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A confined space ultimately depends on what that space is going to be used for. For example if the space is going to hold a lot of office equipment then the size may not matter, however if staff are going to be using it then a confined space will not be the best choice.

Nancy Pearce

It is sometimes difficult to define a confined space. Personally, I think the best screening is to ask "Is this space DESIGNED for regular human occupancy"? If it is NOT then you have to ask if there could be hazards that would prevent safe entry, work and exit from the space. We LOVE to get your comments and will be looking for lots of feedback when we publish a draft of the best practices document by the end of 2013. Follow the progress by signing up for alerts at www.nfpa.org/350.

Jeff Martyka

General Industry has a long way to go in understanding what a Confined Space is. Many employers do not have anyone who has the skills or knowledge to properly classify/identify a space so equipment like parts washers and pits are routinely entered by untrained and uneducated employees.

Construction understands the situation a lot better and MANY trade unions now include the training as part of their apprentice training program. However, many "events" occur when classification, air monitoring or ventilation "short cuts" are taken.

Even worse is when a construction activity starts in a general industry "Confined Space", either by in-house employees or contractors, and all kinds of confusion will be occur!

Test your air, ventilate, eliminate the potential of engulfment/entrapment, blind/block are needed prior to ANY Confined Space entry. Maintain the above and you will send home every employee the same way you sent them into the space- - - It's that simple!

What is needed is a serious definition that EVERYONE can understand! Limited means of entry/exit, not designed for continuous human habitation and Void of recognized hazards would make MOST entryway closets in our homes classify as a CONFINED SPACE! (Yes, I am taking liberties!)

Maybe- ANY TANK, VESSEL, VOID, CONTAINER, SPACE DESIGNED TO CONTAIN A LIQUID OR GAS, IS HEATED OR CHILLED, HAS AN OPENING THAT IS BOLTED, WELDED, DOGGED OR HELD CAPTIVE DURING NORMAL OPERATIONS would be a better start of the definition of "CONFINED SPACE" and eliminate the confusion of "IS IT" or "IT'S NOT" as well as saving a few lives every year!

We are long overdue and owe it to our work force to FINALLY get a document out that easily/clearly/forcefully eliminates confusion and is of extreme use!

Nancy Pearce

It will be interesting to see if OSHA does release the confined space construction standard soon....It was on the regulatory agenda for 2012! And agree... thorough risk assessment and control of hazards prior to entry is essential. Never mind just following the basic regulations... let's move beyond this and towards best practices!!

Steve Osborne

My experience is that construction always wants confined space entry requirements relaxed. I understand the cost and schedule implications, but I disagree with the practice.

Are the primary hazards (oxygen depletion; exposure to toxic or reactive materials; falling objects; collapsing walls; etc.) any different? No, they are not. The same standards should be applied to ALL confined space entries.

I am not against the use of limited personal discretion, but anything less than strict compliance with CSE standards must be discouraged until AFTER a thorough risk assessment takes place. These are human lives (mothers, fathers, sons, and daughters) at stake.

Paul Burnett

California's Cal/OSHA has had two different confined space regulations for decades - one is for "general industry" and the other is for construction, agriculture, natural gas and electrical and other special exposures.

Whether a given space is a confined space or not, or a permit space or not, if it makes sense to use air monitoring, ventilation, fall protection, hot work control and whatever else...go for it if it keeps entrants safe.

Nancy Pearce

I completely agree that we should have a single standard, however, the current OSHA standard on confined spaces does not cover the construction industry. The assertion was that in construction there are confined spaces that are constantly created and eliminated as construction takes place. The intent of the NFPA Best Practices document is to cover the safe work practices for all industries. If you would like to follow the progress of the document, sign up for alerts on the NFPA document information page at www.nfpa.org/350. We are meeting again for the second time in two weeks to continue work on a draft document! Thank you for your comments!

Jennifer Tetreault, HazCommpliance

I would tend to agree with Mr. Northam. The basic idea is to assess, test and monitor no matter what the hazards are, in any industry. My opinion that to create standards so specific to different industries can actually be more confusing, as there are always instances that may not be pigeon-holed in to each and every category. At that point, it would default to the general rule: assess, test and monitor.

Chuck Northam

29CFR1910.146 is general enough to include construction activities. Some already mention evaluating the space for hazards, such as trenches/excavations and welding. Hazard identification is the key, and it's a matter of having the expertise and equipment to do it properly. It can be applied to any situation.

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