Nov 7, 2022
While the OSHA definition of a confined space seems straightforward at first, confined space trainer and expert Curtis Chambers, President of OSHA Training Services, Inc., sees evidence that too many business owners and managers do not properly identify all of the confined spaces at their worksite. And he usually attributes that failure to the fact that they do not understand the true definition of a confined space per OSHA regulations.
The OSHA definition of a confined space lists three qualifying criteria:
(1) The space must be large enough and configured that an employee can bodily enter and perform assigned work; and,
(2) The space has limited or restricted means for entry or exit (for example, tanks, vessels, silos, storage bins, hoppers, vaults, and pits are spaces that may have limited means of entry); and,
(3) The space is not designed for continuous employee occupancy.
"The OSHA confined space standards do not clarify many sub-terms used within the OSHA definition of a confined space. For example, many employers believe the term 'limited or restricted means of entry or exit' means the space has only one way in or out, but that is not the case. There are supporting OSHA documents which clarify that a limited or restricted means for entry or exit exists where the entrant is required to crawl, climb, or twist to enter or exit a space. Limited or restricted also means an entrant may be constrained in a narrow opening while inside the space, or they must follow a lengthy path to escape. In other words, the entrant must exert unusual effort to enter or leave the space. Additionally, OSHA states that a limited or restricted means of entry or exit exists if the way out could become sealed or secured against opening from inside the space."
As another example of where employers also misinterpret the OSHA confined space definition, Mr. Chambers explains that "bodily enter" is often misunderstood by employers and managers. "The term 'bodily enter' means the confined space is large enough and configured so a worker can get their entire body inside of the space. While the OSHA confined space standards do not provide a definition of the term 'bodily enter', the fact that the confined space standards only apply to spaces big enough for a worker to completely get inside is explained in detail within the preamble to the OSHA permit-required confined space entry standard."
Mr. Chambers encourages employers and managers to take advantage of the regular posts he makes to his Confined Space Training Blog. "We cover OSHA's definition of a confined space in our blog, to help readers truly understand how to identify all confined spaces at their worksites," says Mr. Chambers. In addition, there are helpful online confined space training courses available on his company website.
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