2023 Jul-Aug RETA Breeze

• Finally, let’s take a harder look at the phrase “to perform assigned work”. I have seen 55 gallon drums used as trash cans, and although you could fully enter one, I have never seen one placarded as a Confined Space. At least part of the reason is there is just no work to do in there. So honestly, it you have an oil separator that you could conceivably enter fully (if the coalescer filters were removed) should it be considered a Confined Space when the only assigned work could not be performed if you are in the space? So, what are an employer’s obligations under 29 CFR 1920.146? Step one is the performance of an assessment of the work- place to determine if it contains spaces that meet the OSHA definition of a Permit- Required Confined Space. One of the most common citations under the Confined Space Standard is failure to identify Confined Spaces in the workplace. Step two , the employer must inform affected employees of the existence of all the PRCS’s, their locations and the hazards contained therein. Employee notification can be accomplished as easily as posting appr- opriate signage on PRCS’s. Step three— you must make a decision as to whether you will allow your employees to enter PRCS’s or if you are going to hire contractors to perform any work that must be accomp- lished in a PRCS. If you plan to have your own employees enter PRCS’s, you must develop a written program. That of course is a topic in and of itself, but the standard is explicit and detailed. By the way, have you read the Standard? Once you do, here are some links that are useful in gaining a better understanding of the subject:. https://www.osha.gov/laws-regs/ regulations/standardnumber/1910/1910.1 46#:~:text=Confined%20space%20 means%20a%20space,have%20 limited%20means%20of%20entry. https://www.osha.gov/sites/default/files/ publications/osha3138.pdf https://www.michigan.gov/leo/-/media/ Project/Websites/leo/Documents/MIOSHA/ Fact-Sheets/GISHD/Fact_G019.pdf https://tools.niehs.nih.gov/wetp/public/ Course_download2.cfm?tranid=4372

definition of a Confined Space. OSHA published a booklet in 2004 designated OSHA 3138-01R that goes a long way toward clearing up misconceptions about imple- mentation of a Permit-Required Confined Space policy. So, let’s take a more detailed look at what makes an enclosed space a Confined Space. The OSHA definition of a Confined Space is any space that possesses all three of these characteristics: • It’s large enough and so configured that an employee can bodily enter and perform assigned work. • It has limited or restricted means for entry or exit. • It’s not designed for continuous employee occupancy. We are going to examine each of these of the criteria that define a Confined Space in reverse order. • A concept that is sometimes misunder stood is “designed for continuous occupancy”. The Michigan OSHA (MIOSHA) means that the space could be occupied during normal operations; not that it is continually occupied.” For most of the enclosed spaces we would concern our- selves with, the answer would be no, they are not designed for human occupancy. • Limited or restricted means for access or egress. A door can make a big differ- ence. Not just a door, but a door that can be opened from inside the space. Oil separators don’t have doors. Evap- orative condensers do, but not doors that are operable from inside the space. • To “bodily enter” means that it is possible for an employee’s entire body to enter the space. This is also referred to by OSHA as to “enter fully”. MIOSHA puts it this way: “To ‘bodily enter’ means that it is possible for an employee’s entire body to enter the space. If the space itself is too small, or the opening into the space is not large enough for the entire body to enter, then bodily entry cannot take place; such a space cannot be a confined space.” This is where the bucket doesn’t make the cut—you just can’t get your whole body in there. is helpful with their explanation: “ ‘Continuous employee occupancy’

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