Wines & Vines

September 2015 Finance Issue

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September 2015 P R A C T I C A L W I N E R Y & V I N E YA R D 67 C onstellation Brands manage- ment teams in the Central Coast region contacted California Health & Rescue Training to assist them in developing a confined space training program in late 2014. They felt strongly that confined space entries continue to be a highly dangerous opera- tion, and they wanted to enhance the training of all personnel. They had identi- fied specific personnel within their facili- ties that they wanted to focus specialized training for in order for them to provide in-house training of other employees. A "train-the-trainer" program was developed for 10 Constellation Brands personnel. The personnel were selected based on the facility where they worked, their ability to develop as a trainer and their leadership qualities. They were given 24 hours of instruction and the training materials to instruct other employees. The expectation was to develop sub- ject matter experts who would be work- ing the production floor and instructing co-workers on proper confined space protocol. This approach would enhance the ownership aspect of safety among all employees. The program needed to ensure that all mandatory components of the "Permit Required Confined Space Regulations" found in California Code of Regulations section 5156, 5157 and 5158 under the California Occupational Safety Health Administration (Cal/OSHA) were being met. While many industries in California have been successful in securing vari- ances or exemptions from the most strin- gent confined space regulation (section 5157), winery operations do not have that option and must comply with the "Permit Required Confined Space" regu- lations found in section 5157. The focus of the training was to dis- cuss and review options for ensuring proper training in rescuing workers who may become incapacitated while working in any space classified as "per- mit required." The safety managers felt relatively comfortable with the entry program but noted there were lapses in the contingencies for rescue. The team wanted to improve the "hands- on" training and contingency planning specific to rescue. The regulations clearly list mandatory components and positions that must be met. The difficulty in the regulations are that, while it lists mandatory com- ponents, it provides latitude in how to comply with those components and, in some cases, it allows dropping some or all of them if we can reclassify the space or provide for alternate entry. The con- sensus of the group was to deal with all of the spaces as "permit required" and not attempt to do a reclassification or alternate entry. Despite eliminating hazards and providing ventilation to assure that no hazardous atmosphere can develop, the truth is you can never truly assure that all hazards have been eliminated. When you ventilate, you can still develop pock- ets of bad air even if you calculate venti- lation air exchanges. Training is important for removing someone from a confined space. With these components in mind, the managers felt much more comfortable defending the program if it considered all tanks to be "permit required." Below is a brief outline of the mandatory components of the permit-required regulations that need to be covered in every confined space entry/rescue plan. Mandatory components Training: Training appropriate to the position and task of the employee. The regulation lists three basic positions: entry supervisor, attendant and autho- rized entrant. The employer must pro- vide appropriate training for employees holding those positions. Equipment: The employer must pro- vide the equipment needed to safely and effectively complete entry into the confined space. Examples of equipment needed would be atmospheric monitor- ing equipment, lock-out/tag-out equip- ment, harnesses and retrieval poles and lines. Written procedure: The regulation clearly requires that the employer develop a written plan outlining the expectation of performance for the employee. This written plan should list not only what it is expected that the employee will do, but also what they should not be allowed to do, making them aware of the hazards they may face when making entry. Entry permit: This document is Kent Freeman, California Health & Rescue Training, Roseville, Calif. BY Entry into Permit-Required Confined Spaces BEST SAFETY PRACTICES An authorized entrant equipped with harness and personal atmospheric monitor prepares to enter a wine tank. W I N E M A K I N G PHOTOS BY KENT FREEMAN

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