Classification Of Confined Space 1

[BRIS]

I understand KRS's comments on the thread "Fatality in Water valve Manhole" to read that all potable water chambers are classified as confined spaces and should not be entered without first monitoring the atmosphere.

Not all contributors to this forum are in the US and as such we are not all bound by US health and safety legislation. In the countries where I work chambers, on potable water pipelines, are never monitored before entry.

This also used to be the situation in UK. Storm water and foul water manholes on sewers would be monitored but not chambers on potable water mains.

I would be interested to learn whether in fact it is normal practice in the US to monitor the atmosphere in all potable water chambers before entry. I would also be interested to know what current practice is in UK and Europe

Brian

 

[saxon]

Bris, In our operations we consider all manholes, catchbasins, vaults, man accesible piping/process equipment/etc., trenchs/pits deeper than waist high, as permit required confined spaces. The following is a definition for a Confined Space:
1. A space that is large enough and so configured that a person can bodily enter.
2. Has limited or restricted means for entry or exit
3. Is not specfically designed for human occupancy.
For permitting requirements see the OSHA Guidelines.

Hope this helps.
saxon

 

[KRSServices]

ACtually Bris, to help clarify, I'm Canadian. The US and Canada have been undertaking remarkable progress in terms of workplace safety and many of our regulations and guidelines are the result of information sharing and correspondence. I am very happy and satisfied that my thoughts were able to provoke thoughts in other parts of the world.

This is a great forum!

KRS Services

http://www.krs-services.com

 

[stanier]

You could download two publications from Standards Australia via

http://www.standards.com.au

for a modest cost. Our standards are extremely cost efficient compared to American and British Standards.

These are:-

AS 2865 Safe Working in Confined Spaces
HB 213 Guidelines for Working in a Confined Space

Sharing knowledge is a way to immortality

 

[KRSServices]

Bris,

If it would help, I can scan the regulations as they pertain to confined spaces. This would be the definition and how to safely work in them. It is about 2 or three scanned pages. Let me know if you would like me to email them to you. I have regulations for BC and Alberta.

KRS Services

http://www.krs-services.com

 

[BRIS]

KRS

Thanks for the offer. In fact I have confined space trianing from UK but now I work entirely in developing countries. I was mainly iterested to learn how the regulations are interpreted in other countries. That is whether it is normal practice to monitor the atmosphere in a valve cahmber on potable water pipelines before entry. As I understand the regulations the fact that a valve chamber is classified as a confined space does not mean that it has to be monitored for oxygen deficiency before entry. In the countries where I work it is very unlikely that even foul sewer manholes will be monitored before entry. (A scarf tied over the face provides all the protection that is needed!!).

brian

 

[dicksewerrat]

They must have a lack of lawyers where you work. I once had to rescue a guy in a "potable" water manhole. No oxygen in the air in the manhole. I would stress safety no matter what the country. Once you kill a couple people because you didn't monitor the confined space, the morale of the troops goes way down.

 

[BRIS]

Unfortunatly there are still many developing countries where major projects are undertaken - often with international funding- with neither lawers nor safety featurinng on the agenda. Death rates are often in double figures. I would be very surprised if the opeting authority for the local sewer system would even recognise a gas monitor.

brian

 

[tgreif]

Here in the United States, OSHA establishes the requirements for "permit-required confined spaces". The federal regulation 29-CFR-1910.146 covers this. This regulation is for general industry and contains procedures to protect employees in general industry from the hazards of entering confined spaces. Note that this regulation does NOT pertain to construction.

OSHA's construction safety and Health regulations Part 1926 covering construction safety issues does not include a permit-required confined space requirement. However it does specify certain safety training and education requirements for people who are required to enter confined spaces.

I mention the above just to clarify that entry rules are different for contractors and owners. The rest of this message deals with permit required confined space classification for general industry.

First, let's review some basic definitions. A confined space needs to satisfy the following three criteria (per OSHA):
1. large enough to enter and perform work.
2. has limited or restricted means for entry or exit.
3. is not designed for continuous occupancy.

First off, if it's not a confined spece, it can't be a "permit-required" confined space. We've intentionally overdesigned metering and sampling VAULTs with ventilation fans, actual stairs and spring loaded, full size Bilco doors in order to eliminate the LIMITED OR RESTRICTED MEANS FOR ENTRY OR EXIT criteria. Yes, it's more expensive to build but for vaults that must be entered regularly, it's well worth the additional cost not to have to contend with a confined space.

Next, once you have a space that's classified a confined space, you really have to start with the worst possible scenereo and prove your way backward. That basically says that all confined spaces are "permit required" confined spaces until proven otherwise. OSHA's permit required criteria stresses the existence of a hazardous or potentially hazardous atmosphere. But it also has a catch-all statement "a space that contains any other serious safety or health hazard". So if you have a confined space, it's difficult to classify it as anything other than "Permit-Required". Water system meter and valve vaults are included here.

Let me give you an example. About 30 years ago, we were involved in supervision of the construction of a pipeline. This was a new sewage force main that had never had anything in it, and had not even been pressure tested. On that force main was a manhole and in the manhole was a tee with the side outlet flanged off. This tee was provided to allow future access to the force main. The pipeline and manholes had been constructed without incident. One day a two-man crew was going around grouting the inside of the manholes. Worker A enters the manhole. Worker B goes over to the manhole and sees Worker A laying at the bottom of the ladder. He figures worker A slipped and fell off the manhole ladder. So worker B goes in after him. Supervisor sees both workers at the bottom of the manhole and calls the fire department. Both workers died in a manhole which was completely sealed from the pipeline that had never had anything in it. It was determined to be oxygen deficiency but nobody ever determined the cause.

With a permit-required confined space, OSHA allows what is called "Alternate Entry", which lets you enter a space using permanent or portable forced air ventilation alone if you can show that the only hazard posed by the space is a potential hazardous atmosphere. You can enter as long as the space is ventilated and monitored, but you don't have to comply with the "permit" requirements of having an attendant, a safety harness and a rescue team on notice. This alternate entry procedure is for that one event only. You still need to fill out an entry form documenting the entry event and the fact that it was done on "alternate entry".

Sorry this is so long winded. I hope it helps. Be safe.

 

[ptmoss]

Anyone who reads National Geographic might have noticed the artical about India a few months ago that partially dealt with the caste system. The "lowest" people had the job of crawling down into the sewers and physically cleaning them, unplugging obstructions, whatever was necessary. They had no protection. There is a picture of one of the men who had just come out of a manhole and was covered head to toe in filth.

I'm guessing that their confined space requirements have to do with what rung on the ladder you are born into.

 

[BRIS]

ptmoss

It is not confined to India. I am in Lebanon and today I have watched two Bangladeshi labourers crawl into a foul sewer to unplug obstructions.
Third world lower cast labourers work throughout the Middle East and North Africa on construction works with no safety protection.

The main objective of my original question was to get a measure of the huge gap in current safety practice between that practiced in the West and that practiced in developing countries (or developed countries using low cost labour from developing countries).

I know what the dangers are: we see more people killed on one project than engineers in the West will see in a lifetime of construction. Although we insist on safety requirements being built into contracts etc. etc. we can only make very slow improvements on the overall attitudes to safety.

My original question was "I would be interested to learn whether in fact it is normal practice in the US to monitor the atmosphere in all potable water chambers before entry. I would also be interested to know what current practice is in UK and Europe" I don't think I have got an answer to this.

Brian

 

[saxon]

bris, Here in the States, the OSHA Confined space regulations are de-rigour. If they are not followed, severe penalties and fines can and will result. If companies aren't following them, it's like the three Chinese monkeys, Hear no evil, See no evil, Speak no evil and I doupt that anyone will comment on the issue. Good luck on getting anyone to call attention and blow the whistle on themselves.

saxon

 

[tgreif]

OK Bris, I'll give you an answer. Every single water utility I know (and I've been in the business for over 30 years) has an official policy of total compliance with the OSHA regs. That means that every vault or tank entry is done by the book, with atospheric monitors, etc. I've also witnessed violations by utility personnel, and they even had the harness and air monitors in the truck.

You won't find a utility in the USA that doesn't profess complete compliance with OSHA's permit required confined space regs. You also probably also won't find a utility that doesn't "cheat" once in a while.

And I agree with Saxon, nobody's going to be stupid enough to admit violating the regs on a public forum, unless they post in complete anonymity.

 

[BRIS]

tgreif

Thanks - I don't believe that in the UK it is normal practice to monitor the atmosphere before entering a chamber on a potable water pipe. It was not when I last worked for a UK water authority but that was 32 years ago!.

As an aside I sat in a meeting with a Korean contractor working in North Africa where the client complained of lack of progress. The contractor response was that he was expediting progress by not using trench sheeting and taking the risk of trench collapse. Two worlds!!

Brian

 

[ch81pc]

Brian

I have recently attended a week long course on confiined space entry in the UK, including assessment and classification of CS's . I work for on drinking water site and all pits, chambers, shafts, even certain open topped tanks or basements are classified as confined spaces and should have the atmospheres tested and monitored before enrty. This link provides a good overview on the current advice given:

http://www.hse.gov.uk/pubns/indg258.pdf

to anyone workin gin Cs's in the UK.

Hope this is helpful

Paul

 

[panelman]

i work as a contractor on the dirty water side in the uk...on monday a manager took me into a dry well to look at a job....no permit, no gas monitor and he was smoking...today my guys go to do the job and the same manager insists on permits and even checks the calibration date on our monitor

 

[dicksewerrat]

Well I guess the best way to change minds on confined space entry is to use a 'canary'. The canary being the ENGINEER and OWNER go in first.

 

[ptmoss]

Can't we put the lawyers in first?