The U.S. Department of Labor’s Occupational Safety and Heath Administration defines a “confined space” as any space large enough, or so configured, that an employee can bodily enter and perform assigned work, has limited or restricted means for entry or exit, and is not designed for continuous employee occupancy. A confined space is a hazard for suffocation, due to inadequate oxygen levels, carbon monoxide and hydrogen sulfide poisoning, explosive or flammable substances combusting, or heat-related injury. Confined space training is necessary for all Emergency personnel in the case a rescue is needed.

At the Naval Air Station – Patuxent River, firefighters in the Fire and Emergency Services Division must attend a 24-hour, three-day class in confined space training. They must also pass a written exam to qualify in confined space rescue. This is a look at what confined space training looks like at NAS Patuxent River. . . Pax River Battalion Chief Charles Adams said, “We utilized an abandoned water tank and rescue dummies and ran everyone through the procedure. Safety came in first to make sure the site was gas free and give their approval, and then we suited people up in harnesses with rope and breathing apparatus. The goal was to enter the tank, locate and assess the victim, determine which type of system to use to get him out, and then properly package him up and bring him out. Some of our new members still need to take the required classes before earning their certification,” he said, “but participating in the exercise helps them get their feet wet.” During the exercise, two or three members would enter the tank, while others worked outside to monitor levels of oxygen and those of any potentially poisonous or combustible substances.

According to Adams, though the course is required of new members, it also proves to be a welcome refresher for those who are already qualified. Adams says, ““We usually work with the Maryland Fire Rescue Institute and courses are offered a couple times per year,” Following the course, all personnel involved critiqued their own processes and those of their colleagues, in an effort to identify what was done correctly and what could have been done better.

OSHA-approved safety training in confined space entry is crucial to those employees who may be operating in such a setting and to those employers tasked with monitoring them.

Citing a confined space violation along with six other citations Cal/OSHA fined Bumble Bee Foods with penalties of $74,000. In October , 2014 an employee at the Bumble Bee Foods manufacturing plant in Santa Fe Springs California, Jose Melena, became trapped in a pressure cooking machine and was literally cooked to death.

The California Division of Occupational Safety and Health (CalOSHA) began an investigation to find out what the cause of Melena’s death.  A 25-page report on the investigation was released at that time detailing the events that led to the fatal accident.

Melena, who had been employed at the plant for five years, had the responsibility of loading cans of tuna into the 36 foot ovens that are used to process the tuna and also to sterilize aluminum cans in which the tuna is packaged. On the day of the accident Melena was given the task of loading one of the ovens, but as he worked he discovered a problem with the oven and went in to attempt to repair or adjust it.

Another employee saw the pallet jack that Melena left outside the machine, and assuming Melena had gone to the bathroom, decided to use the pallet jack to load the baskets containing the tuna cans into the machine, unaware that Melena was inside the oven. A supervisor noticed the second employee loading the oven and inquired as to the whereabouts of Melena. After an hour and a half search, Melena’s body was finally discovered inside the oven.

Confined Space Violation A Repeat Offense

Bumble Bee Foods was issued citations for serious violations including failure to evaluate and identify the ten ovens like the one in which Melena was trapped as hazardous, permit-required confined spaces, a clear confined space violation. The company was also cited for not identifying dangerous areas with signage and not implementing a safety plan for working in the ovens according to standards for confined space entry. This latter offense also resulted in a confined space violation.

A confined space violation pertains to the inappropriate preparation of the space as well as a stated plan to rescue or respond to incidents. Because of a number of fatalities related to confined space violations in the state in recent years, Cal/OSHA has initiated a statewide Confined Space Special Emphasis Initiative to help promote awareness of the hazards of working in confined spaces. The confined space violation program also involves the education of workers and employers on how to prevent injuries and deaths by following the proper safety procedures. By following OSHA standards related to confined space entry – such as training for both supervisors and workers, clearly labeling the dangerous spaces, creating and following safety plans for working in a confined space including obtaining the necessary permits, and developing an emergency response plan – serious accidents and the resulting injuries and fatalities can be prevented.

Both the Cal/OSHA website at www.dir.ca.gov/dosh and the OSHA website at www.osha.gov have information available on the regulations regarding confined space entry including permit-required confined spaces, and on the hazards and safety procedures to follow to prevent those hazards when working in confined spaces.

Phoenix Industrial Cleaning of Berkeley, Illinois was cited by the U.S. Department of Labor’s Occupational Safety and Health Administration for 28 serious safety violations, including 18 for confined space entry violations, following the death of an employee on November 29, 2012. Bernardo Martinez, 37, of Cicero, fell from a ladder to his death while cleaning a chemical tank at the Sunnyside Corporation plant in Wheeling after being overcome by chemical fumes.

Rescue crews from numerous fire departments along with special rescue technicians attempted to rescue Martinez, who fell to the bottom of a 6,000 gallon, 50 foot deep tank with only a 28 inch wide opening, approximately the size of a manhole. Wheeling Fire Department Chief Keith MacIsaac said, “We assessed the air situation and found it to be an oxygen-deficient atmosphere, as well as charged with chemical vapors…It appears the individual was overcome by chemical vapors within the tank, based upon the limited chemical equipment that this individual was wearing.” The tank contained methylene chloride. Rescue personnel had to go through a decontamination process to remove the dangerous chemicals before leaving the site.

The eighteen serious violations involving confined space entry requirements included failing to develop and implement a confined space entry program for workers cleaning chemical storage tanks; failure to train workers on acceptable entry conditions; failure to provide equipment for testing atmospheric conditions; failure to have proper entry-control permits; failure to provide a means of communication between an attendant and workers entering a confined space; failure to provide emergency rescue equipment and a retrieval system to facilitate a no-entry rescue; and failure to determine the proficiency of rescue services available.

The company was also cited for serious violations involving OSHA’s methylene chloride standard, including failure to provide workers with information and training on the hazards associated with methylene chloride and assessing exposure. The company also failed to provide effective garments.

Five of the serious violations involved OSHA’s respiratory protection standards, including failure to evaluate the respiratory hazards present in the workspace and select appropriate respiratory protection based on the hazards; failure to provide a written respiratory protection program and train workers on such a program; failure to conduct medical evaluations for workers required to use respiratory protection; and failure to properly fit-test respiratory protection.

Phoenix Industrial Cleaning provides industrial cleaning of tanks, silos, cooking exhaust ventilation, and similar equipment at commercial and industrial work sites. The company received citations for violating standards on confined spaces after two of their four previous OSHA inspections. The last inspection of the company by OSHA was in 2001.

OSHA has proposed fines of $77,200 for the violations. Phoenix Industrial Cleaning has 15 business days from receipt of the citations to comply, request an informal conference with OSHA’s area director, or contest the citations and penalties before the independent Occupational Safety and Health Review Commission.

Diane Turek, OSHA area director of the Chicago North Area Office in Des Plaines, said, “No job should cost a person’s life because of an employer’s failure to properly protect and train workers. Phoenix Industrial Cleaning failed in its responsibility to evaluate working conditions and provide proper respiratory and personal protective equipment to workers cleaning storage tanks containing hazardous chemicals.”

Confined space standards, or lack of them, came into play for a Minot, North Dakota company. First Choice Energy was cited with nine serious safety violations by the U.S. Department of Labor’s Occupational Safety and Health Administration. Five of the nine citations involve violations of OSHA confined space standards, including lack of atmospheric testing, permits, signs, and emergency response procedures.

Confined Space Standards Were Central but Other Violations Cited

While lack of confined space standards was the central issue, the company was  also issued four other citations. These included:

involving lack of proper protection of workers from open pit fall hazards

lack of energy control and lockout/tag out procedures and equipment

failing to conduct annual inspections of energy control procedures

failure to train workers on such procedures.

OSHA investigated the work site as the result of the death of a worker at an oil field drilling and fluid disposal operation in Stanley, who was caught in an agitator of an oil field vacuum truck storage tank in March.

OSHA’s area director in Bismarck, North Dakota, Eric Brooks said, “First Choice Energy failed to develop and implement the most basic of confined space standards and energy control safety protocols. Companies have a responsibility to recognize – and train their workers to recognize – hazards unique to their job sites in addition to protecting workers from such hazards.”

A confined space is defined as a space with limited or restricted means for entry or exit, and which is not designed for continuous employee occupancy. The specific OSHA standards which apply to confined spaces can be found on the OSHA website at: http://www.osha.gov/SLTC/confinedspaces/index.html.

Proposed fines for the confined space standards violation and the four others are $33,000. First Choice Energy has 15 business days from receipt of the citation to comply, request an informal conference with OSHA’s area director, or contest the findings before the independent Occupational Safety and Health Review Commission.

For compliance assistance, to file a complaint, or report any possible dangers to workers, or to ask questions, the public can call the OSHA toll-free hotline at 800-321-OSHA (6742). Information is also available on OSHA’s website at www.osha.gov.

Entering grain storage bins can be a very dangerous activity and requires following safety procedures to prevent potentially fatal hazards. The atmosphere inside the bins can sometimes be toxic and lack adequate oxygen. There is also a danger that workers can be engulfed by grain and suffocate as a result. In many cases, the grain storage bin dust can combine with available oxygen or other material to cause intense flash fires.

Grain storage bins are configured in such a way that they fall under OSHA’s Confined Space Entry standards in 29 CFR 1910.146 and the new 1910.146 Subpart AA for Construction worksites. Companies that store, install or maintain these bins should undergo General Industry confined space training or, if applicable, Construction Industry training  as a cornerstone to an overall, compliant safety program.

Safety Precautions for Grain Storage Bins

The following safety procedures should be followed when entering grain storage bins:

• Turn off, disconnect, lock-out and tag, or block off all equipment, particularly grain-moving equipment.
• Test the air in the bin for oxygen content and the possible presence of hazardous gases before workers enter. Ventilation should be provided, if necessary, to eliminate unsafe atmospheric conditions. If the unsafe conditions cannot be eliminated, respirators should be provided to workers.
• Prohibit “walking down” grain to make it flow.
• Prohibit entry where grain is built up on the sides of  grain storage bins.
• Provide each worker with a body harness that has a lifeline, or with a boatswain’s chair. Ensure that the lifeline is long enough and positioned in a way that will prevent the worker from sinking more than waist-deep in the grain.
• Provide workers with rescue equipment, such as winch systems.
• Have an observer outside the grain storage bin who is equipped to provide assistance or perform rescue operations.
• Ensure that the observer and the workers inside grain storage bins maintain visual, voice or signal line communications at all times.
• Unless the employer is present during the entire operation, a permit should be issued each time a worker enters a bin certifying that all of the above precautions have been implemented.

The hazard of engulfment within grain storage bins can be caused by several different situations. “Walking down” grain can result in the grain acting like quicksand and a worker can become buried within a few seconds. Another cause of engulfment is known as bridging. This occurs when a worker stands on or below “bridged” grain, which is grain that has clumped together due to moisture or mold. There can be empty spaces below the clumps that can cause the bridged grain to suddenly collapse under the weight of a worker, causing the worker to become buried in the grain storage bins. Grain which has accumulated on the sides of a bin can suddenly collapse onto a worker. Sometimes workers are instructed to dislodge the grain from the bin’s sides and it will collapse during this procedure. Often when other workers attempt to rescue a coworker who is buried in grain, they also become victims.

By following these procedures which are required by OSHA’s Inspection of Grain

Handling Facilities standard, 29 CFR 1910.272, injuries and fatalities of workers entering grain bins can be prevented.

OSHA defines a confined space as one that is large enough to enter and perform assigned work in, but has limited or restricted ways to enter or exit and is not designed to be occupied continuously by a worker. A permit space is a confined space that has any serious safety or health hazards such as containing a hazardous atmosphere; containing a material than can engulf a person; or one that has an inside design that could trap or asphyxiate a person who is inside. Any one of these hazards or a combination of these or any hazards to health or safety in a confined space requires a permit to be issued in order to enter and work in the confined space.

Atmospheric Testing Is Used to Evaluate Hazards

Atmospheric testing is required to evaluate the hazards of a permit space and to verify that acceptable conditions exist to allow entry into that space. To test the atmosphere in a confined space, equipment that can detect chemicals at levels well below the defined exposure limits is used. In this way it can be determined what chemical hazards may be present (or become present) in the space’s atmosphere. Once hazardous chemicals are identified, it can be determined what steps will be necessary to ensure that the atmosphere is safe for a worker to enter. Testing results are evaluated or reviewed by a technically qualified professional such as a certified industrial hygienist, a registered safety engineer, or a certified safety professional from an OSHA consultation service.

Before workers can enter a permit space, the same atmospheric testing must be done again to make sure that the chemical hazards that may be present are within safe levels, as identified on the permit. Tests are done for oxygen levels, for combustible gases, and for toxic gases and vapors. These test results are also recorded on the permit. There is a minimum response time for the testing device to detect the chemicals set by the manufacturer of the equipment, but if hosing or a probe extension is attached for spaces with different depths, additional time is needed to test thoroughly.

If the permit space is deep or extends a distance beyond the entry point, there must be further atmospheric testing four feet from the entry point in the direction of travel and four feet to each side. The person doing the testing must move slowly enough to allow the equipment time to properly respond in each area before moving to a new area. Each time a space is entered or re-entered this testing must be repeated to make sure the atmospheric conditions are safe for entry.

These requirements are covered by Title 29 Code of Federal Regulations1910.146, Appendix B.

Confined Space Issues dominated the list of 11 major violations, including two willful against Dedicated TCS, LLC  OSHA  proposed penalties of $142,000. An OSHA inspection at the one facility in Lansing, Illinois was initiated after a complaint was received. The facility  cleans tank trailers.

Gary Anderson, OSHA area director in Calumet City stated, “A confined space has limited or restricted means for entry or exit, and it is not designed for continuous employee occupancy, which makes monitoring workers’ activities in these spaces vital to their safety and health. OSHA is committed to protecting workers on the job, especially when employers fail to do so.”

Confined Space Issues Are Preventable If Proper Procedures Are In Place.

The OSHA permit-required confined space standard provides procedures to protect workers from confined space issues.  Especially in danger are those who enter, work in, or exit confined spaces that hinder their activities. The configurations of these spaces can increase workers’ exposure to hazards which include entrapment, engulfment, and/or hazardous atmospheric conditions, all of which could lead to serious injury, illness, or death.

Two willful violations regarding confined space issues were found at the Lansing facility. The first was  for failing to provide a mechanical lifting device that could help rescue workers from confines spaces. The second was for failing to provide an attendant to monitor the safety of workers operating within permit-required spaces. Willful violations are ones committed with intentional knowing or voluntary disregard for the law’s requirement, or indifference to worker safety and health. OSHA has clear and extensive standards for confined space issues in the work place.

Nine serious violations were found, seven of which also related to confined space issues. The violations include:

• failing to test conditions
• failure to verify permit entries with required tests and procedures
• failing to sign permits to authorize entry
• failure to provide appropriate explosion-proof lighting
• failure to review entry operations
• failure to provide training for safe performance of duties in confined spaces
• and failing to certify that training had been accomplished

The other violations included failure to provide hazard communication and failure to provide personal protective equipment training for workers exposed to contact with corrosive chemicals.

Dedicated TCS, LLC is based in Lansing but also has facilities in Channahon, Illinois and in New Orleans, Louisiana. Their Channahon facility received eight serious citations in September which were also primarily related to permit-required confined space violations. The company has 15 business days from receipt of the citations and penalties to comply, request an informal conference with the OSHA area director, or contest findings before the independent Occupational Safety and Health Review Commission.

OSHA has a toll-free hotline at 800-321-OSHA (6742) to report workplace incidents, fatalities, or situations which pose imminent danger to workers.