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Performing the Confined Space Assessment
By W. Jon Wallace, CSP, MBA
"One worker died after entering a toluene storage tank. During the rescue attempt, a fireman was killed when the tank exploded."
Confined space fatalities such as this example are a common occurrence in the workplace. According to NIOSH, during the 10 year period from 1980 to 1989, 585 separate fatal incidents occurred in confined spaces, claiming 670 victims. Unacceptable atmospheric conditions, such as toxic atmospheres or lack of oxygen, contributed to over half of the confined-space related deaths. Engulfment from loose materials, such as excavation cave-ins, contributed to approximately one-third of the fatalities. The remaining 10% of confined space fatalities were caused by drownings and engulfments in other materials (i.e., sludge and manure).
On January 14, 1993, in response to the large number of employees killed while working inside confined spaces, OSHA issued its final rule on Permit-required confined spaces 29 CFR 1910.146. This standard contains several requirements intended to ensure employee safety while performing work in confined spaces.
The first step in implementing an effective confined space program is to conduct a facility-wide confined space assessment to identify all confined spaces. OSHA defines a confined space as a space that meets all three of the following criteria:
The confined space assessment is now complete and all permit-required confined spaces have been identified. Employers must inform employees of the presence of confined spaces by posting danger signs, or by any other effective means, such as training and written procedures. Please remember that employers may utilize a definition of a permit-required confined space that is more stringent than OSHAs definition.
If an employer elects not to have employees enter permit-required confined spaces, appropriate measure must be taken to prevent employees from entering these spaces. If it is decided that employees will enter permit-required confined spaces, the provisions of 29 CFR 1910.146 must be satisfied. However, a company may elect to use alternate procedures or reclassification. These options eliminate the requirements for entry permits, attendants, rescue provisions and mechanical retrieval devices.
Alternate procedures and reclassification are defined as follows:
Alternate Procedures: The employer can demonstrate that that the only hazard posed by the permit space is an actual or potential hazardous atmosphere and that continuous forced air alone is sufficient to eliminate any hazardous atmospheres and prevent their accumulation.
Reclassification: This applies to all spaces that pose no actual or potential atmospheric hazard and if all hazards are eliminated without entry into the space. Some common examples include augers that may be locked out from outside the space or an engulfment hazard where the material is removed from the confined space.
If alternate procedures or reclassification is not possible, all provisions of 29 CFR 1910.146 must be satisfied prior to employee entry into the space.
If you have any questions concerning this article or other safety issues, please contact W. Jon Wallace, "The Safety Guru", at 919.933.5548 or by