The OSHA Permit Required Confined Spaces standard, 29 CFR 1910.146, is perhaps the most widely known confined space standard. It provides practices and procedures to protect employees in general industry from the hazards in permit-required confined spaces. The 1910.146 standard does not apply to agriculture, construction or shipyard employment. OSHA’s 1910.272 standard provides basic guidance for entering confined spaces in grain handling facilities. 1915 Subpart B of OSHA provides requirements for entering confined and enclosed spaces in shipyard employment. To date OSHA does not have a confined space entry standard for the construction industry. A proposed rule was published in 2007 and it is on OSHA’s current regulatory agenda. Extensive information on confined space entry can be found on OSHA’s confined space topic page .
There are a number of organizations with consensus standards that relate to confined space entry. The National Fire Protection Association (NFPA) has several consensus standards. NFPA 306 ,Standard on the Control of Gas Hazards on Vessels, provides minimum requirements for entry into vessels that carry hazardous materials in shipyards or ship repair facilities. This standard requires the use of a marine chemist to issue a certificate describing conditions for entry and work in a confined space. NFPA 326, Standard for the Safeguarding of Tanks and Containers for Entry, Cleaning, or Repair, includes minimum procedures for removing hazards prior to entering a tank that may have contained hazardous materials prior to repair including hot work. NFPA 1670 ,Standard on Operations and Training for Technical Search and Rescue Incidents, includes a chapter on confined space rescue. This chapter describes the requirements for organizations responsible for confined space rescue.
The American Society of Safety Engineers (ASSE) has developed a consensus standard ANSI/ASSE Z117.1, Safety Requirements for Confined Spaces. The original standard was published prior to the OSHA standard. It describes minimum safety requirements to be followed while entering, exiting and working in confined spaces.
Industry specific consensus standards have been developed by the American Petroleum Institute (API). ANSI/API 2015, Requirements for Safe Entry and Cleaning of Petroleum Storage Tanks, provides requirements for entry and work being performed in stationary tanks used in all sectors of the petroleum and petrochemical industry. ANSI/API 2016 ,Guidelines and Procedures for Entering and Cleaning Petroleum Storage Tanks, provides additional guidance and supplements the requirements of specific aspects of tank cleaning given in the ANSI/API 2015 standard.
Most of the standards currently in existence provide minimum requirements for entry. They are generally not prescriptive but are performance based leaving the employer or safety professional to decide how to best evaluate, enter, work in and exit the space. There are still approximately 100 employees a year killed in confined spaces. As safety and health professionals we need to do a better job preventing these fatalities.
The new document that will be developed by the NFPA technical committee is expected to go above and beyond the minimum requirements and will provide more detailed guidance on evaluating confined spaces and controlling hazards. It is expected that this document will extract some of the best practices from existing documents and will include additional recommendations for evaluating, entering, working and exiting confined spaces.
We are hoping this document becomes a “gold standard” for confined space entry. What would you like to see included in this type of document? Let us know!