Confined Space: More to Consider

Dan Smith, Contributor

When I hear the words “confined space,” my claustrophobia goes out of the way to crank up the anxiety factor a few notches. Clinically, I have been told to accept the anxiety as an “irrational fear.”  I am working on rewiring my brain to help me recognize and deal with these cognitive distortions.

On the other hand, let us remove the “irrational” factors from the discussion and consider the “rational” fear factors in confined spaces.

By nature, confined spaces carry these fears.

The OSHA1910.146 standard does a good job informing confined space workers by identifying dangers and providing guidelines for managing what I call “rational” fears within permit required spaces.

To start making sense, laid out below is the structure, definition and direction dictated in the OHSA 1910.146 standard(1).

Permit-Required Confined Space Standard 29 CFR OSHA 1910.146

Confined Space

(1) “Is large enough and so configured that an employee can bodily enter and perform assigned   

     work; and …

(2) has limited or restricted means for entry or exit (for example, tanks, vessels, silos, storage bins,

     hoppers, vaults, and pits are spaces that may have limited means of entry.); and …

(3) is not designed for continuous employee occupancy.”


Permit-Required Confined Space

“… has one or more of the following characteristics:

(1) Contains or has a potential to contain a hazardous atmosphere;

(2) contains a material that has the potential for engulfing an entrant;

(3) has an internal configuration such that an entrant could be trapped or asphyxiated by inwardly converging walls or by a floor which slopes downward and tapers to a smaller cross-section; or

(4) contains any other recognized serious safety or health hazard.”


Non-Permit-Required Confined Space

“A confined space that does not contain or, with respect to atmospheric hazards, have the potential to contain any hazard capable of causing death or serious physical harm.”


After confessing my own phobia of confined spaces, I can safely say that, regardless of whether a permit is required or not, all confined spaces can be frightening places.

There is more to consider, in that not all confined spaces are created equally. On its own merit, a permit-required confined space deserves greater recognition because of obvious IDLH hazards identified in detail in OSHA 1910.146. But, a permit-required space does not deserve all of the recognition; non-permitted spaces hold their own undefined and uncontrolled dangers.

Just like irrational fear and rational fear, unidentified dangers are not as easy to manage and control as the dangers in a permit-required confined space.

For instance, working within a permit-required confined space comes along with a complimentary confined space attendant. OSHA 1910.146 dictates the attendant’s role as to identify, authorize entry and monitor entrants in one or multiple permit-required confined space; this cannot always be afforded to an entrant in a non-permit required confined space.

Below are excerpts from OSHA 1910.146 (b) Permit Required Confined Spaces standard definitions (2):

“’Attendant’ means an individual stationed outside one or more permit spaces who monitors the authorized entrants and who performs all attendant’s duties assigned in the employer’s permit space program.”

Rational vs. Irrational Dangers

You don’t have to be a scaredy-cat like me to recognize “rational” dangers. Spiders, snakes, slips, trips, falls, bee stings, heat stroke, cardiac and diabetic events cannot always be predicted, but every one of these dangers can quickly turn a non-permit required, non-IDLH atmosphere into an IDLH atmosphere.

Given these uncontrolled and unplanned dangers, the non-permit-required confined space can involve quickly becoming an IDLH atmosphere—not in the sense of the traditional definition of a permit-required IDLH confined space—but instead fits the spirit of a broader definition of IDLH. Below is OSHA’s definition of the IDLH atmosphere. (Excerpts from OSHA 1910.146 (b) Permit Required Confined Spaces standard definitions(3).)

“’Immediately dangerous to life or health (IDLH)’ means any condition that poses an immediate or delayed threat to life or that would cause irreversible adverse health effects or that would interfere with an individual’s ability to escape unaided from a permit space.”

Let’s go back to the beginning and look at OSHA 1910.146 in a much broader sense, without reference to either permit-required or non-permit-required confined space.

Permit-Required Confined Space Standard 29 CFR OSHA 1910.146

Confined Space

(1) “Is large enough and so configured that an employee can bodily enter and

     perform assigned Work; and …

(2) has limited or restricted means for entry or exit (for example, tanks, vessels,    

     silos, storage bins, hoppers, vaults, and pits are spaces that may have limited

     means of entry.); and…”

How many operations are you a part of that fit with the above?

How many of these operations would never be considered a permit-required IDLH atmosphere?

The best any confined space entrant can hope for is found in either the comfort of having an attendant monitoring them and/or having another means of signaling distress and summoning assistance; preferably, by sending a distress signal to be received immediately by other personnel.

Sending a distress signal would not require the entrant to be conscious and then automatically trigger an alarm by sensing “lack of motion” or a “fall” to automatically send the distress signal. A best practice would also provide an entrant with a device having the means to manually press a button to send a distress signal, when conscious, to summon assistance on their own.

Staying Safe, Rationally

The combination of all these features come together to create a confined space safety monitoring system capable of protecting anyone working alone, working at heights and/or working in confined spaces.

If these devices existed, would you want to learn more?

Regardless of the requirement, as part of permit-required environmental monitoring or simple non-permit-required lone worker confined space monitoring operation, the good news is these systems currently exist today and are available for all who work alone, at heights or in the confined space.

With more to consider, not all confined spaces are created equally, but may carry with them many common dangers demanding our “rational” attention. IHW

Dan Smith brings over 30 years of broad experience across several industries including manufacturing, public safety land mobile radio design consulting and personal safety product manufacturing. He is currently Director of Sales and Marketing at Grace Industries, in Fredonia, Penn.

Additional Resources:

1 https://www.osha.gov/laws-regs/regulations/standardnumber/1910/1910.146

1910.146(b)

 

2  https://www.osha.gov/laws-regs/regulations/standardnumber/1910/1910.146

1910.146(b)

3 https://www.osha.gov/laws-regs/regulations/standardnumber/1910/1910.146

1910.146(b)

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