What is a Confined Space?

For many people the term confined space is used to describe any area where our access is limited and where it is difficult to move around. This definition would also include areas such as the one found when riding in the back of a small compact car. If you are a tall person, that may seem like a confined space!

But a confined space is more than that, and can be much more dangerous. In many instances, a confined space can be a tank used to store liquids, a grain silo, a trench at a construction site, a sewer system, or many other types of areas where we are limited in what we can do. No matter what industry or job function you work in, you probably are exposed to confined spaces and in some cases, may not even know it.  

To find OSHA's regulation on confined spaces we need to look in their regulations. In this case we would turn to the 29 CFR 1910.146. Some of the key parts of the regulation are below, but for those of you who may want more information, here is a link to see the entire regulation: 29 CFR 1910.146.

Here we find what OSHA's definition of what a confined space really is - an area that must meet all of these three criteria:

1. Is large enough and so configured that an employee can bodily enter and perform assigned work; and
2. Has limited or restricted means for entry or exit (for example, tanks, vessels, silos, storage bins, hoppers, vaults, and pits are spaces that may have limited means of entry); and
3. Is not designed for continuous employee occupancy."

Or, we could identify a confined space by asking these three questions:

1. Is it large enough for someone to get into and work in?
2. Is it hard to get in and/or out of the space?
3. Is it designed for people to be in there continuously?

Answering these questions will let you know if you're dealing with a confined space. However, we often find that these questions raise other questions.  

Is it large enough for someone to get into and work in?

How big does a space have to be to be able to enter? Would a space between the walls in a building meet that part of the definition? It is certainly confined within the studs of the walls. What about a small trench in the yard used to install sprinkler pipe? Could either of these places meet that criteria and therefore considered a confined space?

While OSHA does not state the specifics of how big something needs to be, the generally prevailing thought is that something needs to be about four feet deep in order to be big enough to enter and perform work. While this is not perfect, it gives us some guidance in this area. In this case, the space in the walls or the sprinkler pipe trench don't really qualify as confined spaces although there still may be hazards present which will still need to be addressed.

Is it hard to get in or out of the space?

While they term this "limited ingress and egress" in the regulation, those are rather subjective terms. Many people try to simplify this question by asking if there is only one way in and one way out. If you think about it, most rooms meet that criteria. In actual fact, it has nothing to do with the number of ways in and out, it has to do with the difficulty that you go through to get in and out.

It is really quite simple. If it is hard to get into the space in the first place, it is going to be a problem for us if something goes wrong and we need to get out in a hurry or worse yet, someone needs to come in and help to rescue us. Getting in and out are major concerns in areas which could pose a hazard. Think about the importance of "Fire Exits" in the workplace or in public areas. Always consider the "what-if's" - what if an emergency were to occur?

An open trench with unlimited ways in and out can be limited in ingress and egress and can meet the OSHA definition. To find out what OSHA means here we can turn to their own guidance documents and review the responses they have written to those who ask this question. When we look at OSHA's interpretive letters, we find that they have defined "limited ingress and egress" as any entry that would require the person who enters the area to do something that is not normally required. This could involve the need to bend over, crawl into, step over something, or any entrance or exit that is not large enough for an employee to enter/exit with free, unobstructed movement. Ask if it has a door size opening which is easily accessible without any special effort?

Is it designed for people to be in there continuously?

This one is a bit easier to determine  since areas designed for people to be there in the first place generally are not full of other things such as liquids, grain, or other materials. Further, if a space were designed to hold people for an extended period of time there likely would be things in the space to accommodate that activity. This could include adequate ventilation or even the lack of other hazards or materials in the space as we just reviewed. The bottom line is this, is the space somewhere that I would like to spend time?  If not, you likely meet the criteria for this space being classified as confined.

If you have further questions, you can always contact us at [email protected]. If you need training on a confined space, we have an online course to meet your needs. Check out the course description at hazmatschool.com.

hazmatschool/confined space. 

There's Nothing To Fear Here...That's What Scares Me

The title of this comes from the hit movie, Raiders of the Lost Ark (http://www.imdb.com/title/tt0082971/), and is in one of the opening scenes where the hero, Indiana Jones, and his colleague reach the room where the treasure they seek is found. After trekking through the jungle and through a temple fraught with booby traps, the two finally reach the room and everything looks like it is finally safe. Indiana stills acts with caution, which makes his colleague remark that there is nothing to be afraid of. Indiana Jones replies "that's what scares me." Of course, Indiana Jones is right, and shortly after they grab the treasure mayhem ensues and only Indiana escapes with his life, but barely and only in a very dramatic fashion (it was an action movie, after all).

Despite being an iconic scene in movie history, we think that the scene also has something to teach us about safety management. You could argue that one common theme exists in almost every accident - something that someone saw as benign turned out to be dangerous. Think about the operators who were running the BP Texas City Refinery plant who overflowed a tower, leading to a release and explosion (scmsafety.blogspot.com/2014/04/procedure-violations-from-human.html). Or the truck driver who got behind the wheel and ended up crashing into a limousine carrying comedian Tracy Morgan and others (scmsafety.blogspot.com/2014/06/stop-trying-to-punish-error-out-of.html). In each of these cases, the people involved did things under the assumption that there was nothing to fear...but it turned out they were wrong.

And, even though with these two examples we focused on the individuals closest to the accident, you could say the same about others higher up in the organizations having influence over the accident. The plant management and corporate managers over the BP Texas City Refinery didn't think that there was anything to fear when they made further cuts to maintenance, training and process safety spending...but they were wrong.

This is a common theme in safety management - thinking that everything is "safe", when there is much to fear. This is interesting when we in the safety profession spend so much time thinking about what could go wrong in terms of hazard and risk. We have piles and piles of paper composing all the regulations, procedures, hazard and risk assessments, and training that should help us prevent these instances. Yet, a common theme emerges as one studies major accidents - these things are often in place, yet the accident still happens.

What gives?

We think that the problem is stems firstly from the Newtonian idea of cause and effect - that big causes lead to big effects. Therefore, to have a big effect, you need a big cause. This isn't really true though. If you study major accidents, it's often, at best, small things, sometimes called "weak signals", that signal that something is amiss. Of course, the problem is that after the accident those signals no longer seem so weak, because we can draw an easy correlation between the weak signal and the accident. But, in the moment, the signals are weak indeed, and many times, they are so weak that only in retrospect, after the accident, can those signals have meaning. So, in the moment, we go along, assuming that there's nothing to fear, when mayhem is about to ensue.

That's why we think that there needs to be a paradigm shift in safety management. Most tools and interventions in the safety profession are designed to find obvious things - hazards, "unsafe acts" (scmsafety.blogspot.com/2015/01/beyond-unsafe-behavior.html), etc. But there are few tools designed to help safety professionals understand and find those "weak signals" in organizations that lead to real disasters. Part of the problem, in our opinion, is that many of these weak signals are just normal work - i.e. things continuing on successfully. And, in the safety profession, we're not equipped to learn from success. Our bread and butter is learning from failure (or at least it should be scmsafety.blogspot.com/2013/11/dont-ask-whos-to-blame-ask-whats-to.html). But if all we do is learn from failure, we learn about only a small part of our organization's operations, because most of the time things don't fail. Most operations succeed, and we have no idea why. For example, what if the same things that we think are leading to failure (e.g. "unsafe acts") are also leading to success? Wouldn't that suggest that saying that accidents are caused by human failure is, at best, inadequate at explaining accidents?

The time has come for the safety profession to change focus. We need to stop learning from failure alone and start looking for those weak signals, those normal, everyday things, that may be the triggers of the next major accidents in your organization. Diane Vaughn, in the book mentioned above, called this the "banality of accidents". Why? Because accidents are caused by everyday work.

So how can we start looking at and learning from normal, banal work in our organizations, so we can both increase the chance of success and decrease the chance of failure? Here's some tools we recommend you consider:

• Get out from behind your desk, get on the shop floor, and learn from your workers. Note, this is not the same things as you going out and looking for "unsafe" things. This is not a hazard hunt. Certainly we're not asking you to ignore clearly dangerous situations, but this excursion onto your shop floor is designed to help you learn about what's actually happening on a daily basis in your organization.
• Consider holding debriefing sessions after a shift or a project with work crews and multiple levels in your organization (from top to bottom). This is commonly done in the military, but not as much in the civilian world. Ask your crews what worked, what didn't, and what surprised them? Where did they have to bend the rules and change the plans to get the job done? Where were the rules and plans spot on? Where did they feel uncomfortable with the task? (Obviously this should be done in a safe, blame-free environment, so that workers feel comfortable sharing.)
• Conduct a formal success investigation (scmsafety.blogspot.com/2014/04/success-investigations-safetys-under.html). Next time a project goes right (however you define that in your organization), do an investigation, just like you would if there had been a failure. Interview witnesses, look at evidence, etc. Find out why things are working and you just might find some clues as to how things could fail that you weren't aware of.
• Start learning about drift (scmsafety.blogspot.com/2014/07/drift-to-danger.html), weak signals, and human and organizational performance. There are plenty of resources out there, this blog being one of them, but others, such as other blogs (www.safetydifferently.com and humanisticsystems.com), podcasts (disastercast.co.uk), and authors (sidneydekker.com and erikhollnagel.com) that can get you started.

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