OSHA has recently issued citations for yet another fatality that occurred adjacent to a confined space. As discussed in a previous blog, the hazards of adjacent spaces are not often recognized by employers and are not specifically addressed in the OSHA Permit Required Confined Space standard (1910.146)
North Carolina Dept of Labor recently cited Smithfield Packing ~ $250,000 for a fatality that occurred when a worker was overcome by hydrogen sulfide gas while filling a tanker with liquid sludge. The atmosphere outside the tank was not tested prior to or during the filling and since the worker never ENTERED the tank, there were no confined space entry procedures set in place. There was no permit, no attendant, not testing. See story.
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 can create both health and safety hazards. Workers can die as a result of breathing in toxic materials released into the adjacent space or as a result of a fire and explosion caused by flammable vapors leaking into the adjacent space.
How should we address those hazards that are not necessarily inside the confined space but are 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 will likely include the evaluation of hazards in the area adjacent to the confined spaces. We would love to hear your ideas for how to address adjacent space hazards in the new document!