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Confined Space Entry, or CSE, is a training specialty at Findlay All Hazards, and one of our programs that has been boosted by recently-completed custom hardware (our Mobile Confined Space Simulator). Occupational Safety and Health Administration regulations in the CSE category are frequently updated, as was the case this year (see CFR 1926, subpart AA, which centers on the construction industry), so we’re always on watch for ways that new regs might change the way our clients work safely.
CSE work is always going to be complex and dangerous, and failing to meet OSHA specifications can be very expensive, too. A Missouri company was recently cited for 11 different CSE code violations, including not providing proper respiratory protection, and their fines totaled almost $85,000. Worse than that, in the circumstances that prompted investigation and citation, a worker lost his life through suffocation inside a truck tank.
One of the issues surrounding CSE standards is the proper understanding of how regulations effect confined spaces where hazards are known to be present, those that are without such hazards, and when the former becomes the latter. Not understanding the differences between the danger level of two seemingly similar spaces, or not realizing that a space is now more dangerous than it was previously, can result in the wrong choice of safety equipment or other work tools. Of course, without proper safety gear, it’s fair to expect a calamity.
How we refer to such spaces can be confusing in itself. As pointed out in a recent online article in Occupational Health & Safety magazine, “confined space and non-permit confined space can be used interchangeably to describe a confined space where no hazards are present. However, this same space becomes a permit-required confined space the very next day when an employee enters it to weld.” In the OH&S magazine piece, the potential hazard that now redefines the space is one that a worker brought there – welding tools that produce sparks and fumes. Even a can of paint in the confined space reclassifies that space as one with a specific hazard.
Once a space is classified as inherently hazardous, the legal demands for personal protection, skills training, and posted permits change. Then there is, naturally, a greater burden on the employer and property-owner to insure safe entry, work, and exit from any confined space.
Many EHS managers rely on the OSHA-supported document NFPA 350: Guide for Safe Confined Space Entry and Work, published by the National Fire Protection Association, to help clarify best CSE procedures thanks to the guide’s simplification of such spaces. The NFPA guidelines dispense with differing terminology for various spaces and assume all to be inherently hazardous to a certain degree. And that degree is determined in each incidence by a pre-entry evaluation of any space, with NFPA 350 providing the inspection procedure.
The inspection and work guidelines of NFPA 350 are valuable tools for safely performing tasks in confined spaces. But they are no substitute for experience and practice. Findlay All Hazards brings both to those organizations seeking to improve their safety policies and procedures. Findlay trainers have abundant real-world experience thanks to years in public service and private industry.