Best Safety Practice: Entry into Permit-Required Confined Spaces

An authorized entrant equipped with harness and personal atmospheric monitor prepares to enter a wine tank.

Constellation Brands management teams in the Central Coast region contacted California Health & Rescue Training to assist them in developing a confined space training program in late 2014. They felt strongly that confined space entries continue to be a highly dangerous operation, and they wanted to enhance the training of all personnel. They had identified specific personnel within their facilities that they wanted to focus specialized training for in order for them to provide in-house training of other employees.

A “train-the-trainer” program was developed for 10 Constellation Brands personnel. The personnel were selected based on the facility where they worked, their ability to develop as a trainer and their leadership qualities. They were given 24 hours of instruction and the training materials to instruct other employees.

The expectation was to develop subject matter experts who would be working the production floor and instructing co-workers on proper confined space protocol. This approach would enhance the ownership aspect of safety among all employees.

The program needed to ensure that all mandatory components of the “Permit Required Confined Space Regulations” found in California Code of Regulations section 5156, 5157 and 5158 under the California Occupational Safety Health Administration (Cal/OSHA) were being met.

While many industries in California have been successful in securing variances or exemptions from the most stringent confined space regulation (section 5157), winery operations do not have that option and must comply with the “Permit Required Confined Space” regulations found in section 5157.

The focus of the training was to discuss and review options for ensuring proper training in rescuing workers who may become incapacitated while working in any space classified as “permit required.” The safety managers felt relatively comfortable with the entry program but noted there were lapses in the contingencies for rescue. The team wanted to improve the “hands-on” training and contingency planning specific to rescue.

The regulations clearly list mandatory components and positions that must be met. The difficulty in the regulations are that, while it lists mandatory components, it provides latitude in how to comply with those components and, in some cases, it allows dropping some or all of them if we can reclassify the space or provide for alternate entry. The consensus of the group was to deal with all of the spaces as “permit required” and not attempt to do a reclassification or alternate entry.

Despite eliminating hazards and providing ventilation to assure that no hazardous atmosphere can develop, the truth is you can never truly assure that all hazards have been eliminated. When you ventilate, you can still develop pockets of bad air even if you calculate ventilation air exchanges.

Training is important for removing someone from a confined space. With these components in mind, the managers felt much more comfortable defending the program if it considered all tanks to be “permit required.” Below is a brief outline of the mandatory components of the permit-required regulations that need to be covered in every confined space entry/rescue plan.

Mandatory components

Training:Training appropriate to the position and task of the employee. The regulation lists three basic positions: entry supervisor, attendant and authorized entrant. The employer must provide appropriate training for employees holding those positions.

Equipment: The employer must provide the equipment needed to safely and effectively complete entry into the confined space. Examples of equipment needed would be atmospheric monitoring equipment, lock-out/tag-out equipment, harnesses and retrieval poles and lines.

Written procedure: The regulation clearly requires that the employer develop a written plan outlining the expectation of performance for the employee. This written plan should list not only what it is expected that the employee will do, but also what they should not be allowed to do, making them aware of the hazards they may face when making entry.

Entry permit: This document is intended to serve as a checklist, assuring that we have not forgotten anything required to be done before or during the entry. It also serves to track entry times, entrant identities, atmospheric monitoring results, etc. The form serves to document that the obligations have been met and must be filed for one year following the entry.

Energy control: Lock-out / tag-out procedures must be completed to assure that employees have secured any energy source that could adversely impact the authorized entrant.

Atmospheric monitoring: With atmospheric hazards being the No. 1 killer in confined space operations, it is imperative that the atmosphere be monitored before entry, continuously throughout the entry, periodically logging the readings at increments, monitoring first for oxygen, secondly for flammability and third for specific toxins.

The monitoring is routinely achieved with a single instrument with multiple sensors that check volume of oxygen, percentage of the lower explosive limit of a calibrated gas and toxins that may be specific to the operation or could be present. In winery operations, the employer may choose to monitor for carbon monoxide because it may be present due to operating any internal combustion motor or carbon dioxide (even though it is not necessarily a toxin) because it may be present due to residue left in a wine tank. Other sensors sometimes provided include hydrogen sulfide or sulfur dioxide.

Retrieval line: It is imperative that each entrant enter with a provision for non-entry rescue. The regulation states that each entrant should enter with a retrieval line that is attached somewhere outside the space and to the entrant in a manner that creates the smallest possible profile. While this component is mandatory, the regulation also allows the line to be detached if it is impossible to make entry with the line or if it increases the chance of injury or death to the entrant.

Entrant harness: While the entrant should be in a manufactured full-body harness that meets all safety standards, the overriding objective is that it is safe, secure and creates the smallest possible profile of the entrant if they were to become unresponsive.

Mechanical advantage/device: This requirement in the rescue section (5157 k) is to assist in lifting the entrant whenever they are lowered or descend 5 feet or more below grade.

Communications:While the regulation requires there to be a viable communications link between the authorized entrant and the attendant, it does not stipulate what system or plan must be utilized. In simple operations voice communications or hand signals may be adequate; in other occasions hardwire communication systems or portable radios may be needed.

Provisions for rescue: The regulation requires the employer to develop provisions for rescuing an entrant and states that at least one person must be available to immediately begin rescue. The rescue plan should progress from low risk to high risk, starting with non-entry procedures.<

Optional components

Lighting:While providing entrant lights is not a mandatory component, it could become mandatory if the entrant cannot operate safely because of darkness or dim lighting.

Ventilation: When the space being entered has been monitored and there is no expectation of developing a bad atmosphere, there is no requirement to ventilate the space. While the provision for ventilating the space is not a mandatory component, it is prudent to always have provisions for improving the atmosphere should there be a change. Having ventilation equipment available is cheap insurance against the No. 1 killer: hazardous atmosphere.

Respiratory protection: If the atmosphere is within normal limits and there is no expectation of a hazardous atmosphere, then providing respiratory protection for the entrant is not required. But we must always remember that if you are making an entry rescue, statistically it must be assumed that the atmosphere is bad regardless of whether or not the atmospheric monitors are alarming, as there is no way to assure you have the specific sensor for the vapor causing the problem. In addition, the vapor could be toxic enough to be fatal but not flammable enough to cause an alarm beyond the 10% lower explosive limit or enough of it by volume to displace the oxygen to the 19.5% level.

Development of training program for rescue operations

Once it was determined that the Constellation Brands confined space program covered the mandatory and optional components, a training program for rescue operations was developed. The program would be provided at Constellation Brands wineries in the Central Coast: Estancia, Gonzales and Wild Horse. The training program provided an overview of the hazards, reviewed the mandatory and optional components listed in the regulation and then focused on tactical priorities for the attendant to follow if anything outside of normal occurred.

The intent was to provide a tiered rescue plan that progressed from low-risk to high-risk options, with the high-risk options being provided by off-site professional personnel. The instructional program consisted of a PowerPoint presentation with descriptions of the process and video examples of the actual techniques.

The classroom instructional program was followed by hands-on training that consisted of setting up the entry with considerations for non-entry rescue operations before the entry began. During the routine entry, the entrant would be instructed to simulate becoming unconscious, which would force the attendant to practice the tactical priorities that had been instructed and reviewed in video format in the classroom. Simulations were done repeatedly, with each one progressing through the low-risk options of assessing survival profile of the victim, calling for additional help, improving survival profile of the victim and attempting non-entry rescue options.

The new trainers led the trainings within each facility. They proved capable of providing complete confined-space training for full-time and temporary employees. They were also able to provide topic-specific safety orientation to contractors and were able to remediate when deficiencies are found in entry procedures.

Taking it to the next level

Buy-in for developing a culture of safety has occurred at every level. It started with concerned managers and culminated with employees who are committed enough to the project to attend additional training. Today the organization has informed and educated personnel on the production floor looking out for safety every day and sharing that information with others.

When working in confined spaces, participants work as a team, keeping an eye on each other and ensuring that no one is cutting corners. Developing in-house trainers has added to the buy-in that every employee needs to watch out for others as well as themselves. At the end of the day, safety is the top priority of the job.

Kent Freeman is the owner of California Health & Rescue Training and a 32-year veteran of the fire service. He recently retired as a captain and coordinator of technical rescue services for Roseville Fire Department in the greater Sacramento, Calif., area. He is the author and developer of California State Fire training divisions, Confined Space Rescue Awareness program, and served as the project leader of the curriculum development team for the Confined Space Rescue Technician program. Contact him through calrescue.com.