0:00

This week is going to be confined space determination

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. So how do you decide if something

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is a confined space , is it

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not a confined space ? Is it a permit required

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? Confined space .

0:09

All good questions .

0:10

All good questions , so let's dive in

0:12

.

0:12

Here we go , Okay

0:29

. So I'm walking out there and

0:31

I look at everything . I'm like I think it's

0:33

confined space . You don't think it's confined space

0:35

?

0:35

I don't think so there we go , there we go .

0:38

There's the star . That's how it starts right there , Everywhere

0:40

we go , it starts like that . So

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we thought you know what ? Let's do an episode breaking that down

0:44

.

0:45

All right . So the first one is

0:47

just going to be kind of deciding is it limited or

0:49

restricted egress first . So is

0:51

it a person door , an exit size

0:53

door , or is it a small hatch ? What

0:55

are we working with ?

0:56

or somewhere in between , because we get asked all the time

0:58

. People read the standard . Yeah , they say , well

1:00

, it says this , what ?

1:01

does limited or restricted mean , and that's one

1:03

of the biggest things OSHA does not give

1:05

us a definition of what that means in terms

1:07

of inches or feet

1:10

of the size of the

1:12

space opening . So that's

1:14

the first thing is you've got to decide

1:16

that , as a company is what are you going to consider

1:18

that ? Is it either a full exit size door

1:21

or it's ?

1:21

somewhere you take an air makeup unit , they're all

1:23

different kinds of doors . Condensers all different

1:25

kinds of doors yeah . Dancers different kinds

1:27

of doors . Spiral chillers different kinds of doors .

1:28

Yeah , you got to break that down so you've got to first decide that

1:31

does it have this sloping floors

1:33

, you know ? Can you get in it ? Is it big enough

1:35

to to get your body in there or not

1:37

, and is it meant for you to basically

1:40

camp out in there ?

1:41

like this . Can you do a podcast in there ?

1:42

Yep , Can you work in there ? Is it normal

1:45

work environment where everything

1:47

is fine to just be in there ? It's just

1:50

what's going on inside that space .

1:52

You say , no , it's got a lot of ammonium product

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. Well , guess what ?

1:55

Guess what . So that's the first question is

1:57

you've got to decide as a company , size

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opening . What are you going to call

2:01

a space or not , and kind of work through that . And what

2:03

are you going to call a space or not , and kind of work through that . And then , the biggest thing

2:05

that you want to keep in mind when you're looking at limited or restricted

2:07

egress can you get in it ? Does it have the slopey floors

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? How hard is it going to be to get the person out ? that's

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the first thing I look at if they have a problem

2:14

of any kind could be medical

2:16

, could be something else is

2:18

is it going to be a problem ? And I think one of the biggest things

2:20

you could do during your annual tours

2:22

with the fire department , ask them .

2:25

Yeah , do you think would you go

2:27

in there and get the person out of there ? No , he thinks confined

2:29

space . Well , guess what ?

2:30

yeah , or your ambulance crews for that matter . Would

2:32

an ambulance crew , an emt crew , go

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in and treat a person that's had

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an issue in that space ? And if they're like

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, no , because your emts they don't generally

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, for the ambulance crews have confined space training

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won't go in . They want the person to come to them

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.

2:46

No one has ever wrote on a permit . I

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will have a medical condition while I'm in there , so

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we have to plan for it .

2:54

Yes .

2:55

So that's where you look at it .

2:56

All right . So that's the first thing . The

2:58

next thing we're going to work through is what

3:00

is going to it is

3:08

what is going to it .

3:09

So do we have vapor or ?

3:09

chemical or process water or anything like that , piped to going to it Some kind of

3:11

product , something flowing in grain ? Is it coming

3:14

from above ? What does that look like ? Is it steam

3:16

? What's happening inside that space

3:18

? What are the hazards ? You're also going to be

3:20

looking at things like is there a fall hazard

3:22

?

3:23

Yeah it could be a 10 foot drop

3:25

.

3:26

Yeah . And people say Perfect space , but

3:28

if it has a flat ladder entry and

3:31

it's a huge drop of 10 feet or

3:33

something , well , that's , that goes back to my limit

3:35

.

3:35

It's still hard to get out of this .

3:36

Yeah . So , and just to let

3:39

you know , you can go back to episode 12 and 13

3:41

and kind of reference some of the stuff . And again , this is just our

3:43

opinion . This

3:50

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

3:52

been there for rescues , we've been there for problems and some things . So I mean , I don't know , we probably do a couple

3:54

thousand rescues and entries during our drills every

3:57

year , and then we've been there for live projects and stuff where they're

3:59

doing them live . So this

4:01

is just our opinion .

4:02

Take it how you want our daily life , yes , so

4:05

all right .

4:05

So then the next thing we're going to want to break down is

4:08

what is the job task that the

4:10

person is going to be doing inside that space you

4:12

want ?

4:12

to consider that , because some people say it's not a confined

4:14

space , but actually at 10 o'clock

4:16

it is at night .

4:18

Yep . So the person that you're working

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with when you're doing these confined

4:22

space determinations , you want to make sure that they

4:24

know the entire

4:26

life cycle of that space , what's

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happening and what do we have to do . We have to go in

4:31

there and PM some stuff quarterly or do

4:33

swabs or enter in every hour

4:35

.

4:35

I just did a call and they talked about they got to go in and clean

4:37

out a condenser . So

4:40

what are they going to lock out and what are they not ? But it's the

4:42

cleaning is what they had the questions about . It wasn't about if

4:44

it's a space or not .

4:49

The cleaning is where all the questions are coming from . Yep , you're starting to introduce additional hazards

4:51

at that point . That's one of the questions that you may have Now . If you have additional

4:53

questions beyond what this covers again episode

4:55

12 and 13 , or if you're looking for

4:58

really in-depth stuff , you

5:02

can go to allensafetycoachingcom , our only sponsor , our only sponsor , allensafetycoachingcom

5:04

. I've got an entire confined space module

5:06

on how to manage all of this , from

5:08

doing the determinations , doing

5:11

the assessments , all the way through how to structure your

5:13

permit , what should be in it , the training , the

5:15

program , all of it so you can get more data on there if you're

5:17

looking for that . So the last

5:19

one that I have is why

5:21

would we not want to classify

5:23

something as a space ?

5:24

Because we usually get a lot of pushback when

5:26

we say that's a confined space . Once

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we say those words , I mean like the

5:30

pushback I'll ask sometimes

5:32

before I go well , they'll say can you

5:34

send a bid ? You know , like what do you want me to do ? Right

5:36

, confined space says how many space you got . We got 12

5:38

, I get there , they got 52 of them yeah , or

5:41

200 yeah how did you get to 12

5:43

? But it comes down to what she's going to say they , they

5:45

don't believe it is for certain

5:47

reasons .

5:48

Yeah , so the biggest one

5:50

hands down is

5:52

going to have to do with the labor piece

5:55

and how often we're entering

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it .

5:57

Yep , we go in daily .

5:59

Yep . So it's amazing how we

6:01

have to do something daily , hourly

6:04

. Somehow that negates everything that we

6:06

just talked about , because we have to do it all the time

6:08

and we can't be taking that offline every day

6:10

or every hour . We can't be doing a permit .

6:12

How much downtime , and it's like I mean the permit

6:14

takes at least two minutes a day to fill out .

6:16

So , but it doesn't negate all these

6:18

things that we just talked about , and that's where you want

6:20

to stay focused when you're doing your determinations

6:23

. Frequency doesn't have anything to do with

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whether it's a space , and if

6:27

you have to do it on a Saturday and pay overtime

6:30

, that doesn't have anything to do with it either . So

6:32

those are the two biggest pushbacks

6:35

that we generally see a location have

6:37

to work through when they're working on

6:39

is this a space or is it not Training

6:41

? We don't want to have to do all that . We want to train all those people

6:44

. We don't want to have to train food safety , even though they're

6:46

going in the spiral all the time .

6:47

We don't want to do that .

6:48

We don't want to have to buy all the gear , the equipment

6:51

, the meters and calibration of

6:53

those and CalGas . We don't want to do all

6:55

that . We don't want to fill out a permit . We don't want to have a permit

6:57

. We don't want to do all that . We don't want to have to have rescue

7:00

.

7:00

It's going to take

7:03

days , but it's not . That's

7:05

the point . So what happens is people they

7:08

almost like start adding up . It's going to take three

7:10

months to get all this done .

7:11

So it's not a space You're

7:13

like no , it takes a few hours

7:16

and you're fine for the whole year . Yeah , so

7:18

the amount of time that it takes

7:20

to now , if we say this is a space , now

7:22

we got to do all this stuff . We got to have a program , we got to have a program

7:24

we got to develop all these things .

7:25

Yes .

7:26

That doesn't negate it was always a space

7:28

.

7:29

It was always a hazard .

7:29

You should have maybe always been doing these things , and

7:31

the fact that we haven't done them yet doesn't

7:34

mean that it's not a space , and

7:36

that there aren't hazards in putting the employee at

7:38

risk potentially . So the

7:40

biggest thing that I would encourage

7:43

you to do is reframe this

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and look at it as confined space

7:47

, and utilizing a permit is a management

7:50

tool . It shouldn't be viewed

7:52

as a negative . Remember , our goal is zero

7:54

injuries . So how do we manage zero

7:56

injuries If we know that we've

7:58

got some of these hazards going on ? It could be hard

8:00

to get them out of the space .

8:02

Because if I'm going to break the plane , Yep

8:04

. And somebody says it is a space

8:06

or not a space . The management tool helps

8:08

decide those problems .

8:10

It helps make sure and part of the management tool could be .

8:12

Do I even need to be breaking the plane ?

8:14

Do I need to be breaking the plane ? It's going to help

8:16

me figure out what kind of PPE do I

8:18

need . It's going to help me determine where

8:20

should someone be , so that I can yell

8:22

hey , I'm having a problem in here , I need some help . There's

8:25

someone there . There's somebody on standby . There's somebody

8:27

right outside the space . I've got gas meters

8:29

where maybe I wouldn't have them if I said that it wasn't

8:31

a space , so it's putting buffers

8:33

in place just to make sure

8:35

we don't have a problem .

8:36

It's an insurance policy Because I got a weird one , so

8:39

big , big trash dumpsters Yep

8:41

, got them at the plants , got them at the housework

8:44

. Empty a big door

8:46

at the end , open them up . I don't call them confined

8:48

space at all . You

8:53

close the end and you fill it with a whole bunch of busted pallets and everything

8:55

else with nails , and now somebody tries to climb in there to get something out

8:57

. Now the edge is so high up , it's

8:59

so full . How do you get them out if they get

9:01

an injury ? Now I will call that a confined

9:03

space because it's a management

9:06

tool . Don't go in there , cause we say in awareness

9:08

training don't go anywhere . That has a sign

9:10

.

9:10

Yep . So for those of you

9:13

who are in food plants , we're just going to run down a

9:15

list really quickly of the , the

9:17

spaces the most debated

9:19

, and , and we'll give you our opinion at the very

9:22

end .

9:22

Are you doing number one ? Am I doing number one ?

9:24

Go ahead .

9:24

Tumblers .

9:25

Tumblers , tumblers .

9:26

We have a lot of people talking about those .

9:28

Yep Tumblers , I would say condensing

9:30

towers .

9:31

Yes , absolutely , I've got one . It's called

9:33

a spiral

9:35

.

9:36

A spiral freezer .

9:37

Spiral freezer . Yep , because they have big doors , you

9:39

go all the way up and all the way back

9:41

and underneath .

9:43

Yep , and it's got a big door , so sometimes we

9:45

have's another one that's interesting another one

9:47

is mixers mixer blenders well

9:49

, it's only five foot deep yeah

9:51

but you have to crawl all the way in there to

9:53

repair the paddles yep , you do so

9:56

we actually weld on the paddles and you know just

9:58

I'll give this away how you know if

10:00

your maintenance team is welding on the paddles

10:02

, look at it during sanitation the one

10:04

that everyone complains about with the doors

10:07

is the air makeup units air makeup units . We got

10:09

to change filters . Yep , so

10:11

that entire list .

10:12

And there's you need to go through as a company or

10:14

decide , and break down how do you get a manager

10:17

?

10:17

a disclaimer . Again , this is just my

10:19

opinion , but I'm gonna tell you right now yeah

10:21

, in your opinion . I'm gonna tell you right now all those are spaces in

10:23

my world because , typically

10:26

speaking , we haven't put other engineering

10:28

controls in place and

10:30

so most of the time when I see

10:32

them and I walk up on them , they're spaces and

10:35

someone's got to have a really strong argument

10:37

for me to be like I agree , those are not

10:39

spaces . So , typically speaking , I

10:41

would look at those when you go out and evaluate

10:43

your site as they are first and

10:46

then try and figure out how

10:48

are they not ?

10:49

because we've had people have 400

10:51

spaces and agree to 392

10:54

of them , but not these four .

10:55

Yes , yes yes , it's , interesting how

10:58

. These are the ones so what I would also

11:00

encourage you to do . Last thing before we end here is

11:02

if frequency is one of the

11:04

big things , or labor is one of the big things

11:06

, or you don't want to call these a confined space

11:08

, find an engineering control . Reconfigure

11:11

it . Find out a way to not have to break the

11:13

plane and not have to go in . Look at technology

11:15

. What can we do and how do we make it so

11:17

that we're not putting the employee at

11:20

risk ?

11:20

because the goal is what ? Yeah , no injuries

11:22

that's the goal , no matter what .

11:23

All the other stuff is just stuff so

11:26

how do we make sure the employee is not being

11:28

put in harm's way and that we've got management

11:30

tools and we've got some different things that are permanently in

11:32

place so that we don't have to do

11:34

it ? So instead of saying it's not a space , let's put something

11:37

in place so that we don't even have to do that job task

11:39

we find a different way , absolutely .

11:40

I think we're almost done on this one .

11:42

We are Again . You can catch us

11:44

on social media . Allen Safety LLC is our handle

11:47

. Joe Allen , jen Allen .

11:48

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11:50

, Facebook . I mean

11:52

, how many things we got .

11:53

Now you can listen to us offline if you want

11:55

, on the podcast side , if YouTube doesn't work for you

11:57

and yeah , you can catch

12:00

us on LinkedIn . And other than that

12:02

, we'll catch you next time . Thanks

12:05

, everybody , and have a great week . Thank you for listening to safe , efficient , profitable

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