OSHA's confined spaces standard: how does it apply to camps?

Few camp directors consider the Occupational Safety and Health Administration 29 CFR [section]1910.146 Permit-Required Confined Spaces standard promulgated on January 14, 1993. A general misconception is that confined spaces are only encountered in industrial settings. The fact is that the spirit and requirements of the standard still apply. A published summary of OSHA's impact analysis lists camps and other lodging places (SIC 70) as examples of permit spaces found elsewhere in industry.

What constitutes a confined space?

In short, a confined space:

* has limited openings for entry and exit

* is large enough for a person to enter and perform assigned work

* is not intended for continuous occupancy

* has limited or no means of natural ventilation.

A space is considered to have been entered once any part of the body breaks the plane of entry.

There are many variations of confined spaces in terms of size, work process, and hazard. Typical spaces include tanks, underground vaults, silos, vessels, sewers, septic systems, and storage bins. Other types of spaces include pits, crawl spaces, pipelines, boilers, and furnaces.

Why evaluate camps for confined spaces?

It's important to find out if your camp environment does, in fact, contain permit-required confined spaces. Failure to recognize and control hazards associated with confined spaces can place your organization in a vulnerable position. The responsibility for ensuring safety rests squarely on the shoulders of employers. The employer must determine whether the environment contains PRCS and, if it does, implement an effective confined-space program.

All too often, confined-space programs in nonindustrial settings are either deficient in certain areas or simply nonexistent. Approximately 60 percent of the deaths due to confined-space accidents occur during a rescue attempt. Proper planning and preparation could minimize confined-space incidents.

How do camps develop a confined-space program?

The trick to tailoring your program is to become knowledgeable about recognized hazards. Whether the potential hazard is entrapment, engulfment, or atmospheric, the more you know about the possible risks, the better prepared you will be. Use the Permit-Required Confined Space Decision Flow Chart developed by OSHA. This chart poses a series of questions that help determine if your camp has a PRCS and lists steps to develop your program. The basic steps are: identify the need for a permit, conduct air testing, train employees, prevent unauthorized entrance, and monitor program use.

Identify the need for a permit

The first step toward complying with this standard is to evaluate your camp to determine whether on-site spaces meet the definition of a confined space. This evaluation should be performed by a qualified safety professional, such as a Certified Industrial Hygienist, Certified Safety Professional, or Professional Engineer with specific safety and health education and experience. With this evaluation, you can then make the best decision about how to develop, implement, and update your camp's confined-space program. OSHA's PRCS Decision Flow Chart leads to the following three conclusions:

* The standard does not apply when a space meets the definition of a PRCS but you can accurately show and document that the space does not have known or potential hazards.

* A permit is not required when the hazard can be eliminated or when the space can be maintained in a safe condition by forced air ventilation.

* A permit is required prior to each entry when a space has known or potential hazards that cannot be eliminated.

Conduct air testing

Air monitoring must be done whenever the atmosphere is known to be hazardous or potentially hazardous. It is possible to legitimately downgrade to a non-permit-required confined space by demonstrating that the hazards within the space have been eliminated or are being controlled through forced air ventilation. In order to properly implement this type of program, you must log air monitoring results and keep up-to-date records. Remember that evidence from air monitoring will only help dictate the type of precautions needed if it is gathered at the time of entry.

Atmospheric hazards account for 40 percent of confined-space fatalities. The major categories of concern are toxic gases, such as carbon monoxide, and flammable gases.

Toxic gases

A pool of standing water at the bottom of a pit may look relatively harmless. The hidden danger comes from algae bloom and bacterial action that may produce hydrogen sulfide and methane as waste products. These gases displace the oxygen content in the bottom of the pit, particularly when the gas is heavier than air. The only way to know whether the oxygen level is at least 19.5 percent (minimum level of oxygen) but not greater than 23.5 percent (oxygen-enriched atmosphere), is to use a properly calibrated oxygen meter. The instrument is only reliable if its performance relative to a specific gas has been verified through calibration. A weak battery could cause an inaccurate reading.

Flammable gases

As a general rule, you should test the air with an explosimeter to keep a flammable gas 10 percent below the lower explosive limit. Under the right conditions, the flammable gas may be present in a concentration above the upper explosive limit. Ventilating the space will actually lower the concentration of the gas into the explosive range, between the lower explosive limit and the upper explosive limit, thus creating an explosive environment.

Train employees

Train all employees, even those who do not enter on-site confined spaces. Employees need to know what a confined space is in order to know not to enter it. At the very least, inform employees prohibited from entering confined spaces about the hazardous atmospheres in those spaces and about alternatives to entering such spaces. Periodically update employees concerning changes in the physical camp environment and work processes.

A comprehensive confined-space training program also addresses such concerns as:

* establishing modes of rescue from confined spaces (on site or off site)

* the availability, maintenance, and use of rescue equipment (e.g., life lines, harnesses, tripods)

* the selection and proper use of personal protective equipment

* the use of air monitoring equipment.

Prevent unauthorized entrance

Employers sometimes use outside contractors to perform work on PRCS. If you choose to do so, you must take certain precautions to prevent employees and unauthorized individuals from entering the space. For example, post signs at confined spaces stating:

Danger: Permit-Required Confined Space - Authorized Entrants Only

Monitor program use

Supervise and monitor employee interaction with confined spaces. Review records regularly.

Develop a two-way avenue of communication between you and contractors performing work in confined spaces. Tell contractors about the space, prior experiences with the space, and special procedures or equipment located within the space. Ask contractors to demonstrate their use of a confined-space program that conforms to the OSHA standard. If you do not make sure that the contractor implements the program, you create an avenue for litigation against your camp beyond the protection of contractor workers' compensation.

Without question, confined spaces exist in the camp environment. Documented incidents prove that the evaluation process must go beyond looking for industrial-type confined spaces. Use a properly trained and qualified individual to help you evaluate your workplace for the presence of permit-required confined spaces. You'll go a long way toward preventing an unwanted and potentially fatal occurrence.

Derrick Hodge, MS, IHIT, is a Safety & Security Specialist for FOJP Service Corporation. He has a master's degree in environmental and occupational health sciences with a special focus in Industrial Hygiene.