Confined Spaces – Cal OSHA’s Special Emphasis Program

Article written by John McCullough, C.S.P., Wells Fargo Insurance Services USA, Inc., Sacramento, CA

The Division of Occupational Safety and Health, DOSH (Cal/OSHA), has initiated a Special Emphasis Program on Confined Spaces in all workplaces as there were seven confirmed confined space deaths in 2011.

DOSH stated that approximately 60 percent of recent confined space incidences resulted in multiple fatalities as the "rescuers" became themselves victims. It is easy to see how this could happen by imagining walking by a sump and seeing a co-worker slumped over and unresponsive. The initial tendency would be to immediately go in and pull them out thinking they may have slipped or had a heart attack. But what if the reason the co-worker is "down" is that there is not enough oxygen to sustain life? Now you have two persons "down."

New DOSH Inspection Protocols

Employers inspected by DOSH Compliance personnel for any reason will follow a new inspection protocol to determine if there are any Permit-Required Confined Spaces (for general industry) and if all the proper policies, procedures and training are in place. Any deficiencies would certainly be cited as "serious." The following is a partial list of the new protocol:

• Determine if the employer has identified any confined spaces.
• Determine if any spaces have been decided to be permit-required confined spaces.
• During the walk-around inspection look for confined spaces.
• Obtain, review and evaluate for completeness the written permit-required confined spaces program.
• Review entry and on-site rescue procedures. "Note that simply stating that they will call 911 does not comply with 5157."
• Review the completeness of any alternate entry and space reclassification procedures.
• Audit entry permits for the last six months.
• Interview employees who have made entries to determine the effectiveness of their training and knowledge about employer’s confined spaces program.
  

Cal/OSHA Consultation Personnel will also be making the same inquiries during on-site visits to employers though no citations will be issued.

What are Permit Required Confined Spaces?

Most food processors are required to follow General Industry Safety Order 5157, "Permit-Required Confined Spaces" or PRCS. To determine if your company has any PRCS’s they need to first determine if there are any confined spaces:

Under GISO 5157, a "confined space" is defined as a space that:

• Is large enough and configured such that an employee can bodily enter and perform work, and,
• Has limited openings for entry and exit, and,
• Is not designed for continuous employee occupancy.

If there are any confined spaces found, the next step is to determine if they are Permit-Required Confined Spaces. Under GISO 5157 a "Permit-Required Confined Space" is defined as a confined space that has one or more of the following characteristics:

1. Contains or has a potential to contain a hazardous atmosphere;
2. Contains a material that has the potential for engulfing an entrant;
3. Has an internal configuration such that an entrant could be trapped or asphyxiated by inwardly converging walls or by a floor which slopes downward and tapers to a smaller cross-section; or
4. Contains any other recognized serious safety or health hazard.

How to Proceed

GISO 5157(c)(1) calls for a full facility evaluation and to determine if there are any Permit-Required Confined Spaces. If PRCS’s are found, then they must be properly labeled and the employer must evaluate the PRCS’s and determine which course of action they will take on each PRCS - (GISO 5157 Appendix A, the Permit-Required Confined Space Decision Flow Chart, should be helpful).

For each PRCS the employer must determine if their employees will:

• Never enter the PRCS. See GISO 5157 (c)(3) for full details.
• Enter the PRCS by down rating it to a non-permit required confined space. See GISO 5157(c)(7) for full details.
• Enter the PRCS by means of "alternate procedures" if the only hazard posed by the permit space is an actual or potential hazardous atmosphere and continuous forced air ventilation alone is sufficient to maintain that permit space safe for entry. See GISO 5157(c)(5) for full details.
• Enter the PRCS under all of the provisions of GISO 5157 including Permit-Required Confined Space program, entry permit system, duties of authorized entrant, duties of attendants, duties of supervisors and rescue and emergency services.

Permit-Required Confined Spaces in the food industry can certainly be dangerous but by instituting and following the PRCP regulations, future single and multiple fatalities should be eliminated.

Useful resources:
http://www.dir.ca.gov/dosh/Confined_Space_Emphasis_Program.html  
DOSH’s Confined Space Emphasis Program’s website

http://www.dir.ca.gov/title8/5157.html  Text of GISO 5157

http://www.dir.ca.gov/title8/5157a.pdf  GISO 5157 Appendix A - Decision Flow Chart

https://www.naylornetwork.com/cfp-nwl/assets/oshapermitrequiredconfinedspaceentry.pdf
OSHA Training Institute Permit-Required Confined Spaces PowerPoint

California League Of Food Producers