Confined Space FAQs
OSHA Training Institute Education Centers
Chabot, Los Positas Community College, Dublin, CA. http://osha4you.com/courses/osha-safety-standards/40-hour-confined-space-rescue-otc-304
Enviro Safetech (Jay Jamali)
2160-B Oakland Rd.
San Jose, CA 95131
California Health & Rescue Training
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• Full body harnesses are required for lowering or hoisting personnel from vertical confined spaces. Harnesses are required for spaces deeper than 5 feet.
• Full body harnesses are also an integral part of a rescue system. Rescue plans can be of two types. A self-rescue system can be used whereby the Entry Team provides their own rescue to the Entrant through the use of their own equipment on site. The second type of plan is where a rescue service provider, such as a fire department, is relied upon for rescuing an Entrant(s). Both plan types are acceptable under certain circumstances. For either plan used, wearing a full body harness enables emergency rescue
• In general, Entrants must maintain a retrieval line attached to their harness during vertical confined space entry (i.e. manholes and deep vertical spaces such as storm drains) to enable rescue and retrieval. If there is a demonstrated danger of entanglement or hazardous impediment caused by the retrieval line, such that a greater hazard is created, then this condition may be evaluated on a case-by-case basis and exempted by the designated Entry Supervisor.
• Short duration, inspection-type work, which does not involve MRO work or a subcontractor's construction-related work in the space, may rely on the LBNL Fire Department as the rescue service. Provided this exception, a tripod is not required to be on the entry site, although many project managers require it on their projects. Short duration inspection-type operations, without a tripod on-site, must have a rescue plan coordinated with the Fire Department in order to ensure an availability to respond during the time of the entry. Coordination includes calling the Fire Department (510) 486-6015 to determine their staff's availability to perform rescue during an entry event.
• In general, confined space entry does not require a fall matrix permit form be prepared since there is no working from height. If a fall hazard that is not protected by Passive Fall Protection System (i.e. guardrails, safety nets, warning lines, etc.) does exist, than an engineered fall protection system is required; and a fall protection matrix permit will become necessary. Wearing a full body harness in a confined space does not imply working from height as the purpose and intent is specifically for lowering or hoisting personnel from a confined space, whether it is a routine entry or for rescue. Full body harnesses are required to be worn by in-house staff for all vertical confined space entries regardless of the permit type used (i.e. Alternate Entry, Reclassification, Regular Permit).
• For rescue purposes only, Class II rated chest harnesses or wristlets may be worn in lieu of full body harness. Chest harness and wristlets are not to be used for the routine lowering or hoisting of personnel, as they are designed and allowed for rescue purposes only. Since chest harnesses and wristlets are not allowable for lowering or hoisting personnel, it is implied that a ladder will be used to enter and exit the space. This Program does not authorize a requirement, make recommendation or direct subcontractors to downgrade their PPE or controls as required by OSHA or which employees choose to voluntarily wear and use. Class II chest harnesses or for that matter wristlets are not commonly used alone as a rescue harness. It is more common to use a Class II seat harness in conjunction with a chest harness. It is standard industry practice to use a full body rescue harness with either a dorsal or chest D-ring or rescue shoulder D-rings in conjunction with a rescue spreader strap/bar.
• Self-rescue equipment, including a tripod with winch, must be in place or, at the immediate ready during entry operations for either Facilities MRO work or construction-related work.
• An Permit-Required Entry Team that includes an Attendant is required for permit-require confined space entry. In-house staff must have current EHS0276 Fall Protection training to be authorized to work as a member of a Permit-Required Confined Space Entry Team. This is to ensure the proper use and adjustment of a harness as well as other rescue systems such as the tripod, winch, or davit arm. Attendants must be competent in the use of the winch for lowering and hoisting personnel.
• Guarding must be used for vertical confined spaces. Guarding requires the use of a collapsible steel guard gate to warn and prevent pedestrians from falling into an opened confined space.
• Guarding of open manholes from tools and equipment falling into an opened manhole includes the use of a circular, manhole guard ring. Certain manhole configurations may not suitable for using the manhole guard ring. These conditions may include improper sizing that is not within the diameter range of 28", 30", and 32". Another condition may be where the guard ring increases the distance to an upper fixed ladder rung where initial step-down distance becomes too great to allow a worker safe entry. In these situations the use of the guard ring may create hazard and therefore may be exempted by the Entry Supervisor. An alternative is to use a fixed manhole ladder, which extends at least 2 feet above the manhole guard ring. This will generally allow safe entry and exit as well as prevent tools and equipment from falling into the opened space. Another condition where a manhole guard ring may not be a feasible option is when a line of some type must be routed down into the manhole, which prevents proper fit or can crimp off the line. For example supplied airlines, hydraulic lines, etc. An additional option for control of overhead hazards of confined space be to control access to the confined space area and require all tools and equipment be tethered at all times while inside the controlled access zone.
• Adequate illumination must be provided. Headlamps are preferred since they provided hands free operation. Intrinsically safe LED lights are also recommended to provide ambient light.
• Intrinsically safe devices and equipment are required when working in potentially hazardous atmosphere spaces such as sanitary sewer manholes.
• Fixed manhole ladders are to be used when a ladder is required or a portable manhole/trench ladder when an existing fixed ladder is deemed unsafe. Extension ladders are prohibited unless there is a reason why manhole ladders are not as safe to use.
• Facilities or other in-house staff is responsible for acquiring their own harnesses. These may be checked out from Stores or purchased, depending. LBNL EHS does not provide equipment such as harnesses or tripods to subcontractors. Harnesses must be inspected on an annual basis by a competent person and prior to use by the user.
• All entries and Entry Team members must be authorized to perform the entry by the Activity Lead or Project/Construction Manager.