Confined Spaces In Breweries

Confined Spaces in BreweriesKen Anderson andJeff FannoSeptember 18, 2014

Ken AndersonVP Risk ControlUSI Insurance

Confined Spaces Between 2005 and 2009 there were 481confined space deaths in the US 61 percent due to physical hazards, 33percent due to hazardous atmospheres 60 percent of deaths were rescuers From 2005-present OSHA has inspected251 breweries.

Confined Spaces A confined space is defined by OSHA as:– An area large enough and so configured that anemployee can bodily enter and performassigned work, and– Has limited or restricted means of entry or exitand– Is not designed for continuous occupancy. All three conditions must be present to be aconfined space

Permit Required Confined Space A permit required confined space has atleast one additional hazard:– Contains or has the potential to contain ahazardous atmosphere– Contains a material that has the potential forengulfing an entrant– Has an internal configuration that might causean entrant to be trapped or– Contains any other recognized serious safety orhealth hazards.

Confined Space Flow Chart* Space large enough to bodily enter and;* Limited or restricted entry or exit and;* Not designed for continuous NO Not a confined SpaceConfined SpaceHazardous AtmosphereOrEngulfment HazardOrConfiguration HazardOrAny other recognizedserious hazardNonPermitNORequiredSpace

Confined Space Classification There are different categories of confinedspaces:––––Permit Required Confined SpaceReclassified Confined SpaceAlternate Entry Procedure Confined SpaceNot Classified as a Confined Space

Brewery Examples

OSHA Requirements Identify and classify all confined spaces Label confined spaces and notify employees Train employees on confined spaces and thehazards of each space If no entry to PRCS needed, secure accesspoints to prevent entry If entry to PRCS needed, develop PRCSwritten program and entry procedures

OSHA Requirements for PRCS Written programConfined space entry proceduresConfined space entry permitEntrants, Entry Attendant, Entry SupervisorTrainingEquipment – air monitoring, retrieval, etc.Rescue procedures, equipment and trainingProcedures for coordinating withcontractors entering confined spaces

PRCS Reclassification Example Example mash tun with steam jacket, poweredrake and inlet/outlet piping. To reclassify– perform lockout/tagout of rake– Turn off steam, lockout/tagout steam line, andallow tun to cool– Disconnect inlet/outlet piping– Allow tun to ventilate– Test atmospheric conditions inside tun– Certify in writing that tun is now safe to enter Entry into reclassified space must still beapproached with caution

Managing PRCS Requires careful planning and developmentof standard operating procedures Employees must be trained andknowledgeable Best option for most breweries is to notenter permit required confined spaces.–––––Perform work from outside spaceCIP systemsPortable CIP equipment for hard to reach areasLong handled tools and grabbersHire experienced contractor for PRCS work

Atmospheric Testing Multi-gas meter with Oxygen, LEL,CO,CO2 Other gases may be needed, i.e. H2S Must be calibrated and bump tested Users of the meter must be properly trained

Atmospheric Testing Be aware of response timeof meter Atmosphere in space maybe layered, test multiplepoints.Good AirTest top tobottom and sideto sideDeadlyAir

Confined Spaces - Other Issues Safe accessFall exposuresBurns and scaldsChemicals

Confined Spaces BMP Developed by the BA Safety Subcommittee Coming October 2014

Jeff FannoEH&S ManagerStone Brewing Co.

Confined Spaces Reclassification Process Initiated by Cal/OSHA Consultation visit inFebruary 2012 Two hazards identified during the inspection withone hazard related to having onsite rescue servicesrelated to confined space entry. However, Cal/OSHA consultation offered us away out by reclassifying as a non-permit space ifall the hazards are removed, as defined in Section5157 (c )(7).

Confined Spaces Reclassification Process A thorough review of Cal/OSHA’sConfined Space regulations was undertakenwith the focus on what makes a confinedspace a Permit Required Confined Spaceand what constitutes acceptable onsiterescue services Dialing 911 is not considered an acceptableonsite rescue service

Confined Spaces Onsite Rescue Services The local fire departmentwas invited to our site toevaluate, identify anddevelop potential rescuescenarios. The primary vessels ofconcern were ourBrewhouse vessels – LauterTun and Whirlpool as theseare most commonly enteredtanks and our yeastpropagation tanks due to thedifficulty of egress

Confined Spaces Onsite Rescue Services The fire department determined a rescueplan could be devised However, the time for rigging up theequipment and completing the rescue wouldbe considerable and also dependent on thestation’s availability – so no guarantees of atimely rescue

Confined Spaces Onsite Rescue Services In addition, a representative of CapitalSafety (DBI Sala) was brought in to identifywhich equipment would be necessary toobtain and deploy should a rescue beneeded in our confined spaces. An inventory of the necessary equipmentwas developed that would allow trainedemployees to rig and put to use should arescue be required.

Confined Spaces Hazard Assessment A description of the brewery process,cleaning processes and various maintenanceactivities around confined spaces wereprovided to Cal/OSHA In regards to the atmospheric hazards, itwas explained to Cal/OSHA that in ourbrewery the primary atmospheric hazard(CO2) is not present or eliminated prior toentry in our tanks.

Confined Spaces Isolating the space In addition, hazards such as engulfment andmechanical hazards (rotating parts) are eliminatedthrough our lock out tag out (LOTO) program Your LOTO program must compliment yourConfined Space Entry Program – these go hand inhand Simply stated Lock Out Tag Out ensures that anyand all energy sources are secured, drained, and/orisolated to prevent unintended start up

Confined Spaces Examples of energy sourcesrelated to confined space entry SteamGrainRakes or agitatorsChemicals –from CIP systemsWater (hot or cold)

Confined Spaces When the hazard(s) cannot beeliminated Finally, if a tank must be entered where theatmospheric hazard could not be eliminated or wasintroduced (welding), our preferred method wouldbe to delegate that activity to a contractor that wascompetent in permit confined space entry

Confined Spaces Reclassification The justification of reclassifying ourconfined spaces to non-permit confinedspaces was submitted to Cal/OSHAConsultation in writing in March of 2012 Shortly thereafter I received a phone callfrom the inspector along with his managerto walk through the process one more timeand they agreed with our analysis andassessment

Confined Spaces Reclassification with Permit Despite the acceptance with Cal/OSHA ofreclassifying our permit spaces to non-permitspaces, Stone Brewing Co. still utilizes a permitsystem, and follows the standards for PermitRequired Confined Space Entry We are also strongly considering purchasing therescue equipment and identifying key teammembers to receive thorough training forperforming onsite rescue

Zero Tolerance Safety PolicyViolation of Confined Space Entry procedures isconsidered one of our most serious safety offenses.

Confined Spaces In six basic stepsBasic Steps:1. SECURE the space2. Check the ATMOSPHERE3. Complete an entry PERMIT4. INFORM Brew Crew of the task5. Complete the task SAFELY6. CELEBRATE the success

Confined Spaces - Reclassification with Permit Despite the acceptance with Cal/OSHA of reclassifying our permit spaces to non-permit spaces, Stone Brewing Co. still utilizes a permit system, and follows the standards for Permit . PowerPoint Presentation Author: kerry fannon