Few would disagree that OSHA’s Permit Required Confined Spaces standard has improved confined space safety and awareness over the past twenty-two years. The implementation of the new Confined Spaces in Construction standard, which OSHA published in May, is expected to further improve confined space safety. However, despite regulations, nearly 100 employees a year (on average) die in confined spaces in the United States. Clearly, there is still room for improvement.
Some of the deaths, of course, are due to a simple lack of compliance with existing standards. But others appear to result from gaps in existing standards and confusion about what is required for confined space entry. NFPA 350, Guide for Confined Space Entry and Work, scheduled for release this November, will address these gaps, minimize confusion, and provide practical guidance on how to apply requirements in existing standards to improve confined space safety. Three of the key standards used in confined space entry in the U.S.—OSHA 1910.146, Permit Required Confined Spaces; ASSE Z117.1, Safety Requirements for Confined Spaces; and OSHA’s new 1926 Subpart AA Confined Spaces in Construction—admittedly provide minimum performance-based requirements. Performance-based standards focus primarily on the desired outcome—in this case, preventing injuries and fatalities in confined spaces. However, performance-based standards sometimes lack sufficient guidance on how to reach that desired outcome. This is where NFPA 350 fills the void, providing many of the “how-to’s” for confined space safety that will help employers comply with one of the performance-based confined space standards. NFPA 350 provides guidance beyond the minimums, fills in some gaps in safety, and simplifies terminology that can create confusion when applying confined space standards. NFPA 350 is organized so that a facility can utilize the document as a whole, or use particular chapters to bolster an existing confined space entry program. For example, employers who wish to improve their confined space entry program can implement NFPA 350 in stages, perhaps improving their gas monitoring program, then moving toward improving hazard controls or competencies as the program evolves. CONFINED SPACE, PERIOD Perhaps one of the most confusing parts of confined space safety is the terminology used by safety professionals and regulators to describe confined spaces. The terms “confined space” and “non-permit confined space” can be used interchangeably to describe a confined space where no hazards are present. However, this same space becomes a “permit-required confined space” the very next day when an employee enters it to weld or paint. The type of space is different from day to day and depends on what is being done inside the space. Furthermore, there are several different procedures that can be used for entering permit-required confined spaces. “Reclassification procedures” are allowed in spaces where all hazards have been eliminated. “Alternate procedures” are allowed where the only hazard is atmospheric and is controlled by ventilation. A full permit is needed for entry where other hazards exist. Even confined space professionals have expressed difficulty over how to best explain the differences in requirements for entry to employees and employers. To minimize confusion, NFPA 350 uses one term—confined space—throughout the document, instead of renaming a space based on the presence or absence of a hazard. All spaces that meet the OSHA definition of a confined space are referred to simply as “confined spaces” in NFPA 350.
The guide also establishes one procedure for all of those spaces, starting with the pre-entry evaluation form. NFPA 350 does not distinguish between a reclassified space and an alternate procedures entry. All spaces are evaluated on their own merit based on hazards that are inherent, introduced, or adjacent to the space. Whether a permit is required for entry depends on the hazards or potential hazards identified in the pre-entry evaluation form. This approach of using a checklist to evaluate all spaces prior to issuing a permit is already in practice in some industries. The change in terminology does not conflict with OSHA or ASSE regulations or standards. Rather it promotes safety and simplifies the application of requirements: look at the space, determine whether it’s a confined space, and if so, perform a hazard assessment and document it as part of the pre-entry evaluation. CONFINED SPACE IDENTIFIED: WHAT NEXT? OSHA requires a cognitive assessment of a confined space to determine whether hazards exist that would make it a permit-required confined space. If no hazards exist or potentially exist, no further action is required. Currently, OSHA does not require documentation of that hazard assessment, and the evaluation of whether a hazardous atmosphere potentially exists can be performed without monitoring. In NFPA 350, all confined spaces are evaluated using a pre-entry evaluation form, a signed checklist used to identify and document hazards that are inherent, introduced, or adjacent to the space. NFPA 350 takes one additional precaution at this juncture and recommends atmospheric monitoring prior to any confined space entry. Those results are also recorded on the pre-entry evaluation. The default position is to perform atmospheric monitoring prior to entry into any confined space. The analogy is that you should “assume the dog will bite until you find out otherwise.” Because atmospheric hazards continue to be the source of many confined space fatalities, the NFPA 350 Technical Committee decided that the few minutes it takes to perform atmospheric monitoring is time well spent to verify that there is no hazardous atmosphere. If no physical or atmospheric hazards are found, the pre-evaluation form is signed and no permit is needed. The pre-entry evaluation form can also be used as the written certification required for entry using reclassifications or alternate procedures required by OSHA’s Permit Required Confined Spaces standard. If hazards are identified, then a permit is needed and the procedures required for safe confined space entry apply.
Above and Beyond The Minimums
An Overview of NFPA’s New Guide for Safe Confined Space Entry and Work
Editor’s note: The author is an employee of the National Fire Protection Association and vice chair of AIHA’s Confined Spaces Committee.