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17 December 2014

Actually, that IS a confined space

Welborne_BryanWorkplace and employee safety regulations can become confusing. Confined space regulations remind me a bit of the offside rule in soccer – the definition of what it means gets the most attention when one person or the other needs the definition, or opinion, to weigh in that person’s favor.

OSHA remains quite clear, however: A confined space has limited openings for entry or exit, is large enough for entering and working, and is not designed for continuous worker occupancy.

Welborn_Conf-space-1OSHA continues its description, stating that “confined spaces include underground vaults, tanks, storage bins, manholes, pits, silos, underground utility vaults and pipelines.” (If you need more background, feel free to consult OSHA’s General Industry Regulations, 29 CFR 1910.146.) However, keep in mind that this short list does not categorically exclude other types of confined spaces, and it includes many types that we see during our workday, but may not necessarily think of as confined spaces.

But stop right here if you were thinking of expanding your cubicle or office, hoping that using OSHA’s confined space regulations will help you. The third criterion dissolves that argument: cubicles and offices accommodate workers by design.

That large “Sea-Land’-type container at the landfill in which the mechanic stores parts, tools, and lubricants may qualify as a confined space. When ventilation, properly operating doors, perhaps a desk and chair, and proper shelving is in place, it very well could qualify as designed for safe continuous worker occupancy. Think “modern industrial,” if interior decoration interests you.

I'm afraid that umbrella constitutes an enclosed space and must be taken downIf the door hinges twisted and became stiff after the dozer struck them with its blade, if broken shelving juts into the walking space, if the container becomes a dumping ground for junk that people do not want to properly stow, the entry and exit becomes hampered, then it could become a confined space – think “confining”.

How about a baghouse filter chamber? Stack monitoring ports? The hopper of a rear-loader? Oil/water separator? 4-foot-diameter drain pipe? Yes times 5!

Ultimately, the title “confined space” protects the worker – a worker may think twice before casually entering the space during the workday. Perhaps the worker will take an extra few seconds to make sure safe egress exists before entering the space. That instance may spell the difference between a good day and a bad day.

We primarily focus on a confined space limiting an employee’s egress; we should also remind ourselves that it limits others’ ingress. If an emergency responder needs to get to a worker whose heart condition caused a loss of consciousness and declining vital signs, limited ingress would limit the responder’s ability to successfully render aid.

An important note: This information relates to confined spaces alone. We have not even touched the topic of “permit-required confined space” yet. I will cover that another time.

Do you have any interesting examples of confined spaces?

Bryan Welborn has 25 years of experience in safety program development and management in manufacturing and for solid waste operations, as well as OSHA safety programs and USDOT program management.


Categories: Biogas and Landfill Gas, Environmental Planning & Compliance, Landfill Engineering and Design, Operations and Maintenance, Solid Waste, Transfer/Recycling/Processing Facilities
Posted By Bryan Welborn at 11:30 AM  |  No Comments on Actually, that IS a confined space

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