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This fatal Hotwork Incident is a reminder of the dangers of welding inside Confined Spaces, ESPECIALLY those that contained a flammable liquid or gas!  The USCG did an excellent job with this investigation and report, laying out the timeline and facts leading up to this incident that caused this incident to occur.  It is a MUST read for those who permit HW activities within confined spaces.

2013.11.04 - Enclosed Space Flash Explosion Onboard Offshore Platform - Investigation Report Figure 6This incident information refers to an accident that occurred onboard an offshore platform in the Gulf of Mexico during maintenance and repair operations to clean several production vessels, including a high-pressure separator, the floatation cell, the wet-oil tank, and two stacked low-pressure separators, upper and lower. A flash fire ignited within one of the vessel’s causing injuries to four crew members.

Confined space warning 01Right after doing our site assessment, OSHA says that we must identify those spaces that are deemed to be Permit Required Confined Spaces.  Many facilities order hundreds of signs to put on their spaces at a pretty penny… in other words it ain’t cheap to label these spaces!  So one would think that the labeling/marking would be done properly.  Take the image to the left… anyone see anything wrong with this picture?  Think in a futuristic way…   As shown in the photo, most PRCSs are labeled with a sign on the access way covering.  Everything from a hatch door, manway lid, etc. we tend to put the DNAGER sign directly on the access way cover.  As it sits as shown in the photo we have no issue, but what happens when the tank is prepped for entry and the access way covering is opened/removed?  Now we have an OPEN PRCS without any identification as such; a serious unsafe condition, as well as a failure in compliance.

Lets take a look at what OSHA’s 1910.146 says about identifying PRCSs and preventing unauthorized entry into PRCSs.

Two workers were killed while cleaning rail cars and were exposed to a dangerous amount of hydrogen sulfide gas.  The primary cause of death of both employees was closed space asphyxiation and hydrogen sulfide intoxication, a byproduct of the residual organic waste contained in the tank. OSHA determined that neither victim was equipped with an emergency retrieval system before they entered the car. As a result, the liquid animal feed manufacturer has been placed in OSHA’s Severe Violator Enforcement Program.  

Facility also failed to:

  • complete a permit-required confined spaces entry permit
  • use testing and monitoring equipment to evaluate the permit space condition prior to entry; and
  • require employees to use rescue and emergency equipment.

OSHA also found the company failed to:

  • designate trained rescue employees
  • use a retrieval system attached to the worker to aid in rescue
  • train workers and place warning signs about hazards that may be encountered in confined spaces; and
  • ensure rail tank cars had been ventilated prior to entry

OSHA has proposed fines totaling $266,000.  Here is a breakdown of the citations:

The Department of Labor & Industries (L&I), also known as WA-OSHA, has cited a landscaping business for multiple safety violations related to the death of a worker, 19, last July. He was killed by a rotating auger while working inside the hopper of a bark-blower truck.  The company has been cited for two willful and 14 serious violations, with penalties totaling $199,000. The employer has also been identified as a severe violator and will be subject to follow-up inspections to determine if the conditions still exist in the future. Following the July incident, L&I issued a bark and mulch-blower hazard alert to warn others in the landscaping business of the danger of working in hoppers while the equipment is running.  The L&I investigation found workers were regularly assigned to clear jams in the bark-blower truck hoppers while the hoppers were operating. This exposed them to three very hazardous elements: a floor conveyor belt, two rotating-screw conveyors (angled augers) and a rotating stir rod. Exposure to any of these parts of the equipment could potentially result in entanglement, causing severe crushing injuries or death. The employer was cited for two willful violations:

  • for not ensuring lockout/tagout procedures were regularly used; it carries a penalty of $56,000
  • for not training the employees in the proper use of those critical procedures; it carries a penalty of $52,000

Additionally, working in the hopper of bark-blower trucks exposed workers to “confined space” hazards. Twelve of the serious violations cited were for failure to implement safe work practices when entering a permit-required confined space. Two other serious violations were cited for not having an effective accident prevention program and for failure to document lockout/tagout procedures. Each of these violations carries a $6,500 penalty.

Here is a breakdown of the citations:

This Approved Code of Practice (ACOP) and guidance is for those who work or control work in confined spaces.  It explains the definition of a confined space in the Regulations and gives examples. It will help you assess the risk of working within a particular confined space and put precautions in place for work to be carried out safely.  This edition brings the ACOP up to date with regulatory and other changes. The guidance has been simplified to make the understanding and use of the document easier, particularly with clarifying the definition of a confined space.  Other changes include:

  • a flowchart to help in the decision-making process,
  • additional examples including new workplace risks (such as specifically created hypoxic environments, fire suppression systems etc), and
  • amendments relating to the need to check, examine and test equipment

CLICK HERE for this very helpful guidance (regardless of where your Confined Spaces are located)

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