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OSHA 40 or Hazardous Waste Operations and Emergency Response 40 hour Training

OSHA 40 Confined Space Definitions

The hazards encountered and associated with entering and working in OSHA 40 areas are capable of causing bodily injury, illness, and death to the worker. Accidents occur among workers because of failure to recognize that a confined space is a potential hazard. It should therefore be considered that the most unfavorable situation exists in every case and that the danger of explosion, poisoning, and asphyxiation will be present at the onset of entry.

Basic Terms

  • Confined Space: A space that is large enough and so configured that an employee can bodily enter and perform work. Confined spaces have limited or restricted means for entry or exit and are not designed for continuous occupancy. Confined spaces include storage tanks, bins, boilers, ventilation and exhaust ducts, pits, manholes, vats, and reactor vessels.
  • Entry: Confined-space entry begins when any part of the employee's body breaks the plane of any opening of the confined space and continues until the employee exits the confined space.
  • IDLH: Any condition that would pose an immediate or delayed threat to life, cause irreversible health effects, or interfere with an individual's ability to escape unaided from a permit space.
  • Isolation: A process of interrupting and/or disconnecting pipes, lines, and energy sources from the confined space. The space is removed from service, and complete protection from release of energy or substances into the space is provided.
  • Lower explosive limit/lower flammability limit (LEL/LFL): The lowest percentage of a substance in the air that leads to fire or explosion.

Evaluation of Confined Spaces

Permit-Required Confined Space (PRCS). A confined space that has one or more of the following characteristics:

  • Potential to contain a hazardous atmosphere.
  • Material that has potential for engulfing an entrant.
  • An internal configuration that could trap or asphyxiate an entrant such as inwardly converging walls or a floor that slopes downward and tapers to a smaller cross-section.
  • Any other recognized serious safety or health hazard.
  • The space to be entered has a vertical height of 4 feet or greater.

Non-permit-required confined space (NPRCS). A space that meets the definition of a confined space but, which after evaluation, does not contain or have potential to contain any hazard capable of causing death or serious physical harm.

What is the Scope of OSHA 40?

The scope of the OSHA 40 HAZWOPER standard does not cover the inevitable release of a hazardous substance that is limited in quantity and poses no emergency or significant threat to the safety and health of employees in the immediate vicinity. This type of release is referred to as an "incidental release" in 29 CFR 1910.120(a)(3), where "emergency response" is defined.

An incidental release is a release of hazardous substance which does not pose a significant safety or health hazard to employees in the immediate vicinity or to the employee cleaning it up, nor does it have the potential to become an emergency within a short time frame. Incidental releases are limited in quantity, exposure potential, or toxicity and present minor safety or health hazards to employees in the immediate work area or those assigned to clean them up.

If the OSHA 40 hazardous substances that are in the work area are always stored in very small quantities, such as a laboratory which handles amounts in pint sizes down to test tubes, and the hazardous substances do not pose a significant safety and health threat at that volume, then the risks of having a release that escalates into an emergency are minimal. In this setting incidental releases will generally be the norm and employees will be trained to protect themselves in handling incidental releases per the training requirements of the Hazard Communication standard (29 CFR 1910.1200).

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