Confining ideology

Confined spaces come in many shapes, sizes and configurations. Often, they are easy to spot. Sometimes they are not. Employers must ensure that workers recognize that potentially hazardous areas in their facilities exist and are big enough for people to enter, though challenging to access and exit, and definitely not intended for people to routinely occupy. These areas clearly involve dangers that can be expected to cause problems for anyone trying to work within them, such as atmospheric or chemical exposures, fall hazards, moving machinery or electrical systems.

CONFINED SPACES DEFINED

Many workplaces contain areas that are considered “confined spaces” because while they are not necessarily designed for people, they are large enough for workers to enter and to perform certain jobs. A confined space also has limited or restricted means for entry or exit and is not designed for continuous occupancy. Confined spaces include, but are not limited to, tanks, vessels, silos, storage bins, hoppers, vaults, conveyor and scale pits, manholes, tunnels, equipment housings, ductwork, pipelines, etc. In the recycling industry, they also can include automobile crushers, baler/hopper pits, compactors, stormwater collection pits and shredder mills.

OSHA uses the term “permit-required confined space” (permit space) to describe a confined space that has one or more of the following characteristics:

• contains or has the potential to contain a hazardous atmosphere;
• contains material that has the potential to engulf an entrant;
• has walls that converge inward or floors that slope downward and taper into a smaller area that co
uld trap or asphyxiate an entrant; or
• contains any other recognized safety or health hazard, such as unguarded machinery, exposed live wires or heat stress.

A “nonpermit confined space,” on the other hand, means a confined space that does not contain or, with respect to atmospheric hazards, have the potential to contain any hazard capable of causing death or serious physical harm.

DANGEROUS FOR WORKERS & WOULD-BE RESCUERS

The same hazards not only affect workers inside confined spaces, they also affect would-be rescuers of workers who succumb within these spaces. Approximately 60 percent of all confined space fatalities involve would-be rescuers. Most of these incidents occur because workers and rescue personnel are unaware of confined space hazards, proper safety procedures are not established or established safety procedures are neglected.

ASSESSING HAZARDS

Recognition of the inherent capacity of these spaces to harbor hazardous agents is a significant element of any workplace hazard assessment. When confined spaces are recognized to be hazardous, provisions for minimizing the need for entry and for use of appropriate work practices and equipment can be made.

Common control measures include:

• substituting less hazardous materials;
• purging, cleaning and ventilation; and
• proper use of personal protective equipment (PPE).

ACCESSING CONFINED SPACES

Also important are the use of an entry permit system and worker training in entry and rescue procedures.

According to the Recommended Industry Safety Practice (RISP) regarding confined spaces from the Institute of Scrap Recycling Industries (ISRI), Washington, if employees are to enter permit-required confined spaces, additional considerations include:

• classification of employees – authorized entrants, attendants and entry supervisors.
• training requirements – provide training so that all employees have the necessary understanding, skills and knowledge to perform the job safely. This includes training for authorized entrants, attendants and entry supervisors. Training certification must include the employee’s name, the signature or initials of the trainer and the dates of training. Refresher training should be provided whenever an employee’s duties change, hazards in the confined space change or an evaluation of the confined space entry program identifies inadequacies in the employee’s knowledge. Refresher training also must be certified.
• rescue and emergency services – “OSHA (See 1910.146 Non-Mandatory Appendix F – Rescue Team or Rescue Service Evaluation Criteria) believes that compliance with all the provisions of Section 1910.146 will enable employers to conduct permit space operations without recourse to rescue services in nearly all cases. However, experience indicates that circumstances will arise where entrants will need to be rescued from permit spaces. It is therefore important for employers to select rescue services or teams, either on-site or off-site, that are equipped and capable of minimizing harm to both entrants and rescuers if the need arises.”

Additionally, when contractors enter a confined space, the recycling company must ensure the contractor uses an effective confined space entry program. Furthermore, the recycling company must inform the contractor of the known hazards of the space and likewise require the contractor to inform the recycling company of any new hazards that are discovered during the course of the contractor’s operations.

FOR MORE INFORMATION

This article only begins to scratch the surface in terms of what recycling operations need to consider when it comes to worker safety in permit-required confined spaces. For additional information, visit www.isri.org/safety-best-practices/isri-safety/isri-safety-resources/safety-management-program-risps/confined-space.

Terry Cirone is the vice president of safety at the Institute of Scrap Recycling Industries, Washington. She can be contacted via email at terrycirone@isri.org.