Many facility managers get understandably confused when they try to decide if they have to comply with the Occupational Safety and Health Administration (OSHA) standard on Confined Spaces (29 CFR 1910.146).  OSHA requires all workplaces to evaluate the entire facility and determine if there are any permit-required confined spaces. This process has two steps.

Step 1:  Does It Meet the Definition?

You first must evaluate any potential space to see if it meets the definition of a confined space. The OSHA definition of a confined space has three parts:

1. It is large enough and so configured that an employee can bodily enter and perform assigned work. This means the employee must fit his entire body into the space.
2. It has limited means of entry or exit. This could mean a single entry/exit or multiple entries/exits that are very small or hard to get through.
3. It is not designed for continuous employee occupancy. For example, it is not designed to have an employee inside while the system is in operation.

If any spaces meet all three of these parts, then it is a confined space.  If it only meets one or two, it may still be a hazardous area, but it is not a confined space, and 29 CFR 1910.146 does not apply.  As an example, a basement may meet the first and second parts but, as it is designed for employee occupancy, it would not be a confined space.

When it does meet all three of these parts, then the facility must determine if its employees will enter the space. If they will not enter the space, the facility still has requirements to secure the space to make entry difficult, install signage marking the hazard near the point of entry, and train employees where the spaces are and why they should not enter.

If employees will enter the space, then you must conduct Step 2.

Step 2:  What Is the Hazard Type?

You must evaluate each space to see what hazards may exist.  OSHA has identified four potential hazards in a Permit-Required Confined Space

1. Atmospheric: It contains or has a potential to contain a hazardous atmosphere.  Such spaces may lack oxygen, contain toxic gases, have flammable vapors, or hold combustible dust.
   
   EH&S Managers should keep in mind that some spaces may only temporarily have hazardous atmospheres. Tanks and pits that do not normally present a risk could develop a hazard episodically or accidentally.  An example could be a pit that fills with a heavy vapor from a nearby propane fueling area or vehicle fumes.
   
   In order to determine if your space meets any of these conditions, the facility must use an air monitor; normally a three-gas meter that detects oxygen levels and, toxic and flammable gasses.  In addition, you must train any employees who would enter the space to use the meter
   
   
2. Engulfment: Contains a material that has the potential for engulfing a person.  This would include either liquids (water or chemicals) or solid materials (like dusts, grains or resins).  If an worker sinks into particles up to his diaphragm, he has the potential to be asphyxiated before he can be rescued.  Even if a space is temporarily empty, facility managers should remove the potential for the space to fill by locking out any pipe or valve systems that could fail and fill up a space while an employee inside.
   
   
3. Entrapment: The defined confined space has an internal configuration that can trap or asphyxiate an employee by inwardly converging walls, sloping floors, tapering spaces.  Dust collection systems are examples of the inwardly converging walls, while ventilation systems may slope downward and taper at the ends.
   
   
4. Others: Any other recognized serious safety hazard.  This covers a multitude of potential hazards such as electrical, thermal, corrosives, and mechanical hazards such as rotating parts, augers, or blades.
   

If the confined space has one or more of the above hazards, then it falls under the OSHA requirements of a Permit-Required Confined Space for entry.  The employer must prepare a written program that details how the company will protect the employees who enter the space including preparing a permit, training employees, monitoring the space to ensure acceptable conditions are maintained, and emergency rescue equipment.

Exemptions

There are two potential exemptions to the regulation. Employers can install equipment to eliminate mechanical or electrical hazards from the exterior before entering the space or add a forced-air ventilation system to disperse atmospheric hazards.  In each of these exemptions, OSHA requires clearly defined procedures and periodic testing to ensure worker safety.

Safety First

Dozens of workers are injured each year in confined spaces.  It is the employer’s responsibility to ensure that any entry into a confined space must be according to the rules and be safe.  It’s up to you to get your employee home safely at the end of every shift.

Cornerstone offers the most comprehensive hazard evaluation service in the industry, call us today to discuss your confined space program. www.corner-enviro.com

Roger Andrews is the Director of Training Services for Cornerstone Environmental, Health and Safety. He regularly consults with clients in the all areas of OSHA, EPA Hazardous Waste Training, Storm Water Training, Spill Prevention Control and Countermeasures Training and DOT Transportation of Hazardous Materials Training.