Permit-Required Confined Space

            OSHA has a required standard, 29 CRF 1910.146, for all locations that meet the confined space criteria and then also require a permit to enter those areas.  Along with those specifications, there are other steps that need to be taken to ensure safe entry into possibly hazardous confined spaces.  The first step is to determine if the space being entered is a confined space by which a permit will be required.  According to OSHA, a space is designated as a confined space if it meets the following three criteria:

1.     The space is large enough for an employee to enter and complete the assigned responsibilities.

2.     The entry and exit from the space is restricted.

3.     The space is not originally planned for permanent occupancy.

The next step is to inform the employees of the space, along with its location and possible hazards.  Testing and other analysis will need to be done in the space to determine the possible hazards.   Due to the nature of the unsafe space, the employer will need to limit access to that confined space so that unauthorized personnel do not enter the space without proper training and permission. 

The first few steps are the general information on the confined space.  OSHA also then requires a confined space entry program.  This program lays out more of the details that are specific to the facility and the confined spaces being entered.  This program must also be available to employees to access.  The written program must cover the ways that the hazards within the confined space are being controlled for a safe entry.  It will also cover the requirements of the permit needed for entering such a space. The permit is very specific to each confined space.  Tests for hazards and personal protective equipment must be described on the permit.  The permit also designated trained personnel who are authorized to enter the confined space as well as attendants who are a line of safety for those inside the space.  As mentioned briefly above, the personnel and attendants must also be trained on how to safely enter the space.   Another topic the written program has to cover is an emergency plan.  The emergency plan gives information on the necessary steps to be taken in case of a rescue in an emergency.  Many times the fire department is called to assist with rescue, and it is important to coordinate with these services before they are needed to plan for the possible hazards involved. 

Many of the scenarios involving the Permit-Required Confined Space Standard also involve other standards.  One standard that may be referenced during a confined space entry may be the Lock Out Tag Out Standard, 29 CFR 1910.147.  This standard may be necessary if the space being entered involves hazardous energy.  The procedure in this standard covers the precautions that need to be taken to ensure that the hazardous power is shut off during maintenance and will not be able to be turned on while an employee is at risk of injury or death.  Another standard that may be needed during confined space entry is the HazardCommunication Standard, 29CFR 1910.1200.  This standard would be used to communicate the hazards of the confined space to the employees and personnel involved with confined space entry.  There may be engulfment hazards or asphyxiation hazards within the space that personnel need to be aware of and trained to work with.  

              Aside from this lengthy process of permit-required confined space entry, there is an alternative to a full permit for entering a confined space as described by OSHA.  An example where this alternative method would be acceptable is if the employer can show through samples and monitoring that the space is only potential hazardous atmosphere and nothing more, but can be fixed by clearing the space with continuous air ventilation, then they may be exempt from permits and attendants.  The employer must provide tests before entry and continuous air ventilation during the working process to avoid completing a full permit.

 

Risk Management Plans and Process Safety Management

The Risk Management Plan, RMP, was designed by the Environmental Protection Agency, EPA, to be used by facilities that deal with hazardous chemicals in order to prevent chemical accidents from occurring.   According to the EPA, there are three main areas that an RMP must cover.  The first area is that of an assessment of the potential hazards that could occur due to an accidental release of the hazardous chemicals.  Along with that, they must include a history of the accidents in the past 5 years.  Next, they must include safety measures that are in place along with training procedures, and maintenance.  Lastly, the RMP must have an emergency response program in place if an emergency were to occur.  The emergency response program must include emergency protocols involving health care, training procedures, and emergency response.  The RMP must be resubmitted each year to ensure it is up to date.  There are about 250 chemicals that have threshold levels to which a company is responsible for the regulations.  27 of those chemicals are not listed in OSHA’s Process Safety Management. 

            Process Safety Management, PSM, was designed by the Occupational Safety and Health Administration, OSHA, to ensure a safe workplace where hazardous chemicals are used.  As stated in the name, this tool is used to define a ‘process’ that needs to occur in the event of a spill or leak of hazardous chemicals.  This standard has a key focus on the safety of the worker when in the workplace while the RMP has a focus on the environment and the impact of the chemicals on the environment.  According to OSHA, the PSM required written safety information that recognizes the hazards or possible hazards within a workplace to ensure that the workers are aware of their environment.  Each PSM must be updated every 5 years to ensure the most current information.  Similar to the RMP, this standard must also outline emergency procedures in the case of a spill or leak.  The hazards must also be identified in order to determine the best possible way to prevent an emergency from occurring. The details for the PSM are outlined on OSHA’s website and are much more strict that those of the EPA’s RMP.  There are also about 79 chemicals that are listed on the PSM but not on the RMP.  In general, the PSM threshold levels are lower than the RMP threshold levels for responsibility.  

Facilities that store or use highly hazardous chemicals must comply with both the Risk Management Plan and the Process Safety Management.  It is important for facilities to follow both sets of regulations in order to keep the workplace safer for the employees and the environment safer for everyone.  A chemical leak or spill of any sort is dangerous, that it why it is important to have these plans and protocols in place before an emergency was to occur.  In the event of an emergency, the staff and public responders are well informed and have coordinated the appropriate responses for the chemicals involved. Essentially, the RMP deals with spills and leaks that affect outside the workplace, while the PSM handles spills and leaks within the workplace.  

Globally Harmonized System

           As mentioned by OSHA, the four major changes made in the Globally Harmonized System were to the hazard classification, labeling, Safety Data Sheets, and information and training. The new Globally Harmonized System has a new way of categorizing hazardous material that the old hazardous materials system did not. In the new system, there are three different ways to categorize hazardous materials. The first way is with the use of symbols. Symbols convey health, physical, and environmental hazard information. They are assigned to a Globally Harmonized System hazard class and category. This is to make it easier to identify the hazardous materials. There are also signal words. Examples of these words are, “danger, or warning.” They are to emphasize the hazards and the relative severity of the danger at hand. The last part of the label system is standard phrases. These are standard phrases are used to quickly convey the hazards of the chemical.

            Hazard classifications are another part of the Globally Harmonized System. The new system has allowed workers to more easily identify chemicals that are hazardous to the worker. In this case, they have updated the classifications of hazards to be more identifiable. The new classifications read as follows: acute toxicity, skin irritation, serious eye damage or eye irritation, respiratory or skin sensitization, germ cell mutagenicity, carcinogenicity, reproductive toxicity, specific target organ toxicity (single or repeated exposure), aspiration hazard.

            There are now 12 mandatory sections and 4 non-mandatory section formats in the Safety Data Sheets as opposed to 8 non-mandatories in the old system. They were originally referred to as the Material Safety Data Sheets but have been shortened to the Safety Data Sheets now. The total 16 sections of the SDSs are listed below per the OSHA QuickCard.  

1. Identification

2. Hazard identification

3. Information on ingredients

4. First-Aid measures

5. Firefighting measures

6. Accidental release measures

7. Handling and storage

8. Personal protection

9. Physical and chemical properties

10. Stability and reactivity

11. Toxicological information

12. Ecological information

13. Disposal considerations

14. Transport information

15. Regulatory information

16. Other information, including date of preparation/revision

Looking at the OSHA Factsheet, as of December 1, 2013, workers have to be trained on the new labels and Safety Data Sheets. On June 1, 2015, chemical manufacturers, importers, distributors, and employers have to be on the same page in regards to all the new changes of the HCS. Essentially, the new regulations makes it so the world has an easier time understanding these Safety Data Sheets regardless of where in the world the Safety Data Sheets are being accessed. This is why it is referred to as the Globally Harmonized System. The point is to make sure that the world is on one system to allow the workers, employers, and average people, to be able to recognize the dangers of the chemicals that they are working with. Some of the new requirements of the new system force the labels to change within 6 months of finding new chemicals or new details of new chemicals.

            According to SDS Online, Hazard Communication moved up from the #3 spot to the #2 spot in 2012 of OSHA’s most used standards. There have been over 42,000 of Hazard Communication violations since 2009.  Overall, the new system has allowed for much more organization and rules pertaining to chemicals and their hazards.

Entering a Toxic Environment - LA Methane Gas Leak

There are many considerations that must be examined before entering a toxic environment.  Due to the nature of many chemicals, sometimes the worst hazards are not seen.  There were suggestions to consider on Working with Chemicals that are relevant to this topic. When entering a toxic environment, the personnel need to identify the hazards, plan ahead, ensure minimal exposure, and be sure not to underestimate the risk.  Many of the chemicals that individuals are exposed to can be inhaled into the respiratory tract or absorbed through the skin which both create risk for the individual.  Other factors that need to be considered include the weather conditions surrounding the environment, the amount of chemical released, and the reactivity of the chemical to other substances.  

If there is a spill or release of a toxic chemical into the environment, there could also be lasting impacts that are still a concern even after the issue has been resolved.  There could be negative impacts on the health of the community, as well as the environment, water and food supply, and even the wildlife within the environment.

In the case of the LA Methane Gas Leak, the time needed for the leak to be fixed also has an affect on how much the leak has impacted the surrounding environment and community.  This concern was talked about in the LA Times where they reported that it took 110 days for the Southern California Gas Company to fix the leak temporarily.  The gas leak affected more than 1,700 homes within the Los Angeles area many of which were evacuated.  From time the leak sprung to when it was fixed, 150 million pounds of methane was released into the air as reported by The Washington Post. The longer the leak was left unfixed, the more hazardous the environment became.  As stated above, many of the worst hazards cannot be seen. 

Applying the concepts above, there are many factors of this gas leak and its location that make the situation worse.  The methane, a highly flammable gas, was first released in October 2016 and during that time in LA the temperature outside is still very warm which affects the plans to fix the leak.  The personal protective equipment needed to protect the personnel while fixing the leak would be very uncomfortable making the job even tougher and reducing the amount of time an employee could be working within the area to fix the leak.   Therefore multiple people will be needed to complete the planned tasks to fixed the leak.  Another concern of this leak involves the reactivity of the methane gas released, creating more of a hazard.  When methane reacts with oxygen in the air, formaldehyde is formed and released.  If the release of methane wasn’t a big enough hazard, the release of formaldehyde increases the risk and concern.  As mentioned above, 150 million pounds of methane was released, which means 150 million pounds of methane reacting with oxygen to form formaldehyde.  Now, this leak has also created a cancer-causing product, on top of the already flammable methane gas, leading to more harm in the community.  Other factors mentioned by the Toxic Industrial Chemicals Guide that apply to entering a toxic environment include training, monitoring, and medical surveillance of those exposed. 

All of these factors need to be considered when entering a toxic environment such as the methane gas leak in LA.  These factors decide how the issue can be fixed quickly and safely.  The biggest point to be learned from this disaster is that we need to learn to better prevent these leaks and emergencies from happening in the first place.  Most of the time we wait for something terrible, like the LA Methane Leak, to occur before we fix the real issue. The best way to fix this leak was to have procedures in place to ensure it doesn’t occur in the first place.