The existing OSHA 1910.146 Permit Required Confined Space
Standard for general industry does not address hazards immediately outside and
adjacent to confined spaces. Atmospheric
hazards adjacent to a confined space create both health and safety
hazards. Fatalities have occurred when
workers were overcome by toxins present in the vicinity of the confined space. Flammable
atmospheres have been the source of numerous fatalities that have occurred when
a worker was performing hot work immediately outside a confined space. Two employees at Valero Refinery died when
they were overcome by nitrogen as they performed maintenance work near a confined
space opening on the top of a reactor. A worker at DuPont was killed when he was
welding immediately outside a tank containing flammable vapors.
These fatal accidents may have been prevented if the
atmosphere outside these two confined spaces had been tested. How do we address those hazards that are not
necessarily inside the confined space but are very much associated with the
confined space hazard?
In the marine industry, both the OSHA Shipyard standards
(1915.14) and NFPA 306 Standard for the Control of Gas Hazards on Vessels
recognize the hazards of adjacent spaces.
Both standards require that a Marine
Chemist evaluate not only the confined space but also the area adjacent to those spaces whenever hot
work such as welding will take place.
NFPA is developing a best practices document for confined
space entry. The new document is designed to address gaps in existing confined space standards and will
likely include the evaluation of hazards in the area adjacent to the confined
If you have suggestions for what should be included in this
soon to be developed new confined space best practices document we would love
to hear from you. Should the document
address hazards immediately adjacent to confined spaces? Is there a gap in the current OSHA general
industry standard that should address these hazards? We want to hear from you!
A video on the Valero incident