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Case Study: Property Wide Confined Spaces Program

By: Rauch Safety & Engineering

Email Rauch Safety & Engineering
Telephone: 702-818-1765

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Geographic Location: Southeast Asia Industry
Industry Sector: Hospitality-Gaming
Client Type: Private


Background Information

Rauch Safety was appointed by the client to facilitate the development of a comprehensive, property wide confined spaces strategy and to work with clients U.S. and international design and operations internal resources teams, together with external multicultural project critical members which included architects, engineers, government authorities and contractors.

Confined Spaces safety is a global issue that is a growing source of concern in developed and developing countries. According to OSHA, in the U.S. alone, about 90 deaths involving confined spaces occur every year. These incidents occur because workers and employers do not recognize confined spaces and their associated dangers. One study concluded 40 percent of confined space fatalities involve attempted rescuers.

Many workplaces contain areas that are considered "confined spaces" because while they are not necessarily designed for people, they are large enough for workers to enter and perform certain jobs. A confined space also has limited or restricted means for entry or exit and is not designed for continuous occupancy. Confined spaces include, but are not limited to, tanks, vessels, silos, storage bins, hoppers, vaults, pits, manholes, tunnels, equipment housings, ductwork, pipelines, etc.

OSHA uses the term "permit-required confined space" (permit space) to describe a confined space that has one or more of the following characteristics: contains or has the potential to contain a hazardous atmosphere; contains material that has the potential to engulf an entrant; has walls that converge inward or floors that slope downward and taper into a smaller area which could trap or asphyxiate an entrant; or contains any other recognized safety or health hazard, such as unguarded machinery, exposed live wires, or heat stress.

Issues and Challenges

The need to perform operations within Confined Spaces is a truly international problem. Each year millions of dollars are spent trying to remove the need to enter these spaces by changing processes, by designing out the spaces themselves and by the use of new technologies. However, in many instances the only way to achieve operational requirements is for personnel to enter spaces and carry out given tasks.

Irrespective of country, all operations within these spaces are potentially dangerous due to the inherent risks, and world-wide many people are killed or seriously injured each year while working in them. A lack of control, lack of training, unsuitable equipment, or a combination of these invariably causes these incidents.

As with any safety related issue, it is difficult to quantify a realistic return on investment for Confined Spaces expenditures. Competing viewpoints of internal stakeholders such as operations, security, legal and finance, and each of their own budgetary requirements make the task of justifying costs for safety, (which in many cases are seen as intangible measures) particularly challenging.

Solutions and Recommendations

  • Review of property wide drawings to determine any possible deficiencies in overall confined space design and equipment placement.
  • Physical/onsite inspections of property to identify confined space hazards.
  • Meet with Labour Affairs Bureau, to ensure that International Confined Space Regulations (U.S. Federal OSHA, ANSI, CSA, CE) are acceptable to the Labour Affairs Bureau and meet or exceed local standards and requirements.
  • Develop confined space equipment placement and mitigation recommendations.
  • Develop recommendations for confined space procedures and training.
  • Develop budget for property wide confined spaces mitigation, design, engineering, installation, training, and procedures.
  • Identify qualified vendors for equipment and training programs.
  • Develop RFP’s (request for proposals) and provide to qualified vendors.
  • Review RFP’s and provide recommendations to client.
  • Management and oversight of all confined space related vendors and associated internal and external resources such as design, engineering, and operations.
  • Ensure that all training, training materials, procedures, signage etc., are in the appropriate language and dialect.
  • Physical/onsite inspection of property 60 (sixty) days prior to scheduled opening to identify any outstanding or newly created confined space hazards.
  • Observe confined space training by client to its employees 30 days prior to opening

Risk Factors and Assessment

The ability to implement a comprehensive realistic scalable long-term program which has the buy in of all stakeholders including the local authorities, will be the key to the success or failure of the overall confined spaces program.

Training programs to disseminate knowledge and to improve behavior patterns and attitudes regarding safety in general and confined spaces specifically are therefore critical. The inability to clearly articulate and demonstrate the importance of safety to the local workforce will leave the client at significant risk regardless of the amount of funds put towards equipment, plans and procedures.

Project Successes

Rauch Safety was successful in delivering a comprehensive Confined Spaces program. The client was fully committed to building off of their exemplary U.S. property confined spaces safety programs to deliver the highest caliber of training and safe work environment for this international location. Rauch Safety will continue to work with the client to monitor the programs progress.

Trusted by clients since 2001, Rauch Safety & Engineering specializes in guiding private and public clients through complex Fall Protection and Confined Spaces Infrastructure Access and Maintenance projects across specific industry sectors and markets utilizing our global network of resources to provide comprehensive world class advisory and management services.

View Rauch's Expert Witness and Business Consulting profiles.

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