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Dealing With Confined Space A Complicated Challenge
“Still,” says Pettyjohn, “if someone were to be welding galvanized metal with the garage door down and the pedestrian door closed – this occurred to a friend of mine – they might discover their friendly garage to be as deadly as any vault or trench they ever entered.”
Developing a confined space safety program that is instructive and effective begins with regulations but grows past them, Pettyjohn emphasizes, especially those specifically written for a particular construction scenario, like excavations. “I believe it requires three steps: education, evaluation, and elimination,” he added.
Clearly education, especially in the applicable standards in which there are legal obligations to comply with, but education in the nature of the hazardous atmospheres and environments in which engulfment may occur have to be included. Workers need to know how the various atmospheres will affect them and how to recognize them.
Pettyjohn advises employers to “shop” for standards that apply to the specific work their personnel does. OSHA standards to reference include:
• The General Industry Confined Space Standard for its comprehensiveness and the procedures it outlines to eliminate hazards;
• The Proposed Confined Space Standard for Construction, because the word on the street is that it will be enacted soon, and because it closely mirrors the General Industry Standard and knowledge of that standard will help in preparation for its enactment;
• The Excavation Standard because it is a vertical standard with specific requirement for the most commonly entered confined spaces in construction;
• The Tunneling Standard for guidance with ventilation and gas monitoring;
• Telecommunications and Underground Lines standards, also for ventilation requirements;
• Lock Out/Tag Out for controlling the unintended influx of water or other fluids or gases from pipes and other utilities; and
• Hazard Communication provides information about various kinds of exposures and treatments.
“A look at the excavation standard demonstrates why a single standard will typically not suffice,” says Pettyjohn. “OSHA requires that the designated competent person check any excavation over four feet deep. If the competent person believes a hazardous atmosphere might be present, he is to make sure there is at least 19.5 percent oxygen and no more than 20 percent of the LFL (lower flammable limit) of any flammable gases.
“An employee who knows no more than that knows only enough to get killed from a false sense of security created by the regulation.”