Confined Space: When Air Testing Before Entry is Impractical

A client recently called me with a question. At his facility there was a confined space (a large vault) that they wanted to enter using alternate entry procedures (also known as reclassifying the space). Issues such as these are routinely addressed in our Confined Space Train the Trainer classes. Over the years his crews had entered the vault many times and had never encountered a hazardous atmosphere, nor had work activities ever created … [Read more...]

Jim Johnson July 20, 2017
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Confined Space Attendant and Fall Protection

Consider for a moment the issue of fall protection and the confined space attendant overseeing entry operations for workers in a vault or manhole (top down entry). A question I often ask our students is: "Does the confined space attendant need to be tied off?" That is, if the fall hazard is greater than four feet (which it almost always is), does OSHA require the attendant to use some sort of fall protection? In this imaginary scenario we need … [Read more...]

Jim Johnson October 18, 2016
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Confined Space Safety Best Practice: What to Include in the Inventory

One of the challenges in administering a confined space safety program is deciding which spaces to include in your inventory. The simple answer is to just include those spaces that meet the definition of a permit space*, but is this a confined space safety best practice? My sense is that it may not be. In fact, I believe that when you’re deciding which spaces to place under the confined space program, you should consider putting aside OSHA’s … [Read more...]

Jim Johnson June 29, 2016
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Fall Hazards and Permit-Required Confined Spaces

Does the presence of a fall hazard turn a confined space into a permit space? When Oregon re-wrote its confined space rules last year one issue of interest among those attending the stakeholder's meeting hosted by OROSHA, was the question of fall hazards and permit spaces. In other words, if you had a pit twenty feet deep and the only hazard was posed by using a fixed ladder to enter this pit, would the fall hazard be serious enough to make the … [Read more...]

Jim Johnson January 7, 2016
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Confined Space Reclassification: Facts and Myths

Few topics elicit as much confusion as the reclassification of permit-required confined spaces, also referred to (more appropriately as using alternate entry procedures). People want to know if we should control hazards or eliminate them? Or both? Can we weld or grind in a reclassified space? Can we permanently reclassify? What are the benefits? Can I reclassify if there's a fall hazard? Anyone responsible for developing or maintaining a confined … [Read more...]

Jim Johnson November 6, 2015
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Confined Space Rescue: Justifying your Team.

When you are asked the question: Is it worth having a rescue team? Keep the following in mind. Incipient: adjective Definition: in an initial stage; beginning to happen or develop. Common sense dictates that most employees should be able to respond appropriately to an incipient fire. Alarms and extinguishers have saved countless billions in damages and few would argue against spending money to ensure a safe and effective response in the … [Read more...]

Jim Johnson November 6, 2015
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Confined Space Train the Trainer UPDATED!

For the last five or so years we have enjoyed considerable success with Version 3 of our Confined Space Entrant, Attendant, and Entry Supervisor curriculum. Nonetheless, we are excited to release Version 4.  On July 14-15, 2015 in Medford, Oregon we will be holding our first train-the-trainer seminar using Version 4 of our confined space training materials. This class is being held in association with the Southern Oregon Chapter of the ASSE … [Read more...]

Jim Johnson November 6, 2015
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Construction Confined Space Rules: Updated

In both Oregon and nationally we have seen changes to the rules governing entry into confined spaces. On May 4th Federal OSHA released 1926.1201 "Confined Spaces in Construction". Earlier this year OROSHA published OAR 437-002-0146 which covers general industry and construction activities. None of the changes have anything to do with how we identify, evaluate, and safely enter into confined spaces. But there are important changes to the … [Read more...]

Jim Johnson May 28, 2015
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Wind Turbine Safety Standards: Adequate or Not?

Are Wind Turbine Safety Standards Adequate? Last Sunday while skimming the business section of our local newspaper (Eugene's Register Guard), I came across an article on training wind turbine workers so that they can avoid accidents and injuries. A key point in the article was the problem with existing wind turbine safety standards. The  writer, Tiffany Hsu,  asserted that: "Watchdog groups say a hodgepodge of state and federal renewable … [Read more...]

Jim Johnson July 9, 2014
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Intrinsically Safe Classifications

Certain jobs often call for “intrinsically safe” or “explosion-proof” tools and equipment such as lighting and radios. The purpose of this requirement is ensuring that our equipment doesn’t create a source of ignition which in turn could ignite vapors, dusts, mists, or fibers in the atmosphere. There are several classes of intrinsically safe equipment which have been tested and rated by Underwriter’s Laboratories (UL) and they are broken down … [Read more...]

Jim Johnson April 17, 2014
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