The first step in developing a confined space program is to identify these spaces in your workplace. Many confined space fatalities have occurred because an employer failed to recognize the presence of a confined space. While there are several different definitions of what constitutes a confined space, one characteristic is consistent and stands out above the rest-a confined space is NOT DESIGNED FOR HUMAN OCCUPANCY. I once heard an instructor say that if you cannot or would not comfortably put your desk in a space and work there all day then your radar should go up and you should think “possible confined space”. A confined does not necessarily have to be small and “confined” it simply has to be “not designed for continuous human occupancy”. While spaces such as sewer manholes, vaults and tanks may be more readily identified as confined spaces, there are other spaces such as tunnels, vaults, crawl spaces, pipelines, boilers, water reservoirs, ship holds and elevator shafts that may not be as recognizable as confined spaces. A tank that held petroleum may be clearly recognized as a confined space due to the chemical vapors. However a tank that has only held water may not be recognized as a confined space. Yet a rusted water tank could contain a low oxygen atmosphere.
Another key characteristic of a confined space is that it has a limited or restricted means for entering and exiting the space. What does this mean? It means you cannot just walk directly into the space through a doorway or down a set of standard stairs to access the space. Typically access to confined spaces is via a ladder or perhaps a spiral staircase or through a hatch or small opening. Sometimes you must contort your body or crawl to work in, get into or get out of the space. One such example would be a shallow crawl spaces with lots of pipes obstructing access or egress.
A full audit of your workplace should be done to determine if there are any confined spaces present. OSHA 1910.146 Permit-Required Confined Space Entry Standard requires employers to evaluate the workplace to determine if there are any confined spaces. Once identified, these spaces must be labeled and employees informed of the presence of such spaces. OSHA does identify the characteristics of a confined space but does not specify the competencies required of the individual who will evaluate the workplace to determine if confined spaces are present.
NFPA 306, Control of Gas Hazards on Vessels, requires a marine chemist with specific qualifications for evaluating confined spaces on marine vessels. There is no such requirement for other industries although the American Petroleum Institute does have a certification program that provides a body of knowledge for those who serve as API certified tank entry supervisors.
Do you have someone in your workplace qualified to identify the presence of a confined space? Once identified, can theis individual identify the hazards in those confined spaces anddo they know how to eliminate or control those hazards?
The NFPA technical committee on confined spaces will be developing a best practices guide for confined space entry. One possible topic we may include in this document is the training/competencies required for evaluating the presence and hazards of confined spaces. What type of qualifications do you think someone should have to be able to identify confined spaces and their hazards? Do you feel that this evaluation needs to be done by a safety or health professional or simply by a knowledgeable individual who has been trained to recognize confined spaces? Let us know what you think!
(Next blog topic-Identifying Hazards in Confined Spaces)