Page 40 - Occupational Health & Safety, December 2018

GAS DETECTION
Gas Detection for Safe Confined Space Entry
It’s more than a best practice—it is essential to test the air prior to and during entry, as OSHA requires.
BY JERRY LAWS
Atmospheric hazards are a key consider- ation when planning any confined space entry. As Chris Koester, owner of Priority One Safe-T, LLC, an emergency response services and rescue training firm for industrial and manufacturing companies, pointed out in his con- fined space article in our August 2018 issue, NIOSH investigations of 670 confined space fatalities showed that atmospheric hazards were associated with about 56 percent of the deaths. The most common types of gases in confined spaces were hydrogen sulfide and carbon monoxide.
OSHA’s confined space standard, 29 CFR 1910.146, requires employers to identify hazards in confined spaces, test the air prior to entry and also during the entry, keep the space ventilated, have on hand proper safety equipment for entry and exit and rescue, and have procedures for summoning proficiently trained rescue teams that can respond in a timely manner.
A confined space:
■ Is large enough for an employee to enter fully and perform assigned work,
■ Is not designed for continuous occupancy by the employee, and
■ Has a limited or restricted means of entry or exit.
Examples include vaults, tanks, storage bins, pits, silos, and similar areas.
A permit-required confined space as defined by OSHA has one or more of these characteristics:
■ Contains or has the potential to contain a haz- ardous atmosphere
■ Contains a material with the potential to engulf someone who enters the space
■ Has an internal configuration that might cause an entrant to be trapped or asphyxiated by inwardly converging walls or by a floor that slopes downward and tapers to a smaller cross section
■ Contains any other recognized serious safety or health hazards
Employers in general industry must evaluate their workplaces to determine whether spaces are permit spaces. If a workplace does contain permit spaces, the employer must inform exposed employees of their existence, location, and the hazards they pose. This can be done by posting danger signs such as “DAN- GER — PERMIT-REQUIRED CONFINED SPACE — AUTHORIZED ENTRANTS ONLY” or using an equally effective means, according to the agency.
If employees are not to enter and work in permit spaces, their employers must take effective measures to prevent them from entering these spaces. If employees are expected to enter permit spaces, the employer must develop a written permit space program and make it available to employees or their representatives.
Atmospheric Testing in Confined Spaces
A recent OSHA enforcement case against an Alabama tank cleaning firm included citations for failing to en- sure atmospheric testing and monitoring equipment was properly maintained, allowing employees to enter permit spaces without the proper equipment, and al- lowing them to enter without preparing an entry per- mit. Proposed penalties totaled $171,281 in the case, which was announced in October 2018.
One of the citations was for a willful violation, with OSHA inspectors concluding the employer had not done testing for atmospheric hazards at all in a permit space before employees were authorized to enter it.
The OSHA standard directs that, before an em- ployee enters the space, the internal atmosphere shall be tested with a calibrated direct-reading instrument for the following conditions, in the order given: 1) ox-
36 Occupational Health & Safety | DECEMBER 2018
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