Tank repair shops, wash racks need to develop carefully thought out confined space plan

Tank repair shops, wash racks need to develop carefully thought out confined space plan

AFTER Owen McLean was hired as a loss-prevention specialist at Baldwin & Lyons Inc two years ago—before he even had a chance to go through orientation—he was asked to fly to a customer’s location and assist the Occupational Safety and Health Administration (OSHA) in an investigation into why an employee asphyxiated in a tank.

He discussed what he learned during National Tank Truck Carriers’ 2015 Tank Truck Week in Houston, Texas. He reviewed the multiple factors that contributed to a fatal confined space incident at a tank wash rack.

“It was just continual errors they made that really caused this employee to lose his life,” McLean said. “There was one willful and 13 serious violations. The willful violation was for not having a confined-space entry program. The president of the company was arguing that they had one: ‘There it is, this is what we do.’ As OSHA was looking at it and I was looking at it, we saw that although they had a confined-space entry program, it wasn’t theirs. It had contradicted almost everything they did inside that wash facility and what they had listed for the program.

“The willful violation stood at $70,000. That did not get changed. But they argued that the product they cleaned was not caustic corrosive. According to OSHA, that does not constitute a hazardous environment. But they had the person going inside the tank and the tank being the hazard. The problem is the chemical they sprayed inside the tank for cleaning was what caused it to be a permit-required confined space. When the employee went inside, he went with no retrieval gear on, did not have a respirator, there was no attendant on duty, and the company did not really have any kind of rescue program in place for anyone who went inside and ended up having issues. That young man lay in the bottom of that tank for two hours until they finally got him rescued, and by then he had passed.”

McLean said all companies need to examine their locations and their confined-space entry program and make sure they have everything they need to have. And for those companies that believe they don’t have a confined space, and therefore don’t need a confined-space program?

“I would highly recommend you have a confined-space program saying, ‘There are no confined spaces, and we do not enter those,’ ” he said. “That’s because I’ve been on locations where OSHA has come in and asked about certain programs—confined space being one of them—and a company has said, ‘We don’t have confined space. We don’t need to enter it and there’s no reason for it.’ And OSHA asks, ‘How did you come to the conclusion that you do not have a confined space?’ So at least if you have a program that states you don’t have one and you give your reasons, it will help you out that much more.”

In his presentation, “Confined Space: An Inadequate Plan Won’t Cut It,” McLean said that confined space is space that: is large enough so configured that an employee can bodily enter and perform the assigned work; has limited or restricted means for entry or exit (ie tanks, vessels, silos, pits, vaults, or hoppers); and is not designed for continuous employee occupancy.

Types of confined space:

•  Non-permitted. Does not contain physical, chemical, or atmospheric hazards capable of causing death or serious physical harm.

•  Permitted. Does contain physical, chemical, or atmospheric hazards capable of causing death or serious physical harm.

He said permit-required confined space has: an internal configuration such that the entrant could be trapped or asphyxiated by inwardly converging walls or by a floor that slopes downward and tapers to a smaller cross-section; or contains any other serious safety or health hazard.

He said 29 CFR 1910.146 (Permit-Required Confined Space Policy) includes definitions, general requirements (to include deviation of written plan), permit-required confined spaces, permit system, entry permit, training, duties of authorized entrants, duties of attendants, duties of entry supervisors, rescue and emergency services, and employee participation.

He said an attendant is an “individual stationed outside one or more permit spaces who monitors authorized entrants and performs all attendant’s duties assigned in the employer’s permit space program.”

Duties of an attendant:

•  Knows hazards that may be faced during entry.

•  Aware of possible behavioral effects of hazard exposure in authorized entrants.

•  Continuously maintains an accurate count of authorized entrants.

•  Remains outside permit space during entry operations until relieved by another attendant.

•  Communicates with authorized entrants.

•  Monitors activities inside and outside space.

•  Summons rescue and other emergency services.

•  Performs non-entry rescues as specified by an employer’s rescue procedure.

•  Performs no duties that might interfere with primary duty to monitor and protect authorized entrants.

Duties of authorized entrants:

•  Know hazards that may be faced during entry, including information on mode, signs or symptoms and consequences of exposure.

•  Properly use equipment as required by paragraph (d)(4).

•  Communicate with the attendant as necessary to enable the attendant to monitor entrant status and enable the attendant to alert entrants of the need to evacuate space as required by paragraph (i)(6).

Alert attendant whenever:

•  The entrant recognizes any warning sign or symptom of exposure to a dangerous situation.

•  The entrant detects a prohibited condition.

Exit from permit space as quickly as possible whenever:

•  An order to evacuate is given by the attendant or entry supervisor.

•  The entrant recognizes any warning sign or symptom of exposure to a dangerous situation.

•  The entrant detects a prohibited condition.

•  The evacuation alarm is activated.

McLean said engulfment is “surrounding and effective capture of a person by a liquid or finely divided (flowable) solid substance that can be aspirated to cause death by filling or plugging the respiratory system. It can exert enough force on the body to cause death by strangulation, constriction, or crushing.”

He said entry is “action by which a person passes through the opening into a permit-required confined space. Entry includes ensuing work activities in space and is considered to have occurred as soon as any part of an entrant’s body breaks the plane of opening into space.”

He said the entry supervisor is a person (such as an employer, foreman, or crew chief) responsible for determining if acceptable entry conditions are present at the permit space where the entry is planned, for authorizing entry and overseeing entry operations and for terminating entry.

McLean noted that an entry supervisor may serve as an attendant or authorized entrant, as long as that person is trained and equipped as required for each role filled. The duties of an entry supervisor may be passed from one individual to another during entry operations.

Duties of an entry supervisor:

•  Knows hazards that may be faced during entry, including information on mode, signs, or symptoms and consequences of exposure.

•  Verifies, by checking that appropriate entries have been made on the permit, that all tests specified by permit have been conducted and all procedures and equipment specified by the permit are in place before endorsing the permit and allowing entry to begin.

•  Terminates entry and cancels the permit as required by paragraph (e)(5).

•  Verifies that rescue services are available and means for summoning are operable.

•  Removes unauthorized individuals who enter or attempt to enter the permit space during entry operations.

•  Determines, whenever responsibility for the permit space entry operation is transferred and at intervals dictated by hazards and operations performed within the space, that entry operations remain consistent with the terms of the entry permit and acceptable entry conditions are maintained.

Mclean said a hazardous atmosphere is:

•  An atmosphere that may expose employees to risk of death, incapacitation, impairment of ability to self-rescue (ie unaided escape from permit space), injury or acute illness from one or more following causes: flammable gas, vapor, or mist in excess of 10% of Lower Flammable Limit (LFL).

•  Atmospheric concentration of any substance for which dose or PEL could result in employee exposure in excess of dose or PEL. Atmospheric concentration of any substance not capable of causing death, incapacitation, impairment of ability to self-rescue, injury, or acute illness due to health effects is not covered.

•  Any other atmospheric condition that is an immediate danger to life and health. For air contaminants for which OSHA has no dose or PEL, other sources of information, such as MSDSs that comply with 29 CFR 1910.1200, published information and internal documents can provide guidance in establishing acceptable atmospheric conditions.          

He said rescue services are personnel designated to rescue employees from permit spaces. Rescue personnel may be industry emergency personnel, outside rescue service, or a combination of teams.  ♦

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