Accessing a confined space may be a part of industrial activity and may be performed for a variety of purposes. It is normally done to conduct essential activities like inspections, reconstruction, or maintenance. However, in a working environment, a confined space is one of the physical hazards that poses a threat to the employees. Workplaces environments pose many potentially serious hazards, and severe accidents can arise without specialized protocols for safe entry and monitoring employees inside the confined space. For this reason it’s essential that all workers on DoD projects take EM 385 1-1 confined spaces training.
In addition, according to the most recent data available from the Bureau of Labor Statistics, the number of annual confined space deaths in the United States nearly doubled from 88 to 166 between 2012 and 2017.
To administer the hazards involved with working in confined spaces, employers must obtain a ‘permit for confined spaces’ and must implement a confined space hazard assessment and control program.
Defining Confined Spaces
According to the Occupational Safety and Health Administration, or OSHA, confined spaces are not specifically built for individuals to occupy for a long period of time, but they are wide enough for the entry of employees who carry out specific tasks. Some confined spaces include, but are not limited to:
- Bins
- Ductwork
- Equipment housings
- Hoppers
- Manholes
- Pipelines
- Pits
- Silos
- Storage
- Tanks
- Tunnels
- Vaullts
- Vessels
If a confined space meets one or more of the following requirements, it is classified as “permit-required confined space” (permit space) by OSHA:
1. Comprises a hazardous atmosphere or can contain one.
2. Contains materials that have the capability of engulfing an individual.
3. Has inward-converging walls or floors that slope downward and narrow into a smaller region, trapping or suffocating an employee.
4. Includes any other known safety or health hazard namely:
a. Poor air quality:
Employees may lose consciousness or become ill as a result of a lack of oxygen or toxic gases in the air.
b. Chemical exposure:
Chemicals may cause workers to become ill or incapacitated if they come into contact with them through skin contact, inhalation, or ingestion.
c. Slips and falls
Employees may be more likely to lose their balance and fall in manholes, tanks, and silos because they have no built-in fall defense.
d. Extreme heat
Temperatures are amplified in certain confined spaces. These environments can become excessively hot, putting workers at risk of heatstroke or dehydration.
Defining The Permit-Required Confined Spaces (29 CFR 1910.146) of OSHA
The Occupational Safety and Health Act of 1970 obligates the establishment of health and safety requirements that are mandatory or sufficient for providing safe or healthy jobs and workplaces. The law expressly mandates employers to obtain information appropriate for enforcing the Act or establishing information about the nature and prevention of workplace injuries, illnesses, and accidents. Thus, employees can use improved information technology in documenting or maintaining records related to information collections whenever it is necessary.
The information-gathering requirements of the OSHA 29 CFR 1910.146 permit-required confined spaces standard are obligatory to prevent deaths and injuries that arise upon entry into such spaces. Section 6(b) of the Occupational Safety and Health Act of 1970 granted the authority to issue this standard. OSHA confined spaces training is an important aspect of this.
What is the Purpose of the Collected Information?
Employers and employees use the data collections once they enter permit-required confined spaces. The information is essential in ensuring that employers assess the hazards in permit spaces before attempting entry and that appropriate steps are taken to make the spaces safe for entry.
Furthermore, the information is necessary to evaluate whether employers comply with the standard during an OSHA inspection by a compliance safety and health officer. The Agency’s ability to assure that workers are safe from permit-required confined space hazards as required by the standard would be seriously hindered by inadequate regular data collection.
What particular circumstances would necessitate conducting an information collection within the guidelines outlined in 5 CFR 1320.6.?
- Mandating respondents to send information to the agency more often than every quarter of the year. Respondents will not be compensated or given gifts.
- Necessitating respondents to have a written response to a set of information in less than 30 days after receiving it
- Requiring respondents to provide more than two copies of any document in addition to the original
- Necessitating respondents to keep records for more than three years, apart from health, government contract, grant-in-aid, medical, or tax records
- When it comes to a statistical survey that is not structured to yield accurate and reliable results that can be applied to the entire study universe
- Requiring the use of a statistical data classification that has not been accepted by the Office of Management and Budget (OMB)
- That includes a confidentiality pledge that is not recognized by the statutory and regulatory authority, transparency, and data protection policies that are compliant with the pledge, or that unnecessarily prevents data sharing with other entities for compatible confidential purposes. However, it is unnecessary period to disclose sensitive information such as sexual activity and behaviors, religious views, and other generally considered private topics.
- Requiring respondents to submit proprietary trade secrets or other confidential information only if the organization can show that measures have been put in place to protect the information’s confidentiality to the degree allowed by law
What are the conditions for gathering data?
1. Posting confined space danger signs
Under section 1910.146(c)(2), if the workplace includes permit spaces, the employer must notify exposed workers of their presence and location, as well as the danger posed by the permit spaces and by posting danger signs or by some other equally effective means.
2. Creating a written program for gaining access to a permit space
If an employer determines that its workers will enter permit spaces, the employer must establish and execute a written permit space program that complies with this provision, according to Section 1910.146(c)(4). Employees and their approved members must be able to inspect the written program.
3. Documentation of determinations and supporting data
The provision 1910.146(c)(5)(i)(E) states that the employer documents the determinations and supporting data required by paragraphs (c)(5)(i)(A), (c)(5)(i)(B), and (c)(5)(i)(C) of this section and makes them accessible to each employee who enters the permit space under the terms of paragraph (c)(5) of this section, or to that employee’s approved representative.
4. Alternative procedures with written approval
The employer must verify that the space is secure for entry and that the pre-entry steps needed by paragraph (c)(5)(ii) of this section have been taken, according to Section 1910.146(c)(5)(ii)(H). This is done by a written certification that includes the date, the position of the space, and the signature of the individual providing the certification.
5. Eliminated Hazards In a Written Certification (Reclassification of a permit space)
The employer must record the basis for deciding that all hazards in a permit space have been removed through a certification that includes the date, the location of the space, and the signature of the individual making the determination, according to section 1910.146(c)(7)(iii).
6. Specifications for a permit-required confined space program
The employer must comply with the following requirements under section 1910.146(d), the permit space program mandated by paragraph (c)(4) of this section:
- To prevent unwanted entry, take the necessary
- Before workers access permit spaces, identify and assess the hazards.
- Develop and enforce the methods, procedures, and practices required for permit space entry operations that are both secure and effective.
7. Preparation of confined spaces training certification
Each employee’s name, the trainers’ signatures or initials, and the dates of training must all be included on the certification. Employees and their approved members must be able to inspect the certification. Our EM385 Training covers these requirements.
Conclusion: OSHA Confined Spaces Training
Many working environments have areas that are deemed restricted because their layout restricts the activities of workers who enter, work in, or exit these areas. In addition, employees who work in confined spaces are more likely to suffer severe physical injury as a result of hazards such as entrapment, engulfment, and dangerous ambient conditions.
The concepts “permit-required confined space” and “permit space” apply to areas that satisfy OSHA’s concept of a “confined space” and present health or safety hazards. As a result, OSHA needs employees to obtain a permit before entering these areas – this permit is dependent upon the employee having undertaken and passed OSHA confined spaces training.
For up to date 2024 information on safety in DoD projects persuant to the EM 385 manual revision, click here.
