Article

Confined Spaces in Construction

Confined workspaces present a potential hazard to workers. This article outlines steps that can be taken to make confined workspaces as safe as possible.
When the construction standard applies, and there are other applicable OSHA standards, an employer must comply with both the construction and other standards. One example is 1910.147 (b) for definitions located in the general industry standard.

Criteria for a Confined Space
 
There are three combined criteria that must exist for a confined space:
  1. A space large enough and so configured that an employee can bodily enter it;
  2. Has limited or restricted means for entry and exit; and
  3. The space is not designed for continuous employee occupancy.
Note:  The space is large enough that a person can enter into it with their entire body, but entry occurs as soon as any part of the body crosses into the confined space.1
 
Confined spaces present a potentially harmful workplace. Cramped workplaces leading to awkward body positions may result in ergonomic-related injuries. The byproducts of work occurring in the confined space may cause a prior non-hazardous work environment to become unsafe for workers. With limited or restricted means of exiting, if the work environment becomes unsafe, these characteristics will increase the time required to exit the confined space.
 
Hazards of a Permit-Required Confined Space
 
The permit-required confined space can be one or a combination of the hazards listed below. This requirement is unlike the definition for confined spaces that requires all three of the criteria. In addition to those that define a confined space, any of the following criterion constitute a permit-required confined space. Any one or a combination of the four listed below constitute a permit-required workplace:
  1. Contains or the potential to contain a hazardous environment,
  2. Contains a material that has the potential for enfulfing an entrant,
  3. An internal configuration that could trap or asphyxiate due to inwardly converging walls or by a floor that slopes downward and tapers to a smaller cross-section, or
  4. Contains any other recognized serious safety or health hazards2.
Now that you know the definitions of a confined space and a permit-required confined space, here is what you should do.
 
Actions to Take

  1. Identify, secure, and mark all your confined spaces. If you are working on an active new construction site, understand that confined spaces will exist during phases and may no longer exist at other phases. An active ongoing identification practice and procedures appropriate to the type of confined space encountered will be necessary.
  2. Identify and uniquely mark or designate those confined spaces that are permit-required.
  3. Write your confined space and permit-required entry and exit procedures.
  4. Ensure safety and personal protective equipment are available per written plans
    1. Signs and barriers
    2. Appropriate light source
    3. Appropriate tools (e.g., spark resistive)
    4. Appropriate climbing equipment
    5. Means for communication
    6. Appropriate environment and portable air monitoring systems
    7. Respirators and other personal protective equipment
    8. Retrieval equipment
  5. Designate personnel requirements and responsibilities
    1. Entry supervisor
    2. Attendant
    3. Entrant
  6. Employee Training
    1. Definition of confined space and permit-required confined space and how to identify them
    2. Proper equipment and validate understanding
    3. Procedure for implementing the programs
    4. Emergency methods
  7. Develop means to ensure the prevention of unauthorized employee entries. These may be by signs, training, and other methods.
These are seven of the key steps and not an exhaustive listing. Since confined spaces can be fatal, always ensure your procedures at a minimum meet the OSHA requirements for employee safety. Here are some helpful resources from OSHA:For additional assistance, please reach out to your Nationwide Loss Control representative. If you don’t have one, you will find additional resources at our MyLossControlServices.com website.
 
References

1 https://www.osha.gov/laws-regs/federalregister/2015-05-04
2 Yates, W. D. (2017). Safety Professional’s Reference and Study Guide (2nd Edition)


The information presented here is intended to help users address their own risk management and insurance needs. It does not and is not intended to provide legal advice. Nationwide, its affiliates and employees do not guarantee improved results based upon the information contained herein and assume no liability in connection with the information or the provided suggestions. The recommendations provided are general in nature; unique circumstances may not warrant or require implementation of some or all of the suggestions. Nothing here is intended to imply a grant of coverage.  Each claim will be evaluated on its own merits and circumstances. Nationwide, Nationwide is on your side, and the Nationwide N and Eagle are service marks of Nationwide Mutual Insurance Company. © 2021 Nationwide

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