Roco Director of Training/Chief Instructor, Dennis O’Connell reviews the importance of following OSHA safety standards for confined space entry, no matter how many times workers have entered the space. The take away? With confined spaces…It’s NEVER old hat! The importance of preplanning confined space entries and identifying “potential hazards ”should be old hat by now. Yet every year we are still killing entrants and rescuers in confined spaces.

In the story below, we have one very lucky rescuer, but this very easily could have been a multi-fatality event.

Atmospheric Hazards Continue to Claim Lives in Confined Space Entry Scenarios

The importance of preplanning confined space entries and identifying “potential hazards” should be old hat by now. Yet every year we are still killing entrants and rescuers inconfined spaces.  In the story below, we have one very lucky rescuer, but this very easily could have been a multi-fatality event.

It’s always important to remember that each entry stands alone. Each and every time a space is entered, we need to:

(a) identify potential hazards;

(b) eliminate or control them, when possible;

(c) use proper PPE; and,

(d) have an EFFECTIVE Rescue Plan.

Otherwise, as in this story, we will lose or injure workers as well as those attempting the rescue.

Start from scratch and treat each entry like it’s the first time you’re entering the space – it could save your life.

Keep in mind, the history of a space really has nothing to do with the current entry. We’ve all heard people say, “We do this all the time, and we’ve never had a problem!” Or, “We’ve entered this space a thousand times and the air is always good!” Remember this… IT DOES NOT MATTER!! This entry has nothing to do with the last.

As you read of yet another unfortunate incident, let it be a reminder to those of us who make entries or do rescues from confined spaces – do not let your guard down, do not get complacent…it could be deadly. Atmospheric hazards are still one of the leading ways that people are dying in confined spaces. Because humans are visually oriented by nature, if we can see a hazard, we’ll protect ourselves from it. However, if we can’t see it, we tend to assume it’s safe. OSHA’s 1910.146 PRCS standard and others were developed for a reason… people were making tragic mistakes and dying in confined spaces. These standards and guidelines are written so we don’t make the same mistakes.

OSHA FINES UTILITY FIRM $118,580 FOLLOWING WORKER’S DEATH

OSHA has cited a contracting and utilities company for two willful and two serious safety and health violations following the death of a worker at the company’s Texas facility. Proposed penalties total $118,580. An inspection was initiated by OSHA on June 28 in response to a report that employees working on a new sewer line were exposed to inhalation of a hazardous chemical. One employee who entered a manhole to remove a plug in order to flush out accumulated debris became overwhelmed by toxic fumes and died. Another employee was hospitalized after attempting to rescue his co-worker.

The willful violations are for failing to test for atmospheric conditions and provide adequate ventilation and emergency retrieval equipment prior to entry into a manhole.

The serious violations are failing to provide or require the use of respirators as well as conduct an assessment to determine the potential for a hazardous atmosphere where oxygen deficiency, methane, and/or hydrogen sulfide were present or likely to be present.

“The company failed to ensure that proper confined space entry procedures were followed,” said Jack Rector, OSHA’s area director in Fort Worth. “If it had followed OSHA’s safety standards, it is possible that this tragic incident could have been prevented.”

“The fact that we rely on these instruments to detect hazards that may be colorless, odorless, and very often fatal, should be reason enough to motivate us to complete a very strict schedule of instrument calibration/maintenance and pre-use bump testing.”

Here at Roco, we’re often asked for an explanation of the difference between “calibration” and “bump testing” of portable atmospheric monitors. There seems to be some confusion, specifically regarding bump testing. Some folks believe that bump testing and calibration are the same thing. Others think that bump testing is no more than allowing the monitor to run its “auto span function” during the initial startup sequence – or by running a “manual auto span” in order to zero out the display if there is any deviation from the expected values.

To preface this explanation, it is important that the user maintain and operate the monitor in accordance with the manufacturer’s instructions for use. There are some general guidelines that apply to all portable atmospheric monitors and some of the information in this article is drawn from an OSHA Safety and Health Information Bulletin (SHIB) dated 5/4/2004 titled “Verification of Calibration for Direct Reading Portable Gas Monitors.”

Considering that atmospheric hazards account for the majority of confined space fatalities, it is absolutely imperative that the instruments used to detect and quantify the presence of atmospheric hazards be maintained in a reliable and ready state. Environmental factors such as shifts in temperature, humidity, vibration, and rough handling all contribute to inaccurate readings or outright failure of these instruments. Therefore it is critical to perform periodic calibration and pre-use bump testing to ensure the instruments are capable of providing accurate/reliable information to the operator.

Calibration of the monitor involves using a certified calibration gas in accordance with the manufacturer’s instructions. This includes exposing the instrument sensors and allowing the instrument to automatically adjust the readings to coincide with the known concentration of the calibration gas. Or, if necessary, the operator will manually adjust the readings to match the known concentration of the calibration gas.

In addition to using a certified calibration gas appropriate to the sensors being targeted, do not ever use calibration gas that has passed its expiration date. The best practice is to use calibration gas, tubing, flow rate regulators, and adapter hoods provided by the manufacturer of the instrument.

The frequency of calibration should also adhere to the manufacturer’s instructions for use; or, if more frequent, the set protocol of the user’s company or facility. Once the monitor has been calibrated, it is important to maintain a written record of the results including adjustments for calibration drift, excessive maintenance/repairs, or if an instrument is prone to inaccurate readings.

Each day prior to use, the operator should verify the instrument’s accuracy. This can be done by completing a full calibration or running a bump test, also known as a functional test. To perform a bump test, use the same calibration gas and equipment used during the full calibration and expose the instrument to the calibration gas. If the readings displayed are in an acceptable range compared to the concentrations of the calibration gas, then that is verification of instrument accuracy. If the values are not within an acceptable range, then a full calibration must be performed and repairs/replacement completed as necessary.

Modern electro-mechanical direct reading atmospheric monitors have come a long way in recent years in terms of reliability, accuracy, and ease of use. But they are still relatively fragile instruments that need to be handled and maintained with a high degree of care. The fact that we rely on these instruments to detect hazards that may be colorless, odorless, and very often fatal should be reason enough to motivate us to complete a very strict schedule of instrument calibration/maintenance and pre-use bump testing.

For more information on this subject, please refer to the November 20, 2002 ISEA position Statement “Verification of Calibration for Direct Reading Portable Gas Monitors Used In Confined Spaces”; “Are Your Gas Monitors Just expensive Paperweights?” by Joe Sprately, and James MacNeal’s article as it appears in the October 2006 issue of Occupational Safety and Health magazine.

At some point, most atmospheric monitors will display a “negative” or minus reading for a flammable gas or toxic contaminant. First of all, it is not actually possible for an atmosphere to contain a “negative amount” of a substance. These negative readings usually result from improper use of the monitor.

Most monitors will “Field Zero” or “Fresh Air Calibrate” its sensors when powered on. Because of this, it is very important to power on the unit in a clean, fresh air environment away from confined spaces, running equipment or other possible contaminants. Otherwise, the monitor may falsely calibrate based on the contaminant that is present.For example, a monitor that is powered on in an atmosphere that contains 10 ppm of a contaminant and then moved to fresh air may display a reading of minus 10 ppm. Even more troublesome, if that same monitor is then brought to a confined space that actually contains 25 ppm of the contaminant, it may display a reading of only 15 ppm. As you can see, this could easily lead to the improper selection of PPE for the entrant and result in a confined space emergency.

As always, it is very important to consult with the manufacturer of your particular atmospheric monitor in order to determine how to use it properly. Don’t take any chances with this critical part of preparing for confined space entry or rescue operations.

Reader Jeff Machen had a question concerning how much training to give attendants on air monitoring equipment; especially when they may only be working a week long shut down? Here’s our reply from CSRT Manager Bryan Rogers.

When you’re dealing with temporary labor, it is difficult to ensure that they are well trained on something as complex as atmospheric monitoring. We checked with several equipment manufacturers, and they don’t set a specific amount of training required, but leave it up to the customer’s internal company policy and/or person(s) issuing the monitor.

We also spoke to a few of our instructors who work at different plants and refineries. The majority of these companies require a company employee to perform the initial monitoring and then again after a break in work greater than 30 minutes. In addition, they review with the attendant what to look for and what to do if there are changes in the readings or an alarm sounds. One company provides a four-hour PowerPoint presentation on monitoring and attendant responsibilities.

OSHA does not indicate a time frame for this training either. However, it does require that persons be capable of safely performing the tasks assigned. Therefore, I would say your best bet would be to cover as much of the manufacturer’s instructions as possible along with reviewing the most common problems such as…

    - Calibration conversions
    - Turning on the monitor (or “field zeroing”) in the presence of contaminates
    - Negative LEL or negative toxic readings
    - Contaminated sampling hoses
    - Clogged filters

Lastly, I would stress to the attendants the importance of contacting a supervisor if they have any questions or concerns - and, if they get any unusual results from the monitor… “Do not hesitate to have everyone exit the space while the results are investigated!”

Several of the current electro/mechanical CO sensors will give a false indication of CO when exposed to solvents and especially when exposed to isopropyl alcohol. If the potential for CO presence can be definitively ruled out, consider using an atmospheric monitor with no CO sensor.