The existing OSHA 1910.146 Permit Required Confined Space Standard for general industry does not address hazards immediately outside and adjacent to confined spaces. Atmospheric hazards adjacent to a confined space create both health and safety hazards. Fatalities have occurred when workers were overcome by toxins present in the vicinity of the confined space. Flammable atmospheres have been the source of numerous fatalities that have occurred when a worker was performing hot work immediately outside a confined space. Two employees at Valero Refinery died when they were overcome by nitrogen as they performed maintenance work near a confined space opening on the top of a reactor. A worker at DuPont was killed when he was welding immediately outside a tank containing flammable vapors.
These fatal accidents may have been prevented if the atmosphere outside these two confined spaces had been tested. How do we address those hazards that are not necessarily inside the confined space but are very much associated with the confined space hazard?
In the marine industry, both the OSHA Shipyard standards (1915.14) and NFPA 306 Standard for the Control of Gas Hazards on Vessels recognize the hazards of adjacent spaces. Both standards require that a Marine Chemist evaluate not only the confined space but also the area adjacent to those spaces whenever hot work such as welding will take place.
NFPA is developing a best practices document for confined space entry. The new document is designed to address gaps in existing confined space standards and will likely include the evaluation of hazards in the area adjacent to the confined spaces.
If you have suggestions for what should be included in this soon to be developed new confined space best practices document we would love to hear from you. Should the document address hazards immediately adjacent to confined spaces? Is there a gap in the current OSHA general industry standard that should address these hazards? We want to hear from you!A video on the Valero incident