Confined Space Entry

Confined Spaces are abundant and common throughout both large and small Craft Breweries.

Confined Space entries are probably one of the most misunderstood practices that take place daily in the Craft Brewing industry. As a safety professional, having had the opportunity to tour many of the well-established craft beer producers, I have found most have little or no training to be able to conduct a proper and safe Confined Space Entry. Some had no equipment even to test the atmosphere of the spaces they required employees to enter.

Larger Breweries have Health and Safety Departments.

For the most part, the larger players in the brewing industry have legitimate safety programs, policies, and procedures with a support staff to manage, train and enforce the programs.  Due to their size and visibility to state and federal agencies, strict compliance with OSHA is a normal part of doing business.

Craft Breweries and confined space entry compliance.

First, regardless of the size of the Craft Brewery, strict compliance with state and federal OSHA regulations relating to confined space entry must be followed. Failing to do so can cause a financial burden to your business in penalties and fines, but most importantly could cost someone their life.

Mechanical hidden dangers are often found in confined spaces.

What is a confined space?

According to OSHA, a confined space is an area or place that has the following three characteristics:

Large Enough to Enter and Work

Limited Openings for Entry and Exit

Not Designed for Continuous Worker Occupancy

Space must meet all three of these criteria to be classified as a confined space.

  • Classification of Confined Spaces.
  • There are two types of confined spaces, Non-Permit and Permit required. How can you determine one from the other?
  • Non-Permit Confined Space does not have:
  • A hazardous atmosphere
  • Engulfment hazard
  • Internal configuration Hazard
  • Or any other recognized hazard.

All confined spaces need to be identified and labeled.

Permit required Confined space will have or have the potential to have any or all the items listed above.

If all possible hazards can be eliminated prior to anyone entering the confined space, then and only then a permitted space can be reclassified to a non-permit required space.

What is considered an entry?

Any part of the body passing through the opening is considered entry. Something as simple as reaching into a tank or sticking your head into a hatch opening to inspect a vessel is considered an entry.

Why is this so important?

Let’s face it, there is no possible way a craft brewery can produce a finished product without having at least one or several confined space entries occurring during the brewing process.

In 2011 OSHA Investigations identified 188 deaths in confined spaces:

  • 146 atmospheric hazards
  • 42 mechanical hazards

NIOSH studied 55 Confined Space incidents involving 88 deaths.

  • Only three of the victims were trained

Two of every three people who die in a confined space were not the original entrant.

Per OSHA from 2005-2009 in 28 different states, there were a total of 481 confined space entry fatalities. This averages to about 1.85 fatalities per week or about 1 fatality every 4 days. This data covers incidents with at least one fatality or death, and do not include incidents that only resulted in serious injuries or illnesses.

Out of the 481 deaths, 298 of these occurred during construction, cleaning or repairing activities.

It is noted that 83 of the deaths were individuals in management positions.

Most of the deaths (294) were caused by physical hazards, surprisingly hazardous atmospheres accounted for only 160 deaths.

 In 29 CFR 1910.146 Permit-Required Confined Spaces.

What do I need?

To be safe your business needs to understand the requirements.  A qualified person needs to access the facility and identify and label all the known confined spaces. Written policies and procedures must be developed for each piece of equipment.  Also, employees need to be trained on the specific procedures prior to any entry activity, if respirators are required other issues need to be addressed prior to an employee being allowed to use it.  The list goes on and on.

Portable gas detectors are necessary to manage Co2 and Oxygen levels in confined spaces.

Dilution is the solution to clearing atmospheric hazards in a confined space.

State and Federal requirements.

To get an idea of what is required go to the Department of Labor’s website https://www.osha.gov/ and research section 29 CFR 1910.146 Permit-Required Confined Spaces.  From there you will find the following topics and what every employer is required to have:

Policy

Definitions

Responsibilities

Procedures

Contractor requirements

Employee Training

Permit System

Alternate Procedures

Rescue Plan

Confined Space Workplace Evaluation

All of the above is required to be in place prior to anyone entering a confined space.

 Where to get help

If you have no one with the expertise to develop these policies and procedures and conduct the necessary training, reach out our online Health & Safety Consulting firm to assist you with these issues.  Remember non-compliance is not an option.

 

For additional information Contact Terry Botts

804-712-3203

tbotts@comcast.net