July 18th, 2018, A 46-year-old man’s life was taken in an industrial accident. The worker was in a crawl space performing maintenance on a boiler system at Emerson Hospital in Concord, MA. Police and fire fighters responded to a 911 call around 11:30am. (LowellSun.com)
Our thoughts go out to the worker’s family, friends, and co-workers. This is a tragic incident that no one expects to occur.
When a tragic incident occurs a root-cause analysis must be performed. OSHA is currently the leader for this root-cause investigation. OSHA will be thorough and detailed, but this unfortunately results in a lengthy timeline for published findings.
As safety professionals, when we read the various news articles we do not know the exact details around this terrible industrial accident. However, we do know that there is an elevated hazard identified in this specific scope of work. In this article, JLN wants to identify the hazards of this type of work and try to bring reality into the vision of the reader while the incident is fresh in your mind. If this article prevents even just one near-miss, it was worth it.
When you read “crawl space” do you think of a confined space?
You should.
The OSHA standard 1910.146 definition of a “confined space” is as follows:
- Is large enough and so configured that a person can bodily enter and perform assigned work
- Has limited or restricted means for entry and exit
- Is not designed for continuous employee occupancy
Given this criterion, most every crawl space is going to be classified as a confined space. It is seen as a normal and regular industrial practice to go into these crawl spaces to perform maintenance. So why is it not seen as normal or regular industrial practice to check for a hazardous atmosphere? Are the individuals not trained? Or do they simply not realize the potential hazards based on type, configuration, and environment?
Given the worker’s environment, there is good chance there may have been additional hazards inside of the confined space. This would be identified as a permit required confined space. Further standard requirements necessitate the implementation of additional controls to make entry safe. The OSHA standard 1910.146 definition of a “permit required confined space” is as follows:
- Contains or has potential to contain a hazardous atmosphere
- Contains a material that has the potential for engulfing an entrant
- Has an internal configuration that might cause an entrant to be trapped or asphyxiated by inwardly converging walls of a floor which slopes downwards and tapers to a smaller cross section
- Contains any other recognized serious safety or health hazards
Specifically, during maintenance of boilers, there a few safety concerns that might fit into the category of a permit required confined space.
- Boilers have some type of burner in the near vicinity of the unit. Combustion of a fuel oil produces carbon monoxide; carbon monoxide displaces oxygen in the blood. Is the machine offline? Are there any leaks near the exhaust?
- Boilers have water running through them. How much? Is it enough to fill the working location if a pipe failure occurred?
- Does the crawl space taper or slope? Could someone become trapped?
- Did the unit just come offline? Is it still extremely hot?
The worker and those helping him in the maintenance task need to further evaluate on these topics to ensure a safe working environment in that confined space. The procedure and evaluation need to be executed 100% correctly every single entry. If they are not followed or completed 100% correct, the potential for an incident to occur has become possible.
JLN Associates has a diverse group of industrial safety specialists with a vast amount of knowledge in every aspect of safety. There is one topic the entire group is very well-versed in: work and OSHA standard requirements in confined spaces. We have performed numerous rescue services, trainings, and practices to a large number of clients throughout different industries.
100% of the time, the client takes away at least one important principle or practice that allows them to go about their work in a safer manner.https://www.safejln.com/contact/
To break down the reality of the hazard(s) to the simplest of terms and shortest amount of text is a statement below:
Our respiratory system is an incredible system. It protects us 24/7 from daily exposures to harmful irritants and bacteria. However, our respiratory system cannot solely protect us from the potential dangers inside of a confined space. You cannot see most hazardous atmospheres. You cannot smell most hazardous atmospheres. If you even get the opportunity to comprehend you are receiving a exposure, chances are it is too late. A four or five-gas meter, your training, and your judgment are the only tools you have to protect yourself from the dangers of a confined space.
Please re-read the statement and realize the potential severity.
Think about an experience where you knew something wasn’t right. Think about an experience where you worked with someone that took the chance. It was uncomfortable and left you with an uneasy feeling. That is a feeling you need to act on. You cannot gamble with the atmosphere inside a confined space. There is no minor injury. You may get lucky or you may receive severe injury or death when procedure and practices are not followed. You are gambling with your life. Follow procedure and practice.
If you have any questions regarding confined space entry or any safety topic, feel free to contact JLN Associates anytime for free consultation at (860) 723-3556. We will work together to keep you and your crew safe.
Thank you,
Josh Ierna
Online tools to use and/or reference:
Confined Space OSHA Standard
OSHA Confined Space Guide
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