I’m writing about confined spaces today because they are often overlooked in the workplace from a safety standpoint… and there is an important policy change in three weeks.
Confined spaces are large enough for workers to enter and perform certain jobs. A confined space also has limited or restricted means for entry or exit and is not designed for continuous occupancy. Confined spaces include places such as manholes, pipelines, tunnels, tanks, ducts and more.
Occupational Safety and Health Administration (OSHA) announced last week a 60-day temporary enforcement policy of its Confined Spaces in Construction standard, which becomes effective Aug. 3, 2015. The agency is postponing full enforcement of the new standard to Oct. 2, 2015, in response to requests for additional time to train and acquire the equipment necessary to comply with the new standard.
According to OSHA, during this 60-day temporary enforcement period, OSHA will not issue citations to employers who make good faith efforts to comply with the new standard. Employers must be in compliance with either the training requirements of the new standard* or the previous standard. Employers who fail to train their employees consistent with either of these two standards will be cited.
OSHA also shared in a press release the factors that indicate employers are making good faith efforts to comply include: scheduling training for employees as required by the new standard; ordering the equipment necessary to comply with the new standard; and taking alternative measures to educate and protect employees from confined space hazards.
OSHA issued the Confined Spaces in Construction final rule on May 4, 2015. The rule provides construction workers with protections similar to those manufacturing and general industry workers have, with some differences tailored to the construction industry. These include requirements to ensure that multiple employers share vital safety information and to continuously monitor hazards – a safety option made possible by technological advances after the manufacturing and general industry standards were created.
The confined spaces rule could protect nearly 800 construction workers a year from serious injuries and reduce life-threatening hazards, according to OSHA.
Permit-required confined space
OSHA uses the term "permit-required confined space" (permit space) to describe a confined space that has one or more of the following characteristics: contains or has the potential to contain a hazardous atmosphere; contains a material that has the potential to engulf an entrant; has walls that converge inward or floors that slope downward and taper into a smaller area which could trap or asphyxiate an entrant; or contains any other recognized safety or health hazard, such as unguarded machinery, exposed live wires, or heat stress.
Arbill’s safety professionals often see firsthand many workplace spaces that are considered to be “confined” because they hinder the activities of employees who must enter into, work in or exit from them. Our experts often note that many employees who work in confined spaces also face increased risk of exposure to serious physical injury from hazards such as entrapment, engulfment and hazardous atmospheric conditions.
OSHA has documented that confinement itself may pose entrapment hazards and work in confined spaces may keep employees closer to hazards such as machinery components than they would be otherwise. For example, confinement, limited access and restricted airflow can result in hazardous conditions that would not normally arise in an open workplace.
Employers must evaluate their workplaces to determine if spaces are permit spaces. If a workplace contains permit spaces, the employer must inform exposed employees that they exist, where they exist, and hazards they pose. One way to communicate this is with signage such as “DANGER—PERMIT-REQUIRED CONFINED SPACE—AUTHORIZED ENTRANTS ONLY” or something very similar.
Employers must take effective measures to prevent their workers from entering these spaces. If employees are expected to enter permit spaces, the employer must develop a written permit space program and make it available to employees or their representatives.
OSHA further stipulates that the employer’s written program should establish the means, procedures and practices to eliminate or control hazards necessary for safe permit space entry operations. This includes specifying acceptable entry conditions, isolating the permit space, providing barriers, verifying acceptable entry conditions, and purging, making inert, flushing or ventilating the permit space.
In addition to personal protective equipment, other equipment that employees may require for safe entry into a permit space includes: testing, monitoring, ventilating, communications and lighting equipment, barriers and shields, ladders, and retrieval devices.
Detection of Hazardous Conditions
If hazardous conditions are detected during entry, employees must immediately leave the space. The employer must evaluate the space to determine the cause of the hazardous atmosphere and modify the program as necessary.
When workers are prohibited from entering permit space, the employer must take effective measures to prevent unauthorized entry. Non-permit confined spaces must be evaluated when changes occur in their use or configuration and, where appropriate, must be reclassified as permit spaces.
It’s important to note that a space with no potential to have atmospheric hazards may be classified as a non-permit confined space only when ALL hazards are eliminated in accordance with the standard. If entry is required to eliminate hazards and obtain data, the employer must follow specific procedures in the standard.
Arbill offers Confined Space training that is designed to teach the worker to recognize the spaces and hazards, recognize the health effects of exposure, proper selection and use of PPE, and the duties and responsibilities for the confined space entrants. Arbill also offers Confined Space Rescue Training for any individuals who during the course of their employment is expected to make rescues from confined spaces. A combination of drills and classes will take place to teach the proper response to chemical emergencies or other confined space issues by personnel expected to make rescues.
Have a safe day!