If the person conducting the evaluation of confined spaces makes the assumption that the space will never contain a hazardous atmosphere, it opens the door to a potentially fatal incident. There are many cases on record where numerous entries had been made safely under non-permit procedures only to find that conditions had changed and there was, in fact, a hazardous atmosphere. Conditions can change due to events outside the space—even conditions not on the property of the employer that owns the space. I recommend that everyone in the confined space business read, "Worker Deaths in Confined Spaces," by NIOSH, Jan. 1994.
Other issues also come into play when making the permit/non-permit distinction. How do you treat serious fall risks? One example that I have come across is underground utility facilities accessed by a long vertical ladder. Is access by a 30-foot vertical ladder "any other recognized serious safety or health hazard"? If a person falls while descending the ladder, even if equipped with a fall arrest system, can they self rescue? Will you know if they have a problem?
CAUSES AND ASSESSMENTS
Incidents with confined spaces occur for the same five reasons, regardless of their permit or non-permit status. The five leading reasons for confined space incidents are: lack of knowledge, lack of training, lack of proper equipment, lack of proper supervision, and lack of complete standard operating procedures. There are, of course, other contributing causes. But when you read descriptions of incidents, the five just mentioned keep popping up time and again.
While the OSHA standard does not use the word inventory, most organizations conduct an inventory of confined spaces. Part of that inventory process should include a risk assessment for each space. That risk assessment becomes the go-to document for information when preparing a permit, selecting equipment and determining how many personnel are needed for a safe entry. I have developed a risk assessment form that I complete for each space when conducting the initial inventory. If you decide to separate the permit and non-permit spaces, the risk assessment completed during the inventory process is your documentation.
READY FOR RESCUE?
An often overlooked component of the risk assessment is the development of a rescue pre-plan. This is not a required part of the standard, but it does avoid the problems that often arise due to equipment purchased based on what a salesman says you need instead of a formal needs assessment. Right behind the risk assessment should be your rescue pre-plan. These two references enable personnel who complete permits and set up an entry to identify all the equipment they will need and any hidden problems they might encounter.
Do you plan for off-site rescue services or develop your own on-site capability? You should be doing both. Let me explain how I approach the rescue issue. Hidden away in the OSHA Letters of Interpretation is guidance that requires medical treatment for one of the three ready-cases (respiratory arrest, cardiac arrest or severe bleeding) to begin in four minutes. No off-site rescue provider can respond to your site, set up, conduct a rescue and begin treatment in four minutes. What most facilities need is a combination of on-site and off-site resources.
You need a team on-site (your employees or contract rescue personnel) set up and ready to rescue when an entrant goes in. The moment you shift from a routine entry to an emergency rescue, you call 9-1-1. That gets your rescue team back-up, an ambulance, paramedics and other resources you may not have on-site. Once the entrant has been retrieved from the confined space, your personnel can start the first aid while off-site emergency services respond. The OSHA clock has stopped the moment you begin first aid. In some cases you may be able to begin the critical care before the entrant is removed from the space.
When working with off-site emergency organizations, I utilize two forms to facilitate the process. "Choosing an Emergency Responder" is for on-site, and "Emergency Service Confined Space Rescue Checklist" is for the off-site organization. By sitting down across the table from each other with those forms, both organizations benefit from the exchange of information.
The best technique for a rescue is a non-entry retrieval. Using readily available hardware, it is possible in many, if not most, confined spaces to set up a retrieval system that does not require the rescue personnel to enter the space to bring out an entrant in trouble. In addition to the technical skills, the standby and rescue personnel need first aid and CPR training. You cannot begin first aid without trained personnel. In addition to standard CPR, personnel should be equipped with and trained to use AEDs (automatic external defibrillators). While AEDs are not required by any standard, the improved survivability of CPR plus an AED over just CPR makes it a very logical investment.
The best way to avoid a confined space incident is to not use workers at all. The use of technology avoids sending people into a space and remains the best and least costly approach. Utilizing small TV cameras mounted on the end of poles or mounted on small robotic vehicles allows companies to do inspections more quickly, with fewer personnel. ip
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