Confined spaces refer to enclosed areas deemed dangerous due to limited access. These may be a storage tank or a pipe, anything that workers may work in or enter for maintenance that is not a habitable space. Confined spaces are made more dangerous by the hazards associated with them, including suffocation, submersion, entrapment, engulfment, etc. Knowing about confined spaces and their hazards is important because many confined space deaths are preventable. Unfortunately, too many of these are untrained rescuers going in after the original entrant unknowing of the hazards in the confined space and succumb to the same hazard(s) as the person they went in to help.

In fact, most multi-death fatal incidents involve one or more would-be rescuers who are improperly trained and equipped to rescue the original victim.

OSHA defines a confined space as:

1. Being large enough for an employee to enter and perform work,

2. Has limited or restricted means for entry or exit,

3. Is not designed for continuous occupancy.

   
   

A permit required confined space will contain all of the above, plus one or more of the following:

• A potentially hazardous atmosphere

• A substance that has the ability to engulf or asphyxiate the entrant

• Inwardly converging walls within the space or a floor the slopes downward, tapering to a small cross-section

• Contains any other serious safety or health hazard

A confined space attendant provides entrants protection during their time in a confined space. A confined space attendant is an optional service anytime an employee goes into a confined space, however in the event of a permit-required confined space, a confined space attendant is mandatory. A confined space attendant is a very integral part of the safety of the entrant and works as part of the confined space team, whom all have responsibilities to secure the safety of the team.
 

Confined Space Attendants’ Responsibilities

There are a few very important things that confined space attendants are responsible for. First and foremost, there must be at least one authorized attendant present at all times. The attendant controls access to the confined space. The duties of the attendant include testing the atmosphere of the confined space and periodically testing it again or continually monitoring it for any possible changes in the atmosphere. You must never enter a confined space if the atmospheric conditions are not suitable. They must also review and follow all permit procedures in a permit-required confined space. If a confined space attendant sees a hazard that is correctable, they will correct said hazard in a quick, safe, and efficient way. They will summon emergency assistance as needed. In the event that they are unable to correct a hazard, they will report the supervisor those hazards. If an attendant must never abandon his post for any reason while personnel are in the confined spaces unless relieved by another qualified attendant. Lastly, an attendant should keep records of confined space work, such as air test results, personnel entry/exit, etc.

Obviously, the attendant has the responsibility to keep the entrant safe from harm while they are working in the confined space, but an entrants and supervisors have their own responsibilities while working in/around a confined space.
 

Entrant Responsibilities

• To assure that the space has been adequately ventilated, isolated, emptied, or otherwise made safe for entry.
• To immediately exit a space, without question, upon word of the attendant, no matter what the reason.
• To follow all safety rules and procedures.
  • To be familiar with the work to be performed and the procedures.
  • To use the appropriate PPE whenever necessary.
     

Supervisor Responsibilities

• To assure adequate protection is provided to the entrants by verifying adequate lockout/tagout and that all hazards are isolated, controlled or eliminated.
• To support the attendant’s authority in controlling access to a confined space.
• To verify that all personnel have exited prior to closing the space.
• To assure that all personnel involved are aware of the hazards associated with the space.
• To assure that rescue services are available prior to entry.

To that last point about rescue services, we need to be familiar with what that would include. Rescue services, must be available while authorized entrants are in a confined space. As we said in the first paragraph of this article, deaths often occur during rescue. Untrained persons enter the space to help the downed worker can get themselves caught in the confined space, or worse, become a victim themselves to whatever may have harmed the original entrant. Trained professional rescue services are available for this purpose. They are skilled in both non-entry and entry rescue techniques. A small sample of rescue work can be found below, with more extensive coverage found in the 'Non-Mandatory Appendix F -- Rescue Team or Rescue Service Evaluation Criteria' found on OSHA's website!
 

• Non-entry: A rescue that is conducted without entry into the confined space. This can be conducted by such means as a rope or winch.
• Entry by personnel trained to conduct rescues:
• All members of the team must be specially trained in confined space rescue work,
• The team must have at least one member certified in CPR and first aid,
• All members of the team must be trained in the techniques and equipment for specific confined spaces.
• The rescue team must practice in all types of spaces in which a rescue could be required.

In today's article, we will finish up our topic of AWPs, or aerial work platforms, with information on the roles of the trainer and of the dealer. Previously, we discussed 'Tips, Training, and Current Issues' and 'Compliance, Training and Familiarization'. 

Role of the Trainer

As we stated in a previous article, the ANSI A92 Standards have already defined a qualified person. This relates to both operators and trainers:

“Qualified person. One who, by possession of a recognized degree, certificate, or professional standing, or by extensive knowledge, training, and experience, has successfully demonstrated his/her ability to solve or resolve problems related to the subject matter, the work, or the project.”

Attributes

Per the “Statement of Best Practices of General Training and Familiarization for Aerial Work Platform Equipment,” here is a suggested list of attributes a trainer will need in order to successfully educate operators:

Skills/Knowledge

• Must know the rules, regulations and standards.
• Needs to have knowledge of the equipment, the operator safety manual, warning decals and placards.
• Possess awareness of potential hazards and the means to protect against identified hazards.
• Be able to identify and avoid potential workplace hazards.
• Understands manufacturer’s guidelines for proper/improper use and application of the equipment.
• Knows the consequences of improper use and application of the equipment.
• Has a good safety record that is based on consistent implementation of the rules.

Communication

• Possess good communication and presentation skills when speaking with groups or individuals.
• Knows and understands the teaching methods and learning styles of adult learners.
• Be able to obtain acknowledgement from the operator that he/she can implement the training.
• Has the ability to deliver training in a manner and language appropriate to ensure understanding by the audience.

Qualities

• Possesses a concern for the welfare of others so trainers can serve as a safety advocate.
• Be intuitive and perceptive with people, i.e., can “read” the audience.
• Works in a confident and honest manner with people.
   

Role of the Dealer

If you were to rent aerial equipment, you may wonder what the role of the dealer who provides you with the rental equipment is. Do they provide training? Familiarization?
 

General Training

It is the dealer’s responsibility to assist its customers in identifying training resources in order to satisfy its operator training obligations. Some dealers may provide training for their customers; others may choose to offer other training resources such as recommending a training company or getting the customer information on the manufacturer. Potential training resources are any entity offering instruction by a qualified instructor following an appropriate training program. This may be the manufacturer, rental company, independent training company or internal resources of the employer who rented the equipment. 

ANSI/SIA A92 Standards Section 5.7 (Responsibilities of Dealers) state:

“Training. The dealer shall offer appropriate training to facilitate owners, users, and operators to comply with requirements set forth in this standard regarding inspection, maintenance, use, application, and operation of the aerial platform.”

Nothing states that the dealer must accomplish this training itself. Remember, the responsibility for conducting proper operator training has always been on the user and the individual employer. The dealer must offer training or direct the customer to a selection of reasonably available resources to ensure proper training of the customer’s personnel.
 

Familiarization

It is the dealer/rental company’s responsibility to provide familiarization to the designated person(s) receiving the equipment.

ANSI/SIA A92.5 and A92.6 Standards Section 5.8 (Responsibilities of Dealers) state:

“Familiarization upon delivery. Upon delivery by sale, lease, rental or any form of use, the dealer shall have the responsibility with the person designated by the receiving entity for accepting the aerial platform to:

1. Identify the weather resistant compartment (for manual(s)
   storage).
2. Confirm that the manual(s), as specified by the manufacturer, are on the aerial platform.
3. Review control functions.
4. Review safety devices specific to the model aerial platform being delivered.”

Record Retention

Whenever general training or familiarization takes place, documentation should be made to verify that said training/familiarization has been completed. An optional validation of training may come in the form of a certificate or an ID card. These documents should include the information/standards trained on under ANSI/SIA A92.

The documentation (for verification) of training/familiarization should include the following information and should be retained for a period of four years as required by the ANSI/SIA A92 Standards:

• Name of the operator or person receiving familiarization
• Date of training/familiarization
• Equipment covered in training/familiarization
• Identity of the person(s) performing the training/familiarization

Image by Horrgakx on Flickr.

Remember Safety Training Services, Inc. the next time you need aerial lift training! If you simply have questions on training, you can click here! Or click the button below to find out more about our AWP Training.

We wrote last week about the American National Standards Institute (ANSI), what exactly aerial work platforms (AWPs) are, the current issues facing the industry, and some tips to keep you safe on an AWP. This week, we will focus on compliance requirements, operator familiarization and general training.

Roles

ANSI standards heavily promote safety by developing recommendations and guidelines; however these standards are to be considered best practices, and are not laws or regulations. Compliance with ANSI standards is voluntary.

The Occupational Safety & Health Administration (OSHA), a government agency that issues and enforces regulations for employers to ensure workplace health and safety. These regulations are often referred to as standards, but they are in fact laws and compliance is mandatory.

So Why Comply?

It is true that ANSI is voluntary, and OSHA is mandatory, however it is to be noted that the OSHA regulations were in fact based on ANSI standards. Basically, once OSHA adopts the ANSI standards as their own, they no longer are voluntary and become law.

Despite ANSI standards being voluntary, it is in every company’s best interest to comply. Because OSHA law many times is adopted from ANSI standards, the standards in the ANSI handbook are considered a consensus of what’s best to keep employees safe and because of this OSHA can decide that the company is not “free from recognized hazards” and cite the company for the “general duty” clause for not following ANSI standards. So as it turns out, ANSI standards may not be as “voluntary” as expressed. Keep yourself and your employee’s safe, by following the ANSI guidebooks as mandatory as OSHA law.

Operator

Prior to use of an AWP, the operator must be trained before operation of the unit. This training should include the inspection, application, recognition, and avoidance of hazards associated with the equipment. As stated earlier, familiarization of the specific model of equipment should also be received prior to operating. Here is outline of each as stated by ANSI A92 Standards.

Training

• Essentially what prepares an operator to operate AWP
• Can teach multiple pieces of equipment of a particular type
• Covers broad types (push-around, boom lifts, scissor lifts, trailer-mounted boom lifts), as opposed to specific manufacturer/models
• Includes classroom/”formal” training as well as “hands-on”/practical