You have identified all your confined spaces at your workplace. What is next? You need to figure out when and why employees may need to enter those spaces. The best possible scenario is that you make the determination that there is NO NEED for employees to enter this space or at least not to enter except in unusual circumstances. In those cases you need to take steps to insure that these spaces are NOT entered. Sometimes it takes a fresh look at some of your confined spaces to see if it necessary to go in to those spaces at all. The safest option for entry is no entry at all.
A few years ago I was working with a correctional facilities manager to develop a confined space entry program for the facility. He brought me in to the laundry room and showed me a vertical pipe chase in the corner of the room leading several stories down to the basement. The pipe chase had a grate covering over the opening. The facilities manager indicated that occasionally someone would have to open the grate and descend to the basement to retrieve socks and other items that had fallen through the grate. The logical question “Why put employees at risk entering a confined space to retrieve a sock?” Certainly we all have mismatches to deal with! In this case there was also a very logical solution. Put a fine mesh screen over the hole below the grate so nothing falls in! Then lock the grate shut, post a confined space label and if there is a need to enter the space every 20 years to repair a leaking pipe, then review the hazards of the space and safe entry procedures prior to entry.
Technology is available today that can minimize the need for confined space entry. In the past, meter readers had to enter confined spaces such as vaults and manholes routinely to manually read water and electrical meters. There are now remote reading sensors that can be installed so that these same meters can be read without entering the confined spaces. Video cameras can be used to “monitor” spaces and electronic detectors can sense when a valve or gasket may be leaking. A valve stem could be extended so that it can be manipulated from outside a confined space. We need to start figuring out ways to NOT enter confined spaces! (More on prevention through design in a later blog!)
If you determine that there are confined spaces in your workplace that you do not want employees to enter, the OSHA 1910.146 (c)(3) of the Permit Required Confined Space Standard
allows employers to post a sign warning of a confined space hazard, take effective means to prevent entry, and re-evaluate the space if an employee and contractor were to enter the space.
Do you have any examples of confined spaces at your workplace that do not need to be entered? I would love to hear about them and what you did to prevent entry! Remember, the safest entry is NO entry!!