Standard Interpretations - Table of Contents|
| Standard Number:||1926.21; 1926.21(b)(6) ; 1926.21(b)(6)(i); 1926.21(b)(6)(ii); 1910.146; 1910.146(c)(5)|
Stage 1: a concrete base is constructed upon which the tank ring walls will sit. The first tank ring is erected, normally between 8 and 10 feet high. The only means of entry/exit is a manhole cut into one of the steel plates (a "sheet") that comprises the ring.Once the door sheet is cut out in Stage 2, is the space considered a "confined space" for purposes of OSHA's confined space requirements?
Stage 2: a second ring is erected on top of the first ring and welded into place. With this ring in place, the tank walls are 16 to 20 feet high. A "door sheet" is then cut out, creating an opening approximately 8 feet wide by 10 feet high. This opening provides access for personnel, equipment and material. Airflow is typically not a problem at this stage.
Stage 3: The top is erected and forced air ventilation is used to assist in air flow.
For purposes of paragraph (b)(6)(i) of this section, confined or enclosed space means any space having a limited means of egress, which is subject to the accumulation of toxic or flammable contaminants or has an oxygen deficient atmosphere. Confined or enclosed spaces include, but are not limited to, storage tanks, process vessels, bins, boilers, ventilation or exhaust ducts, sewers, underground utility vaults, tunnels, pipelines, and open top spaces more than 4 feet in depth such as pits, tubs, vaults, and vessels.Pursuant to this provision, for a space to be considered a "confined space" under this standard, it must have two characteristics: (1) limited means of egress, and (2) the potential for the accumulation of toxic or flammable contaminants or for an oxygen-deficient atmosphere to develop. The part of the provision specifying that "open top spaces more than 4 feet in depth such . . . as vessels," are considered confined spaces indicates that the Agency found that such vessels have the two listed characteristics. Unless it were clear that the 8' x 10' opening eliminated one of these characteristics, the space would be considered a confined space.
All employees required to enter into confined or enclosed spaces shall be instructed as to the nature of the hazards involved, the necessary precautions to be taken, and in the use of protective and emergency equipment required. The employer shall comply with any specific regulations that apply to work in dangerous or potentially dangerous areas.This requirement must be adhered to irrespective of whether an employer followed §1910.146(c)(5) for its entry operations in a confined space.
(a) Each employer Entering confined spaces is a recognized hazard in the construction industry. Under the General Duty Clause, employers are required to institute feasible means of protecting employees from confined space hazards. While the scope of OSHA's general industry standard for confined spaces excludes construction, one of the ways an employer can meet its General Duty Clause obligations for protecting against confined space hazards in construction is use procedures that accord with the general industry confined space standard at 29 CFR 1910.146.1
(1) shall furnish to each of his employees employment and a place of employment which are free from recognized hazards that are causing or are likely to cause death or serious physical harm to his employees.
|Standard Interpretations - Table of Contents|
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