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Can a single regulatory standard or best practices document adequately address confined space hazards in all types of workplaces? Or do the hazards of confined spaces vary so much from workplace to workplace that no single standard can adequately address all industries?
OSHA’s Permit Required Confined Space Standard published in 1993 covered only general industry and not construction. OSHA indicated that the 1910.146 standard had not included construction due to the unique confined space hazards found in the construction industry. Fourteen years later, in 2007, the proposed OSHA Construction standard was published in the Federal Register. The standard was listed on OSHA's 2012 regulatory agenda, however to date it has not been finalized. When published, OSHA will have separate standards for construction and general industry, as well as Shipyard standards that address confined space hazards in the maritime industry.
Oregon OSHA recently published its regulation on Confined Spaces that includes BOTH general industry and construction. This rule, Confined Spaces in General Industry and Construction, become effective in Oregon in April 2013 and covers the safety and atmospheric hazards in both types of workplace settings.NFPA is developing a Best Practices Document for Confined Space Entry. There is general agreement that this document should include all confined space entries regardless of whether they occur in general industry or construction. Are the hazards of confined spaces similar enough in both industries that a single standard or best practices document is possible? We would love to hear your thoughts on this!
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.
Posted by: Chuck Northam | 01/04/2013 at 02:19 PM
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.
Posted by: Jennifer Tetreault, HazCommpliance | 01/04/2013 at 02:35 PM
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!
Posted by: Nancy Pearce | 01/04/2013 at 03:26 PM
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.
Posted by: Paul Burnett | 01/04/2013 at 03:42 PM
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.
Posted by: Steve Osborne | 01/04/2013 at 04:22 PM
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!!
Posted by: Nancy Pearce | 01/04/2013 at 04:32 PM
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!
Posted by: Jeff Martyka | 01/04/2013 at 05:31 PM
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.
Posted by: Nancy Pearce | 01/04/2013 at 08:55 PM
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.
Posted by: yorkshireprofiles | 02/19/2013 at 08:27 AM