A Special Message to District Management

Observing OSHA guidelines is a big step toward mastery of confined space safety

As the Pool’s Safety Consultant, I get the opportunity to meet many people at member districts. One thing I have discovered, unfortunately, is that many districts access confined spaces, but do not have proper measures in place to do so safely.

Perhaps this can be attributed to the fact that public entities do not fall under the oversight of OSHA, the Occupational Safety and Health Administration. This has allowed special districts to arbitrarily pick and choose which standards to follow.

That could be a costly decision. OSHA’s guidelines are the result of decades of research and occupational expertise, and are considered the reasonable baseline for safety. If your district adhered to OSHA regulations, there might be a trade off in time or cost, but that comes with the confidence that your staff would go home safely every night.

In the last 25 years, there have been well over 650 fatalities in the United States due to confined spaces confined spaces. A study done in 2006 by a California company found that approximately one-fifth of confined space incidents resulted in multiple fatalities. Data also indicated that for every fatality due to oxygen-deficient and/or toxic atmosphere, two non-fatal injuries occurred, one of which would require hospitalization.

The Current Outlook

In general, I usually see one of two scenarios concerning confined space activity when I visit members:

  1. No policy at all
  2. Partial adaptation of Confined Spaces standards

Given the statistics above, this is worrying. I know that every manager takes his or her workers’ safety very seriously. If the greater occupational safety world views OSHA as the baseline, shouldn’t we all at least meet that standard, if not exceed it?

The first step is defining a confined space. A confined space is any space that has limited means of entry or exit, not designed for human occupancy, and large enough so that an employee can enter.

Once you have determined that you have a confined space, the next step is to determine the level of confinement. Is it a permit required confined space or a non-permit required confined space? OSHA defines a permit-required confined space as a space that could contain any of the four items below:

  1. Contains, or has the potential to contain, a hazardous atmosphere
  2. Contains a material that has the potential for engulfing an entrant
  3. Has an internal configuration, such that an entrant could be trapped or asphyxiated
  4. Contains any other recognized serious safety or health hazard

If you can rule out all four of these, then you have a non-permit required confined space. However, you should treat these non-permit confined spaces seriously and address them on an individual basis.

Shoring Up Your Confined Space Ops

If after reading this you think you have some confined spaces within your district, then there are a few steps that you can take:

ONE: Develop a Confined Space policy for your district

  • Include OSHA standards and include any site-specific or district-specific items you feel will help make the policy more efficient
  • Utilize signed confined space permits anytime you are entering a space

TWO: Use a 4-Gas Air Monitor to test the air inside the space before entering

  • Follow the manufacturer’s recommendation for bump testing and calibrations

THREE: Train your employees

  • Train your employees on your policy as well as the steps to take when they are faced with entering a confined space

There are a lot of tools available to help you determine what type of confined space you have or whether the space is actually a confined space to begin with.

A simple flowchart is a great tool that can be used for every situation. OSHA has one particular flowchart that includes compliance considerations. All you have to do is start at the top and work your way through the flowchart by answering the questions. See below for links to some sample flowcharts.

OSHA Flowchart

Yale University’s Flowchart

If you need help developing or refining your confined space policy, we can help. We can offer guidance and training on this topic. If you would like to schedule a meeting or training, please email Adam Johnsen at ajohnsen@mcgriff.com.

OSHA has also put together a confined space compliance guide to help get you started. You can download that at OSHA’s website.

Additional Resources

OSHA Confined Space Index

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