Unfortunately, in our industry, getting in confined spaces to perform work such as repairs or maintenance is a recurring task. It also is undeniably one of the most dangerous things we do.
Every year, grain elevator employees and farm workers get hurt and some never come home. Gratefully, we are curbing the tide when it comes to the numbers of occurrences, but let’s face it – even one occurrence is too many. We can’t get to zero if we don’t have effective confined space entry training.
The first step to effective training is to explain what constitutes a confined space. According to the Occupational Safety Administration (OSHA) Standard 1910.146(b), to be considered a confined space, an area must meet all of the following criteria:
• Is large enough and configured that an employee can bodily enter and perform assigned work.
• Has limited or restricted means for entry or exit.
• Is not designed for continuous employee occupancy.
In addition, an employer must evaluate each confined space with regard to:
• Hazardous atmosphere.
• Engulfment.
• Entrapment or asphyxiation.
• Other recognized serious safety or health hazards.
If one or more of these four indicators risk a worker’s health or safety, the area qualifies as a permit-required confined space as well. Understanding the definition is critical. Training employees on the definition empowers them with knowledge needed to work safely. Employers must be responsible for identifying all confined spaces at every worksite and labeling them accordingly.
OSHA has many requirements for confined spaces training, but compliance doesn’t have to be difficult. Permit-required confined space training must include three key areas:
1. Nature of the hazards.
2. Actions to take when exposed to hazards.
3. How to arrange for a rescue.
Confined space entry is never routine. Ever-changing conditions of atmosphere, climate, grain quality, and grain quantity mean that no two entries into a structure are exactly the same.
Confined Space Decision Chart
Training employees with a confined space decision chart once again allows the employee to diagnose the entry. It’s important to learn how to evaluate the configuration of the space, as well as any physical, psychological, and atmospheric hazards.
In addition, and of equal importance, is the need to create a strategy for identifying and controlling the hazards that may exist in the confined space.
Finally, there must be a need to develop an effective rescue strategy that does not put the rescuers at risk. This approach conveys the necessity of procedures for safe entry and why permit completion is so important.
Training Frequency
Confined space entry training should be conducted before new employees begin any confined space work, when there is a change in assigned duties, when there is a change in the permit program or its operations, and when there are any issues with the employee’s confined space performance.
Different Roles
Identifying and defining the roles associated with confined space entry should be a part of any effective training. Provide training content for each specific role in an entry.
• Entrants are those who are actually entering the confined spaces. They should be trained to understand the hazards that could be present in a confined space. Those hazards, symptoms, and consequences of exposure to hazards need to be trained prior to entry. This includes lockout/tagout procedures and equipment as necessary. Equally important is training entrants on the equipment required for entry, including the proper use of personal protective equipment. Going over the procedures and means to alert an attendant is often overlooked, as are the proper evacuation procedures.
• Attendants also should be trained on the hazards associated with entry. They need to be aware of the behavioral effects of hazard exposure to entrants. Additionally, attendants need to be trained on the when and how to order a stop and evacuation of an entry. Teach attendants that their role is singularly focused on the entry and the entrants inside. Lastly, attendants need to know how to perform a non-entry rescue.
• Supervisors can play double roles, as they can be an entrant or an attendant. The supervisor must be very familiar with the entrant and attendant roles because they need to verify and audit the entry process (i.e., what tests were performed, what equipment was used, and what rescue equipment was in place).
Yes, confined space entry a dangerous part of our industry. Thoroughly training employees on the definition, roles, and hazards helps to ensure the ultimate goal: empowering employees with knowledge and sending them home safely.
Dean Alling is the safety director for Ray-Carroll Coop in Richmond, MO (deana@ray-carroll.com, 817-932-1000).