Confined Spaces: Regulations, Injury Prevention, and Safety Management
Confined Spaces. One of the prime compliance-related topics that employers across industries need to be concerned with. An area where many tragic fatalities and serious injuries have occurred over the years. Not just limited to work access of underground vaults, tanks, storage bins, manholes, pits, silos, process vessels, and pipelines, confined spaces may be found in a multitude of forms. This is an area here you need to consider your exposures and controls on several levels. Those levels include regulatory concerns, safety management concerns, and incident prevention concerns.
It’s always good to outline what is required in your jurisdiction and what approach you will take to get there.
To begin, there are lots of resources out there for setting up and developing programs in this area, such as the following:
State plans such as California’s Cal/OSHA have specific approaches of their own.
There are varied approaches globally as well, such as Canada’s CCOHS guide to confined spaces.
There is also a wealth of information at NIOSH related to confined space issues and injury statistics.
There is also the distinction, made in most jurisdictions, between a non-permit-required confined space and a permit-required confined space. Again, OSHA has some very useful information about permit-required confined spaces.
Any workplace with confined space exposures needs to assess their hazards, decide on controls, and develop a written program. Some good sample written programs from various state and federal entities can provide a good starting point.
Having a written program isn’t the end of program responsibilities. Involved employees must be trained on the program, the program must be implemented and enforced, and revisions and updates must be made when warranted. Ongoing communication and refresher training must be conducted.
There are many good examples of how these requirements have been addressed by various organizations, and also how some programs have added additional elements beyond the regulations to improve program effectiveness.
Some Top of Mind Thoughts
Addressing the regulatory aspect of this is essential, but this is a great issue to consider from an incident prevention perspective as well. To that end, I’d like to highlight three basic questions that can be your starting point for addressing the incident prevention aspect of confined spaces. These questions also make a good jumping-off point for practical, directed employee (and management) awareness of the topic.
Naturally, regulations in any given jurisdiction need to be complied with, but this should always be coupled with a sense of the need to go above and beyond regulations as necessary to reduce the chance of incidents.
Question 1: Is the space difficult to access?
This question is often approached from the regulatory angle, using language along the lines of spaces being designated as confined if a space has limited or restricted means for entry or exit, and it is not designed for continuous employee occupancy. That is fine as a starting point, but I have seen interpretation discussions get hung up on the semantics of the definition.
So consider, as a starting point, to question if a space that is possible to enter, is difficult to access?
Question 2: What difficulties might be faced if someone needs to exit the space in an emergency?
Rescue planning and preparation is a very large part of confined space training and management. Ill-advised rescue attempts by improperly prepared individuals are a significant portion of confined space fatalities.
The simple idea behind the sometimes-complex area of confined space rescue is that any difficulties in exiting the space (or rescuers getting someone out of the space) in an emergency are essential when considering how to use the space with a reasonable level of safety.
Question 3: What hazards are present (or are possible to be present) on the space?
This question is often approached from the regulatory angle, using language along the lines of spaces being designated as permit required based on increased risk of exposure to serious injury from hazards such as entrapment, engulfment and hazardous atmospheric conditions.
Here’s a simple way to approach that concept: What might hurt a worker in the space? And to get one level deeper regarding hazardous atmospheres that might vary or be difficult to perceive, consider this question: How do we know that the atmosphere in the space is safe? This latter question points to the idea that in many cases we need to verify the atmosphere in the space in question and not just operate on assumptions.
The Safety Management Dimension
In conclusion, remember that getting to a state of compliance on paper or achieving some internal audit result is only useful is real-world purposes are also served. Understanding the magnitude of the issue, devoting proper resources to it, seeking effective controls, sustaining performance, and improving over time are all part of the picture. You can’t just dump a copy of the OSHA standard in someone’s lap and expect them to be able to create binder that will get your organization compliant and safe. Thankfully, there are many further great references to guide your steps (Such as the ANSI Z117 standard on Confined Spaces) but you also need to ensure that your approach is appropriately integrated into, and supported by, the overall structure of your organization.