Nancy Pearce is the staff liaison to the NFPA 350 Technical Committee and for more than two years she has been working on this document which has the following scope:
“This guide is intended to protect workers who enter into confined spaces for inspection or testing or to perform associated work from death and from life threatening and other injuries or illnesses and to protect facilities, equipment, non–confined space personnel, and the public from injuries associated with confined space incidents.”
I had a few minutes to talk to Nancy about the history, timeline and importance of NFPA 350.
Q: Why is NFPA 350 so important? A: There are still almost 100 workers killed each year in confined spaces in the United States. Confined spaces can be found in many facilities and workplaces so unless they are identified and confined space entry procedure developed, these spaces will continue to be “ticking time bombs” that under the right conditions can kill an unsuspecting worker.
Q: What was the timeline of the creation of NFPA 350? A: First meeting of the committee held Sept 2012. Preliminary draft to Standards Council for approval August 2013. Out for public input until January 2014. First draft meeting held April 2014. Out for comment until November 2014. Second draft meeting held April 2015. Open for NITMAMS until August 21, 2015. No NITMAMS so will be released this November.
Q: Who are the people that NFPA 350 will help? A: Ultimately the people who go into those spaces will benefit if their employer follows OSHA regulations and uses NFPA 350 to help them comply with those regulations. But will help those using OSHA regulations-supplements and supports, provides guidance and how-to’s and goes beyond minimums which will help improve worker safety.
Q: What is the difference between OSHA requirements and NFPA 350? Or in other words, how does NFPA 350 bridge the gap between OSHA? A: NFPA bridges the gap between performance based minimum confined space entry standards by providing some of the “how to’s” and best practices for activities such as hazard identification and control, gas monitoring and ventilation. It also starts to define competencies for those involved in confined space entry and encourages the use of management of change and prevention through design to get to the core of many confined space entry challenges.
Q: What has been your most challenging moment in working with the technical committee? What has been the most rewarding thing in dealing with the technical committee?
A: Most challenging-discussion about how to “fix” and simplify some of the language in OSHA standards. For more than 20 years the term “permit-required confined space” has been used yet it continues to create confusion. The most rewarding was when we figured out how to simplify the language without conflicting with existing standards.
Nancy went on to say “Confined space entry is a real passionate subject for me. To have an opportunity to impact confined space safety and to go beyond the minimums is something I would not have envisioned and is the most rewarding and impactful project I have worked on in my 30 (plus) year career as a safety professional. We still have work to do but the committee is just as passionate as I am and we are determined to continue to improve and add to the document as we revise it over the next few cycles.”
Nancy will be hosting a live, online training event on October 28, 2015 from 11 am to 1 pm EDT on the subject of “What’s New in Confined Space Entry.” Click here for more information or to register.