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Operation-Specific Sheets
Entry into Confined Spaces |
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Activity Description
- This activity sheet is for response and recovery workers who enter confined and enclosed spaces. It also applies to the attendants and to the entry supervisor.
- As a result of Hurricanes Katrina and Rita (2005), many confined and enclosed spaces will need to be entered because the equipment they contain needs to be assessed, repaired, or replaced prior to resuming operations. In other cases, spaces must be entered because they have been impacted by contaminated water, and/or sand and sludge.
- Confined spaces have limited means of entry or exit, are large enough to bodily enter, and may contain physical or atmospheric hazards. Examples include storage tanks, process vessels, bins, boilers, vaults, ventilation or exhaust ducts, sewers, tunnels, pipelines, and pits more than 4 feet in depth. Hurricane-related events might introduce hazards or potential hazards into confined spaces. For example, a space might have a potential to contain a hazardous atmosphere due to the presence of decomposing organic matter, to the use of hazardous chemicals in the space, or to the performance of operations in the space, such as welding, cutting, or burning, that may create a hazardous atmosphere. Additional precautions must be taken to make the space safe for entry.
- In addition, since flooded homes, buildings, and basements may contain hazards similar to those discussed above, the following best practices may be used during entry into these areas.
- Response and recovery workers conducting this operation may be employed by Federal, State, local, and private employers. Review How to Use This Matrix in the introduction for a discussion of how this information may apply to different employees.
About the Activity Sheet
This activity sheet does not provide an in-depth analysis of OSHA standards and regulations and cannot address all hazards. It does not increase or diminish any OSHA requirement or employer obligation under those requirements. It is intended as a guide and quick reference for employers and response and recovery workers. The Matrix captures major activities involved in hurricane response and recovery, highlights many of the hazards associated with them, and recommends beneficial work practices, personal protective equipment (PPE), and other exposure control methods. Employers must evaluate the specific hazards associated with the job/operation at the site where the work is being performed.
Employers are responsible for providing a safe and healthful workplace for their employees. OSHA's role is to assure the safety and health of America's workers by setting and enforcing standards; providing training, outreach, and education; establishing partnerships; and encouraging continual improvement in workplace safety and health.
The Hazard Exposure and Risk Assessment Matrix for Hurricane Response and Recovery Work provides a general overview of particular topics related to current OSHA standards. It does not alter or determine compliance responsibilities in OSHA standards or the Occupational Safety and Health Act of 1970, or the equivalent State Plan standards and requirements. Because interpretations and enforcement policy may change over time, you should consult current OSHA/State Plan administrative interpretations and decisions by the Occupational Safety and Health Review Commission and the courts for additional guidance on OSHA compliance requirements. Employers should modify their procedures as appropriate when additional, relevant information becomes available.
General Recommendations
Key Engineering Controls and Work Practices. See general recommendations document.
Personal Protective Equipment. The general PPE is recommended for
all response/recovery tasks/operations; only the additional
PPE that may be needed for a specific hazard is noted below.
General PPE includes:
- Hard hat for overhead impact or electrical hazards
- Eye protection with side shields
- Gloves chosen for job hazards expected (e.g.,
heavy-duty leather work gloves for handling debris with sharp edges
and/or chemical protective gloves appropriate for chemicals potentially
contacted)
- ANSI-approved protective footwear
- Respiratory protection as necessary—N,
R, or P95, filtering facepieces may be used for nuisance dusts
(e.g., dried mud, dirt and silt) and mold (except mold remediation).
Filters with a charcoal layer may be used for odors.
Recommendations Specific to Hazards Associated with This Activity
PERMIT-REQUIRED CONFINED SPACE ENTRY
Key Engineering Controls and Work Practices
- Although the terms “confined space,” and particular, “permit-required confined space” have regulatory implications pursuant to OSHA’s general industry standard, 29 CFR 1910.146. These terms along with the term “enclosed space,” which has regulatory implications in OSHA’s construction standard, are used in this Matrix to identify a process of evaluating these spaces for physical hazards (e.g., mechanical, electrical, hydraulic, pneumatic energy; engulfment hazards; inwardly converging surfaces) and atmospheric hazards (e.g., atmospheres that are oxygen-deficient or oxygen-enriched, contain or may contain flammable gas, vapor or mist, airborne combustible dust, toxic substances, or any other atmosphere that is immediately dangerous to life or health)
- Evaluate each space to determine if it is a confined or enclosed space subject to physical or atmospheric hazards such as those described above
- Once identified, mark these spaces and prevent unauthorized entry
- Evaluate the purpose for entry; limit the initial entry to assessment activities only
- Develop and implement an entry program that includes a means of evaluating the hazards of each space; specifying acceptable entry conditions; a system permitting entries; training for entrants, attendants, and supervisors; air monitoring; and provisions for rescue/emergency services
- Eliminate, control, or otherwise protect employees from all hazards identified in the space before entry and document this procedure
- Ensure that the entrant and attendant are able to communicate throughout the entry
- Exit the space immediately if unsafe conditions develop (failure of ventilation system, meter alarms, experience unexplained symptoms)
- Emergency rescue must be attempted only by individuals who are trained in safe entry and rescue procedures and who have the proper tools and personal protective equipment, such as self-contained breathing apparatuses for entry into atmospheres that are immediately dangerous to life and health. If an off-site party (e.g., local fire department) will provide rescue services, coordinate with them to ensure that they can provide this service for each space and can get to each space timely
Additional Personal Protective Equipment
- Harness and retrieval system
- Based on planned activities and anticipated hazards, select protective clothing, respiratory protection, gloves, and other PPE
ATMOSPHERIC HAZARDS
Key Engineering Controls and Work Practices
- Assess the contents and condition of tanks and equipment in the space; evaluate those that might contain hazardous chemicals, gases, flammable materials, and, if the contents were released, pose a risk of creating hazardous/oxygen deficient conditions
- Establish acceptable entry conditions and document these on the entry permit
- Consider the operations that will be conducted in the space and the materials that will be used in the space. If these operations or materials may create a hazardous atmosphere in the space, ensure that the ventilation, PPE, and other controls identified on the permit will be protective for these hazards also. Also see, welding, cutting, and burning, below
- Conduct initial air monitoring to determine suitability for entry and for continued work. Use air monitoring equipment (e.g., for oxygen, flammable gas, hydrogen sulfide, and carbon monoxide) to monitor for each of the hazardous conditions that might be present
- Ventilate the space while entry is conducted
- Conduct periodic air monitoring to ensure that acceptable atmospheric conditions are maintained
- Unless known not to contain asbestos, treat all insulating materials as asbestos-containing and limit contact or disturbance of them. If material will be disturbed or needs to be removed to complete work, test material for asbestos content and implement an abatement program if necessary
Additional Personal Protective Equipment
- Based on planned activities and anticipated atmospheric hazards, select protective clothing, respiratory protection, gloves, and other PPE
PHYSICAL HAZARDS
Key Engineering Controls and Work Practices
- Evaluate potential physical hazards (e.g., rotating machinery, exposed electrical hazards) to determine suitability for entry
- Limit access until stability and structural integrity of the structure is known. Ensure that a competent person inspects the space and surrounding work area before entry to perform work. A competent person is able to recognize existing and predictable hazardous conditions and has the authority to take prompt corrective measures to eliminate the hazardous conditions. See general recommendations document for additional information on structural integrity
- Remove or secure objects (glass, structural members) that may fall while employees work under them
- Take precautions to eliminate or reduce the threat of physical hazards. Contact utility company to assist in locating, marking, and shutting off/purging utility lines that may pose a hazard or may be impacted; ensure that lines have been purged as needed before beginning work. Other precautions may include:
 removing residual material (water, residue) from outside the space- guarding dangerous equipment
- deenergizing and securing (lockout/tagout) all hazardous energy sources; verify that source is secured
- bleeding and then blocking pipes leading into and out of the space
- Use testing equipment (e.g., voltmeters) to assess potential exposure to physical hazards
- If utilities cannot be secured, treat them as live/charged/energized
Additional Personal Protective Equipment
- Harness and retrieval system
- Based on planned activities and anticipated physical hazards, select protective clothing, gloves, and other PPE
POWER AND HAND TOOL USE
Key Engineering Controls and Work Practices
- Use ground-fault circuit interrupters (GFCIs) or double insulated power tools, or implement an assured equipment grounding program
- Inspect power tool condition (including any cords) and verify operation of safety features before use
- Do not use equipment that is defective, such as equipment with inoperable safety switches, missing guards, frayed/cut cords etc.
- Ground power tools properly
- Avoid standing in wet areas when using portable power tools
Additional Personal Protective Equipment
- Hearing protection-see Noise hazard
- Hand protection for cut- and abrasion-control and vibration dampening
- Eye protection appropriate to the impact hazard
SLIPS, TRIPS, AND FALLS ON WORKING SURFACE
Key Engineering Controls and Work Practices
- Limit people at space entrance to attendant and supervisor
- Provide lighting in the space
- Take extra care when stepping into areas that are unstable/uneven or where the surface cannot be seen
- Ensure that the space is closed and labeled upon completion of the entry
- See the general recommendations document
WELDING, CUTTING, AND BURNING
Key Engineering Controls and Work Practices
- Remove flammable and combustible materials from the area
- Do not perform "hot work" such as welding, cutting, or burning in areas where flammable, combustible, corrosive, or toxic substances are being used, stored, or may otherwise be present
- Maintain a fire watch during all hot work until material has cooled
- Ensure fire extinguishers and extinguishing agents are available in the immediate area
- Provide natural, exhaust, or forced ventilation to control exposure to the metal fumes and other contaminants being generated (e.g., generator exhaust)
- Ensure that pipes and other vessels are purged of hazardous materials
- Identify building materials that will be welded, cut, or burned and that may contain lead, such as painted surfaces and pipes. Test materials and provide exposure controls identified in 29 CFR 1926.62 as necessary; see the lead hazard in the general recommendations document
Additional Personal Protective Equipment
- Gloves and protective clothing for the activity being performed
- At a minimum, filtered lenses and face-protection as appropriate for the activity being performed
- Respiratory protection based on anticipated exposure to metal fumes, including lead
CHEMICAL AND MATERIAL STORAGE AND USE
Key Engineering Controls and Work Practices
- Segregate and store incompatible chemicals separately. For example, store solvents and oxidizers (e.g., peroxides) separately, and acids and caustics separately
- Secure compressed gas cylinders and ensure that they are stored properly when not in use (regulators off and valve caps on when not in use; separate oxygen and fuel gas by 20 feet or using a non-combustible barrier (5 ft high, fire-resistant rating of at least ½ hour))
- Store chemicals in containers approved and designed for chemical storage and mark all storage locations
- Store and handle hazardous materials in areas with natural or forced ventilation; do not store or handle in low-lying areas
- Isolate, secure and identify storage areas
- Prohibit smoking near storage areas
- Keep ignition sources at least 25 feet away from storage areas
- Ensure that fire extinguishers and extinguishing agents are available in the immediate area
- Bond and ground containers before dispensing flammable liquids. Reference 29 CFR 1926.152(e)(2)
Additional Personal Protective Equipment
- Gloves made of material that will protect user from chemicals handled
- Face shield or goggles with indirect venting. If a face shield is selected, eye protection must be worn under the face shield
- Coveralls or apron resistant to chemicals being handled
- Disposable boot covers resistant to the chemicals being handled
- A respirator and cartridges specific for chemical, as necessary
EXPOSURE TO CONTAMINATED WATER AND/OR FLOODWATERS
Key Engineering Controls and Work Practices
- Reduce the exposure to splash or aerosolized liquid hazards by limiting the number of people in the area and having those in the area stay upwind of water discharge areas
- Ensure that good hygiene, especially hand washing, is practiced before eating, drinking, and smoking. If clean water is not available, use an alternative such as hand sanitizer or sanitizing wipes
- Ensure that cuts and bruises are protected from contact with contaminated water
- Clean areas of the body that come in contact with contaminated water with soap and water, hand sanitizer, or sanitizing wipes
Additional Personal Protective Equipment
- Goggles if routinely working near splashing floodwater
- N, R, or P95 respirators may be necessary for exposure to contaminated water that may become aerosolized
- Watertight boots with steel toe and insoles
- Waterproof gloves for contact with contaminated water
GENERATOR USE
Key Engineering Controls and Work Practices
- Never attach a generator directly to the electrical system of a structure unless a qualified electrician has installed a transfer switch for the generator. If the structure’s electrical system is not isolated, it may energize the utility’s wiring system for great distances and create a risk of electrocution for utility workers and others in the area
- Always plug electrical equipment directly into the generator using the manufacturer’s supplied cords or grounded (3-pronged) extension cords that are rated for the total anticipated load
- Do not overload a generator; it can overheat and create a fire hazard
- Ground and bond generators according to the manufacturer’s recommendations; ensure that any manufacturer-required connections are secure before using the generator
- Keep the generator dry; protect with a canopy if needed; do not use it in wet or rainy conditions
- Carbon monoxide (CO) is a poisonous, colorless, and odorless gas that is produced by the incomplete burning of the generator’s fuel. CO is harmful when breathed because it displaces oxygen in the blood and deprives the heart, brain, and other vital organs of oxygen
- Never use a generator indoors or in enclosed spaces such as garages and basements; opening windows and doors may not prevent CO from building up in those spaces. Do not use a generator outdoors near doors, windows, and vents that could allow CO to enter
- Ensure that a generator has 3 to 4 feet of clear space on all sides and above it to ensure adequate ventilation and cooling
- Before refueling, shut down the generator and allow it to cool
Additional Personal Protective Equipment
IMPROPER LADDER USE
Key Engineering Controls and Work Practices
- Inspect ladders for cracked, broken, or defective parts before use
- Do not exceed the load rating of ladders—remember that load ratings include people, tools, and equipment
- Set up ladders on stable surfaces
- Set extension or straight ladders at a 75 degree angle from the ground (1/4 foot back for every foot of rise) and provide 3 feet above an upper landing surface to ease climbing onto/descending from height
- Use non-conductive ladders (e.g., fiberglass) and exercise extreme caution when working near power lines
- Secure ladders that can be displaced by work activities; consider barricades at the base to keep traffic away
NOISE
Key Engineering Controls and Work Practices
- Place generators and other noisy equipment at a distance or behind a barrier when possible
Additional Personal Protective Equipment
- Hearing protection when working around potential noise sources and when noise levels exceed 90 dBA. A useful "rule of thumb"-if you cannot hold a conversation in a normal speaking voice with a person who is standing at arms length (approximately 3 feet), the noise level may exceed 90 dBA
DISCOVERY OF HUMAN OR ANIMAL REMAINS
Key Engineering Controls and Work Practices
- If found, contact public health/mortuary personnel for removal
DISCOVERY OF UNKNOWN CHEMICALS
Key Engineering Controls and Work Practices
- If hazardous chemical containers are found or leaking materials are detected:
- Do not use spark-producing devices (e.g., engines, tools, electronic, and communications equipment) in the immediate area
- Take self-protective measures (i.e., move to a safe distance upwind) and contact hazardous material response personnel for evaluation/removal before continuing work in the area
Additional Personal Protective Equipment
- Evaluate the need to revise protective clothing, respirator, and glove selection
OTHER POTENTIAL HAZARDS
Select any of the following potential hazards that can be associated with this activity in order to access relevant recommendations in the general recommendations document:
Additional Medical Needs
Additional Training Needs
Other Resources and References
- 29 CFR 1910.146, Permit-required confined space. OSHA.
- Atmospheric Testing in Confined Spaces. OSHA Quick Card, (2005), 21 KB PDF, 2 pages.
- NIOSH Interim Guidance: Working Safely in Confined Spaces. Centers for Disease Control and Prevention, (2005).
- Confined Spaces. OSHA Safety and Health Topics Page.
- Hydrogen Sulfide. OSHA Quick Card, (2005), 20 KB PDF, 1 page.
- Respiratory Protection. OSHA Safety and Health Topics Page.
- NIOSH Respirator Selection Logic. Centers for Disease Control and Prevention, (2004).
- Using Portable Generators Safely. OSHA Fact Sheet, (2005), 22 KB PDF, 2 pages.
- Portable Generator Safety. OSHA Quick Card, (2005), 19 KB PDF, 1 page.
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