Confined Space

The Confined Space Law

The permit required confined space law was promulgated on January 1, 1993 and took effect on Apri115, 1993 This law was enacted after many years of discussion and comments being relayed to OSHA. The law is Title 29 Code of Federal Regulations number 1910.146, or 29CFR1910.146.

In addition to identifying many workplace and rescue issues, it essentially identifies two basic types of confined spaces, based on their types of hazards. The first, is commonly called a "confined space", or as the law refers to it as a "non-permit" confined space. This identifies the ingredients required to call any space something that is confining, however not necessarily dangerous to health or life by itself. The law indicates that a "confined space" means a space that:

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

2) 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

3) Is not designed for continuous employee occupancy.

Note that the definition requires that the space contains ALL of the above. It cannot be a confined space if it only has one or two of the characteristics.

The next definition shows that the confined space defined above is more dangerous to the entrant. The law says: Permit-required confined space (permit space) means a confined space that has one or more of the following characteristics:

1) Contains or has the potential to contain a hazardous atmosphere;

2) Contains a material that has the potential for engulfing the 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.

In addition, the employer may use what is known as the "alternate procedures/guidelines" for entering permit spaces. Under this concept, the employer does not have to comply with certain requirements of the "permit required" confined space law IF the only hazard posed by the permit space is an actual or potential hazardous atmosphere AND the employer can demonstrate that continuous forced air ventilation alone is sufficient to maintain the permit space safe for entry. While using alternate procedures/guidelines the employer is not required to comply with the following: having a permit or an attendant at the space ensuring a rescue team is available

OSHA Statistics

The Occupational Safety and Health Administration (OSHA) has statistics indicating that 60%-80% of the fatalities in confined spaces are would-be rescuers. The term "would-be rescuers" include bystanders or good Samaritans that simply try to jump into the space thinking they will just quickly drag the entrant out. This high mortality rate is the result of these untrained responders not understanding the hazards involving confined spaces. Up to 90% of these fatalities are a result of atmospheric hazards per industry statistics.

Reasons to Enter Spaces

There are many reasons workers enter confined spaces each day. Generally, some reasons are to perform some type of maintenance or inspections. This would include work that may entail cleaning, welding, cutting or grinding, just to name a few. Other reasons for entering these spaces may involve the rescue service, either with actual rescues, or for training in the spaces, to become knowledgeable with these spaces.

General Hazards Associated with Confined Space Rescue Operations

There are numerous other hazards associated with confined space rescue operations. The AHJ should make every effort to identify the hazards that might be encountered within the jurisdiction and should provide members with training and awareness of these other hazards in order to perform rescue operations safely and effectively.

The types of hazards that may be encountered in a confined space are numerous. Some of them include:

• atmospheric
• falls
• slippery floors
• tripping hazards
• mechanical electrical
• pneumatic (high pressure air)
• drowning/ engulfment
• excessive temperatures (heat or cold)
• other hazards as pre-determined by the AHJ
• hazards introduced by rescuer

The authority having jurisdiction (AH]) should ensure these potential hazards are understood prior to the incident if the rescue service is expected to respond.

Initial Company Operations

The initial duties of the first due fire or rescue service companies are numerous. These first in companies must realize that there are many things that need to be accomplished or at least verified as completed prior to anyone entering a confined space.

Size-up is obviously the first task that needs to be performed. A good initial size-up will help ensure that all responding rescue personnel have an understanding of the conditions that were found early in the incident. This will also help to ensure that the incident command structure is put into place and that adequate resources are being assigned to the incident. During size-up, access to the space and number of victims should be determined. In addition, contact with the patient should be attempted if it can be done safely.

Securing the scene early in the incident will ensure that the general area is safe, not only for bystanders, but also for subsequent responding rescue units and personnel. The general area should be made safe by ensuring the control of traffic, whether vehicular or pedestrian. All unnecessary persons must be kept away from the area. This may include industrial workers who are trying to help their co-worker. Unless they are trained rescuers, knowledgeable in the space and have rescue capability, they should remain in an advisory capacity .Remember that these workers have the victim' s best interest in mind, and as such, can be a very valuable asset to the rescue. They must be made aware of their role in the rescue, such as providing better access to the area or the space, and determining the proper isolation points for numerous electrical or mechanical hazards. This is considered Lockout/Tagout per 29 CFR 1910.147. There may be the need to shut down all sources of vibration or excessive noise in the area in order to complete the rescue effectively. These co-workers will help ensure this can happen.

The attendant at the scene will be one of the most valuable sources of information as to what happened in the space. In addition, anyone who may have been in the space recently should be located to help with gathering information. This may not be feasible if the space is a utility vault or other such area, which workers access regularly without assistance.

While information is being gathered, the first responding unit(s) must ensure that a qualified rescue team is being notified to respond for assistance. This team must be identified by the AHJ prior to the incident, to ensure a quick response without any confusion.

Qualified rescue teams need to be notified. These teams should be identified by the AHJ or department SOP/SOG.

Don't get pushed into someone else's emergency. The law requires the owner of the permit required confined space to provide for a rescue tam prior to any entry. This does not mean that we by virtue of being the Fire Department are obligated to provide this service. The owner of the space, if he wants to utilize the Fire Department s his rescue team, must have an agreement with that Fire Department, that they will provide this specialized service.

In addition, while information is being gathered, initial rescue actions that may be completed by awareness level units should be:

• Monitoring, to determine any potential atmospheric problems; this would include oxygen levels, combustibility , and any potential toxins.
• Ventilation of the space, ensuring contaminants are not being moved to an area that could become a problem. This would include providing warm or cool air to the victims if necessary .
• Non-entry rescue- if a pre-rigged device is available and the victim may be moved out without additional injury , awareness personnel should attempt to use the device IF they are knowledgeable in its operation and can do so without entering the space.

Although the reasons for a confined space rescue are numerous, rescue personnel must gain information as to the types of spaces, and the type of work that was being performed prior to any rescue team attempting to enter the space. It should be assumed that if a space was deemed to be simply a confined space, the rescue team must reclassify it to a permit-required confined space if the rescue service has been called there to perform a rescue.