OSHA offers advice about confined spaces
"If your momma has to crawl over plumbing pipes and shinny up a ladder to get out of the basement . . . you might have a permit-required confined space."
Like comedian Jeff Foxworthy’s never-ending, "You might be a redneck" routine, there seems to be no end to the questions concerning the federal standard on confined spaces that went into effect in April 1993. Can it be a confined space if it has a door? How do you warn employees of a confined space? What about when a contractor works in the space?
The federal Occupational Safety and Health Administration (OSHA) in Washington, DC, promulgated the Permit-Required Spaces for General Industry standard after 20 years of research, but it still is offering clarifications on just what the standard means. Occupational Health Management recently asked OSHA to answer some of the most common questions regarding confined spaces. Here is the agency’s response:
• When are stairs or ladders considered "limited or restricted means of egress?"
Ladders almost always are considered limited or restricted egress. Stairs may be if they are temporary, movable, spiral, or articulated. Fixed industrial stairs can be considered limited or restricted egress if they would make exiting the space or rescuing a worker difficult because of the configuration of the space or the hazards present.
• Can a space be a permit-required confined space if it has a door?
Yes. A door or portal that is too small to allow an employee to walk upright and unimpeded through it is considered a restricted means of escape. Similarly, the space may require a permit if the worker must crawl over pipes or equipment to reach it or if there is equipment in the doorway. OSHA stresses that the presence of a door does not rule out it being a permit-required confined space. The overall situation must be assessed.
• Does it matter how far a worker must travel to reach safety?
Yes. If the worker must travel a substantial distance in an enclosed space, such as a tunnel, to reach safety, the space might be a permit-required confined space.
• Can a space be confined if it is entirely open on one plane, such as a large pit?
Yes. OSHA may consider the space confined if the means for exiting the pit, such as a stairway, are narrow, twisted, or otherwise would hinder a quick escape. The presence of pipes and other materials that would get in the way also can make it a confined space.
• When defining a space as a permit-required confined space, does it matter what the specific hazard is in the space or does it only depend on the means of egress?
The type of hazard in the space can be significant in determining whether the exit is limited or whether rescue would be hindered. So one hazard/exit combination might qualify as a permit-required confined space while another hazard combined with the same exit might not.
• Does the mere presence of water in a space, such as a manhole, make it a permit-required confined space?
No. There must enough water to pose a hazard or hinder escape. Keep in mind that a small amount of water, just a few inches, can pose a hazard if it conceals floor openings or trip-and-fall hazards.
• Does OSHA require employers to physically survey each confined space to determine if it is a permit-required space?
Not necessarily. The survey requirement may be met through existing records and knowledge of the space if that information is adequate for making a determination. If you have records showing that the hazards, or lack thereof, are identical in a series of spaces throughout the workplace, you would not have to physically survey each space.
• If you decide that no employee should enter a certain permit-required space, what does OSHA consider "effective measures" to prevent entry?
The measures could include permanently closing the space, placing physical barriers, or bolting and locking the entry. Those measures should be supplemented with employee training and warning signs, but OSHA specifies that warning workers away from the site is not enough. Physically preventing entry is necessary.
• Concerning hazardous atmospheres, are simple alarm devices considered to be the "direct reading instruments" required in some situations?
No. Alarm-only devices are not acceptable for either pre-entry or periodic testing of a confined space. The device must provide information on the actual concentrations.
• Can an employee be both an "entry supervisor" and an "authorized entrant?"
Yes, as long as the employee has had the proper training, and the duties of one activity do not conflict with the duties of the other.
• When a single attendant is monitoring more than one permit-required space, is there a limit on how far the attendant can be from any of the spaces?
There is no distance requirement, but the attendant must be able to fully perform all the attendant duties for each space.
• Is nonentry rescue preferred even in horizontal rescues?
Yes. OSHA acknowledges that lifelines and lanyards may be more likely to snag and tangle in horizontal rescues, so entry may be necessary more often than in vertical rescues. Nevertheless, nonentry rescue is preferred when practical.
• Is an elevator pit considered a confined space?
Yes, but it is not necessarily a permit-required confined space. That has to be determined on a case-by-case basis.