Cal/OSHA Chief Ellen Widess yesterday announced a Special Emphasis Program on confined space compliance, following a series of confined space deaths in 2011. Employers can expect, at the minimum, that any future inspection will include not just a request to review your IIPP and Heat Illness programs, but your written Confined Space plans as well.
We suggest that you inventory your facilities to determine whether you know of all spaces which could be considered confining, and update your written program and training. See Title 8 California Code of Regulatons section 5156 to 5158 for the technical stuff.
In practice, the requirements for a successful confined space program are so onorous that we recommend that all but the most sophisticated and resource-rich employers do everything possible to eliminate the need for their employees to enter confined spaces. For starters, there is the requirement that two employees be present: One inside and one as a hole watch outside who is trained in extraction of a downed employee. That’s person-power. Second, while most employers will want to rely on first responders (Fire, paramedics, etc.) for rescue and treatment, that help must be no more than five minutes away. Few employers can guarantee that level of response… unless they have fully trained in-house teams.
If you do decide to create your own plan, you should invest in the assistance of an experienced (preferably Certified) Industrial Hygienist to be sure you get it right. Once your plan is in place and has been tested, we recommend you invite Cal/OSHA Consultation (not Enforcement!) in to observe a simulated event.
We also recommend that your employee training, whether you require entry or not, include the warning that fully 60% of confined space victims are those who attempt to rescue the first victim.
Finally, we wondered how long a Special Emphasis Program lasts? We don’t know, but there are “active” emphasis programs listed on the Fed/OSHA website which were adopted in 2006.