary. Also the amount of rubber tubbing lowered into the CS will change the length of time necessary for an accurate reading.
Good air near the opening does NOT mean there is good air at the bottom!
There must be no hazardous atmosphere within the space whenever any employee is inside the space. A hazardous atmosphere is defined as one with the following characteristics:
The oxygen content is less than 19.5% or greater than 23.5%, Flammable gas, vapor, or mist is in excess of 10% of its lower flammable limit (LFL), Airborne combustible dust is at a concentration that meets or exceeds its LFL, The presence of toxic materials is in excess of its permissible exposure limit (PEL), Or it contains any other atmospheric condition that is immediately dangerous to life or health (IDLH).
Special Circumstances ‐ Open Floating Roof Storage Tanks: Activity on the roof of an open floating roof storage tank requires an Entry Permit under the following conditions: 1. The floating roof is four feet or more below the top of the tank. 2. The roof is not in the static position. 3. The tank is in benzene service or has the potential to contain H2S, regardless of roof level.
When an Entry Permit is required for an open, floating‐roof storage tank, the following conditions must be met. 1. An attendant must be present. 2. An O2/combustible gas meter is used by personnel descending to a roof in the non‐static position, or one that is four feet or more below the top of the tank. 3. An H2S monitor is used if the tank has the potential to contain Hydrogen Sulfide. 1. Prior to entering a confined space, the space must be _______. (check all that apply) Measured Cleaned Drained Isolated 2. Methods of isolation of a confined space include: (check all that apply) Bleeding Blinding Blanking Lockout
3. For purposes of entry, a line should be blinded: (check one answer) At each control valve. By the Safety Department. At the flange closest to the space to be entered. On both sides of a block valve. 4. The correct method for ventilating a confined space is: (check one answer) To fill it with water and then empty it. To force fresh air into the space with fans. To displace the atmosphere in the space with oxygen. To draw air through the space by means of an air mover. 5. Nitrogen may be used to power pneumatic equipment during entry provided sufficient air is available. True False 6. Tests for which of the following must be run prior to entry? (check all that apply) Toxic materials Flammable materials Oxygen content Carbon dioxide 7. Which of the following represents a hazardous atmosphere? (check all that apply) It contains toxic substances greater than the PEL. It contains 22% oxygen. It is considered an immediate danger to life or health. 8. What does PEL stand for? (check one answer) Permissible Equipment List Personal Emergency Life vest Permissible Exposure Limit Permitted Equipment List 9. A hazardous atmosphere contains: (check all that apply) More than 20% oxygen. Less than 21% oxygen. Less than 19.5% oxygen. More than 5% nitrogen. 10. If the roof of a floating‐roof storage tank is not in a static position, an Entry Permit is required. True False 11. Which of these is required anytime an Entry Permit is in effect? (check one answer) An attendant Source of flame Flame retardant clothing An electric ventilation system 12. If you hear an emergency alarm while on the roof of a confined space, remain where you are and wait for instructions. True False
Lesson: 6 ‐ Permitting
The entry permit must identify:
The permit space to be entered, The purpose of entry, The date and authorized duration of the permit, The authorized Entrants within the space, by name or other means that enables the Attendant to determine quickly and accurately which Entrants are inside the space at any given time.
The permit must also contain:
The personnel, by name, currently serving as Attendants, The name of the current Entry Supervisor, with a space for the signature or initials of the Entry Supervisor who originally authorized the entry, The hazards of the permit space, The measures used to isolate the space and to eliminate or control space hazards before entry,
The acceptable entry conditions, The results of initial tests and periodic tests and the name or initials of the person that performed the tests, The rescue and emergency services that can be summoned and the means for summoning them, The communication procedures used by Entrants and Attendants to maintain contact during the entry, Equipment to be provided such as personal protective equipment, testing equipment, alarm systems, etc., Any other information necessary to ensure safety of the Entrants, Any additional permits, such as hot work permits, which have been issued to authorize work in the permit space. Prior to entry, all employees involved in the entry must be trained in the safe performance of the duties assigned by the regulation.
1. An entry permit must be signed by: (check all that apply) The Entry Supervisor The Safety Manager The Unit Process Engineer The Attendant 2. An entry permit must contain: (check all that apply) The vessel construction materials. The name of the Entry Supervisor. The name of the current Attendant(s). The purpose for entry. 3. The entry permit must: (check one answer)
Be approved by the Plant Manager. Contain information on any other permits. Be reissued every shift. Be filled out in triplicate.
Finally, let’s consider the necessary rescue and emergency services that must be in place.
1. Each member of the rescue service must be provided with, and trained in use of, the personal protective equipment and rescue equipment necessary for making rescues from the permit space,
2. Each member of the rescue service shall practice making permit space rescues at least once every 12 months by means of simulated rescue operations in which they remove dummies, mannequins, or actual persons from the actual permit spaces or representative spaces. Representative permit spaces shall simulate the type, size and accessibility of actual space from which rescue is to be performed. 1. If someone other than the host’s employees are to perform rescues, the host employer must inform the rescue service of the hazards they may confront when called on to perform a rescue and provide the rescue service with access to all permit spaces so that rescue plans can be developed.
2. To make non‐entry rescue easier, retrieval systems or methods are to be used whenever an Authorized Entrant enters a permit space. Retrieval systems include a chest or full body harness with a retrieval line attached at the center of the Entrant’s back near shoulder level or above the Entrant’s head. Wristlets may be used instead if it can be demonstrated that the use of a harness is not feasible or if it would increase the risk. The other end of the retrieval line is to be attached to a mechanical device or fixed point outside the permit space. A mechanical device must be available to retrieve personnel from vertical‐type permit spaces more than 5 feet deep.
3. If an injured Entrant is exposed to a substance for which a Material Safety Data Sheet is kept, it must be made available to the medical facility treating the exposed Entrant.
In addition, many employers require the following safety equipment as part of the personal protective equipment during entry:
Five minute escape bottles, Cylinders of breathing air, Impervious body‐covering clothing, Explosion‐proof or intrinsically safe lighting for interior illumination, And respiratory protection. If oil‐lubricated compressors are used to supply breathing air, they require either a high temperature alarm or a carbon monoxide alarm, or both.
Locate air compressor intake away from sources of air contamination. Install a filter station on regular air compressors to upgrade the air to breathing air quality.
Remember that all these rules and regulations are designed to make confined space entry safer for everyone involved.
1. Members of the rescue team must be retrained: Prior to every entry. Every six months. Every three years. Annually. 2. Which of the following are appropriate retrieval systems? Basket stretcher An Attendant with full face breathing apparatus Wristlets Harness with a retrieval line
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