This week was filled with remorse and sorrow that three worker lost their lives in a single confined space area. As investigations are still on going the comments are endless but one important reminder sticks out for everyone to cover in their safety meetings. If it was up to me EVERY worker in NORTH AMERICA involved or near confined space enter would print and sign a copy of this reminder and place same in their Human Resources File!!!!!
Did you test the AIR all the way down not just at the top? Many workers are injured and killed each year while working in confined spaces. An estimated 60% of the fatalities have been among the would-be rescuers. A confined space can be more hazardous than regular work spaces for many reasons. To effectively control the risks associated with working in a confined space, a Confined Space Hazard Assessment and Control Program should be implemented for your workplace. Before putting together this program, make sure to review the specific regulations that apply to your workplace.
Hazards in confined spaces can include:
- Poor air quality: There may be an insufficient amount of oxygen for the worker to breathe. The atmosphere might contain a poisonous substance that could make the worker ill or even cause the worker to lose consciousness. Natural ventilation alone will often not be sufficient to maintain breathable quality air.
- Chemical exposures due to skin contact or ingestion as well as inhalation of ‘bad’ air.
- Fire Hazard: There may be an explosive/flammable atmosphere due to flammable liquids and gases and combustible dusts which if ignited would lead to fire or explosion.
- Process-related hazards such as residual chemicals, release of contents of a supply line.
- Safety hazards such as moving parts of equipment, structural hazards, entanglement, slips, falls.
- Temperature extremes including atmospheric and surface.
- Shifting or collapse of bulk material.
- Barrier failure resulting in a flood or release of free-flowing solid.
- Uncontrolled energy including electrical shock.
- Biological hazards.
Air quality testing: The air within the confined space should be tested from outside of the confined space before entry into the confined space. Care should be taken to ensure that air is tested throughout the confined space – side-to-side and top to bottom. A trained worker using detection equipment which has remote probes and sampling lines should do the air quality testing. Always ensure the testing equipment is properly calibrated and maintained. The sampling should show that:
- The oxygen content is within safe limits – not too little and not too much.
- A hazardous atmosphere (toxic gases, flammable atmosphere) is not present.
- Ventilation equipment is operating properly.
Every state and province note the same actions
· (1) The employer shall appoint a person with adequate knowledge, training and experience to perform adequate tests as often as necessary before and while a worker is in a confined space to ensure that acceptable atmospheric levels are maintained in the confined space in accordance with the relevant plan.
· (2) If the confined space has been both unoccupied and unattended, tests shall be performed before a worker enters or re-enters.
· (3) The person performing the tests shall use calibrated instruments that are in good working order and are appropriate for the hazards identified in the relevant assessment.
· (4) The employer shall ensure that the results of every sample of a test are recorded.
· (5) If the tests are performed using continuous monitoring, the employer shall ensure that test results are recorded at adequate intervals.
· (6) The tests shall be performed in a manner that does not endanger the health or safety of the person performing them.
· (7) In this section,
· “sample” means an individual reading of the composition of the atmosphere in the confined space;
· “test” means a collection of samples.
Representative sampling should take into consideration the presence of stratified atmospheres and pockets of contaminated air within the confined space. The selection of testing equipment will depend on the circumstances of the confined space, the nature of the work within the space, and knowledge of possible atmospheric hazards. Whenever practical, continuous monitoring should be considered. Equipment performance characteristics to be considered include, but are not limited to: principle of detection of the hazards of concern, specificity, interferences, detection concentration range, response time, calibration requirements, and intrinsically safe equipment for spaces with potential accumulation of flammable hazards. Natural ventilation (natural air currents) is usually not reliable and not sufficient to maintain the air quality. Mechanical ventilation (blowers, fans) is usually necessary to maintain air quality.
- If mechanical ventilation is provided, there should be a warning system in place to immediately notify the worker in the event of a hazard or a failure in the ventilation equipment.
- Care should be taken to make sure the air being provided by the ventilation system to the confined space is ‘clean’ throughout the entire space.
- Ease of air movement throughout the confined space should be considered because of the danger of pockets of toxic gases still remaining even with the use of mechanical ventilation.
- Do not substitute oxygen for fresh air. Increasing the oxygen content will significantly increase the risk of fire and explosion.
- The use of mechanical ventilation should be noted on the entry permit
- Ensure air being removed from the confined space is exhausted away from workers on the outside.
All workers involved with confined space entry should be trained to understand the testing results, in accordance with the relevant plan.
Continuous monitoring is required:
· when performing hot work in a confined space that contains or is likely to contain an explosive or flammable gas or vapour.
· when the atmosphere in the confined space has been rendered inert by adding an inert gas, or
· as set out in the confined space plan.
When using continuous monitoring equipment, which may have data logging capability, are records required for test results?
Even though a continuous monitor may have data logging capability, results must still be recorded at adequate intervals as determined by the plan, above and beyond the data logging printout or electronic storage. This ensures that workers are actually aware of the levels they are encountering and aware of any fluctuation that may be occurring in order to warn them of any unusual conditions as they develop. Monitors may have alarms; however, depending at what level they are set, they may not give the workers adequate warning of fluctuations or increases in atmospheric levels that should be investigated.
What is the required frequency for recording atmospheric test results?
The frequency of recording test results is determined by the confined space plan, based on the potential for accumulation and possible fluctuations of the atmospheric hazards as determined by the assessment.
What are the requirements for record keeping?
In general, the employer must retain atmospheric testing records for the longer of the following periods: one year after the document is created; or, the period that is necessary to ensure that at least the two most recent records of each kind that relate to a particular confined space are retained. For confined spaces with multi-employer involvement, the constructor or employer (as the case may be) responsible for creating the record shall retain the record. On construction projects, the records must be kept by the constructor or employer (as the case may be) for at least one year after the project is finished.