OSHA's new confined spaces entry regulation.

Stiff compliance costs and even stiffer fines accompany new permit designations and safety rules.

The U.S. Occupational Safety and Health Administration (OSHA) estimates that more than 60 workers died from confined-space related injuries in 1992. While over 1.5 million employees enter confined spaces every year, OSHA's data suggests that no current standards effectively prevent workers from atmospheric and mechanical hazards.

What Is a Confined Space?

OSHA's definition of a confined space is any that allows human access, has limited means of entry and/or exit, and is not large enough for continuous employee occupancy. In foundries, affected spaces would include resin, gas and scrubber solution storage tanks, mullers, pits under furnaces, sand silos and shakeout units with limited access.

OSHA has begun to restrict access to these types of confined spaces with a new regulation that it expects will prevent 54 deaths and more than 10,000 injuries per year.

The new regulation governing workplace practices in confined spaces (29 CFR Part 1910.146), which took effect last April, is expected to affect more than 200,000 worksites, including foundries. The new standard creates safety requirements, including a permit system, for entry into potentially hazardous confined spaces. Permit Designations

According to the regulation, confined spaces are separated into "permit-required" and "nonpermit-required" spaces. Nonpermit-required spaces have been certified by a competent professional and don't exhibit conditions that may cause death or serious injury. Therefore, they may be entered without a permit. Some nonpermit-required confined spaces are crawl spaces, drop ceilings and certain types of ductwork.

Permit-required spaces pose more serious safety hazards and before entry is to be granted there must be an entry-permit program in place. Such a program should at minimum consist of training programs; safety equipment; hazards evaluation; a designated entrant list; and comprehensive emergency plans.

The spaces should be clearly marked with signs designating the requirement and the degree of danger. Permits themselves must be specific in listing names and functions of occupants, present safety conditions, dates and lengths of entry, and equipment to be used.

Furthermore, any entry must be monitored by an attendant. A lifeline must be attached to the entrant and run back to a tripod, wench or electrical retractor. Then, if the situation arises, the attendant can pull the entrant to safety without needing a rescuer to enter the space.

Training Requirements

It has been determined that multiple deaths resulting from confined space entry injuries most often were caused by untrained workers trying to rescue the original entrant. (Therefore, OSHA considers these poorly trained workers to be a "group at risk.") Thus, the presence of the trained attendant with the proper rescue equipment and training is considered critical.

In addition to implementing standard emergency procedure training for entrants, attendants and supervisors, plant management is required to have fully trained rescue teams ready to respond to any situation. OSHA allows management to choose between in-plant rescue teams and outside agencies, weighing which would be more efficient and cost effective under the circumstances. Outside agencies must be fully informed of any and all hazards that may be encountered, and of any special equipment that may be needed when responding to a call.

Atmospheric Hazards

Since many confined space injuries are caused by hazardous atmospheric conditions within the vessel, standby rescuers are required to wear proper apparatus for respiratory protection. All atmospheric toxins, asphyxiates or potentially explosive gases are to be listed on the material safety data sheets required for permit spaces by the regulation.

OSHA requires confined space atmospheres to adhere to specific standards of less than 10% of the lower explosive level for combustibles---lower air contamination levels than those specified in the text of the regulation and 19.5-23.5% oxygen content.

The Cost of Compliance

Compliance with 29 CFR 1910.146 is expected to cost American industry more than $200 million annually. Non-compliance, however, carries penalties of $70,000 per occurrence, and it is expected that numerous fines will be imposed on businesses that commit serious violations.