Written on: July 12, 2016 by ICM
From the July/August Indoor Comfort Marketing–
Bill Spohn, TruTech Tools, LTD, TruTechTools.com
Techs in the HVACR industry are no stranger to working in cramped spaces with varying job site conditions that can often be deemed hazardous. Although
practicing safe habits and protocols on the job comes with the territory, a recent Occupational Safety & Health Administration (OSHA) ruling now includes attics and crawlspaces as confined spaces in many cases. This will require new processes and
on the job techniques to address the confined space hazards. This means more training and new routines and may require some new tools.
We will focus this article on thermal and atmospheric hazards.
Implementation and details
On May 4, 2015, a new amendment to OSHA Construction Standard was published. On Aug. 3, 2015, the amendment went into effect. It extended the definition of confined spaces to include attics and crawlspaces (among other spaces). Up until then, confined spaces were thought of as being more “industrial” in nature, such as these in the following list from the actual Code:1
• Bins; boilers; pits (such as elevator, escalator, pump, valve or other equipment)
• Manholes (such as sewer, storm drain, electrical, communication or other utility)
• Tanks (such as fuel, chemical, water or other liquid, solid or gas)
• Concrete pier columns
• Transformer vaults
• Heating, ventilation and air-conditioning (HVAC) ducts, etc.
Enforcement of this amendment was delayed until March 8, 2016 in residential construction industry, if good faith efforts were being made and as long as the employer was in compliance with the training requirements of the standard.2
The training requirement specifies that all employees required to enter into confined spaces should receive instruction on the nature of the hazards and necessary precautions, as well as the use of protective and emergency equipment. In the most general sense, OSHA rules apply if there is an “employee-employer” relationship. What is more critical (and what makes most sense) is that it is about the presence of a person on a job site and the conditions on the job site, not about the business relationship. Quoting an OSHA FAQ:
Host employers need to treat temporary employees as they treat existing employees. Employers must assure that all workers—whether temporary or existing—are provided with a safe workplace and all required training and protections. Temporary staffing agencies and host employers share control over the employee and are therefore jointly responsible for temp employee’s safety and health. 3
What is a Confined Space?
There are three mandatory characteristics of a Confined Space:
1. It must be large enough for a worker to enter it (It is important to note that even poking your head into a confined space constitutes entry).
2. It is not intended for regular continuous entry (For example, a normally “finished” attic is not a confined space).
3. It is difficult to enter or exit (Places like joist-only walkways or areas requiring belly-crawls to move about are considered “difficulties”).
What is a Permit for Confined Spaces?
A Confined Space Permit is not like a building or construction permit. It is not filed with any governing body. Instead, it is a document that you keep on file at your business and at the work site. Most importantly, a confined space permit is written specifically for each and every work site.