Confined-space hazards: What employers need to know

Recently, Minnesota OSHA (MNOSHA) Compliance had a significant case regarding a worker fatality in a confined space. Employers are required to keep employees safe in confined spaces, which can be dangerous and deadly for entrants, through proper entry procedures in compliance with OSHA’s standards.

A confined space is defined as a space that:

• is large enough to bodily enter;
• has limited or restricted means for entry and/or exit; and
• is not designed for continuous human occupancy.

In addition, a confined space is considered a permit-required confined space if it also has one or more of the following:

• contains or has the potential to contain a hazardous atmosphere;
• contains a material that has the potential for engulfing an entrant;
• has an internal configuration such that an entrant could be trapped or asphyxiated by inwardly converging walls or a floor that slopes downward; or
• contains any other recognized safety or health hazards.

All employers in Minnesota are required to evaluate their workplaces to determine if there are any permit-required confined spaces that employees access. If permit-required confined spaces are identified, employers are required to take action to either prevent employees from accessing those spaces or to develop a permit-required confined-space program in compliance with 1910.146 (for general industry employers) and 1926.1200 through 1926.1213 (for construction employers). Some required elements of a permit-required confined-space program include: developing a written program; providing training for affected employees; conducting air monitoring of the confined space; completing and retaining written permits for confined-space entry; and establishing rescue services and non-entry retrieval systems for rescue in the event of an emergency.

Some common examples of potential confined spaces in workplaces include ready-mix cement truck drums, sewer manholes, tanks (including transportation tanks), dust collectors, silos, ovens, hoppers and pits. For examples of permit-required confined-space programs in some of these industries, employers may reference Appendix C of the 1910.146 confined space standard for general industry, which provides example programs for sewer entry, meat and poultry rendering plants, and workplaces where tank cars and other portable tanks are fabricated or serviced.

Additionally, the federal OSHA Chicago region maintains a Regional Emphasis Program for transportation tank cleaning operations, because these tanks are typically considered confined spaces and may have one or more of the components of a permit-required confined space. Employers operating in the field of transportation tank cleaning may reference the federal OSHA instruction CPL 04-00-028 for additional guidance about maintaining employee health and safety while conducting transportation truck cleaning. 

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For assistance in creating and evaluating your facility’s confined-space program, employers may contact MNOSHA Workplace Safety Consultation at 651-284-5060 or osha.consultation@state.mn.us.