Safety for employees working in a “confined space” needs to be a major consideration for operations of agricultural retail operations handling bulk materials such as dry and liquid fertilizer. More often than not, the concern about working in confined space centers on grain handling facilities, but fertilizer manufacturing and handling facilities and structures can be just as dangerous.
The Occupational Health and Safety Agency has set the rules related to defining confined space and permitting workers to enter such space to do things like repairs or clean out. Although OSHA 1910.146 starts out with a disclaimer about not covering agricultural operations, that isn’t a disclaimer omitting industry storing, handling and manufacturing of agricultural inputs.
Jeff Laverty with KC Supply Company provided an extensive overview with details, most of them demonstrated with photos, about enforcement of 1910.146 for safe entry into confined spaces. Laverty outlined requirements of employers during last summer’s National Agronomic, Environmental, Health and Safety School in Bloomington, Ill.
As a starting point, confined space is defined as large enough to enter and perform work, a space that has limited entry or exit and a space not designated for continuous occupancy, or in other words, it’s a place that only needs entered occasionally during a year.
FILL OUT PERMITS
An employee/employer is required to fill out a “Confined Space Entry Permit” (CSEP) before an employee can enter if any one of four situations exist or potentially exist—atmosphere hazard, engulfment hazard, internal design that could trap or suffocate an entrant or any other recognized hazards present such as electrical or mechanical.
Laverty showed examples of typical confined spaces—although the exact specifics of construction will determine if some of these are confined spaces—ammonia storage tanks, boot pits, fertilizer storage tanks, fertilizer warehouse bins, flat storage, basements, liquid storage tanks, tunnels, receiving pits, scale pits and circular steel bins. In some cases such as flat storage, the structure might be classified as confined space when it is full of grain or fertilizer but not confined space when empty and entry can be made from more than one entrance or by more than an 18-inch to 24-inch portal.
The use of the CSEP form provides for a checklist to evaluate hazards and verification that hazards are eliminated before an employee enters the space. Laverty compared using the CSEP to the checklist an airline pilot will use before leaving the airport gate, and the checklist is used for the safety of everyone on board the airplane.
“The permit is your friend because it tells you how to do things, and on the other side it is a CYA. You are making sure you did everything right plus if you get inspected, you can show what you did. It shows that you actually went through all the procedures,” Laverty said.
“A permit forces you to look at each facility, each structure that anyone goes into to determine what hazards there are, verify that hazards have been eliminated and provides documentation. Just because you say so doesn’t mean that it happened.
“OSHA inspectors like to see documentation, and the more documentation the better,” Laverty added.
Laverty went through his own checklist of things that employers should be concerned about for confined spaces requiring a CSEP.
Only having one door for entry and exit is a main concern that usually plays a big part in determining the need to classify a confined space as needing a permit to enter. That one entrance influences atmosphere and air flow in the space, and if anything should happen in the space, the employee could be trapped without another way out.
“You have to evaluate the hazards, know what you are getting into and know if there is an electrical problem, know that there is an auger that needs locked down and much more,” he said. And this evaluation should be used to establish a written step by step program that the company requires for entering any confined space.
EXAMPLES TO FOLLOW
In many cases, for example, the safety procedure will require a three-person team of the authorized entrant to the space, an entrance attendant and an entry supervisor. That entrance attendant must keep a constant vigil with some form of communication, usually radio or visual.
Certain safety equipment is required for specific entry in most cases. Employees need the proper safety equipment in full working condition, and they need to be properly trained in its use.
“Make sure you have a safety equipment inspection program; make sure that the harness isn’t 30 years old or a rope isn’t frayed,” he said. It’s too late once inside a confined space to then realize “a buckle doesn’t work or a loop is missing.”
“Make sure everybody entering is properly trained, rescue people are properly trained and anyone affecting that entry point is properly trained,” Laverty warned.
As for rescue, in many cases it will fall on the shoulders of the local fire department; therefore, having the firemen familiar with all the facilities can be extremely important. The rescue personnel should be trained for your type of facility, he said.
“A great solution is to invite your local fire department in and have them walk through your facility so that they have some knowledge about your facility and they’ll know what they are getting into. Get them on your site. Walk them through all your potential hazards. Let them know what they might experience. Educate them as much as possible,” Laverty recommended.
MUST DO SAFETY
Before entering, per the CSEP, atmosphere testing and ventilation testing need to be completed. Oxygen and gas monitors are a necessity that must be kept in good working order and recalibrated occasionally per the owner’s manual. His tip is to turn any monitor on in the office, which is a safe environment at a reasonable temperature, and let it come up to function before using it in the extremes of the confined space, which might be 10 degrees below zero or blazing hot at 120 degrees.
“Lock out and tag out (LOTO) any known energy sources—electrical, hydraulic, pneumatic or anything that might activate equipment or create a hazard when you are inside a tight space,” he explained. “Make sure it is locked out. Once you’ve locked it out, test equipment to make sure it won’t activate. Release any hydraulic or pneumatic pressure and then make sure it’s locked out.”
“Technically, you don’t have to have a tag and lock per worker, but it is a lot safer,” he noted. If each employee has a padlock and lockout hasp, then there won’t be the situation of someone leaving and taking the padlock and lockout with them. He suggested $15 for these two items per person is a cheap assurance that things go smooth in doing lock out and tag out.
Laverty continually emphasized safety as the overall goal. “Be serious about safety and follow the procedures every time.” No one should complain about following prescribed procedures because it might take an extra 30 minutes preparation; it is time well spent to possibly save a life or prevent a major injury.
“You cannot assume that a boot pit is in the same condition it was a month ago or that a boot pit on this side of the facility is the same as the boot pit on the other side of a facility,” he said.
Laverty said, “The whole point is to be safe.”
This article is brought to you in cooperation with the National Agronomic Environmental Health & Safety School (NAEHSS).