Confined Spaces

3 min read

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November 2016

For those who work in confined spaces, awareness of surroundings can mean the difference between life and death. These situations call for rules specifically designed to help maintain heightened awareness of the potential dangers of working in environments considered “confined.”

The Occupational Safety and Health Administration (OSHA) introduced the construction standard for confined spaces (CFR1926.1200, subpart AA) on May 4, 2015. This standard includes construction on electrical power transmission, and distribution lines and equipment. Prior to OSHA’s May release, those performing construction had to apply the confined space rules outlined in the general industry standard (CFR1910.146) to their own work and daily tasks. The general industry standard rules were meant to be applied universally, but lacked the specificity needed in the confined space situations encountered in construction.

According to OSHA, a confined space must meet all of the following criteria:

1. Is large enough and so configured that an employee can bodily enter and perform assigned work;
2. Has limited or restricted means for entry or exit (for example, tanks, vessels, silos, storage bins, hoppers, vaults and pits are spaces that may have limited means of entry); and
3. Is not designed for continuous employee occupancy.

Examples of confined spaces related to utilities include manholes, utility vaults, utility subbasements, water tanks, filter tanks and clarifiers.

Some confined spaces may necessitate the acquisition of a permit prior to entry due to the presence or potential presence of certain hazards. Permit-required confined spaces have any one or more of the following characteristics:

1. Contain or have a potential to contain a hazardous atmosphere;
2. Contain a material that has the potential for engulfing an entrant;
3. Have an internal configuration such that an entrant could be trapped or asphyxiated by inwardly converging walls or by a floor which slopes downward and tapers to a smaller cross-section; or
4. Contain any other recognized serious safety or health hazard.

One of the most impactful changes to the construction standard is the way in which employers must now approach the planning process prior to allowing employees to enter a space defined as “confined,” including additional measures which must be taken in order for employees to be in compliance when they enter.

Many alterations were made to the construction industry standard in an effort to align with the general industry standard. These changes include requiring continuous atmospheric and engulfment hazard monitoring when possible, the addition of attics and crawl spaces as confined spaces, and the opportunity for permit suspension instead of cancellation under certain circumstances.

One of the most impactful changes to the construction standard is the way in which employers must now approach the planning process prior to allowing employees to enter a space defined as “confined,” including additional measures which must be taken in order for employees to be in compliance when they enter. According to the updated rule, the work site must first be evaluated for the presence of confined spaces, with points of entry and exit identified, air quality testing performed to ensure proper ventilation methods, and precautionary rescue procedures determined. Training must also be completed in a language that is understood by the employee.

The new standard provides more concrete guidance to employers and employees within the construction and utility industry, helping to better safeguard workers and prevent unnecessary injuries and fatalities that can occur in confined space situations.

AMP places a high priority on member safety and preparation through education. A confined space entry and rescues class is offered as part of AMP’s monthly, subscription-based OSHA Compliance Program, intended to help members learn the safe and compliant practices for entering and exiting confined spaces. The OSHA Compliance program currently has 38 subscribing members and approximately 1,000 monthly participants from member communities.

For additional information on AMP’s safety programs, please contact Kyle Weygandt, director of member safety, at [email protected].