Next month, documenting and controlling confined space entries will no longer be just good industry practice; it will be the law. Is your company ready to comply with OSHA's new confined space safety standard?
At BFGoodrich's Geon Vinyl Div., some 20 confined space entries, mostly into chemical process vessels, occur each day. Division Safety Manager Herm Waltemate says he's confident that all of those entries -- which he said are "potentially one of our most hazardous jobs" -- are being done in a safe manner through implementation of the company's procedures for entry permits, atmospheric monitoring, worker training, and rescue. Since 1974, in fact, confined space safety has been one of BFGoodrich's four "Cardinal Safety Rules," along with lockout/tagout, hot work, and forklift trailer entry.
"We have been working in confined spaces for a long time and have had some bad experiences, including fatalities," said Waltemate, CSP, a 29-year safety professional whose Independence, Ohio-based division produces polyvinyl chloride used in various consumer products. "Because of that, we've really done a lot to ensure worker safety."
Many other employers, guided by documents from NIOSH, the American National Standards Institute, and several trade associations, have implemented similar programs over the years. Beginning next month, though, full-scale confined space safety programs will be more than just a good idea or a reflection of sound industry practice; they will be the law of the land, as a result of OSHA's new confined space safety standard for general industry (29 CFR 1910.146).
The standard, which had been in the works since the mid-1970s, was published in the Jan. 14 Federal Register and is scheduled to take effect Apr. 15. OSHA estimates that the standard will prevent 54 of 63 annual confined space fatalities in American general industry, as well as some 5,000 lost work-day injuries. (Other experts estimate that as many as 300 U.S workers die in confined space accidents each year.)
The standard applies to such spaces as boilers, storage vessels, furnaces, railroad tank cars, manholes, pits, and cooking and process vessels in general industry. It does not cover the construction, maritime, agriculture, and shipyard sectors of industry.
As the June 5, 1989, proposed rule did, the final standard reflects much of what many employers, including BFGoodrich, are already doing in terms of identifying confined spaces, requiring permits for entry, training workers, and implementing emergency response. However, experts said that most of the 240,000 workplaces covered by the standard will have to make at least modest changes in existing programs. Covered employers with no comprehensive program previously are going to be "hard-pressed" to be anywhere close to compliance by Apr. 15, according to Robert Stegall, CSP, coordinator of health and safety, Texaco Chemical Co., Houston. "I would not want that assignment," said Stegall, who said his company's existing program will need only minor revisions, mostly to meet the standard's paperwork requirements.
In announcing the rule, former Acting OSHA Administrator Dottie Strunk labeled it "a major milestone for this agency." Response to the standard has been mostly positive, though organized labor has concerns about specific items in the performance-oriented standard, and several sections in the 102-page, final rule are open to wide variations in interpretation.
Terry W. Krug, CIH, president of Industrial Hygiene Technical Consultants, Bartlett, Ill., said that although complying with the letter of the law may prove difficult, meeting the standard's intent is worthwhile and not especially difficult. "It boils down to the employer having to document and control confined space entries," he said.
"The standard is rather performance-oriented, but it certainly gives employers the flexibility to do things right," added Vic Hillman, CSP, CIH, director of industrial hygiene field services for Boston-based Liberty Mutual Insurance Co. …