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Nancy Pearce
Certified Industrial Hygienist, Senior Fire Protection Engineer NFPA
Recent Activity
We’ve got it all….(almost)! We have a great group of chemical and fire protection engineers who are highly motivated and work well as a team. We work hard, support and encourage each other-and we have fun! Since we cannot clone our previous boss, we are on a mission to find a new leader who will continue to inspire our team to achieve and take on new challenges. If your actions inspire others to dream more, learn more, do more and become more, you are a leader. (John Quincy Adams). If you are that person, please apply to our Industrial and... Continue reading
Do not panic! The Technical Committee responsible for NFPA 600 has just completed a revision of their document which is now titled Facility Fire Brigades instead of Industrial Fire Brigades! The Committee wanted to emphasize that fire brigades are not limited to just industrial settings but exist in other facilities such as hospitals, universities and airports. Although work on fire brigade standards has been going on for over 100 years, with the first document on private fire departments published in 1902, the Committee recognizes that the world of fire brigades has changed. As a result the Committee is already beginning... Continue reading
Anyone out there as passionate about confined space safety as I am? If you are at all involved with confined space entry then come hear about the new NFPA 350 Guide to Confined Space Entry and Work at the NFPA conference next week in Chicago! The Technical Committee has completed the second draft revisions and, absent any NITMAMs, the new guide will be released this coming November! This document explains “how to” comply with provisions in the existing confined space regulations and standards by providing more detailed guidance on subjects such as hazard identification, air monitoring, ventilation and rescue. It... Continue reading
The NFPA 704 “diamond” provides a tried and true method for warning emergency responders of the hazards they could encounter during a spill or fire involving a hazardous material. Staff at NFPA often receive questions about the application of the ratings such as “How does this system differ from other labeling systems” or “Where should I post the NFPA 704 placards at my facility”? A new Frequently Asked Questions (FAQ) document has been developed to address some of these common questions. The FAQ document is now posted and available for download. What else is happening with NFPA 704? Well-those of... Continue reading
The preliminary draft of NFPA 350 has been approved by the NFPA Standards Council and is now open for public input. This guide, with non-mandatory language, incorporates the best practices that organizations and confined space professionals have utilized to comply with regulations and standards for the past 20 years since the initial publication of OSHA’s final rule. It also draws on NFPA’s experience with a number of confined space activities including hot work, the maritime industry and emergency rescue operations. The Guide primarily focuses on addressing gaps in standards and on providing prescriptive guidance on how to implement requirements in... Continue reading
When OSHA announced last year that it was updating its Hazard Communication Standard to include the adoption of the Globally Harmonized System of Classification and Labeling of Chemicals, many companies and emergency responders asked “How will this impact NFPA 704”? NFPA 704, Identification of the Hazards of Materials for Emergency Response, uses a combination of color coding and numbers to describe a hazard’s severity, and provides a simple, readily recognized, and easily understood label to assist those who are responding to an emergency such as a fire or spill. OSHA’s revised Standard, known as Hazard Communication 2012 or HC2012, is... Continue reading
Well, my confined space blog may have slowed down a bit in the past couple months due to other ongoing work, but unfortunately the confined space fatalities have not slowed down... In April, seven workers were killed in a tank that was undergoing maintenance and cleaning at a plant in Mexico City operated by Corona beermaker, Grupo Modelo. It is believed that four victims were maintenance contractors and three victims were other Modelo employees. There are few details available on the incident. It is speculated that the deaths were due to “unspecified toxins” and that the three Modelo employees had... Continue reading
The Technical Committee on Confined Space Safe Work Practices put some “finishing touches” on the preliminary draft of a new confined spaces guide at a meeting in Charlotte NC last week. This best practices guide, written for all types of confined space entries, will complement other confined space regulations and standards and will provide more prescriptive guidance to address some of the gaps in existing confined space documents. For example, the guide provides detailed information on the selection and use of atmospheric monitoring devices and ventilation. It also outlines qualifications and competencies for those involved in confined space entry and... Continue reading
In 1984 a rescuer was killed when an explosion occurred while he and his coworkers were attempting to cut a hole in a toluene tank to retrieve a worker who had died entering the confined space. The accident, captured on video, provides a graphic view of the hazards of performing hot work around confined spaces. This incident was not unique. Fatalities from welding and hot work are often are associated with confined spaces and the areas adjacent to these confined spaces . The CSB has identified over 60 fatalities since 1990 due to explosions and fires from hot work activities... Continue reading
Photo: Typically we think of climbing down into tanks, vaults or manholes for confined space entries. Most would not think of wind turbines as having confined spaces. Large enough to enter and perform work, restricted means of entry or egress and not designed for continuous human occupancy…. Wind turbines clearly have components that meet the definition of a confined space AND they have potential hazards. With the push towards green energy, wind turbine installations are increasing rapidly. In 2012 wind energy became the number one new energy source, with over 45,000 wind turbine installations currently in the U.S., according... Continue reading
I used to (naively) believe that training was the only way to prevent workplace injuries and fatalities. If I did a great job training workers on the hazards of a particular task and demonstrating and explaining how they could eliminate the risk of injury or fatality, I believed they would follow my advice. However, after more than 25 years experience, I now understand that while training is important, it is not the complete panacea I was hoping for. I could provide a great training session and get lots of positive feedback from those participating, only to observe unsafe procedures and... Continue reading
Gas monitoring with proper equipment is probably the number one most important step you can take to protect against confined space fatalities. But selecting the right gas monitor for entry is not without its challenges. Gas monitoring for confined space entry can be straightforward or it can be complicated, depending on the type of space being entered and the work that will be performed. All gas monitoring for confined space entry must include tests for both oxygen (%) and flammables (% LEL). Beyond these two tests, it is up to the employer to determine what other toxic gas monitoring needs... Continue reading
About once a month I scan the web to see if there have been any confined space fatalities. Tragically, I almost always find one, and it is not unusual to find several fatal confined space incidents. Even worse, there are times I find multiple fatalities in a single confined space entry. The fatal confined space accident I found this month was particularly disturbing to me. It seemed so blatantly obvious that the space and work being performed would require at least some basic confined space entry procedures, yet none appear to have been followed. A company that cleans industrial tanks... Continue reading
Do you recognize any of these people? These are some of the hard working members of the Confined Spaces committee who met this week in Tampa to continue work on a Best Practices document for Confined Space Entry that will become NFPA 350. This is one hard-working committee with some task groups working into the night developing chapters for the document. The goal is to come up with a document that includes the best work practices that should be used for all confined space entries regardless of type. It will provide guidance on confined space entry in all workplaces, whether... Continue reading
The NFPA Confined Spaces Committee will be meeting in Tampa next week for the second time to continue working on the development of a draft Best Practices Document for Confined Space Entry. The Committee continues to work on this ambitious project that will bring all the best practices for confined space entry for various types of industries and spaces together and merge them into a single document. The Committee continues to analyze gaps in existing standards and guidelines and plans to have a draft ready for the July NFPA Standards Council meeting. Once the Standards Council approves the draft it... Continue reading
Historically, atmospheric hazards have been the leading cause of worker deaths in confined spaces therefore testing the atmosphere prior to entry has always been a priority. When teaching confined space entry classes, I always told the students that if they only took away one piece of information from my class, it should be that NO confined space should EVER be entered unless the atmosphere had been tested with a properly calibrated gas monitor! The OSHA Permit Required Confined Space Standard 1910.146 indicates that confined spaces must be tested, with a calibrated direct-reading instrument, for oxygen content, for flammable gases and... Continue reading
Can a single regulatory standard or best practices document adequately address confined space hazards in all types of workplaces? Or do the hazards of confined spaces vary so much from workplace to workplace that no single standard can adequately address all industries? OSHA’s Permit Required Confined Space Standard published in 1993 covered only general industry and not construction. OSHA indicated that the 1910.146 standard had not included construction due to the unique confined space hazards found in the construction industry. Fourteen years later, in 2007, the proposed OSHA Construction standard was published in the Federal Register. The standard was listed... Continue reading
OSHA has recently issued citations for yet another fatality that occurred adjacent to a confined space. As discussed in a previous blog, the hazards of adjacent spaces are not often recognized by employers and are not specifically addressed in the OSHA Permit Required Confined Space standard (1910.146) North Carolina Dept of Labor recently cited Smithfield Packing ~ $250,000 for a fatality that occurred when a worker was overcome by hydrogen sulfide gas while filling a tanker with liquid sludge. The atmosphere outside the tank was not tested prior to or during the filling and since the worker never ENTERED the... Continue reading
While atmospheric hazards have historically been the cause of the majority of fatalities in confined spaces, in more recent years, it appears that the safety hazards are taking over as the leading cause of confined space fatalities. Common safety hazards responsible for fatalities in confined spaces include explosions, engulfment by solids, drowning, entrapment, falls, and contact with electrical, mechanical and hydraulic energy sources. Because confined spaces are not designed to be “occupied”, they often contain exposed electrical and mechanical equipment that would normally be covered and guarded in occupied areas. In addition, the likelihood of contact with equipment and energy... Continue reading
It is generally recognized that lack of oxygen is the leading cause of death in confined spaces. You cannot see or smell a oxygen deficiency therefore the hazard is not readily apparent to someone entering an oxygen deficient environment. The only way to determine if a confined space has sufficient oxygen is to test the atmosphere with a calibrated gas monitor. The air we breathe contains approximately 20.9 % oxygen. Most of the remaining 79% is made up of nitrogen with smaller quantities other gases such as argon and carbon dioxide. Interestingly, contrary to what most people think, the percentage... Continue reading
What does history mean when it comes to confined space entry? I am often asked if you can use the results of previous monitoring data to show that there is no hazardous atmosphere. The answer of course is a resounding “NO”! If a space is truly a permit required confined space then it ALWAYS has the potential to have a hazardous atmosphere or other potentially fatal hazards. Most confined spaces where fatalities have occurred were entered previously without incident. Spaces below grade ALWAYS have the potential for gas infiltration or decay. A misunderstanding of the irrelevance of history when it... Continue reading
How do you demonstrate hazardous atmospheres to trainees? A training video can only go so far to demonstrate this principle. I once read an article that contained a “recipe” for setting up an excellent training prop that I have now used in training for many years. It provides a very visual example of how an apparently benign looking enclosure such as a water tank or valve vault can actually be deadly. Take a large office water cooler size empty water bottle. How bad could a water bottle be after all? Add a handful of leaves, tiny bit of dirt or... Continue reading
Confined spaces can visually look completely safe but as we know, often they are not. Historically, atmospheric hazards have been the leading cause of deaths in confined spaces. In order to assess atmospheric hazards, both visual inspections and atmospheric testing of confined spaces must be done. There is often more than meets the eye! When you look at a confined space, you must ASSUME that it could have a hazardous atmosphere until you verify that it is safe with a properly selected and calibrated gas monitor. But while it may be quite clear that there is a need to test... Continue reading
The Confined Space Safe Work Practices Committee, a group of 25 highly qualified individuals with extensive experience in all aspects of confined space entry, met for the first time this past week in Philadelphia, Pennsylvania. This Committee will develop a document that can fill in “gaps” in existing regulations, standards and guidelines and will become a best practices guide for confined space entry. Task groups worked on developing chapters on gas monitoring, ventilation, rescue and training/competencies. Additional chapters to be developed include hazard identification and control and prevention through design. The Committee is highly motivated to develop a draft document... Continue reading
One week from today the Confined Space Safe Work Practices Committee will meet for the first time in Philadelphia to begin work on a NEW best practices document for Confined Space Entry. The committee is preparing for the meeting by reviewing existing documents and standards related to confined space entry. We have a number of guests attending the first meeting including several members of the Philadelphia Urban Fire Search and Rescue team, Pennsylvania Task Force One and staff from the Chemical Safety Board! We have task groups established for gas monitoring, ventilation, rescue and training/competencies. Additional chapters will be developed... Continue reading