1. Compliance and Safety
in Confined Spaces
for the Windpower
Industry

2. Sponsored By:

3. Before We Start
 This webinar will be available at
www.windpowerengineering.com & via email
 Q&A at the end of the presentation
 Tweet with hashtag #WindWebinar

4. Moderator
Steven Bushong
Windpower Engineering &
Development
Presenters
Scott Bramlett
EDF Renewable Services
Rob Siegel
ENSA North America

5. Confined / Enclosed Spaces in the
Wind Industry Scott Bramlett – EDF Renewable Services

6. Confined / Enclosed Spaces in the Wind Industry
• Introduction / Overview
• Employer Duties / OSHA
• Confined Space Assessment / Classification
• Written Program & Training
• Coordination

7. Occupational Safety & Health Administration
Under the Occupational
Safety and Health Act, the
Occupational Safety and
Health Administration
(OSHA) was created within
the Department of Labor
to:

8. Occupational Safety & Health Administration
• Encourage employers and employees to reduce
workplace hazards and to implement new or
improve existing safety and health programs;
• Innovation of H&S practices
• Develop rights / responsibilities

9. Occupational Safety & Health Administration
• Recordkeeping
• Training
• Develop / Enforce H&S Standards (29CFR)
• State programs

10. Employer Duties:
“General Duty Clause – Section 5(a)”
(a) Each employer
(1) shall furnish to each of his employees employment
and a place of employment which are free from
recognized hazards that are causing or are likely to
cause death or serious physical harm to his employees;
(2) shall comply with occupational safety and health
standards promulgated under this Act.

11. Employee Duties:
29 USC 654
(b) Each employee shall comply with occupational
safety and health standards and all
rules, regulations, and orders issued pursuant to this Act
which are applicable to his own actions and conduct.

12. Confined / Enclosed
Spaces

13. Enclosed vs Confined Space:
1910.269 – Enclosed Spaces
• Limited Entry / Egress
• Not designed for continuous occupancy
• Underground transmission areas or “vaults”

14. Enclosed vs Confined Space:
1910.146 – Confined Spaces
• Large enough for employee entry
• Limited Entry / Egress
• Not designed for continuous occupancy

15. Permit-Required Confined Spaces:
1910.146 – Permit-Required Confined Spaces
• Is a Confined or Enclosed Space
and…
• Contains or has the potential to contain a hazardous
atmosphere
• Contains material that could engulf an entrant
• Configuration is such that it could cause entrapment
• Any other recognized safety or health hazard…

16. OSHA Regulation and the Wind Industry:
• PRCS Reclassification (1910.146(c)5-7)
• (if) The employer can demonstrate that the only
hazard posed by the permit space is an actual or
potential hazardous atmosphere;
• The employer can demonstrate that continuous
forced air ventilation alone is sufficient to
maintain that permit space safe for entry
• Develop and provide continuous monitoring…

17. OSHA and the Wind
Industry

18. OSHA and the Wind Industry:
Electrical Power Generation, Transmission, and
Distribution (generally post-commissioning)
• 29CFR 1910.269 / 1910.146
• Enclosed / Permit-Required Confined Space

19. Employer Duties: Enclosed Spaces
• Evaluate potential hazards
• Safe practices – entry, work, rescue
• Training – hazards, entry & rescue procedures
• Rescue – Provide “prompt” rescue
• Based on the type of hazard / potential

20. Employer Duties: Permit-Required Confined Spaces
The Employer shall: (CFR1910.146(c)(1))
• Evaluate the workplace to determine if any spaces
are permit-required.
1910.146 Appendix A (flowchart)
• Inform Employees of the spaces and their location

21. Employer Duties: Permit-Required Confined Spaces
• Take effective measures to prevent its employees
from entering the permit spaces (if it decides not to
allow employees to enter prcs)
• Develop and implement a written permit space
program as applicable (employer decides to allow
prcs entry)

22. Enclosed / Permit Spaces in the Wind Industry

23. Turbine Sump or “Basement”

24. Turbine Sump or “Basement”
• Limited
entry/exit
• Atmospheric
Hazards
• Electrical
• Environmental

25. Rotor Hub Enclosure:

26. Rotor Hub Enclosure:
• Limited
entry/exit
• Rotational
Hazard
• Mechanical
(pitching)
• Electrical
• Pressurized fluid
• Environmental
hazards

27. Blades:
• Inwardly
converging
walls
• Rotation
• Narrow
configuration
• Atmospheric
hazards
• Limited
entry/exit
• Environmental
hazards

28. Classification:
Start with the hazards in the space prior to entry
• Are they able to be eliminated?
• Are they controlled (Personal Protective
Equipment, ventilation etc.)

29. Classification:
What hazards will be present in the space once work
starts?
• Will the work create a hazardous atmosphere?
(Welding, painting etc)
• Does the work create any other significant
hazard?

30. Classification:
As a rule of thumb, if the hazard in the space is
significant enough to limit or prevent unassisted
evacuation of the space (because of
configuration, injury or exposure) the space should be
considered permit-required.
You must create safe working conditions inside the
space…

31. Written Program (1910.146):
• Identifies the spaces
• Prohibits unauthorized entry
• Specifies acceptable entry conditions
• Provide monitoring & access to monitoring
• Ensures hazard elimination
• Provides all necessary PPE
• Coordinates entry
• Ensures necessary training

32. Training:
• Authorized Entrant
• Authorized Attendant
• Entry Supervisor
• Rescue Team
• Annual Rescue training / evaluation

33. Coordination:
• Communicates status of the space / permit
• Ensures continuity of protection
• Shift changes
• Contractors
• Rescue services

34. In Summary
• Each employer must evaluate its enclosed or
confined spaces
• Develop a program addressing the hazards
associated with the space and potential hazards
• Provide the necessary equipment for safety / rescue
• Provide adequate training for Entrants, Attendants,
Supervisors, Exposed Employees
• Coordinate entries with contractors as necessary

35. For more information…
• 29 CFR 1910.269 (e) Electrical Power
Generation, Transmission, and Distribution
• 29 CFR 1910.146 Permit Required Confined Spaces
• American Wind Energy Association

36. Confined Space Entry – Wind Energy

37. 37
Wind Turbines contain spaces that are considered to be "confined" because
their configurations hinder the activities of employees who must enter into,
work in or exit from them. Employees who work in confined spaces face
increased risk of exposure to serious physical injury from hazards such as:
 Entrapment,
 Engulfment and
 Hazardous atmospheric conditions
Confinement itself may pose entrapment hazards and work in confined spaces
exposes employees to hazards they would otherwise not be exposed to. For
example,
 Removal and reinstallation of heavy pitch pumps and motors
 Accumulator tanks
 Electrical cabinets and battery boxes

38. 38
Many workers who enter into the narrow spaces of
the blade to inspect lightning protection equipment or
repair blades or fiberglass skin can be subjected to
space penetration distances that are excessive
without alternative means of access or escape.
Consequently the workers are then further isolated
from a rescuer.
A number of persons are killed or seriously injured in
confined spaces each year in North America and the
environment in which wind energy operates poses
many confined space hazards to both technicians and
those who would rescue them.

39. Discussion Objectives
• Locations of work vs. Determination
• Hazards Identified
• Hazard and Risk Assessments
• Rescue Planning
• Training Entry, Rescue and Company Policies
• Resources

40. Determination & Work Locations
Regardless of State or Province - Confined spaces are high
risk locations to perform work in. (Countries with Mature
Safety Standards)
o Same underlying theory exists for confined space work
• Determine if there is work in confinement
• Define those locations
• Assess for hazards

41. WTG Anatomy - Basements
Confined Space Assessment
It is sufficiently large for a worker to enter and work Yes
Its entrance and exit have size limitations Yes
Is designed for continuous occupancy No
Basements that meet the CS criteria:
• Simple
• Permit Required

42. IDENTIFYING HAZARDS
• Physical
• Biological
• Chemical
42

43. Non-exhaustive Example
Written Assessment - Basement Survey

44. Non-exhaustive Example
Written Assessment - Basement Survey

45. Non-exhaustive Example
Written Assessment - Basement Survey

46. Non-exhaustive Example
Written Permit Entry

47. Case Study – Need for Training
• Employees who were required to enter the hub (a permit-required
confined space) or act as attendants to employees entering the hub had
not been trained in emergency rescue procedures from the hub.
August 2007 – Excerpt from News Source Oregon Electrical
During its investigation, Oregon OSHA found no structural problems with the
tower. However, several violations of safety rules were discovered, including:

48. Resources
• Confined Space and Structural Rope Rescue, Michael
Roop, Thomas Vines, and Richard
Wright, Published by Mosby, Inc., 1998.
• Safe Work in Confined Space-Wind Industry, Published
by Robert Siegel
ENSA Access and Rescue 2008

49. Robert Siegel – Executive Director
Robsiegel@ensa-northamerica.com
262-705-4558 Mobile
Training@ensa-northamerica.com
www.ensa-northamerica.com
www.ensawerks.com
Wind Energy

50. Questions?
Windpower Engineering
& Development
Steven Bushong
sbushong@wtwhmedia.com
Phone: 440.234.4531
Twitter: @WTWH_Renewables
ENSA North America
Rob Siegel
Rob.Siegel@malloryco.com
Phone: 262.705.4558
Twitter:@ENSATraining
EDF Renewable Services
Scott Bramlett
Scott.Bramlett@edf-re.com
Phone: 858.521.3575

51. Thank You
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 This webinar will be available at windpowerengineering.com & email
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