Jan 22, 2018
Does your facility require a rescue team? What OSHA standards require some kind of emergency response procedures? If your facility needs some level of emergency response, how do you develop these capabilities? What types of procedures, equipment, and training is needed? Or should it be out sourced?
Sep 6, 2017
The rules that deal with confined space training are clear. Entrants and attendants may need to know a lot about medical issues.
Jul 19, 2017
A client recently called me with a question. At his facility there was a confined space (a large vault) that they wanted to enter using alternate entry procedures (also known as reclassifying the space). Can you enter a space to test the air to determine if it’s safe to enter using alternate entry procedures? Or do you have to make an initial entry using all protections afforded by the confined space rules?
Jun 21, 2016
One of the challenges in administering a confined space safety program is deciding which spaces to include in your inventory. The simple answer is to just include those spaces that meet the definition of a permit space*, but is this a confined space safety best practice? My sense is that it may not be. In fact, I believe that when you’re deciding which spaces to place under the confined space program, you should consider putting aside OSHA’s legal definition of a permit space and instead use a broader measuring stick.
May 4, 2016
Given a topic as potentially complex as confined spaces, we can often enhance our understanding of the safety requirements by looking at other, similar standards. The shipyard employment standard (29 CFR 1915 Subpart B) offers us one such opportunity.
Jan 7, 2016
When Oregon re-wrote its confined space rules last year, one issue of interest among those attending the stakeholder’s meeting hosted by OROSHA, was the question of fall hazards and permit spaces. In other words, if you had a pit twenty feet deep and the only hazard was posed by using a fixed ladder to enter this pit, would the fall hazard be serious enough to make the confined space a permit space?
Nov 4, 2015
Few topics elicit as much confusion as the reclassification of permit-required confined spaces, also referred to (more appropriately as using alternate entry procedures). People want to know if we should control hazards or eliminate them?
June 2, 2015
For the last five or so years we have enjoyed considerable success with Version 3 of our Confined Space Entrant, Attendant, and Entry Supervisor curriculum. Nonetheless, we are excited to release Version 4.
May 27, 2015
In this post I’d like to review the basic requirements for the new Federal OSHA confined space rules for construction (§1926.1200 through 1213). This is intended for people who already have a basic understanding of the confined space rules for general industry (§1910.146) and are curious about the added requirements (none were taken away) that will apply to construction activities.
May 20, 2015
In both Oregon and nationally we have seen changes to the rules governing entry into confined spaces. None of the changes have anything to do with how we identify, evaluate, and safely enter into confined spaces. But there are important changes to the scope of who must comply with these rules and the types of documentation they must maintain. In addition, both sets of rules changed the reclassification process.
Mar 3, 2015
Does your facility require a rescue team? What OSHA standards require some kind of emergency response procedures? If your facility needs some level of emergency response, how do you develop these capabilities? What types of procedures, equipment, and training is needed? Or should it be out sourced?
Feb 16, 2015
After years of comments, proposals, discussions, edits, issuances, retractions, amendments, and related activities, OROSHA has issued its Confined Space Rule: OAR 437-002-0146. The permit space rules became effective for general industry on January 1, 2015 and will become effective for construction on March 1, 2015. Will your location be in compliance with Oregon’s new rules? What does it mean to Oregon employers? If you were in compliance with the Federal rules (1910.146) will you be in compliance with this one?
Jan 27, 2015
We are often asked how much training or equipment a confined space team really needs, and while we’d like to be able to respond with a simple answer, the answer is really not simple. The problem may be the use of the term ‘rescue team’ and what this term connotes; specifically a crack squad of former fire fighters who never encountered a hole they didn’t want to jump into or a tower they wouldn’t climb. But if we drill into the intent of the regulations we can see that OSHA does not require everyone who enters a confined space to be backed up by a rescue team, they simply require you to have a means of rescue. So how much rescue capability is enough at your location?
Oct 9, 2012
Should rescuers enter a non-IDLH confined space to observe conditions during the entry?