Confined space work is full of unexpected challenges and hazards that put employees at risk. Most employees who work in and around confined spaces know that they need to do atmospheric testing in the space at all times. However, there are many aspects of confined spaces related to fall protection that are commonly overlooked.
Training professionals travel the globe to educate safety professionals and workers as to the proper way to enter a confined space. Over the years, several hazards and oversights have emerged within the confined space sector relating to fall protection. Detailed below are three of the most common oversights that I’ve seen in my years of training confined space professionals.
1 Hatch & cover removal
The first among these common misconceptions is the belief that workers do not need to wear fall protection equipment while working around a confined space opening if they’re not planning to enter it.
In reality, all workers in the vicinity exposed to an open confined space, such as an open hatch or cover, need to be wearing fall protection equipment. When a hatch or cover is removed, an unprotected opening presents a fall hazard made all the more dangerous by the fact that the opening could also be releasing methane gas.
If a confined space contains methane, a gas lighter than air, the gas would be released as the cover is removed. This may cause the worker monitoring the space to lose consciousness. In this situation, the worker could potentially fall into the hole.
Most general industry programs do an excellent job of following OSHA 1910.146 standards for permit required confined space entries, which outline possible methods that can be used to control such hazards. In all confined space safety programs, lockout/tagout, isolation and atmospheric testing procedures are important factors in keeping workers safe while in the space. Some safety professionals, however, do not take into consideration the fall protection portion of the standard as it relates to holes, opening or unprotected edges.
When making a vertical entry, the first step is to remove the hatch or cover to begin atmospheric monitoring. When the hatch or cover is removed, safety professionals must find a way to protect employees from the fall hazard created. This should be a primary concern, as employees can easily lose their situational awareness and accidentally fall into the uncovered hole.
According to the OSHA confined space standard, 1910.146(k)(3), an employee entering a confined space should wear a full-body harness to be used in the event that a non-entry rescue is needed. The same type of harness can be utilized to provide fall protection to the employee performing air monitoring and ventilation work.
As previously stated, there is a chance that an employee could fall into an unprotected hole, so a fall restraint system should be used to prevent the worker from reaching the hazard. This could be accomplished by using a lanyard or a vertical lifeline attached to an anchor. If the concept of fall restraint or the use of this equipment is new to the employee or no training documentation is on file, the employee must be trained in inspection and use of fall protection equipment as well as general fall protection issues.
2 More than single-line protection
OSHA references and requires the use of fall protection equipment throughout the 1910 and 1926 standards. Since the need for fall protection equipment is only briefly stated in the OSHA 1910.146 standard, some training courses fail to properly address confined space fall protection needs. Many employees who were trained this way state that the need for additional fall protection while being lowered into a confined space is not necessary. Not only is it required by the regulations, all U.S. manufacturers require the use of fall protection equipment when using davit arms and tripods.
When an employee is being lowered into a confined space on a life safety rope or personnel-rated winch, that person is being protected by a single line. This is no different than a window washer or tower climber relying on a single rope, which can have disastrous consequences if the rope fails. But if a worker is using a fixed ladder to descend into a confined space, the ladder becomes the primary means of fall protection and a self-retracting lifeline (SRL) along with a winching mechanism becomes the backup or secondary means of fall protection.
3 Non-entry rescue
Typically, the safest and most effective fall protection systems include SRLs. These lifelines should come integrated with a retrieval system in all confined space entry situations; this allows the entry attendant to perform a non-entry rescue, should it become necessary.
All confined space entry situations are required to have non-entry rescue systems, unless they pose a greater hazard to the employee. OSHA states that the purpose of non-entry rescue is twofold: 1) that rescue of the authorized entrant can begin immediately, thus saving valuable time and 2) the procedure does not place the rescuer at risk to the hazards contained within a permit-required confined space.
Regardless of how thorough your confined space program is, the entry attendant may be called upon to perform a non-entry rescue should a medical or other unforeseen emergency arise within the confined space.
Commonly overlooked confined space fall protection hazards could develop into a preventable tragic event. If your confined space program overlooks any of the hazards described above, we recommend competent training and appropriate equipment. As an organization that is fully committed to fall protection and confined space safety, we often ask customers one question: “How competent is your competent person?” You’d be surprised by the number of trained professionals who cannot answer some basic questions.
Even if you went through a training course a few years ago, you may be in need of a refresher course. Fall protection training programs address these issues and work to educate on-site personnel on how to address confined space fall protection hazards and how to use application-specific equipment.