This post is based on an article written by David Kennedy which originally appeared in the August 2016 issue of Occupational Health & Safety.

Based on OSHA statistics, almost two workers are killed each week in confined space-related accidents.

That’s 92 deaths and nearly 11,000 injuries per year. Of those 92 annual deaths, one-quarter of them occur during repair, maintenance, cleaning, and inspection activities done in enclosed spaces.

Sadder yet is the fact that between 40 and 60 percent of all confined space deaths include would-be rescue workers.

Despite OSHA’s spotlight on confined spaces, the number of deaths remains relatively the same as 23 years ago.

In November last year, the National Fire Protection Association released NFPA 350: Guide for Safe Confined Space Entry and Work to provide extended guidance and best practices to fill in gaps or confusion in relation to OSHA standard 29 CFR 1910.146.

What’s Considered a Confined Space?

Working in ovens, silos, reaction vessels, vats, boilers, holding tanks, pits, or similar structures or enclosures qualifies as working in a confined space.

OSHA defines a confined space as one that is large enough for an employee to enter fully and perform assigned work; is not designed for continuous occupancy by the employee; and has a limited or restricted means of entry or exit.

According to NFPA 350, “All confined spaces have the potential to become OSHA-defined permit-required confined spaces, depending on the work to be performed and the inherent, potential, or introduced hazards in the space at the time of the entry.”

Permit-Required Confined Space – What’s That All About?

OSHA standards designate a permit-required confined space when it has a hazard to health or life associated with it, such as containing a hazardous atmosphere; material with the potential to engulf someone who enters the space; an internal configuration that might cause an entrant to be trapped or asphyxiated by inwardly converging walls or by a floor that slopes downward and tapers to a smaller cross section; and/or contains any other recognized serious safety or health hazards.

Hazard Abatement – Best Solution is to Eliminate the Hazard!
Whether it is a confined space or a permit-only confined space, the same health and safety hazards that typically exist on the shop floor, such as ergonomic hazards, slips and falls, overexertion, explosion, and uncontrolled release of energy also exist in confined spaces. However, in confined spaces, there is a smaller margin for error!

Any time organizations can engineer out or minimize health and safety hazards with controls, it reduces risk and therefore it is the preferred method of handling hazards. This is why the NFPA dedicated an entire chapter in NFPA 350 to hazard elimination and control.

Because 25 percent of confined space deaths occur during cleaning, NFPA 350 states, “whenever possible, workers should clean the confined space from the outside, without the need for entry.”

If eliminating entry entirely is not a feasible solution, evaluate if the exposure can be severely limited by using industrial grade vacuum cleaning systems or other means to do the majority of the work while standing outside the confined space area.

Another option is to contract the confined space work to an outside contractor with the well-trained personnel and equipment needed to complete the task safely. This shifts the majority of the responsibility and liability to the contractor, once you have properly completed the due-diligence necessary to select a contractor who can provide documented proof of proper confined space training.

For further assistance, please contact us.