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Requirements for use of Confined Space Gas Detectors

Regulatory Requirements

  • OSHA 1910.146 "Permit-required confined spaces"
  • OSHA CPL 2.100 "Application of the PermitRequired Confined Spaces (PRCS) Standards, 29 CFR 1910.146"
  • 1915 Subpart b "Confined and Enclosed Spaces and Other Dangerous Atmospheres in Shipyard Employment"

Requirements for use of Confined Space Gas Detectors

  • Use of gas detectors in hazard assessment
  • Use of gas detectors in non-permit spaces
  • Use of gas detectors in permit spaces which have been reclassified as non-permit spaces
  • Use of gas detectors in permit-required confined spaces (per 1910.146)

Using Confined Space Gas Detectors

  • "Pick-hole" sampling
  • Pre-ventilation
  • Sampling during initial (purge) ventilation
  • Final pre-entry
  • Monitor continuously while entry underway!

Sample at all vertical levels!

  • Atmosphere tested (at least) a distance of approximately 4 feet (1.22 m) in the direction of travel and to each side

1910.146 Appendix E: "Sewer System Entry"

  • Major points:
    • Sewer workers' usual work environment is a permit space
    • Because isolation not complete, always potential for atmosphere to become suddenly and unpredictably lethal
    • Testing instrument should be carried by the entrant while in the sewer to warn of any deterioration
    • Atmospheric monitoring equipment must calibrated according to the manufacturer's instructions

Broad range vs. substance specific sensors in sewer entry per Appendix E

  • Broad range best suited for initial use where actual or potential contaminants have not been identified
  • However, such sensors only indicate that a hazardous threshold of a class of chemicals has been exceeded
  • Therefore, substance-specific best suited for use where actual and potential contaminants have been identified.
  • However, sewers may change unpredictably, and substance-specific devices may not detect new potentially lethal hazards

Broad Range vs. Substance Specific Sensors in Sewer Entry

  • OSHA emphasizes it’s up to the employer to decide, based on knowledge and experience, what the best type of testing instrument may be for any specific entry operation.