Tank Talk 39

Summer 2008 Confined Space Safety in Water Storage Tank

Specifications
By: Jennifer Coon, CHMM, CET

When preparing specifications for tank In addition, the contractor will hold the
coatings rehabilitation projects, several owner, engineer, and engineers consultant
safety precautions need to be addressed harmless from any civil or criminal penal-
within the specifications. These precautions ties imposed because of the contractors non
are meant to not only protect the engineer, -compliance with these requirements.
engineers consultant, and the tank owner
from liability, but also to promote a safe Material Safety Data Sheets
working environment for the coatings
Material Safety Data Sheets (MSDS) con-
crews. A safe working environment will
tain crucial information about hazardous
ultimately make achieving a quality product
materials commonly found on coatings job-
a more attainable goal, as disruptions and
sites, including but not limited to:
turnovers associated with injured employ-
ees, unsafe conditions, and regulatory Abrasives
agency violations will be reduced. Whether Coatings
you are a coatings contractor or a specifier, Thinners and other solvents
be sure to verify that these safety items are Welding materials
addressed in tank coatings project specifica- Flexible sealant material
tions: Disinfecting agents
Material Safety Data Sheets (MSDS)
Confined space entry procedures Information on the MSDS is critical, not
Designated Competent Person only to the contactors employees, but also
to anyone else (such as representatives of
General Requirements the owner, engineer, or engineers consult-
ant) who may need to enter the project site.
At the beginning of the project specifica- The specifications should not only require
tions, a general statement should be made MSDS be located on the site, but the specs
summarizing what is expected of the con- should also require that the MSDS be dis-
tractor. The statement should require the
played in a readily locatable area. Some
contractor to comply with all applicable
contractors prefer to place the MSDS on the
laws and regulations such as the Occupa- signage displaying emergency phone num-
tional Safety and Health Act (OSHA).
bers and contact names.
When state and/or local government re-
quirements referenced or specified are more The prominent display of MSDS is obvi-
restrictive than the federal requirements, the ously important during the project work
more restrictive requirements must be met. hours, but it is also necessary after-hours as
well. Emergency personnel will need the
The general statement should also require information found on an MSDS if they are
the contractor to: called to the job site regardless of the
provide all necessary safeguards for hour. For example, if vandals wander onto
worker and safety protection the site and cause mischief at 2:00 AM, re-
stipulate that the costs associated with sponding emergency personnel will need
safety must be included in the contrac- information on any hazardous materials
tors bid found on the site.
specify that no additional compensation
will be paid for changes in the laws,
regulations, or any re-interpretation that
may occur.
Page 2 Tank Talk
Confined Space Entry Verifying that engineering controls in use are in operat-
It should also be specified that the coatings contractor must ing condition and functioning properly
comply with the OSHA Confined Space Standard, 29 CFR Controlling access to the work site and demarcating
1910.146, entitled Permit Required Confined Spaces. contaminated control boundaries
The coatings contractor must have a confined space pro- Maintaining documentation
gram documenting all entry procedures, permits, roles, and
responsibilities of workers, training, gas monitoring, poten- Applicable Codes and Standards
tial hazardous situations, rescue procedures, and documen-
tation. By definition, a confined space is one that is large A well-written tank spec will also include references to
enough and designed for personnel to enter, has limited or applicable industry standards for coatings. The following
restricted means of access, and is not designed for continu- industry standards contain useful safety-related provisions:
ous occupancy. A tank, even when empty, falls under this
definition. American Water Works Association (AWWA) Stan-
dards
Anytime entry into a confined space occurs, it must be as-
American Welding Society (AWS) Standards
sumed that the space is a permit-required space, unless it is
well documented that the space does not possess any recog- American Petroleum Institute (API) Standards
nized or potential safety and health hazards, or if it can be American Institute of Steel Construction (AISC) Stan-
proven that the hazards are eliminated without entry into dards
the space. This means that a well-written tank spec will NACE International (NACE) Standards
mandate that a coatings contractor implement a confined SSPC: The Society for Protective Coatings (SSPC)
space entry program for all crew members working on the Standards
project. Occupational Safety and Health Administration
(OSHA) Standards
Competent Person American National Standards Institute (ANSI) Stan-
dards
It should be specified that the coatings contractor must des-
United States Environmental Protection Agency (US
ignate a Competent Person, and identify that person to the
EPA) Standards
owner, engineer, and engineers representative. The Com-
petent Person must be capable of identifying existing and
Whether you write the project specifications as a specifier,
predictable conditions on the work site that are unsanitary,
or adhere to them as a coatings contractor, it is your re-
hazardous, or dangerous to employees. The Competent
sponsibility to insure that the specs contain comprehensive
Person must also be authorized to take prompt corrective
safety requirements. Applying coatings in a tanks con-
measures to eliminate these conditions without the help of
fined-space can be an especially dangerous situation, there-
the owner, engineer, or engineers consultant.
fore, several safety precautions must be addressed when
The Competent Person must have the complete support of preparing (or reviewing) the specifications for tank reha-
top management and the written authority to ensure these bilitation projects. These precautions are meant to not only
operations are carried out in accordance with compliance protect the engineer, engineers consultant, and the tank
plans and governmental regulations independent of pro- owner from liability, but to promote a safe working envi-
duction pressures. As such, the Competent Person must ronment for everyone on the jobsite. It is up to specifiers
report directly to the contractors headquarters and not to and coatings contractors to be sure that the projects safety
the site foreman. Some of the Competent Persons respon- specifications address the MSDS, entry procedures, and
sibilities should include: Competent Person designations. Its not only good busi-
ness practice it can also be a matter of life and death.
Ensuring that all of the coatings contractors safety pro-
grams are being followed Jennifer Coon, TIC Safety Director, is responsible for
Confirming that all employees are trained in the use of developing, communicating, and monitoring TICs
extensive Health and Safety program. Jennifer is a
personal protective equipment (PPE), personal hygiene Certified Environmental Trainer (CET) as designed by
facilities, respiratory protection, decontamination prac- the National Environmental, Safety & Health Training
tices, and fall protection systems Association and is designated by OSHA as an outreach
trainer for the 30-Hour General Industry course. She
Performing daily inspection and approval of any rig- has an MS in Environmental Science (Hazardous
ging and scaffolding equipment Materials Management CHMM) from Indiana
University. Coon@TankIndustry.com