The first step to avoiding fines for violations of the Confined Space standard (29 CFR 1910.146) is knowing how to identify confined spaces. The OSHA definition of a confined space is one that: Is large enough for an employee to enter fully and perform assigned work; It is not designed for continuous occupancy by the employee; and Has limited or restricted means of entry or exit.
Though typically difficult, if you can engineer your space to remove any of those three stipulations, your space is no longer considered a confined space and isn’t subject to the standard. It’s more likely, though, that you’ll need to understand how to make your confined spaces as safe as possible.
OSHA recognizes that some confined spaces are more dangerous than others. Thus, there exists what OSHA refers to as permit-required confined spaces. These spaces satisfy the three conditions of a confined space as listed above but also include ANY of the following:
These permit-required spaces necessitate additional safety measures beyond standard confined spaces. To avoid fines in these permit-required spaces, the following should be addressed:
As with many OSHA regulations, proper paperwork and documentation are essential. These records must be available to OSHA during inspections or investigations.
An employer is responsible for documenting specific processes, safety measures, and control measures that workers must follow during entry into the space, including procedures for atmospheric testing, ventilation, communication, rescue, and other safety protocols.
An employer must also document any time it has determined that all hazards in a permit space have been eliminated, noting the date, the location of the space, and the signature of the person who made the determination.
The key to avoiding fines is being educated on the particular requirements of confined space entry and your responsibilities as an employer to educate each employee about the spaces and their risks.
Naturally, all the guidelines to avoid fines align with strategies for avoiding accidents. After all, the regulations were designed to prevent incidents. That said, it’s one thing to check boxes to clear regulatory hurdles but another to actually facilitate the safety of your workers.
Yes, it’s part of the guidance to avoid fines and non-compliance, but following through and testing the space for the presence of toxic gases or flammable materials is vital before entry. Skipping this critical step could leave a worker incapacitated immediately upon entering the space.
It’s also important that the worker evaluates the condition of the space once inside. Are there any noticeable bury risks, such as materials that could engulf, swallow, or overcome the person inside? Is the worker capable of monitoring oxygen levels?
The normal atmospheric concentration of oxygen is around 21%. Confined spaces can naturally reduce that level through various factors. Poor ventilation, rust, and other chemical reactions can utilize some of the oxygen. Other gases can displace oxygen from the space. Whatever the cause, when oxygen drops to 16%, humans experience increased pulse and respiration. As the percentage dips further loss of coordination becomes an issue. If the oxygen level drops below 10%, workers face nausea, vomiting, loss of consciousness, and even death.
It seems obvious but is too frequently overlooked that simply conducting a thorough evaluation of the space before entry can reduce the likelihood of accidents.
There’s no substitute for training, which is why OSHA has all manner of requirements for training and certifications. When it comes to confined spaces, not only is training about hazards and regulations important, but training to execute emergency procedures in the event an accident happens.
A rescuer who doesn’t know proper protocols is as dangerous to a trapped person as any hazard. Anyone deemed responsible for rescue should be certified to conduct this job. Training should be reviewed and refreshed to help diminish the likelihood that a person relies on instincts in an incident instead of training.
The right equipment is essential to any job, and the same applies to safety. Ensuring workers are provided with proper gear to keep them safe should be a no-brainer, but sometimes loses out to laziness or cost-cutting.
While it’s probably easy to understand the dangers of working in confined spaces, it’s important to note that more than 60% of confined space fatalities occur among would-be rescuers. Think about that: the majority of confined space deaths (of which there are about 100 per year in the U.S.) are NOT the workers who initially got trapped in the space.
Therefore, it’s critical to recognize that even if you follow all the regulations and guidelines, knowing how to react to an incident can be the difference between one death, multiple deaths, or no deaths.
The requirement of a written rescue plan isn’t just bureaucratic. It needs to be considerate of the space and available resources. The more detailed your plan, the better. And written because it’s more likely to be executed.
It’s natural for emotions and adrenaline to take over when a co-worker gets trapped in a precarious situation, and these immediate reactions can supersede training or documentation. Unfortunately, many of these reactions misguide the safest extraction of a trapped person – such as using a winch when it actually puts the victim in more danger, or having the extraction angle incorrect in a vertical rescue.
Without running mock rescues, you may not foresee some of the challenges that can complicate or endanger a rescue, and when time is critical, complications can be deadly. Even if your standby rescue crew satisfies regulations, having an expertly trained and experienced on-site team is always the best way to ensure everyone exits confined spaces alive. Of course, never needing the rescue crew is the ideal situation, but having the crew and not needing it is the superior choice to not having one and suffering an immeasurable loss of life.
The presence of a qualified rescue crew reinforces your commitment to the safety of staffers and allows them to conduct their jobs confidently. It also demonstrates good faith to OSHA or any other investigative bodies when incidents or inspections occur.
Confined spaces can be dangerous – even deadly. But the most harmful thing about them is apathy toward the details of making these spaces safe for workers. Having a sound plan and following through with that plan can prevent your confined spaces from ever leading to fines, injuries, or deaths. An expert safety team like SITEX ensures you always meet compliance regulations and provide the safest confined space working conditions for your employees.
SITEX saves lives. For over 35 years we’ve delivered safety services, environmental services, industrial hygiene expertise, rescue solutions and training, and rental equipment to ensure compliance, reduce risk, protect workers, and promote safety in every industry. We invest in highly trained personnel and technology so you don’t have to.
