We’ve been hearing that more and more Washington employers are being cited for confined space violations…
Confined spaces can be found in the facilities and job sites of just about every Approach client, so it’s important to know how to:
• Recognize a confined space
• Protect yourself and your co-workers in and around confined spaces
Recognize a confined space
Many confined spaces are easy to see and identify, like a tank or drainage pipe. But, even big spaces like attics or open-air spaces like trenches can be confined spaces.
There’s a three-part test to know if a work space is a confined space:
1. Big enough to hold a worker
2. Not primarily designed for continuous human occupancy
3. Limited entrance and exit
If a space has all three of these aspects, it’s likely confined and you need to take the next step, outlined below.
- Protect yourself and your co-workers in and around confined spaces.
- Once you’ve identified a confined space, you now have to determine if it’s a permit-required or alternate space.
In short, permit-required spaces have additional hazards, such as the potential for: loss of oxygen/breathing difficulty, fire or explosion, or difficulty reaching a worker in the space in case of emergency. Special measures must be in place for these spaces and access must be controlled so that no one can enter unless authorized.
Refer to Appendix E (on the Labor and Industries website) to write a confined space plan.
Alternate spaces (formerly known as non-permit spaces) have no hazards within them – none. You must document this using Appendix J (on the Labor and Industries website) and keep a copy at the alternate space entry point.
Non-permit spaces have changed
Alternate spaces used to be known as non-permit spaces. With the new confined space rule that went into effect February of 2018, the policy makers removed non-permit confined spaces and now say either you have permit-required or alternate spaces. This has created some confusion since the non-permit confined space is not in the rule anymore.
Again, regardless of what it is called, you should always document why it is “not” a permit-required confined space and keep the copy of your documentation available so it’s clear you have assessed the space.
Make sure you’ve documented all the confined spaces where your employees or subs may be working. And, if you’re working in or near a space you think may be confined, STOP and check with your supervisor right away.