It is around the year 110 A.D.; the Roman Emperor Trajan sentences three criminals to clean sewers, an occupation considered to be one of the worst. How Many Of These Confined Spaces Are In YOUR Jurisdiction? Auto repair lift pits Below-grade basements...
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It is easy to underestimate the serious risk potential of a confined space incident. They are particularly difficult to manage for us in the fire service, due to our limited exposure to and experience with actual rescue incidents. They simply do not occur with the frequency of fire duty; hence, our “learning curve” for confined space incidents, as in other technical rescue operations, is much greater.
In 1993, after about 18 years of information gathering, study and public hearings, OSHA issued a comprehensive Federal Regulation that addresses worker safety in confined spaces (29 CFR 1910.146). Although primarily targeted toward industry (excluding the agriculture, construction and maritime industries, which have their own standards regarding confined space operations), fire departments, to varying degrees, are affected by this regulation. OSHA does not have jurisdiction over state and local public employees but if a state adopts its own OSHA plan, it must extend coverage to its public employees. Twenty-five states are regulated by state OSHA plans but must adhere to the federal confined space standard until their state plans adopt a comparable updated version for confined space operations. Six states recently had their own confined space standards in effect.
In many states, government agencies such as fire departments, emergency services and police departments are exempted from this federal regulation. However, the U.S. Department of Labor defines the federal OSHA standards as minimum standards and has furnished research and tabulated data to support the regulations.
Regardless of whether your state is bound to implement the OSHA regulations for public employees, it is recommended that these minimum requirements be used as a baseline guide to develop your own standard operating procedures. The liability could be tremendous and financially devastating to be ignorant of or neglect the minimum safety parameters established by these standards. A civil liability case would be a strong possibility and certainly hard to defend against if recognized minimum safety standards were not utilized. For this reason it would serve in the best interest to use the standard in confined space activities as a template to ensure the safety of fire department members.
Many other agencies have a potential impact on fire department confined space operations:
- National Institute for Occupational Safety and Health (NIOSH).
- American National Standards Institute (ANSI).
- National Safety Council.
- National Fire Protection Associa-tion (NFPA).
- State and local level agencies.
Some agencies contributed much data and counsel to the OSHA Federal Regulation Final Rule; others have direct impact regarding equipment and operating methods when it comes to confined space incidents. (For example, NFPA Standard 1983 recommends specific requirements and tensile strengths for ropes and associated hardware and software used extensively in retrieval systems for confined space entry.)
Much reference material and many guidelines are available regarding confined space operations; it is up to each fire department to utilize whatever information it deems relevant in establishing a standard operating procedure for confined space rescue operations.
Recognition Of Confined Spaces
According to OSHA, a confined space is defined as a space:
- Large enough and so configured that an employee can bodily enter and perform assigned work.
- With limited or restricted means for entry or exit (for example, tanks, vessels and pits are spaces that may have limited means of entry).
- Not designed for continuous em-ployee or human occupancy.
OSHA further defines specific confined spaces in a class that has, or has the potential for, one or more of the following characteristics as “permit-required confined spaces” (OSHA requires that these be inspected and all potential hazards reduced before a permit is issued prior to entry):
- A hazardous atmosphere.
- An engulfment hazard.
- An internal configuration that could trap or asphyxiate an entrant (such as inwardly converging walls or a downward sloping floor that tapers to a smaller cross-section).
- Any other recognized serious safety or health hazard.