Confined Space Considerations for the Small Employer
A common failure of these programs is doing nothing, because it is easy to put this topic off during a tough economy.
Safety professionals working with or for small employers deal with a substantial injury potential and must assess the need for various programs. During the past two economically terrible years, which included massive employee layoffs, company closings, downsizing, and shifts in processes and work duties made just to survive, many hazardous situations may have fallen through the cracks of your usually effective program. In my opinion, one of the most hazardous is Confined Spaces.
Per OSHA: A confined space has limited or restricted means for entry or exit, and it is not designed for continuous employee occupancy. Confined spaces include, but are not limited to, underground vaults, tanks, storage bins, manholes, pits, silos, process vessels, and pipelines. OSHA uses the term "permit-required confined space" (permit space) to describe a confined space that has one or more of the following characteristics: contains or has the potential to contain a hazardous atmosphere; contains a material that has the potential to engulf an entrant; has walls that converge inward or floors that slope downward and taper into a smaller area which could trap or asphyxiate an entrant; or contains any other recognized safety or health hazard, such as unguarded machinery, exposed live wires, or heat stress.
Small companies have rarely been under greater stress than they are today. Many employees are taking on new roles while overloaded with duties. I believe in trusting your employees' ability (that is, trust but verify with training, assessment, and inspections), yet it is still the employer's responsibility to implement a sound program if needed and to update it as necessary.
For a small employer just getting started, these are a few items to think seriously about:
Review the entire confined space issue and the need for a program. If you aren't qualified to do this, hire a really good safety consultant who is. If you cannot commit to the program, make sure you have an alternate plan: No employee ever enters a confined space, and only qualified contractors may enter, etc.
Include every potential job duty, routine or not. Inspect the site, interview employees, review old and new processes, and examine all related programs, such as heat stress, where confined spaces will be an issue. You have to look at the hazard, not just the configuration of the work space.
Be blunt with employees during your education/awareness efforts. Mincing words here may cost a life. Tell them up front what is at risk and what you plan to do if they fail to use the program correctly and take chances. Tell them that dead employee will be them or the person sitting next to them, and if shortcuts are taken, they will be fired. (Be sure of your authority here, and that you have the true support of management.)
Paid consultants aren't the only tool available to you; consider government resources, college/university programs, video rentals, CD programs, and customized training sources. Use what works for your industry and the work you're doing.
Contractors can perform needed confined space work. This is one of the most cost-effective methods. You subcontract to someone who has the equipment, knowledge, support framework, and training. Just make sure your employees do not get involved and assist.
Failures of small employers' programs often include:
- Doing nothing, because it is easy to put it off.
- Not monitoring for changes in work situations and new processes. The employer assumes all is well because it was 10 years ago.
- Placing too much trust in employees' judgment.
- Assuming corrective actions were actually put into place. You have to follow up and make sure the correct items were purchased, unboxed, trained on, and used.
- Inadequate approvals. Make sure checks are in the program so one person does not make all of the decisions. You need a checks and balances system in case the wrong person is calling the shots to save money.
- Inadequate equipment. Atmospheric monitoring devices, rescue equipment, and the rest: How often is it equipment tested, inspected, and used for employee training? If your answer is "randomly," you have a time bomb in the making.
As safety professionals, we do make an impact every day. We can effect change to help employees help themselves, one standard at a time, and return home safely. With all of the headaches, stress, and hardships we as safety professionals endure, it is a great reward in an often thankless job.
Confined Space Checklist
- Is your workplace considered a small employer?
- Do you have a comprehensive safety program in place that is usable and updated regularly for all employees and processes?
- Has your workplace been assessed for the need of a confined space program by a qualified and competent person or committee?
- Has each potential confined space been labeled by a durable means to ensure any employee, visitor, or contractor knows it is a confined space? Are labels in multiple languages if needed?
- Do you have a specific description of each confined space location, process, and hazard associated with the space so others fully understand the dangers with this space? (All confined spaces are not the same as the hazards, and your actions to work safely in them can change.)
- Is a management system in place to ensure proper access and authority to allow entry to confined spaces?
- Do you have a backup authority system in the event the primary person is on vacation or off site?
- Is there a designated place on site for all documentation related to the safety program and confined space documents? Are employees aware of the location, and is it available 24 hours a day?
- Do subcontractors work on your site? Are they made aware in writing of potential confined spaces and their actions required prior to entry? Are liability and responsibility explained?
- Are emergency plans in place for rescue and treatment in the event of a confined space injury?
- Do you have interaction with local emergency/rescue teams for assistance if needed? Is this in writing?
- Is all documentation of your confined space program easy to follow and understand for all levels of employees, including policy, permit paperwork, labeling of confined spaces, description of associated hazards with each confined space, training format, equipment records, monitoring records and logs, and service documentation?
Linda J. Sherrard (firstname.lastname@example.org), MS, CSP, is Safety Consultant II with Central Prison Healthcare Complex in Raleigh, N.C., and is the former technical editor of OHS.