Page 47 - OHS, May 2021

tank to perform work at a chemical plant. ThThey had an entry permit already secured, but they had not yet been informed what had been stored in the tank and had not even bothered to ask.
How can you already have a plan or entry permit in place, if you don’t even know what had been in the tank? The contractor had a meter to test the air, but what if there had previously been a corrosive chemical in the tank? The air might have been fine, but skin contact with surfaces in the tank could have been very dangerous. Only rinsing out the tank and performing a PH test would confirm whether hazardous chemicals were present.
On the other hand, there was a municipal water utility that had the same rigorous protocols in place across the entire organization, regardless of the hazards in each individual space. Whoever wrote the confined safety procedures made the requirements for every water meter or pump vault the same as they would for a chemical tank.
This can be problematic for two reasons. Firstly, because if you have a pump that is broken and affecting the water supply and your safety procedures are too burdensome, then you are adding pointless delays that are impacting your customers and business. But even more insidious than this: if your confined spaces protocols are unnecessarily complicated, and your workers know (or believe they know) that certain hazards don’t exist, then they may become complacent, and you can lose workers’ trust in the helpfulness of the rules. I have seen this come up again and again. It is vital that training programs exist to make sure that workers fully understand both the risks and the required controls for each situation. Without this knowledge, workers will assume you are “crying wolf” and may eventually fail to heed a critical and necessary safeguard—with disastrous results. This is why it is crucial to identify only the hazards that are, or may be, present, and have your procedures fit those specific hazards.
For a deeper and more comprehensive dive into this topic, I encourage you to read the OSHA and ANSI standards yourself, and to review the protocols at your particular worksite. Remember that confined space entry requirements will vary greatly, based on the presence or potential for hazards in the space, and whether the hazards can be controlled. Ask yourself: are
we aware of all the confifined spaces hazards, and are we putting the right measures in place to control them? Does our program distinguish between types of spaces and entry, including permit-required and non-permit required, or alternate entry procedures? Are our workers trained to understand what risks exist and why these protocols are necessary to mitigate them?
Safety precautions can often seem onerous,especiallyforworkerswhoarevery accustomed to a particular type of work and have been doing it for years without
incident. But compare taking appropriate precautions to wearing a seatbelt. You might drive every day for twenty years and never actually need one. But then, the one time you get into a horrifific accident, you’ll be very glad you strapped in.
Tom Burgess, MS, CSP, CIH, serves as Cli- ent Manager, Industrial Hygiene and Safe- ty for T&M Associates, a leading national consulting, environmental, engineering, technical services, and construction man- agement company.
www.ohsonline.com
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