Since we are sharing NIOSH Investigative Reports tonight, I thought I would share one of the reports that floors me every time I see it! In March 2011, a safety manager for the government agency that inspects “dairy plants” was concerned that the inspectors were not being properly protected from Confined Space hazards, so he requested NIOSH conduct one of their investigations. The findings are scary and painful! Scary that we have GOVERNMENT WORKERS at this level of risk and painful that we have GOVERNMENT WORKERS at this level of risk. Here we sit, having to comply with one of the most fundamental and life-saving standards, and there is a government agency entering PRCSs and doing it VERY POORLY; in fact, if any private industry facility pulled this crap, it would be a heft citation (or should be!). Here is what NIOSH found…
NIOSH investigators evaluated a federal agency’s confined space program for equipment inspectors in dairy plants on March 1–2, 2011, after receiving a request from the agency’s health and safety manager. The requestor was concerned with potential exposures to oxygen-deficient atmospheres and off-gassing of cleaning and disinfection products during equipment sanitation surveys in dairy plants. No health concerns were specifically reported. We toured one dairy plant on March 1, 2011, to learn about dairy plant processes and equipment. We evaluated typical procedures during an equipment sanitation survey on March 2, 2011, at a second dairy plant. We also reviewed the agency’s draft written confined space program and interviewed equipment inspectors about their confined space practices and work-related health and safety concerns.
NIOSH learned that dairy plants within the United States are increasing in size, which usually means more confined spaces in a plant. What NIOSH found:
- They observed six partial permit-required confined space entries (head and arm/hand into a vessel manhole for less than a minute) by an equipment inspector.
- They also observed several inspected pieces of equipment that were not confined spaces. The equipment inspector was accompanied at all times by plant personnel and usually wore a lab coat, safety glasses, hearing protection, bump cap, and a hair net, and used a high-intensity portable flashlight.
- They found the agency’s draft confined space program hard to understand because much of it was written using legal jargon. Also, the program was not specific to the dairy industry and did not include rescue procedures in case of an emergency during an equipment sanitation survey.
- Interviews with equipment inspectors revealed that they routinely entered permit-required confined spaces during equipment sanitation surveys but were not always familiar with the permit-required confined space and rescue procedures of the dairy plants.
- Although equipment inspectors usually wore the PPE required by the dairy plant they were inspecting, we observed instances where equipment inspectors did not follow all of the plant’s requirements (for example, not wearing safety glasses or a bump cap when entering a confined space).
Recommendations:
NIOSH recommends
- the equipment inspectors obtain information about the plant’s permit-required confined spaces before visiting a dairy plant. This may include, but is not limited to, a copy of the plant’s written confined space entry program, recent calibration of the plant’s confined space air monitoring equipment, and information on confined space emergency and rescue plans.
- the agency tailor its confined space program to the equipment and hazards found in the dairy industry, including rescue procedures.
- the agency should provide equipment inspectors with adequate PPE, calibrated air monitors, and yearly training in confined space entry specific to the dairy industry.
- inspectors should follow plant PPE requirements and permit-required confined space procedures during equipment sanitation surveys.
- inspectors use a bump cap with a chin strap, safety glasses, and intrinsically safe flashlights.
- inspectors should also have lockout/tagout locks and full-body harnesses.
CLICK HERE to download the full NIOSH Report.
