This incident highlights the need to better identify and maintain awareness about work activities that could change the status of confined spaces. The M&O contractor had not anticipated that abrasive blasting would generate particulates that could reach hazardous levels when its representative issued the daily work permit for work in a non-permit status confined space. Therefore, the site management assumed that the tank was in a non-permit status. The subcontractor, on the other hand, knew that blasting produced high levels of particulates and required supplied air respirators. It did not provide any air monitoring to measure the concentration of particulates in the air, but relied on its prior experience to select PPE for its blasters. Site responders to the medical emergency relied on the 4-gas monitor to assure themselves that no atmospheric hazards existed, unaware that a particulate hazard might still exist, because there was no monitor present to measure this hazard. Responders had no air monitoring equipment with them and did follow their permit-required confined space entry procedures when they entered the tank.
Lessons Learned: Identification and communication processes for classifying and reclassifying confined spaces should be strengthened to address the potential that work activities may change the conditions within those spaces.
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