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Dealing With Confined Space A Complicated Challenge
“Most of us who’ve taught in the public sector have experienced employees telling us they don’t have to do ‘that OSHA stuff’ because they are not under OSHA’s jurisdiction,” Pettyjohn explains. “Likewise, employees in the construction workplaces often state, complain or brag that the confined space standard applies to general industry, not construction, and OSHA doesn’t even call excavations – probably the most commonly entered space where hazardous atmospheres could easily accumulate – confined spaces, so they don’t have to put any real effort into confined space safety.
“My typical response has been to ask them if they really think the methane or hydrogen sulfide was going to tap them on the shoulder and ask them if they were public sector employees or working in a general industry scenario before it decided to kill them.”
Pettyjohn believes that when workers begin to understand that lethal atmospheres aren’t playing by the “rules” (regulations), they also begin to understand that their lethal opponent has to be understood and dealt with by using effective means and methods that may exceed minimum requirements of OSHA.
A good starting point is with definitions of confined spaces which will illustrate the problems with regulations.
The OSHA General Industry Standard of a confined space is one large enough and so configured that an employee can bodily enter and perform assigned work, which has limited or restricted means for entry or exit, and is not designed for continuous human occupancy. The OSHA Construction Standard defines a confined space as any space having limited means of egress which is subject to accumulation of toxic or flammable contaminants or has an oxygen deficient atmosphere.
"This is good as far as it goes," says Pettyjohn, "but workers need to make sure they haven't limited themselves to a strict reading and interpretation of a definition, but rather focus on whether the space – whatever it may be, however it may be configured and the activity being conducting – could result in the generation and containment of a hazardous atmosphere or an engulfment.”
As an example, consider the garage of a house, he added. The limited access/egress definitions certainly don’t apply, and folks who have installed a beer fridge, TV, stereo, pool table and dart board would defy the “not intended for continuous occupancy” definition.