Assessments, permits and required roles for entering confined spaces
Farms have several confined spaces that must be assessed prior to entry.
A confined space is defined as a fully or partially enclosed space that is not designed or constructed for human occupants and/or has limited/restricted methods of ingress and egress. Furthermore, a confined space may have an atmospheric hazard because of construction, location, contents or because of the work done in it. Confined spaces are only to be entered under special circumstances such as for inspections, cleaning, maintenance or repair.
Consider your dairy; can you think of potential confined spaces? Some places that come to mind for me are grain silos, milk tanks, bunker silos, feed bins, crawl spaces, valve boxes and all types of manure handling and storage areas such as tanks, ponds and pits.
A hazard assessment must be performed prior to confined space entry by a competent person who will identify and assess the hazards an employee is likely to be exposed to while in the confined or restricted space. This person will also specify the type and frequency of inspections and tests necessary to determine the likelihood of employee exposure to any of the identified hazards and perform said inspections and tests specified. The hazard assessment will also specify the safety and personal protective equipment (PPE) required to perform the work and identify the PPE and emergency equipment to be used by an employee who undertakes rescue operations in the event of an accident or other emergency.
The hazard assessment must also consider the condition which may exist prior to entry due to the confined space’s design, location or use, or which may develop during work activity inside the space. The assessment will also determine potential for oxygen enrichment and deficiency, flammable gas, vapour or mist, combustible dust, other hazardous atmospheres, harmful substances requiring lockout and isolation, engulfment and entrapment, and other hazardous conditions. Additionally, the assessment will include confined space and the confined space types at the worksite or each group of confined spaces which share similar characteristics. Work activity, or group of work activities which present similar hazards, to be performed inside a confined space will also be assessed at this time. As expected, the types of hazards that are or may be present at each confined space will be included in the hazard assessment.
The hazard assessment must be documented and detail the hazards assessed, tests and determinations, and recommendations for special precautions and PPE. Following the assessment and before anyone is permitted to enter or work in a confined space, you must take measures identified to reduce, control or eliminate the risks. The controls must ensure entrants are protected against the release of hazardous substances, contact with electrical energy, contact with moving parts and against drowning, engulfment, entrapment and suffocation.
Control of hazardous substances and energy
Finally, the hazard assessment will also determine how to control the hazardous substances and energy that is part of the confined space. Supervisors and senior leadership must determine how an employee will be protected against the release of hazardous substances, electrical energy and moving equipment parts when in the confined space. All equipment should be disconnected, disengaged, de-energized and a lockout/tagout procedure should occur before entry into a confined space. Employees also need to be protected against drowning, engulfment, entrapment, suffocation and other hazards from free-flowing material by adequate means.
Duties of authorized entrants
The authorized entrant is the employee who will enter the confined space with many responsibilities while performing the job. The authorized entrant needs to fully understand the hazards of the job they are doing and know signs and symptoms of exposure while in a confined space. This person must use all proper equipment and PPE as required and communicate often with their attendant. The authorized entrant must know when the conditions in a confined space change, alarm sounds or if their attendant directs them to exit safely and immediately.
Duties of attendants
An attendant shall be stationed outside a confined space while it is occupied by employees. Their responsibilities involve the well-being and care for the authorized entrant through proper and constant communication. The attendant will be trained on how to do a rescue if required and is never to leave their designated area. The attendant must monitor activities inside and outside the space to determine if it is safe for entrants to remain in the space and order the authorized entrants to evacuate the permit space immediately if they detect a prohibited condition, if oxygen levels fall below 19.5% or rise above 23%, if they detect the behavioural effects of hazard exposure in an authorized entrant or if they cannot, for any reason, effectively and safely perform all the duties required.
Duties of supervisor
A competent and adequately trained supervisor must be assigned to supervise the job before any employee enters a confined space. The supervisor must know the hazards that may be faced during entry, including information on the mode, signs or symptoms and consequences of the exposure. The supervisor is required to verify that all pre-entry tests and inspections specified by the permit (detailed below) have been completed. The supervisor must verify that rescue services are available and the means to summon them are operable, and only allow authorized employees to enter a confined space and remove unauthorized individuals who enter or attempt to enter the permit space during entry operation.
Confined space entry permit
A confined space entry permit should be issued every time an employee has been approved to do work inside a confined space by a supervisor. An entry permit should include the following information: the location of the confined space, the date and time which the permit applies, a description of the work that needs to be performed as well as a description of the hazards and corresponding control measures. It should also list which employees will be involved, a record of an employee’s entrances and exits, a list of equipment the employee will be using as well as a complete pre-use inspection of the equipment. The permit should also include a rescue plan, equipment that will be needed for it and results from atmospheric testing. Finally, the confined space entry permit should include whether the work requires hot work (i.e., welding), what equipment will be used for this and a place for the supervisor and all employees who will be part of the work to acknowledge that they have read the permit and have prepared for the work in a confined space.
General permit entry
If the confined space hazard assessment has identified that any potential hazardous atmosphere can be adequately controlled by ventilating the space and other hazards such as potential for engulfment or other safety hazards such as mechanical hazards, exposed electrical wires or energized equipment, gas or chemical lines, or hazards related to elevation or falling can be adequately controlled, then a general confined space entry permit must be issued.
Any employee who is required to enter the confined space must verify that the confined space is not hazardous and establish a proper method of communication between employee entering and exiting the confined space and others must be established on appropriate intervals. Communication can be through cellphone or two-way radios with the attendant. A general permit entry must also include an emergency procedure plan if the employee becomes injured or incapacitated.
Hazardous permit entry
If the confined space hazard assessment has identified the space contains or has the potential to contain a hazardous atmosphere that cannot be adequately ventilated, it must be considered a hazardous environment. If the confined space hazard assessment has identified that the space contains other hazards such as potential for engulfment or other safety hazards such as mechanical hazards, exposed electrical wires or energized equipment, gas or chemical lines, or hazards related to elevation or falling that cannot be adequately controlled, it must be considered a hazardous environment.
Pre-entry requirements must be followed for all hazardous permit entries and access must only be granted to authorized entrants that have an approved entry permit. An attendant must be in place at all times and a rescue plan must be established.
Pre-entry atmospheric tests must be made before entering a confined space and the atmosphere must be periodically tested while persons are within the confined space. This testing must be conducted by a competent person using calibrated instruments in good working order and appropriate for the hazards identified in the relevant assessment. Testing should include acceptable ranges of oxygen content, flammable atmosphere and toxic concentrations using a calibrated, direct reading, gas monitoring instrument and occur regularly and documented properly.
If atmospheric hazards exist or are likely to exist in a confined space, the confined space must be purged, ventilated or both before any employee enters it to ensure acceptable atmospheric levels are maintained in the confined space while any employee is inside. Ventilation must be in place to control respiratory hazards. If not practicable, appropriate respirators such as self-contained respirators must be used. Respirators or dust masks will not filter out all gases and fumes. Adequate protections must be determined in the confined space hazard assessment. Ventilation equipment must provide continuous forced air from clean air sources so that proper air exchanges for the enclosed space are maintained at all times.
Confined space rescue plan
A rescue plan must be established for each confined space, and rescue equipment must be available. An adequate number of trained persons must be available for immediate implementation of the on-site rescue procedures. The attendant must, by whatever means are available (voice, radio, phone), summon rescue and other emergency services as soon as they determine that authorized entrants may need assistance to escape from permit space hazards. Rescue personnel and equipment must be readily available to respond to a confined space emergency before an employee enters a confined space; this equipment should be inspected before use and regularly maintained.
The emergency response plan shall include the emergency procedures to be followed if there is an accident or other emergency. No one is permitted to enter a confined space to perform a rescue if they have not been trained or if they will endanger themselves or others by entering.
Every employee who enters a confined space, is an attendant at a confined space, who may be required to participate in rescue or who performs related work shall be given adequate training and deemed competent in the safe work practices for working in confined spaces before any work is done in or around a confined space. Additional training for specific tasks and confined spaces must also be completed. All training must be documented. Written certification must include name and trainer signature/initials, and dates of training will be provided upon completion of required levels of training as provided by outside contract training resources.
You must retain every assessment, plan, coordination document, record of training, entry permit, record of an inspection and record of a test for at least two years.