By Glenn McGinley, Director, Ohio Public Employment Risk Reduction Program and member of the NFPA Technical Committee on Confined Space Safe Work Practices
Have you ever had a feeling of claustrophobia – that feeling that you’re trapped and a longing for open spaces while the refrain of “don’t fence me in” plays repeatedly in your mind?
Maybe your intuition is trying to tell you something…something you should listen to.
Each year, on average, at least one worker dies every week performing work in confined spaces and dozens more are seriously injured. According to the Bureau of Labor Statistics (BLS) Census of Fatal Occupational Injuries (CFOI) program, there is an average of 92 confined-space-related fatalities every year.1
Unfortunately, these fatality statistics don’t fluctuate very much year to year and the overall number of annual fatalities hasn’t changed much since the creation of the OSHA “general industry” permit-required confined spaces (29 CFR 1910.146) in 1993. In 2015, a new OSHA standard for the construction industry (29 CFR 1926 Subpart AA) went into effect and this new standard and other new publications have turned the spotlight on the hazards of confined space work.
So why hasn’t there been a significant reduction in confined space related fatalities? I think the answer is a lack of recognition of the nature and existence of confined spaces in workplaces.
Many workplaces have enclosed or confined spaces that require procedures, training and appropriate equipment before employees can safely enter and perform assigned work tasks. However, many times employers have not identified these spaces and employees are unaware of their existence or the precautions that are necessary to ensure their safety.
What is a confined space?
The OSHA standards define a confined space as a space that:
- Has a restricted or limited means of entry/exit;
- Isn’t designed for continuous occupancy by employees, but is large enough for employees to “bodily enter” and perform work.
There are a lot of work areas that meet this definition. When a hazardous condition exists or is introduced into that work space it can become life threatening very quickly. Examples of confined spaces include sewers, silos, vats, vaults and tanks (open and closed). Areas like crawlspaces, air handlers and ductwork are also prime examples of confined spaces.
The standard also identifies high risk spaces or “permit-required” confined spaces as those spaces that have one or more potentially hazardous characteristics that include:
- An actual or potentially hazardous atmosphere;
- Material(s) that can engulf (cover or trap) an entrant;
- Walls that converge inward or floors that slope downward and taper into a smaller area which could trap or asphyxiate an entrant;
- Any other recognized safety or health hazard (e.g., unguarded machinery, exposed energized electrical wires and temperature extremes).
So, what are some best practices that employers can use to identify confined spaces and ensure they eliminate or control hazardous conditions when employees work in or around those spaces?
The following are resources to help you identify confined spaces and then begin the process of developing and implementing a confined space program in your workplace.
The National Fire Protection Association (NFPA) recently issued NFPA 350, Guide for Safe Confined Space Entry and Work. This extensive resource focuses on “best practices” and provides a how-to for confined space entry and work. The document explains and interprets what the regulations require and provides practical approaches to implement those requirements. The OSHA standards establish minimum requirements, while the “NFPA 350 strives to establish work practices that achieve a higher level of safety.”
OSHA Publication 3825, (September 2015), Protecting Construction Workers in Confined Spaces: Small Entity Compliance Guide addresses some of the most-common compliance issues that employers will face. While OSHA has geared it toward the construction industry, many of the concepts are useful for developing a program for any workplace. OSHA also has “safety and health topics” pages with additional confined resources for general industry and construction employers.
The National Institute for Occupational Safety and Health (NIOSH) also has a web page devoted to confined space information. The web page contains several resources, including the results of fatality investigations and health hazard evaluations that it has conducted under the NIOSH Fatality Assessment and Control Evaluation (FACE) and Health Hazard Evaluation (HHE) programs.
BWC’s multi-disciplinary team of experts and services can assist you with identifying confined spaces in your workplace and with the process of developing a confined space program.
BWC also has an excellent training program on Confined Space Assessment and Work and a confined space “Safety Talk” that can help jumpstart the confined space conversation in your workplace.
Our team is available to help your team improve safety in your workplace. Give us a call today!
1 Source: U.S. Department of Labor (USDOL), Bureau of Labor Statistics (BLS) Census of Fatal Occupational Injuries (CFOI).