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.
For more information on this and other confined space safety best practices, consider attending one of our Confined Space Train the Trainer classes.
Why should we put aside the OSHA rules? The simple answer is the rules don’t take us as far as we’d like to go if we are truly going to follow confined space safety best practices and protect our employees. In other words, instead of relying on a compliance-based safety system (following rules) we should use a risk-based safety system (identifying and managing/eliminating hazards).
To understand this approach, let’s examine some of the deficiencies in the current permit space rules.
OSHA Rule Deficiencies
The permit space rules provide a foundation for our decisions about identifying permit spaces and managing hazards, but they have several deficiencies. These include:
- Working Alone: While the rules allow an entrant to work alone if using alternate entry procedures, most companies understand the inherent risks of an employee performing work activities with no one else in the vicinity. This can be true of any remote location, not just enclosed areas. A minor accident may not stay minor if an employee cannot summon help.
- Medical Events: The average age of the workforce increases slightly every year and is projected to be about 42 in 2020. We all understand that aging workers are more likely to experience medical events which, if they occur in a confined space, can make evacuating the patient a challenge. OSHA focuses on preventing workplace accidents but employers also need to be concerned with all possibilities including health events.
- Gray-area Spaces: The definition of a permit space* is fairly strict, and spaces that meet that definition should be easy to identify. But other enclosed spaces (which may have some but not all of the permit space characteristics) may also require special preparation and entry procedures. If we include these spaces in our inventory, are we obligated to follow all the permit space rules when entering them?
Overcoming OSHA’s Deficiencies
As most people know, OSHA rules represent the lowest level of required worker protection but most companies choose a more comprehensive approach. What does this approach look like? We find that it has the following characteristics:
- Including a Wider Variety of Spaces: We have a number of clients in the wood products industries which typically contain spaces such as dryers and baghouses. This equipment is usually equipped with large doors and wouldn’t be defined as a confined space since the egress (with the doors open) doesn’t impede self-rescue. Nonetheless, these spaces are similar to a permit space. They often require specific isolation and cooling procedures and employers also need to prevent inadvertent entry. By including these spaces in their permit space program, employers are able to ensure (by using a permit or similar checklist) that these procedures are completed and that workers have been apprised of the hazards and hard control measures.
- Assigning an Attendant Based on Job Activities: In a typical manufacturing facility many spaces can be entered using alternate entry procedures which does not require an attendant. Nonetheless, there are times when a second worker on the outside is a good idea, both for safety and to help with the job. To deal with this, a company’s program could specify that if using alternate entry an attendant is not needed if performing, say, an inspection. But it would be required if performing hot work or similar hazardous job activities. Cleaning or removing debris may or may not require an attendant based on the judgment of the entry supervisor.
- Developing a Patient Evacuation Plan for the Entire Facility: The confined space rules require employers to have a means of removing entrants from the space, but the space opening may not be in a location that is accessible to gurneys or ambulances. Therefore a best practice is to develop a plan for removing stricken employees from any and all locations where they may be assigned to perform work. Roofs, catwalks, fixed ladders, scaffolds, and similar locations should all be analyzed and a means developed to move a stricken worker to a place of safety.
Advantages to this Approach
Including a broader array of enclosed areas in our confined space plan provides a number of benefits including:
- Less Confusion: As you know, discussions over whether a given space is or isn’t a permit space can consume a lot of time. Including all enclosed areas which require special, pre-entry hazard-abatement procedures in your confined space program provides workers with clarity on the entry requirements and also lessens the debate over whether a given space is a permit space. Instead the focus of the discussion is one the hazards, which is where the focus should be.
- Provides Your Program With an Open Architecture: A system with an open architecture is one which can be built on to reflect future needs. As your facility undergoes changes over time, your program has to be updated to reflect these changes. By including a wider variety of spaces in your program you are encouraging workers to take a wider view of areas where they feel that safety improvements can be made whether or not these areas meet OSHA’s strict definition of a permit space.
- Allows Flexibility in Managing Hazards: If a space is classified as a permit space, then the safety requirements are quite clear. If a space is entered under alternate procedures (reclassification), then the rules are equally clear in spelling out things that aren’t required, although they may be needed (e.g. a permit, attendant, entry supervisor, and means of rescue). A risk-based approach to confined spaces may add back some of these requirements based on the hazards in the space, the work activities performed, the location of the space, the underlying health of the workers, and other important considerations.
Hazards that can injure or kill don’t care about the definition of a permit space or OSHA interpretations regarding minimal safety measures. Well-run organizations appreciate this fact and so they make it a core mission to understand their operations and how these activities might affect the well-being of their co-workers. OSHA regulations provide a starting point for this process but the end point is uncovering and implementing confined space best practices.
When it comes to space to include in your confined space inventory, a best practice is casting a wide net.
* Permit-required confined space definition: Large enough to enter, not designed for continuous occupancy, limited access/egress, and contains a hazard which prevents self-rescue.