Multiple Confined Space Entries
QUESTION: What is required for making multiple confined space entries, and can an Attendant/Hole Watch monitor more than one entry at a time?
ANSWER: Good question! And, the answer is YES according to OSHA 1910.146. However, each space must be evaluated on its own merits with all regulations and requirements applying to each individual entry. Here we will provide some tips when considering one Attendant for multiple entries. This is also where preparing comprehensive rescue preplans becomes essential, and we'll start there.
Suggestions for Writing Rescue Preplans1. One of the first things is to identify and categorize the space as “permit-required” or “non-permit required.” You’ll need to carefully consider the possible hazards based on the information gathered.
2. Once you’ve identified the hazards, you’ll want to consider what actions might be taken to eliminate or control the hazard to allow for a safe entry. OSHA 1910.146 defines "acceptable entry conditions" as the conditions that must exist in a permit space to allow entry and to ensure that employees involved with a permit-required confined space entry can safely enter into and work within the space.
3. Next, you would need to consider the type of work that is going to take place inside the space. A very important question to ask... could the work create its own hazard? (An example would include hot work being performed inside the space.) Then, what about rescue capabilities and requirements? Next, you’ll need to determine whether the entry should be considered “Rescue Available” or “Rescue Stand-by?”
Roco uses the terms “Rescue Available” or “Rescue Stand-by” to better prepare for safe entry operations and in determining more specific rescue needs for that particular entry. Here’s the way we use these distinctions...Rescue Available would be your normal entry that is NOT considered an IDLH (Immediately Dangerous to Life and Health)entry. In this case, a 10-15 minute response time for a rescue team would generally be sufficient to satisfy OSHA regulations and is typical during turnarounds where multiple entries are taking place.
On the other hand, we use Rescue Stand-by when a more immediate need is anticipated, such as with a hazardous atmosphere or potentially hazardous atmosphere. For example, with an IDLH entry, it may require the team to be standing by just outside the space in order to reach the patient in a timely manner (i.e., how long can you live without air...3 to 4 minutes?) Or, how quickly can the entrant be engulfed where there is a potential engulfment hazard? OSHA 1910.134 requires a standby person or persons capable of immediate action with IDLH atmospheres. (See reference below.)
OSHA Reference Note to Paragraph (k)(1)(i): What will be considered timely will vary according to the specific hazards involved in each entry. For example, §1910.134, Respiratory Protection, requires that employers provide a standby person or persons capable of immediate action to rescue employee(s) wearing respiratory protection while in work areas defined as IDLH atmospheres.
Regarding multiple entries, this Rescue Stand-by status could certainly limit the number of entries that could take place due to the availability of qualified responders and equipment. You must also consider that if you’re doing an entry that requires Rescue Stand-by and are called to respond to a rescue from a Rescue Available space, the entrants at the Rescue Stand-by entry must be evacuated before the team can respond. And, if there is only one rescue team, all other entries must stop during a rescue, as the team is no longer available.
Can an Attendant cover more than one confined space entry at the same time?
According to OSHA (see below), attendants can cover multiple spaces as long as they meet the responsibilities and duties at each entry site. If the spaces are “Rescue Available” and are in close proximity, this may be possible. However, without seeing the spaces and if they are on different levels as you mentioned, it could be very difficult for an Attendant to meet all of the requirements OSHA defines for Attendants.
OSHA Notes regarding Attendants and Multiple Entries...
NOTE to 1910.146(d)(6): Attendants may be assigned to monitor more than one permit space provided the duties described in paragraph (i) of this section can be effectively performed for each permit space that is monitored. Likewise, attendants may be stationed at any location outside the permit space to be monitored as long as the duties described in paragraph (i) of this section can be effectively performed for each permit space that is monitored.
1910.146(d)(7) If multiple spaces are to be monitored by a single attendant, include in the permit program the means and procedures to enable the attendant to respond to an emergency affecting one or more of the permit spaces being monitored without distraction from the attendant's responsibilities under paragraph (i) of this section;
Once all these critical factors have been reviewed, you will need to consider the following when writing a rescue plan for an identical space:
For hazards and LOTO procedures, you may be able to use the same rescue plan to cover those spaces. An example would be in doing ten (10) ground-level entries into 6-ft deep manholes, each with a 24” round, horizontal portal with a valve at the bottom. The rescue plan may be identical for all of these entries with the same description and hazards. However, on the rescue plan, you would need to allow for any unexpected hazards such as a possible change in atmosphere. This would be needed to be detected and properly handled by the responders at the time of the incident.
So, these are some of the basics you need to consider when writing a rescue preplan for confined spaces and for determining if (and when) an Attendant can effectively monitor multiple spaces.
If you have questions concerning these topics, please feel free to contact Roco at 800-647-7626.