Confined spaces are some of the most dangerous areas for an employee to be working in. When entry and exit points are restricted, life-threatening hazards are amplified in the event of an emergency.
To protect workers that need to enter confined spaces while on the job, OSHA published its confined space standard for general industry workers, (29 CFR 1910.146) and later released its confined space standard for the construction industry (26 CFR 1926 Subpart AA) in August of 2015.
We've put together this helpful resource to help you comply with these regulations, and mitigate or eliminate the risks of an incident when your employees are working in or around a confined space. You'll learn the differences between OSHA's two standards, the circumstances in which each are applicable, and steps to keep your workers safe.
What Are the Differences Between OSHA's Confined Spaces General Industry and Construction Standards?
OSHA's construction standard generally contains many of the same requirements outlined in the general industry standard, which has protected workers for nearly two decades. However, there are a few key differences between these two standards that organizations should be aware of.
Requirements for Multi-Employer Worksites
In the construction industry, it's extremely unlikely that only a single employer will be operating at a building site, especially throughout more complex projects.
As a result, OSHA's confined space standard for the construction industry includes detailed provisions requiring the coordination of activities when there are multiple employers, contractors, and subcontractors at a worksite that will need to enter the same confined space.
The burden of ensuring compliance with the construction standard falls on the site's host employer, who must ensure all parties are following OSHA regulations. Ultimately, though, it's in everyone's best interest to comply, as both contractors and the host employer can be cited for confined space violations under OSHA’s multi-employer citation policy (CPL 2-0.124), which states the following:
“On multi-employer worksites, more than one employer may be citable for a hazardous condition that violates an OSHA standard."
4 New Defined Roles for Confined Space Workers
Employers should also be aware that OSHA's construction standard also goes beyond the general industry standard by defining the four roles of employees involved in working in permit-required confined spaces.
These roles are:
- Authorized entrants to the space. These are any employees who are authorized by the employer to enter a permit space and perform the work. Entrants will be trained in all the safe work procedures that are required for working in confined spaces, including the proper use of personal protective equipment (PPE) and how to monitor the air quality while inside a confined space. Because communication is so important between entry team members, entrants will also be trained to use communication equipment such as walkie-talkies to stay in touch with attendants.
- Attendants. These are employees that are designated to continuously maintain an accurate count of all authorized entrants in the permit space. An attendant's job is to stay by the entrance and monitor what goes on both inside and outside the space. Attendants must make quick, informed decisions about whether it's safe for the entry to continue, or if the work should be stopped and the entrants should be evacuated.
- The entry supervisor. Before any worker enters a permit space and begins working, the entry supervisor must first certify that all of the required safety tests have been made, and that all needed required procedures and equipment are in place. The supervisor will also make certain that rescue services are standing by, and that the systems that are used to contact them are working, too. When satisfied, the supervisor will sign off on the confined space's entry permit, and the work can proceed.
Entry supervisors will also monitor the progress of the work in the space, to ensure that it proceeds within the guidelines established by the Permit. Finally, the space's Entry Supervisor will make certain that rescue services are standing by, and that the systems that are used to contact them are working, too.
- Emergency and rescue personnel. Employees who conduct rescues must be provided with proper PPE and rescue equipment and trained in the proficient use of that equipment. Employers must inform each rescue team or service of the hazards they may confront when called on to perform rescue at the site, and provide the rescue team or service selected with access to all permit spaces from which rescue may be necessary so that the team can develop appropriate rescue plans and practice rescue operations.
It's critical that organizations designate which employees are assigned these roles. For example, if no employee is clearly designated as an authorized entrant, OSHA will consider the failure to do so as an implicit decision to allow any employees to enter the confined space if they are working near it.
Regardless of whether any unauthorized employees actually enter the confined space, a failure to designate authorized entrants is a violation of the construction standard and will result in hefty OSHA fines and citations.
Which Confined Space Standard Should You Follow?
In order to determine whether you need to follow OSHA's confined space standard for general industry, or construction, you first need to ask yourself if the work that needs to be done in the confined space could be classified as maintenance or a construction activity.
If maintenance is being performed, you need to follow OSHA's general industry standard. If any construction activity needs to be conducted in the space, you need to follow OSHA's construction standard. It might seem simple, but keep in mind that you may actually need to comply with BOTH standards, depending on the tasks at hand.
If you're not sure what standard to follow, OSHA has also released several letters of interruption (LOI) that should help. In these letters, the agency defines maintenance as:
“Keeping equipment or a structure in proper condition through routine, scheduled or anticipated measures without having to significantly alter the structure or equipment in the process. For equipment, this generally means keeping the equipment working properly by taking steps to prevent its failure or degradation."
Construction activities, on the other hand, should be defined as “… work for construction, alteration, and/or repair, including painting and decorating.” The agency also clarifies that construction work is not limited to new construction, but can include the repair of existing facilities or the replacement of structures and their components.
For example, the replacement of one utility pole with a new, identical pole would be maintenance; however, if it were replaced with an improved pole or equipment, it would be considered construction.
It's important to evaluate your work carefully so that you understand what standards and requirements you'll need to follow for a project.
What Do Employees Engaging in Confined Space Work Need to Know?
Confined space standards for BOTH the general and construction industries place great emphasis on safety training.
Involved employees performing each entry role described above have specific training requirements based on potential hazards in the confined space, and the tasks they'll be carrying out. These requirements also determine when individuals assigned to a certain role must receive training.
For example, employees who are designated as part of the search and rescue team not only have to be trained as authorized entrants of the confined space, but also must be trained to perform rescue duties as well. This means that each employee in the emergency and rescue team must be trained in basic first aid and cardiopulmonary resuscitation (CPR). At least one member of the rescue team needs to have an active certification in basic first aid and CPR.
The standard also requires the rescue team to practice performing confined space rescues before attempting an actual rescue. This type of training needs to reoccur on an annual basis (once every 12 months) by performing simulated rescue operations in a replicated confined space.
It's important for the rescue team to perform practice rescues and for all employees to maintain training compliance. In a study conducted in 2017 by the National Institute for Occupational Safety and Health (NIOSH), rescuers were shown to account for approximately 60% of confined-space fatalities. The study also found that only 15% of ALL employees involved in a confined space incident had received confined space training.
How Can Organizations Provide Proper Confined Space Training?
Though training is critically important for worker safety, it's no secret that scheduling and coordinating it can be difficult, time-consuming, and can even delay work.
Organizations can streamline the safety training process by using online training management systems to schedule and track their employee training. The latter is particularly important, as both OSHA's general industry and construction standards require organizations to maintain detailed training records. You'll need to be able to easily provide an OSHA compliance officer with training records in the event that your business is subject to an OSHA inspection.
It may be beneficial to also consider online training content for easy training delivery. Full-length online courses have been found to be effective for safety training while minimizing overhead costs.
Online safety training courses can also contain mid-point quizzes and learning checks to improve employee engagement and verify that learners have the knowledge they need to work safely in confined spaces.
In the event of a lack of oxygen, workers only have 4 minutes to escape a confined space. When workers are properly trained, the time it takes to return to a safe area is dramatically reduced and could potentially save lives.