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31 Posts authored by: nancypearce Employee

“Do we really need another standard on confined spaces?” That’s the question I get asked most often in response to NFPA 350, Guide for Confined Space Entry and Work. My answer is a definitive “yes,” and here’s why: Fatalities continue to occur in confined spaces each year, despite regulations.  Virtually all of the fatalities could have been prevented by following the regulations and using the “how-to” provisions provided in NFPA 350.
I recently wrote the article, "Why Use NFPA 350," for the August 2017 issue of Occupational Health and Safety magazine (see image above), which provides a substantive overview of what’s covered in the guide.  The article explains gaps in existing regulations and how NFPA 350 fills in those gaps with information needed to safely enter and work in confined spaces.  If you have any comments or questions about the article, feel free to share them here.
Also, here's an NFPA 350 fact sheet, which defines what confined spaces are, along with the associated hazards and how to maximize safety for people working in them.

History shows that confined space operations are an extremely dangerous activity for the fire service. The danger starts when firefighters and responders don’t recognize the presence of or hazards within a confined space and enter without appropriate atmospheric monitoring and equipment.  In many cases, the rescuer then becomes the victim.  Last evening’s episode of Chicago Fire brought this issue to the forefront showing how taking shortcuts when entering confined spaces can lead to fatal consequences. These events do not just take place on television, they occur regularly in real life. (See my previous blog: “Three die in confined space and firefighter in critical condition”.)


Recognizing the continuing hazard for the fire services, NFPA will soon be offering a free Confined Space training for fire service professionals designed to raise awareness and understanding about the risks associated with confined spaces in May 2017.


In the meantime, login or register for Xchange today to download the NFPA 350 Fact Sheet to keep as a reference – and by downloading, you will receive an invitation to the free training when it’s available.



Got confined space? If so, please join me for a free one-hour webinar on NFPA 350, Guide for Safe Confined Space entry and Work on March 29th at 2 PM (EDT)  sponsored by OHS online. The webinar will provide an overview of how NFPA 350 can be used to supplement compliance with existing regulations by simplifying requirements and by providing the “how to’s” that will help you comply with existing standards.


For example, NFPA 350 includes information on identification of hazards that are not just inside the space but that may be adjacent or introduced into the space. It also provides detailed procedures for the selection, calibration and use of gas monitoring equipment and addresses the organizational aspects of confined space rescue that may be present in a fire department but not necessarily for on-site rescue teams.


Register for the free event today.  Hope you can join me and learn how NFPA 350 can help you improve confined space safety.


The first edition of NFPA 400, published in 2010 incorporated a number of existing NFPA hazardous materials code into a single code and utilizes the MAQ (maximum allowable quantity) concept to provide fundamental safeguards for the storage, use, and handling of hazardous materials such as ammonium nitrate, corrosives, flammable solids, organic peroxides, oxidizers, pyrophoric materials, toxic and highly toxics, unstable reactives and water reactives.


The first draft report on NFPA 400 Hazardous Materials Code was recently posted and is open for public comment at until May 10, 2017. The technical committee is seeking comments on a number of proposed changes made at the First Draft meeting (First Revisions) as well as on Committee Inputs.  Highlights of changes made at first draft include requirements for the storage of ammonium nitrate in railcars and the division of Class II Organic Peroxides into two classes, IIA and IIB, based on differences in burning rates. Key changes proposed in committee inputs include the consolidation of occupancy tables into a single table to improve ease of document use and the reclassification of a number of organic peroxides in Annex F.  To stay informed about upcoming meetings and document revisions sign up for email alerts located above the information tabs at


Confined space hazards know no borders.  


Less than two weeks after three workers died in a confined space in Florida, four workers died from atmospheric hazards  while preparing to clean a sewage pit at a Bangkok market on Thursday. The same story-just a different country.  


The incident occurred in a Bangkok marker area where workers were about to carry out maintenance on a 3 meter deep sewage pit. The first worker opened the cover, leaned over, and likely was overcome by the atmospheric hazard and fell into the space.  A second worker entered in an attempt to save the first worker.   A third worker entered and also became non-responsive.  His brother proceeded to enter to try to save him, making him the fourth victim.


A team of rescue workers arrived on scene and assumed that four men had been electrocuted while cleaning the pit.   After turning off the power to the entire market, one rescue worker proceeded to enter the space on a rope but without a proper respirator such as an airline respirator or an SCBA.  The rescue worker passed out but fortunately was pulled to safety using the rope.  Without that rope, he likely would have become victim number 5.  


This first fatality that started this incident began before the first worker had even entered the space.   NFPA 350 Guide for Safe Confined Space Entry and Work discusses "adjacent space" hazards that occur in the vicinity of confined spaces and provides safe practices to prevent incidents such as this from occurring. 



Note- these recent tragedies have authorities across the country looking to NFPA to learn more about the codes, standards and safety practices related to confined space entry. NFPA offers an online confined space training series for those that design, work in, or supervise a facility that has one or more confined spaces. Content is ideal for facility managers, risk managers, safety directors, architects, engineers, industrial hygienists, construction workers, and technicians.

Three construction workers died when they entered a manhole Monday without taking any of the precautions needed to safely enter a confined space. The hazards of the space were readily predictable and preventable. Many workers have died in manhole entries. Any one of several key confined space safe entry procedures likely would have prevented this tragedy.  

The incident occurred when a private contractor who was fixing a roadway in Key Largo climbed into a 15 foot deep hole to investigate complaints of sewage backups in the neighborhood. Reportedly the first man went in and lost contact with his coworkers above. The second worker climbed down in search of the first coworker and also lost consciousness. A third man then went down in a desperate search to find his two coworkers. A volunteer Key Largo firefighter attempted to rescue the downed workers and entered the space without an SCBA since the space was so narrow. He became incapacitated within seconds of entering. The space was later tested and found to contain elevated levels of methane and hydrogen sulfide as well as decreased oxygen levels. Atmospheric hazards in confined spaces are typically the result of material previously stored in the space, or in this case likely were the result of decaying organic material and rust.

While many news reports point to the lack of “air packs” being used as the problem, respiratory protection, such as self-contained breathing apparatus are the last line of defense to be used only after all other control measures are applied. They can rarely be used in spaces such as manholes due to the small configuration of the space.  

The real reason for this incident involved the lack of confined space entry procedures that would include;

  1. Recognition that this was a confined space and evaluation of the atmosphere using a calibrated gas monitor
  2. Identification of all hazards in the space and control of the atmospheric hazards using ventilation
  3. Issuance of a permit by the on-site entry supervisor that included rescue procedures

If the workers had recognized that the space was a confined space and used a properly selected and calibrated gas monitor, they would have known the space was unsafe to enter.   If the workers had identified the atmospheric hazard and used ventilation to remove the hazardous atmosphere, they would not have entered until the atmosphere was verified as safe to enter.   Finally, if confined space entry procedures were followed, an entry supervisor would have issued a permit that would describe the hazards and control measures for the entry and would have established a non-entry rescue procedure. A non-entry rescue procedure would require the first worker to enter the space with a harness attached to rescue equipment such as a tripod/winch system so that the attendant could remain outside the space and winch the first worker to safety should the worker become incapacitated or the atmosphere become unsafe. If the confined space procedures had been established, there would be no need for the second or third worker or the firefighter to enter for rescue. These basic requirements have been present in OSHA’s confined space regulation 1910.146 for over 20 years.  

In an effort to further improve confined space safety, and recognizing that confined space incidents continue to occur, the recommendations in NFPA 350 Practices for Safe Confined Space Entry and Work were established to provide more detailed information on “how to” implement the requirements in the OSHA standard. NFPA 350 explains how to select, calibrate and use the atmospheric monitoring equipment and how to ventilate a space depending on the hazard. Competencies are included for those performing various aspects of the confined space entry and a rescue procedures with pre-plans are established.  

For more information you may view NFPA 350 free of charge at You will also find a free 5 minute video on confined space identification as well as information about on-line and instructor lead confined space training.  

The recent death of a worker in a water tank in Braintree, Massachusetts this past week provides a grim reminder of the importance of following safe entry procedures for all confined spaces.

Water tanks are confined spaces because they are not normally occupied and their design and configuration offer limited means for entry and exit. When they are entered for the purpose of periodic inspection and maintenance it is essential for workers to be familiar with the characteristic hazards of such spaces and to have a plan for safe entry, work, and exit. Typically these tanks are entered through a hatch in the top of the tank, requiring workers to climb to the top of the tank, where there might not be guardrails around the top to prevent falls and often there are no appropriate anchorage points for the connection of fall protection devices.   Atmospheres inside the tank can be unsafe due to rusting or decomposition of residual debris which can lead to unsafe levels of oxygen or other atmospheric hazards.   Water tanks may also be covered with snow or ice, leading to slip hazards. Rescue from these spaces is also a challenge because of the elevation and the possibility for the rescuers falling.  

In this recent incident, reports indicate there were two workers on the top of the tank. The tank did not appear to have guardrails on top and it is unclear if there were anchorage points in the vicinity of the hatch. The victim (the entrant) was inside the water tank wearing diving equipment to inspect the tank while a “spotter” was outside the tank. The spotter in this case acted like the “attendant” in a confined space entry. When it became apparent that the diver’s equipment was compromised, the spotter “heroically” jumped into the space in an attempt to rescue his coworker. Ultimately, the spotter had to be rescued by fire department and technical rescue personnel.

There are on average 100 deaths per year caused by confined spaces. It is estimated that 60% of fatalities that occur in confined spaces involve the “would be” rescuers. The spotter who dove into the tank was rescued but could have become the second victim in this incident for a myriad of reasons including a hazardous atmosphere above the water level due to oxygen deficiency, a condition that frequently occurs when a metal tank rusts and uses up oxygen. Entering a space without testing is risky, which is why NFPA 350, Guide for Safe Confined Space Entry and Work, recommends atmospheric testing all confined spaces prior to entry to ensure there is no hazardous atmosphere.

Safe confined space entry procedures that include identification, evaluation and control of hazards in and adjacent to confined spaces are addressed in the guide.   The document provides guidance beyond OSHA regulations and explains “How To” comply with requirements in OSHA regulations, including best practices for entering into and providing rescue from confined spaces.   Prevention through Design (PtD) information is also addressed and covers safe design practices such as designing guardrails, anchorage points or other means of fall protection in or adjacent to confined spaces.

You can view NFPA 350 free of charge on line at the document information page found at   If you are unsure whether you have a confined space in your workplace check out this a free 5 minute video available.

An online training program is also available and site specific training is also available on request. Click on the training tab for further information. Additional questions on confined spaces and the new NFPA 350 Guide for Safe Confined Space Entry or work can be directed to me at  

HazMatSquare_words_500px.gifMany have asked how the OSHA HazCom2012 classification numbers, which are inverse in severity from 704 rating numbers, would impact NFPA 704 and whether or not the rating system in NFPA 704 would be changed during the next revision cycle. The newly released 2017 edition of NFPA 704 addresses this concern and provides the user with the rationale for maintaining the current emergency response system.  A new Annex G has been added to the standard that explains why the ratings remain the same and compares NFPA 704 to OSHA HazCom 2012.


To summarize, OSHA and NFPA are in agreement that there are differences between HazCom 2012 and NFPA 704 with two distinct set of numbers developed for different purposes.  HazCom 2012 uses a hazard classification system whereas NFPA 704 uses a hazard rating system. The NFPA 704 label has been used for over 50 years and was developed to provide a simple, readily recognized and easily understood system of markings to provide information in a concise manner to emergency personnel responding to a spill or fire.


In comparison, OSHA’s hazard classification system provides information for workers exposed to materials primarily under normal conditions of use. The numbers that are part of the OSHA HazCom 2012 hazard classification system are required in Section 2 of the new SDS format.  These numbers are then used to determine the correct pictograms, signal words and hazard statements for container labels but the numbers themselves are not required to be posted on labels.


For further information you can view the 2017 edition of NFPA 704 by creating a free email account  You will also be able to download two free documents including a, “NFPA/OSHA Comparison" Quick Card and an updated “Frequently Asked Questions" document.

We’ve got it all….(almost)! We have a great group of chemical and fire protection engineers who are highly motivated and work well as a team. We work hard, support and encourage each other-and we have fun!   Since we cannot clone our previous boss, we are on a mission to find a new leader who will continue to inspire our team to achieve and take on new challenges.


If your actions inspire others to dream more, learn more, do more and become more, you are a leader. (John Quincy Adams).   If you are that person, please apply to our Industrial and Chemical Engineering Manager Position!


Do not panic! The Technical Committee responsible for NFPA 600 has just completed a revision of their document which is now titled Facility Fire Brigades instead of Industrial Fire Brigades!  The Committee wanted to emphasize that fire brigades are not limited to just industrial settings but exist in other facilities such as hospitals, universities and airports.  Although work on fire brigade standards has been going on for over 100 years, with the first document on private fire departments published in 1902, the Committee recognizes that the world of fire brigades has changed.  As a result the Committee is already beginning work on the NEXT edition of NFPA 600, looking at a number of issues that they feel need to be addressed such as “Is there a need to do anything different for fire brigades that look and operate like a full-fledged fire department?“  And “Is there a need to address the issue of fire brigades that also have duties other than fire suppression such as confined space rescue and first aid?”


If you are coming to the NFPA Conference in Chicago next week, and have an interest in fire brigades and NFPA 600, there will be a presentation on the changes made to NFPA 600-2015 and the issues that the Committee is grappling with for the next revision cycle bright and early on Monday morning at 8 AM in room S503ab.  If you cannot attend but are interested in following the work of the committee please sign up for email alerts at    Hope to see you there!

Anyone out there as passionate about confined space safety as I am?    If you are at all involved with confined space entry then come hear about the new NFPA 350 Guide to Confined Space Entry and Work at the NFPA conference next week in Chicago!   The Technical Committee has completed the second draft revisions and, absent any NITMAMs, the new guide will be released this coming November!  This document explains  “how to” comply with provisions in the existing confined space regulations and standards by providing more detailed guidance on subjects such as hazard identification, air monitoring, ventilation and rescue.   It also addresses some of the gaps in the existing standards and provides best practices for confined space entry. 

A presentation on NFPA 350 is scheduled for Wednesday June 24th 9:30-10:30 in Room S404bc.   For those who are not attending the conference, you can stay on top of what is happening with NFPA 350 by signing up for email alerts at  Hope to see you at the conference!

New FAQ for NFPA 704 available for download.pngThe NFPA 704 “diamond” provides a tried and true method for warning emergency responders of the hazards they could encounter during a spill or fire involving a hazardous material.   Staff at NFPA often receive questions about the application of the ratings such as “How does this system differ from other labeling systems” or “Where should I post the NFPA 704 placards at my facility”?  A new Frequently Asked Questions (FAQ) document has been developed to address some of these common questions. The FAQ document is now posted and available for download.

What else is happening with NFPA 704?   Well-those of you who are still wondering how OSHA’s HazCom 2012 hazard classification numbers may impact NFPA 704 ratings can view a comparison of the two systems on a Quick Card that is also available for download.   In addition, NFPA 704 is currently undergoing revision.  The first draft of the document that includes proposed changes is now open for public comment.  You can view the First Draft Report on the next edition tab on the document information page to view changes proposed for the 2017 edition of NFPA 704.  A few highlighted changes include the addition of the symbol for simple asphyxiant (SA), to be added for liquefied carbon dioxide vapor withdrawal systems and where large quantities of dry ice are used in confined areas,  and the addition of sample placards and explanatory language that can be used in safety publications.  The document is open for public comment through May 15, 2015. 

The NFPA 704 rating system is alive and well and continues to provide emergency responders with the information needed to safeguard the lives of both the public and emergency response personnel!

The preliminary draft of NFPA 350 has been approved by the NFPA Standards Council and is now open for public input.  This guide, with non-mandatory language, incorporates the best practices that organizations and confined space professionals have utilized to comply with regulations and standards for the past 20 years since the initial publication of OSHA’s final rule.  It also draws on NFPA’s experience with a number of confined space activities including hot work, the maritime industry and emergency rescue operations.

The Guide primarily focuses on addressing gaps in standards and on providing prescriptive guidance on how to implement requirements in existing standards, particularly those found in 1910.146. While the OSHA 1910.146 standard simply requires verification of a safe atmosphere prior to entry, the NFPA Guide provides prescriptive guidance on exactly how to do such testing and includes information about gas monitor selection, calibration and limitations and tells you how to select and locate ventilation equipment to eliminate and control atmospheric hazards.  

The Guide incorporates information on requirements not specifically addressed in existing standards such as adjacent space hazards and competencies for personnel involved in confined space entry.  It also addresses best practices not typically found in regulations and standards such as management of change and prevention through design.

The document is a great step in the right direction towards improving confined space safety.  However, the committee recognizes there is still a lot of work to be done on the preliminary draft.  We encourage you to take the time to read the full document or those chapters of particular interest to you and submit public input prior to the closing date of January 3, 2014.   Every public input will be considered carefully by the committee at the First Draft meeting to be held between January and June of 2014.   To view the document and submit input go to   You may also want to sign up for email alerts above the tabs so that you are notified about upcoming meetings and when additional drafts are posted.  

We look forward to your input on this important document!  

Free reference card compares NFPA 704.jpgWhen OSHA announced last year that it was updating its Hazard Communication Standard to include the adoption of the Globally Harmonized System of Classification and Labeling of Chemicals, many companies and emergency responders asked “How will this impact NFPA 704”?  NFPA 704, Identification of the Hazards of Materials for Emergency Response, uses a combination of color coding and numbers to describe a hazard’s severity, and provides a simple, readily recognized, and easily understood label to assist those who are responding to an emergency such as a fire or spill. OSHA’s revised Standard, known as Hazard Communication 2012 or HC2012, is a workplace chemical information system established primarily to provide information and safe work practices for those working with chemicals on a routine basis through the use of labels, Safety Data Sheets (SDSs) and training. 


The concern is that the HC2012 standard incorporates a numerical rating system that appears to be similar to NFPA 704 rating system, however the severity rating on the two standards are inverted.   NFPA 704 uses a numerical of 0-4 with 4 indicating themost severe hazard.   Hazard Communication 2012 uses a numerical rating system for classification of chemicals between 1-4 with a 4 rating indicating the least severehazard.  The inverse numerical rating between the two systems is primarily what creates the concern.


To address this concern, NFPA has been working with OSHA over the past year to promote awareness of the differences between the two systems. It should be noted that OSHA does not necessarily see a conflict between HCS and NFPA 704.  OSHA has indicated that the GHS numbers are not relative ratings of hazards but are used for the purpose of classifying hazards into categories for proper labeling and training information. The numbers for GHS will be placed on the SDS but are not required to be on labels. 


Recently OSHA and NFPA worked together to develop a “Quick Card” showing the differences between the two systems. The Quick card can be found on the NFPA Document information page for NFPA 704  at the bottom of the page under “Additional Information”. Or you may go directly to the Quick Card.   The card can be downloaded and laminated as a two sided document that can be used for easy field reference.    


The NFPA Technical Committee on Classification will continue to assess the impact of GHS incorporation into OSHA’s HC2012 standard.  In the meantime, there is no immediate plan to change the existing NFPA 704 system.   The Committee recognizes that the NFPA 704 consensus standard has been protecting emergency responders, employees, and the public for over 50 years and any changes would need to be carefully considered.   For updates on NFPA 704 it is recommended that you sign up for email alerts on the top of the document information page for NFPA 704.

We welcome your comments on the Quick Card!    

Well, my confined space blog may have slowed down a bit in the past couple months due to other ongoing work, but unfortunately the confined space fatalities have not slowed down...

In April, seven workers were killed in a tank that was undergoing maintenance and cleaning at a plant in Mexico City operated by Corona beermaker, Grupo Modelo.  It is believed that four victims were maintenance contractors and three victims were other Modelo employees.   There are few details available on the incident.  It is speculated that the deaths were due to “unspecified toxins” and that the three Modelo employees had entered the tank in an effort to rescue the other four contract employees.   Mexican authorities are reportedly investigating the incident.  

Confined spaces are or should be clearly recognized in the beer industry.  The large numbers of tanks that are entered for maintenance and cleaning, combined with hazardous atmospheres including carbon dioxide produced during fermentation, inert atmospheres, and ammonia from refrigeration systems creates significant confined space entries and hazards.   These incidents do not just happen in foreign countries, and wine makers are also not off the hook when it comes to confined spaces.  A confined space death occurred just two years earlier at Napa California at Ancien wines when a worker was overcome by nitrogen and argon gases inside a tank.  

Workers entering into tanks in the beer and wine industries should be intimately familiar with confined space entry procedures.  Even if contractors were always used to perform confined space entry work, it is unclear why Modelo employees would have entered the tank if they had been trained to recognize the confined space hazard.  The Modelo company has been in operation since 1925 and is the maker of the number 1 imported beer in the United States. 

This confined space incident has the largest loss of life in one entry that I am aware of.  While it is not uncommon to lose 2-3 workers, this incident claimed the lives of 7 workers.  Confined space entry hazards continue to claim lives despite improved recognition of the hazards and despite regulations and guidelines available to prevent such incidents.  

The National Fire Protection Association is developing a Best Practices document for confined space entry. This document will address gaps in existing standards and will be more prescriptive in describing things like how to test the atmosphere in and around confined spaces prior to entry.  The NFPA document is looking to go beyond the minimum standards and to provide those looking to develop a “gold star” confined space entry program with the information they need to do so.  Please email me at for further information and/or leave a comment below for discussion.  I look forward to hearing from you!

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