Of all the activities a safety professional engages in, dealing with confined spaces can be one of the most stressful and challenging, especially for those who are new to the safety profession or those whose experiences in the field haven’t required much interaction with confined spaces. What most safety professionals do know, regardless of experience level, is that when not managed properly, confined spaces can be deadly.
Within this three part series, we’ll talk about the dangers of confined spaces, discuss situations that many safety professionals find themselves in when navigating through the maze of confined spaces regulations, talk about common confusion points within the management of confined spaces and we’ll introduce a few tools to help get your confined spaces program on track.
In this first part, we’ll talk about a few confined spaces statistics and navigating through the maze of standards.
Confined Spaces—The Grim Statistics
To understand just how deadly confined spaces can be, all one needs to do is look at the statistics reported by the Bureau of Labor Statistics (BLS) stating that between 2011 and 2018, there were 1,030 worker fatalities involving a confined space. Of those fatalities, the most common reasons for death were trench collapses, falls to a lower level, inhalation of harmful substances, engulfment by collapsing materials, fires and explosions and being caught in running machinery, like a screw auger.
As if that weren’t bad enough, the National Institute for Occupational Safety and Health (NIOSH) conducted an investigation into fatalities involving confined spaces and found some startling information. Their investigation revealed that 60% of confined space fatalities happened to unauthorized rescuers and of those rescuers, 29% of them were supervisors. In fact, in 85% of these incidents a supervisor was actually present during the entry process. They also found that only 15% of the participants had received training in confined spaces which could possibly be why out of all of the incidents investigated, not a single one had prepared a rescue plan, or conducted testing prior to entry or provided any ventilation in the space. Lastly, out of the incidents investigated, NIOSH found that only 31% had written entry procedures—none of which were actually used during entry.
So, how does this happen? Where does the management of confined spaces go so terribly wrong that it leads to data like this? To try and answer these questions, we’re going to discuss a few key things that cause confusion when managing confined spaces programs and provide a few tips and tools that might help.
To kick this off, we’re going to start at the beginning by talking about navigating through the federal standards.
Confined Spaces Standards—There’s a Bunch
Every covered industry has its own set of hazards, situations and activities which are unique to that industry. To accommodate for these differences, it’s very common to find the same federal standards written a bit differently for each industry. This is why General Industry, Construction and Maritime each have their own, specific sets of different confined space regulations which are based on the types of activities and hazards present in each respective industry.
This is really just a long winded way of saying “one size doesn’t fit all” when it comes to federal confined space standards.
Clear as mud? Here’s what we mean:
- For the General Industry, 29 CFR 1910.146 Permit-required confined spaces is the primary standard however, 124 General requirements for dipping and coating operations, 1910.252 General requirements for welding, cutting and brazing, 1910.261 Pulp, paper, and paperboard mills, 1910.268 Telecommunications and 1910.272 Grain handling facilities each offer additional regulatory requirements for the management of confined spaces.
- For the Maritime industry, 29 CFR 1915 Subpart B Confined and Enclosed Spaces and Other Dangerous Atmospheres in Shipyard Employment consists of six different standards and two appendixes.
- For the Construction industry, 29 CFR 1926 includes Subpart AA Confined Spaces in Construction and there’s also a final rule which was published in May of 2015 which includes a 161 page breakdown of the construction standard.
- Finally, within the Agriculture industry, OSHA has taken a slightly different approach by relying on the General Industry standard to govern confined spaces instead of having its own set of standards. In addition, they rely on the National Ag Safety Database and NIOSH to provide additional information on how to safely manage specific agricultural hazards found in places like manure pits and grain bins.
To add to the confusion, there are also 28 OSHA-approved State Plans which are required to at least meet the minimum federal standards but can also include more stringent requirements for confined spaces among other standards.
Trying to navigate through all of these different standards is difficult, especially for the less experienced safety professional. It’s made even more challenging when that safety professional is responsible for the entirety of the safety program, has multiple facilities across multiple states and industries or doesn’t have much help. These are the kinds of situations that can ultimately lead to fatalities. Luckily there are several really exceptional tools available on OSHA’s website that can help make sense of confined space standards.
The first one is OSHA’s Confined Spaces Advisor tool which allows users to evaluate individual spaces and get guidance on whether the space is or isn’t a confined space and if it is a confined space, what kind it is. This tool is especially helpful because it offers links to a glossary of easy to understand definitions for the more misunderstood or misinterpreted words and phrases, which helps ensure questions are answered properly. This tool also provides a long list of examples of confined spaces which they’ve broken up by industry.
The second one is the dedicated page devoted solely to the topic of confined spaces. Essentially this page takes the complexity of the standards and re-words them in a more “plain language” type format which is extremely helpful to people who struggle to understand the legalese that most standards are written in. With this one page, users can access confined spaces information for General Industry, Construction and Maritime to include industry specific hazards and solutions, training presentations, quick cards for key concepts within confined spaces, technical papers and other confined spaces related items—like safety bulletins and other e-tools.
If you haven’t visited OSHA’s website to check out these two items, you really should because even the most seasoned safety professional can benefit from a refresher now and then.
In the next installment in our three part series on confined spaces, we’ll talk about the classification process and highlighting the two different types of confined spaces, discuss what happens when conditions change and how the reclassification process applies and then we’ll touch on how the terminology used in the standards can affect negatively affect the classification process. Along the way, we’ll also introduce several of our own new templates and interactive tools to help make the classification and reclassification process easier to understand and document.