Page 40 - Occupational Health & Safety, July/August 2019

CONFINED SPACES
work can proceed. Entry supervisors also will monitor the progress of the work in the space to ensure that it proceeds within the guidelines established by the permit.
■ Emergency and rescue personnel. These personnel are responsible to assist in evacuating the confined space in the event of an emergency. Employees who conduct rescues must be provided with proper PPE and rescue equipment while also being trained in the proficient use of that equipment. Employers must inform each rescue team of the hazards they may confront when called to perform a rescue. You also must provide the rescue team ac- cess to all permit spaces in which rescue may be necessary so that the team can de- velop appropriate rescue plans and prac- tice rescue operations.
It’s critical that you designate which employees are assigned these roles. If no employee is clearly designated as an au- thorized entrant, OSHA will consider this an implicit decision to allow any employ- ees to enter the confined space if they are
working near it. Regardless of whether any unauthorized employees actually enter the confined space, a failure to designate au- thorized entrants is a violation of the con- struction standard and will result in hefty OSHA fines and citations.
Which Standard Should You Follow?
Whether you need to follow OSHA’s con- fined space standard for general industry or construction depends on whether the work that needs to be done in the confined space could be classified as maintenance or a construction activity. If maintenance is be- ing performed, you need to follow OSHA’s general industry standard. If any construc- tion activity needs to be conducted in the space, you need to follow OSHA’s construc- tion standard. It might seem simple, but keep in mind that you may actually need to comply with both standards, depending on the tasks at hand.
If you’re not sure what standard to fol- low, OSHA has released several letters of interpretation3 that should help. In these
letters, the agency defines maintenance as: “Keeping equipment or a structure in prop- er condition through routine, scheduled or anticipated measures without having to sig- nificantly alter the structure or equipment in the process. For equipment, this gener- ally means keeping the equipment working properly by taking steps to prevent its failure or degradation.”
Construction activities, on the other hand, should be defined as “work for con- struction, alteration, and/or repair, includ- ing painting and decorating.” The agency also clarifies that construction work is not limited to new construction, but can in- clude the repair of existing facilities or the replacement of structures and their com- ponents. For example, the replacement of one utility pole with a new, identical pole would be maintenance; however, if it were replaced with an improved pole or equip- ment, it would be considered construction.
It’s important to evaluate your work so that you understand what standards and requirements you’ll need to follow.
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