Safe, Efficient, Profitable: A Worker Safety Podcast
Joe and Jen Allen of Allen Safety LLC take their combined 40+ years of worker safety, OSHA, EPA, production, sanitation, and engineering experience in Manufacturing Plants including Harvest Plants/Packers, Case Readies and Further Processing Plants, Food Production Plants, Feed Mills, Grain Elevators, Bakeries, Farms, Feed Lots, and Petro-Chemical and bring you their top methods for identifying risk, preventing injuries, conquering the workload, auditing, managing emergencies and catastrophic events, and working through OSHA citations. They're breaking down real safety opportunities, safety citations, and emergency situations from real locations, and discussing realistic solutions that can actually be implement based on their personal experiences spending 40+ weeks in the field every year since 2001. Joe and Jen are using all of that experience to provide a fresh outlook on worker safety by providing honest, (no sponsors here!) and straight forward, easy to understand safety coaching with actionable guidance to move your safety program forward in a way that provides tangible results.
Safe, Efficient, Profitable: A Worker Safety Podcast
#51: Is That A Confined Space? How To Do Confined Space Evaluations
In this episode, the hosts delve into the complex process of determining whether a space qualifies as confined, unpacking the various factors that must be considered in making this determination. They emphasize that confined space classification is not a straightforward task and requires a comprehensive assessment of several critical elements. Throughout the discussion, the hosts provide insights and anecdotes drawn from their extensive experience in the field of confined space safety.
The episode begins with the hosts addressing the fundamental question: what constitutes a confined space? They highlight the ambiguity surrounding this definition, particularly in terms of limited or restricted egress. Unlike other aspects of safety standards, OSHA does not provide specific measurements for what qualifies as limited or restricted egress, leaving it up to individual companies to determine based on their unique circumstances. The hosts stress the importance of companies carefully evaluating the size of space openings and the ease of entry and exit when making these decisions.
Moving on, the hosts explore the concept of hazard assessment within confined spaces. They discuss the various types of hazards that may be present, including vapor, chemicals, process water, and potential fall hazards. Through anecdotes and examples, they illustrate the importance of thorough hazard identification and mitigation strategies to ensure the safety of workers entering confined spaces.
Another key aspect covered in the episode is the consideration of job tasks performed within confined spaces. The hosts emphasize the importance of understanding the entire life cycle of a space and the specific tasks that workers may need to perform within it. They highlight scenarios where seemingly non-confined spaces may pose risks to workers due to the nature of the tasks performed within them, stressing the need for comprehensive evaluation beyond mere physical dimensions.
Throughout the episode, the hosts address common misconceptions and debates surrounding confined spaces, such as the frequency of entry and labor requirements. They emphasize that safety considerations should always take precedence over convenience or operational concerns, urging companies to prioritize employee well-being above all else.
In conclusion, the hosts advocate for viewing confined space classification as a management tool aimed at enhancing safety rather than a bureaucratic hurdle. They encourage proactive measures, such as implementing engineering controls and leveraging technology, to eliminate the need for entry into confined spaces whenever possible. Ultimately, the goal is zero injuries, and the hosts underscore the importance of adopting a holistic approach to confined space safety to achieve this objective.
Episode Keywords:
Confined space determination process
Confined Space Assessments
1910.146
OSHA Code
Confined Space Rescue
Confined Space Program
Confined Space Training
Confined Space Permit
Confined Space Entrant
Confined Space Attendant
Confined Space Trainer
Confined Space Help
Safety Help
Safety Training
Safety Toolbox Talk
Monthly Safety Training
Supervisor Training
Maintenance Training
Limited or restricted egress definition
Hazard assessment in confined spaces
Types of hazards in confined spaces
Job tasks within confined spaces
Confined space safety standards
Frequency of entry in confined spaces
Prioritizing employee safety
Engineering controls for confined space safety
Proactive confined space safety measures
Confined Space Definition
Confined Space Safety Measures
Confined Space Rescue Plans
Confined Space Meaning
Confined Space Signs
Confined Space Safety Course
Free Safety Help
Free Safety Training
Confined Space Risk Assessment
This week is going to be confined space determination. So how do you decide if something is a confined space, is it not a confined space? Is it a permit required? Confined space.
Speaker 2:All good questions.
Speaker 1:All good questions, so let's dive in.
Speaker 2:Here we go, Okay. So I'm walking out there and I look at everything. I'm like I think it's confined space. You don't think it's confined space?
Speaker 1:I don't think so there we go, there we go.
Speaker 2:There's the star. That's how it starts right there, Everywhere we go, it starts like that. So we thought you know what? Let's do an episode breaking that down.
Speaker 1:All right. So the first one is just going to be kind of deciding is it limited or restricted egress first. So is it a person door, an exit size door, or is it a small hatch? What are we working with?
Speaker 2:or somewhere in between, because we get asked all the time. People read the standard. Yeah, they say, well, it says this, what?
Speaker 1:does limited or restricted mean, and that's one of the biggest things OSHA does not give us a definition of what that means in terms of inches or feet of the size of the space opening. So that's the first thing is you've got to decide that, as a company is what are you going to consider that? Is it either a full exit size door or it's?
Speaker 2:somewhere you take an air makeup unit, they're all different kinds of doors. Condensers all different kinds of doors yeah. Dancers different kinds of doors. Spiral chillers different kinds of doors.
Speaker 1:Yeah, you got to break that down so you've got to first decide that does it have this sloping floors, you know? Can you get in it? Is it big enough to to get your body in there or not, and is it meant for you to basically camp out in there?
Speaker 2:like this. Can you do a podcast in there?
Speaker 1:Yep, Can you work in there? Is it normal work environment where everything is fine to just be in there? It's just what's going on inside that space.
Speaker 2:You say, no, it's got a lot of ammonium product. Well, guess what?
Speaker 1:Guess what. So that's the first question is you've got to decide as a company, size opening. What are you going to call a space or not, and kind of work through that. And what are you going to call a space or not, and kind of work through that. And then, the biggest thing that you want to keep in mind when you're looking at limited or restricted egress can you get in it? Does it have the slopey floors? How hard is it going to be to get the person out?
Speaker 1:that's the first thing I look at if they have a problem of any kind could be medical, could be something else is is it going to be a problem? And I think one of the biggest things you could do during your annual tours with the fire department, ask them.
Speaker 2:Yeah, do you think would you go in there and get the person out of there? No, he thinks confined space. Well, guess what?
Speaker 1:yeah, or your ambulance crews for that matter. Would an ambulance crew, an emt crew, go in and treat a person that's had an issue in that space? And if they're like, no, because your emts they don't generally, for the ambulance crews have confined space training won't go in. They want the person to come to them.
Speaker 2:No one has ever wrote on a permit. I will have a medical condition while I'm in there, so we have to plan for it.
Speaker 1:Yes.
Speaker 2:So that's where you look at it.
Speaker 1:All right. So that's the first thing. The next thing we're going to work through is what is going to it is what is going to it.
Speaker 2:So do we have vapor or?
Speaker 1:chemical or process water or anything like that, piped to going to it Some kind of product, something flowing in grain? Is it coming from above? What does that look like? Is it steam? What's happening inside that space? What are the hazards? You're also going to be looking at things like is there a fall hazard?
Speaker 2:Yeah it could be a 10 foot drop.
Speaker 1:Yeah. And people say Perfect space, but if it has a flat ladder entry and it's a huge drop of 10 feet or something, well, that's, that goes back to my limit.
Speaker 2:It's still hard to get out of this.
Speaker 1:Yeah. So, and just to let you know, you can go back to episode 12 and 13 and kind of reference some of the stuff. And again, this is just our opinion. This is basically we do can find space for a living shirt. That's one of the things that we train on. We've done a lot of entries, we've been there for rescues, we've been there for problems and some things.
Speaker 1:So I mean, I don't know, we probably do a couple thousand rescues and entries during our drills every year, and then we've been there for live projects and stuff where they're doing them live. So this is just our opinion.
Speaker 2:Take it how you want our daily life, yes, so all right.
Speaker 1:So then the next thing we're going to want to break down is what is the job task that the person is going to be doing inside that space you want?
Speaker 2:to consider that, because some people say it's not a confined space, but actually at 10 o'clock it is at night.
Speaker 1:Yep. So the person that you're working with when you're doing these confined space determinations, you want to make sure that they know the entire life cycle of that space, what's happening and what do we have to do. We have to go in there and PM some stuff quarterly or do swabs or enter in every hour.
Speaker 2:I just did a call and they talked about they got to go in and clean out a condenser. So what are they going to lock out and what are they not? But it's the cleaning is what they had the questions about. It wasn't about if it's a space or not.
Speaker 1:The cleaning is where all the questions are coming from. Yep, you're starting to introduce additional hazards at that point. That's one of the questions that you may have Now. If you have additional questions beyond what this covers again episode 12 and 13, or if you're looking for really in-depth stuff, you can go to allensafetycoachingcom, our only sponsor, our only sponsor, allensafetycoachingcom.
Speaker 1:I've got an entire confined space module on how to manage all of this, from doing the determinations, doing the assessments, all the way through how to structure your permit, what should be in it, the training, the program, all of it so you can get more data on there if you're looking for that. So the last one that I have is why would we not want to classify something as a space?
Speaker 2:Because we usually get a lot of pushback when we say that's a confined space. Once we say those words, I mean like the pushback I'll ask sometimes before I go well, they'll say can you send a bid? You know, like what do you want me to do? Right, confined space says how many space you got. We got 12, I get there, they got 52 of them yeah, or 200 yeah how did you get to 12? But it comes down to what she's going to say they, they don't believe it is for certain reasons.
Speaker 1:Yeah, so the biggest one hands down is going to have to do with the labor piece and how often we're entering it.
Speaker 2:Yep, we go in daily.
Speaker 1:Yep. So it's amazing how we have to do something daily, hourly. Somehow that negates everything that we just talked about, because we have to do it all the time and we can't be taking that offline every day or every hour. We can't be doing a permit.
Speaker 2:How much downtime, and it's like I mean the permit takes at least two minutes a day to fill out.
Speaker 1:So, but it doesn't negate all these things that we just talked about, and that's where you want to stay focused when you're doing your determinations. Frequency doesn't have anything to do with whether it's a space, and if you have to do it on a Saturday and pay overtime, that doesn't have anything to do with it either. So those are the two biggest pushbacks that we generally see a location have to work through when they're working on is this a space or is it not Training? We don't want to have to do all that. We want to train all those people. We don't want to have to train food safety, even though they're going in the spiral all the time.
Speaker 2:We don't want to do that.
Speaker 1:We don't want to have to buy all the gear, the equipment, the meters and calibration of those and CalGas. We don't want to do all that. We don't want to fill out a permit. We don't want to have a permit. We don't want to do all that. We don't want to have to have rescue.
Speaker 2:It's going to take days, but it's not. That's the point. So what happens is people they almost like start adding up. It's going to take three months to get all this done.
Speaker 1:So it's not a space You're like no, it takes a few hours and you're fine for the whole year. Yeah, so the amount of time that it takes to now, if we say this is a space, now we got to do all this stuff. We got to have a program, we got to have a program we got to develop all these things.
Speaker 2:Yes.
Speaker 1:That doesn't negate it was always a space.
Speaker 2:It was always a hazard.
Speaker 1:You should have maybe always been doing these things, and the fact that we haven't done them yet doesn't mean that it's not a space, and that there aren't hazards in putting the employee at risk potentially. So the biggest thing that I would encourage you to do is reframe this and look at it as confined space, and utilizing a permit is a management tool.
Speaker 1:It shouldn't be viewed as a negative. Remember, our goal is zero injuries. So how do we manage zero injuries If we know that we've got some of these hazards going on? It could be hard to get them out of the space.
Speaker 2:Because if I'm going to break the plane, Yep. And somebody says it is a space or not a space. The management tool helps decide those problems.
Speaker 1:It helps make sure and part of the management tool could be.
Speaker 2:Do I even need to be breaking the plane?
Speaker 1:Do I need to be breaking the plane? It's going to help me figure out what kind of PPE do I need. It's going to help me determine where should someone be, so that I can yell hey, I'm having a problem in here, I need some help. There's someone there. There's somebody on standby. There's somebody right outside the space. I've got gas meters where maybe I wouldn't have them if I said that it wasn't a space, so it's putting buffers in place just to make sure we don't have a problem.
Speaker 2:It's an insurance policy Because I got a weird one, so big, big trash dumpsters Yep, got them at the plants, got them at the housework. Empty a big door at the end, open them up. I don't call them confined space at all. You close the end and you fill it with a whole bunch of busted pallets and everything else with nails, and now somebody tries to climb in there to get something out. Now the edge is so high up, it's so full. How do you get them out if they get an injury? Now I will call that a confined space because it's a management tool. Don't go in there, cause we say in awareness training don't go anywhere. That has a sign.
Speaker 1:Yep. So for those of you who are in food plants, we're just going to run down a list really quickly of the, the spaces the most debated, and, and we'll give you our opinion at the very end.
Speaker 2:Are you doing number one? Am I doing number one?
Speaker 1:Go ahead.
Speaker 2:Tumblers.
Speaker 1:Tumblers, tumblers.
Speaker 2:We have a lot of people talking about those.
Speaker 1:Yep Tumblers, I would say condensing towers.
Speaker 2:Yes, absolutely, I've got one. It's called a spiral.
Speaker 1:A spiral freezer.
Speaker 2:Spiral freezer. Yep, because they have big doors, you go all the way up and all the way back and underneath.
Speaker 1:Yep, and it's got a big door, so sometimes we have's another one that's interesting another one is mixers mixer blenders well, it's only five foot deep yeah but you have to crawl all the way in there to repair the paddles yep, you do
Speaker 1:so we actually weld on the paddles and you know just I'll give this away how you know if your maintenance team is welding on the paddles, look at it during sanitation the one that everyone complains about with the doors is the air makeup units air makeup units. We got to change filters. Yep, so that entire list.
Speaker 2:And there's you need to go through as a company or decide, and break down how do you get a manager?
Speaker 1:a disclaimer. Again, this is just my opinion, but I'm gonna tell you right now yeah, in your opinion.
Speaker 1:I'm gonna tell you right now all those are spaces in my world because, typically speaking, we haven't put other engineering controls in place and so most of the time when I see them and I walk up on them, they're spaces and someone's got to have a really strong argument for me to be like I agree, those are not spaces. So, typically speaking, I would look at those when you go out and evaluate your site as they are first and then try and figure out how are they not?
Speaker 2:because we've had people have 400 spaces and agree to 392 of them, but not these four.
Speaker 1:Yes, yes yes, it's, interesting how. These are the ones so what I would also encourage you to do. Last thing before we end here is if frequency is one of the big things, or labor is one of the big things, or you don't want to call these a confined space, find an engineering control. Reconfigure it. Find out a way to not have to break the plane and not have to go in. Look at technology. What can we do and how do we make it so that we're not putting the employee at risk?
Speaker 2:because the goal is what? Yeah, no injuries that's the goal, no matter what.
Speaker 1:All the other stuff is just stuff so how do we make sure the employee is not being put in harm's way and that we've got management tools and we've got some different things that are permanently in place so that we don't have to do it? So instead of saying it's not a space, let's put something in place so that we don't even have to do that job task we find a different way, absolutely.
Speaker 2:I think we're almost done on this one.
Speaker 1:We are Again. You can catch us on social media. Allen Safety LLC is our handle. Joe Allen, jen Allen.
Speaker 2:Apple Podcasts, Spotify, YouTube, Facebook. I mean, how many things we got.
Speaker 1:Now you can listen to us offline if you want, on the podcast side, if YouTube doesn't work for you and yeah, you can catch us on LinkedIn. And other than that, we'll catch you next time. Thanks, everybody, and have a great week. Thank you for listening to safe, efficient, profitable a worker safety podcast. If you're looking for more in-depth discussions or step-by-step solutions on all of the different safety and regulatory topics, please visit us at wwwallensafetycoachingcom for web-based virtual coaching and training, or at wwwallen-safetycom to book our team for onsite services, training sessions, to order merchandise, to learn more about our team and what services we provide in the field, or just simply to request a topic for us to cover on our next podcast. If you found today's podcast helpful and would like to support our podcast further, please help us by subscribing, liking and sharing this podcast with anyone that could benefit from the information we cover here, as that helps us to continue to put out this free content. Thank you.
