Page 47 - Occupational Health & Safety, August 2017

such as gas monitoring, ventilation, and rescue. Those individuals may or may not be the attendant or entry supervisor. For example, the “Gas Tester” as defined in NFPA 350 should be qualified be- yond simply knowing how to turn on the gas monitor and record results. This individual also should understand how to calibrate and interpret atmospheric monitoring results. An attendant who is responsible for both monitoring and ventilating a confined space should be qualified as an attendant but also should understand both the gas monitoring equipment and the ventilation method required to maintain safe atmospheric conditions.
Gaps in confined space rescue are also addressed in NFPA 350. The standard outlines the organizational elements of emergency preparedness normally in place in a fire department but not neces- sarily in a facility rescue program. Providing a tiered approach to response, the rescue chapter also includes information on pre-in- cident planning and evaluation, rescue gear, rescue configurations, and rescue competencies.
Additional Considerations
Since many confined space incidents relate to change, a chapter on management of change (MOC) has been included in NFPA 350. The MOC system identifies and evaluates potential effects of modifica- tions to confined space configurations, equipment, materials, con- tent and work tasks. A sample MOC form, provided in an annex,
serves to document that the effects of change have been considered. Finally, NFPA 350 provides a chapter on prevention through design (PtD) specifically for confined spaces. The PtD concept seeks to initiate a design process to reduce or eliminate inherent risks and hazards associated with the design of facilities, equip- ment, and products. PtD can minimize retrofitting control costs and the use of labor-intensive administrative hazard control mea- sures. PtD targets two types of interactions: the construction and/ or installation of new confined spaces; and the redesign, retrofit, and/or renovation of confined spaces to eliminate, control, or minimize hazards. A bibliography of documents related to the design of confined spaces will be updated as the NFPA 350 Tech- nical Committee is made aware of them. For example, there are documents related to manure pit design and ventilation, as well as documents related to the design of water and wastewater facilities that will be listed in the next edition of the standard. While the implementation of methods provided throughout NFPA 350 will improve confined space safety, the only way to fully prevent con- fined space incidents is to eliminate the confined space completely
through design or redesign.
Nancy Pearce, CIH, is senior fire protection engineer at NFPA and past chair of AIHA’s Confined Spaces Committee. She can be reached at 617-984-7439 or npearce@nfpa.org.
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