As a safety professional and editor/writer, I have had the opportunity to visit fascinating jobsites where construction, manufacturing, and or maintenance takes place.

Whether it’s a major sports stadium under construction or a manufacturing facility producing high-end, explosive-proof safes, I am consistently impressed at the ingenuity and hard work behind how things are built and produced.

At the same time, my safety brain always kicks in and analyzes the potential hazards to worker safety, examining how to keep people safe.

One such place was a vodka distillery and beverage bottling plant, which I had the chance to tour with a mechanical contractor who took care of maintaining the process piping. The area that truly fascinated me was the distillery process for the manufacturer’s premium vodka.

The facility had a large room housing three tall, interconnected stainless steel tanks. The base spirit started in the first tank. From there, it passed through into the second and third via a charcoal filtering process designed to produce a smooth-tasting product at the end.

Given the complexity and size of the operations, I could spot several hazards involved to provide maintenance on those tanks. These included electrical, working at heights, ergonomic, and hazardous and flammable chemical exposure. I also wondered how and if employees would need to enter those tanks, which would likely be classified as confined spaces. 

To permit or not permit 

Of course, a distillery isn’t the only place a contractor will encounter a confined space. Per the Occupational Safety and Health Administration’s confined space regulations (29 CFR 1910.146), a confined space is defined as:

• Having limited openings for entry or exit.
• Large enough for entering and working.
• Not designed for continuous worker occupancy. 

Examples include underground vaults, tanks, storage bins, manholes, pits, silos, underground utility vaults and pipelines.

Working within them is definitely high-hazard work that can lead to serious injuries, let alone fatalities. According to the Bureau of Labor Statistics, Census of Fatal Occupational Injuries, 1,030 workers died from occupational injuries involving a confined space from 2011 to 2018. The annual figures range from a low of 88 in 2012 to a high of 166 in 2017. 

Confined spaces containing serious, difficult-to-abate hazards may be classified as “permit-required.” Per OSHA, permit-required confined spaces are those that: 

• May contain a hazardous or potentially hazardous atmosphere. 
• May contain a material which can engulf an entrant. 
• May contain walls that converge inward or floors that slope downward and taper into a smaller area that could trap or asphyxiate an entrant. 
• May contain other serious physical hazards such as unguarded machines or exposed live wires. 
• Must be identified by the employer who must inform exposed employees of the existence and location of such spaces and their hazards.

Before you enter

Before entering any type of confined space, determine if entry can be avoided. Remember: The most effective method of controlling risk is to eliminate the hazard altogether. In addition, confined space entry occurs as soon as any part of the entrant's body breaks the plane of an opening into the space.

Going back to our distillery tanks, where do they fall in terms of the non-permit vs. permit-required classifications?

According to OSHA, all spaces shall be considered permit-required confined spaces until pre-entry procedures demonstrate otherwise. Therefore, before classifying, let alone entering the space, we need to perform a detailed hazard analysis. 

Matt Stinchfield, a safety specialist for Whalen Insurance, is an expert in this area as safety ambassador and member of the Brewers Association’s Safety Subcommittee. He is also a member of the American Craft Spirits Association’s safety committee and leads The Brewery Safety, a consulting firm serving craft breweries and distilleries with safety and design services. 

“These cellar vessels will have CO2 atmospheres, ethanol vapors, fall hazards, and usually a cone-shaped bottom that makes exiting difficult – so a lot of difficult to control hazards,” Stinchfield says. These tanks are permit-required. In practice, no one enters these tanks with their full body, but they do reach their hands in and peek in with their head and a flashlight to inspect cleaning, thus entering.” 

In addition, there are potential mechanical hazards and other sources of energy that will need to be locked and tagged out. 

Write a program, train employees

If entering these spaces is necessary, ensure that you have a solid written program tailored to your operations. A written permit-required confined space program must at least address: 

• Preventing unauthorized entry. 
• Hazard identification procedures. 
• Workplace evaluation procedures. 
• Procedures, practices, and means necessary for safe permit space entry and closure operations.
• An entry permit system. 
• Training for entrants, attendants, and entry supervisors 
• A system for ensuring that:
  - Pre-entry testing is performed.
   - Pre-entry preparations are completed.
  -  Acceptable conditions are attained. 
• Developing and implementing rescue and emergency measures. 

In addition, no one should enter permit-required confined spaces without being trained and having a permit to enter. Ensure that all employees review and understand your written procedures.

Employee training must include: 

• Recognition of permit space hazards.
• Control of permit space hazards.
• Use of atmospheric monitoring equipment.
• Use and maintenance of personal protective equipment (PPE).
• Use and maintenance of rescue equipment.
• Annual practice of permit space rescues. 

Resources for Success 

When it comes to training materials, program development, and guidance on classifying spaces, there are many free resources are available through OSHA, as well as the National Institute for Occupational Health and Safety.  Below are just a few that you can Google and we will provide the links when this story appears online:

• OSHA Confined Spaces.
• Also see Appendix A to §1910.146 -- Permit-Required Confined Space Decision Flow Chart, which takes you through the process of determining if the space will require a permit. 
• Protecting Construction Workers in Confined Spaces: Small Entity Compliance Guide, which provides valuable information on sewer entry. 
• NIOSH Confined Spaces 

Industry associations, and insurance carriers are also great sources for materials and support. 

As for my tour of the vodka distillery, our last stop was the quality control area where a team of employees were charged with sampling beverages.

While I initially thought what a great job this would be, I immediately pondered about their worker’s compensation insurance costs and hoped that everyone was provided a safe ride home.