Drew Hinton, PhD, CSP, CHMM, EMT’s Post

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President/CEO at Arrow Safety | "The Safety Doc"

This is a basic classifying criteria for confined spaces, yet many people find it difficult to truly define, so we've decided to help out! 👇🏻

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When it comes to classifying confined spaces, what does "not designed for continuous employee occupancy" really mean? 🤔 Since this is one of OSHA's three defining criteria for a "confined space", it's important that we accurately understand it. While this phrase isn't specifically defined in OSHA's confined space standard for general or construction industries, you can find guidance in multiple OSHA interpretations, as well as OSHA's "Confined Spaces Advisor". Using these resources, the phrase "designed for continuous employee occupancy" refers to a workplace that is intended as a place for regular work on a daily basis, and is supplied with ventilation, lighting, and other conditions necessary to support life. In addition, you will also see a slight difference in this terminology between OSHA and the American National Standards Institute (ANSI). ANSI's confined space standard (ANSI/ASSP Z117.1) uses the phrase "its primary function is other than human occupancy", rather than OSHA's "not designed for continuous employee occupancy". Although the distinction between the "primary function" (ANSI) and the "design" (OSHA) of a space may seem inconsequential, OSHA believes that their definition properly places the focus on the design of the space, which is the key to whether a human can occupy the space under normal operating conditions. Thus, if a space is truly designed for human occupancy, then the primary function of the space is irrelevant. It's important to note that even though something may not be classified as a "confined space" (or even a "permit-required confined space"), that doesn't mean it is always safe to enter and perform work. Instead, rather than assessing and documenting the hazard(s) on a confined space entry permit, the hazard(s) would be documented on your organizations risk assessment, JSA, JHA, or other similar document. OSHA Interpretation: https://shorturl.at/Srbyh OSHA's Confined Spaces Advisor: https://shorturl.at/1NRmA #arrowsafety #safety #safetyconsultant #safetytraining #manufacturing #osha #glasgowky #louisville #kentucky #assp #construction #oilandgas #training #confinedspaces

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Shelley Tijerina, MS, CSP

Occupational Safety and Health Consultant

1mo

Drew Hinton, PhD, CSP, CHMM, EMT what a timely post. I’ve noticed that the definition“not designed for human occupancy” is one that people outside of our profession do tend to get stuck on. Also, I appreciate the last bit of guidance regarding using a JHA to document the hazards when the space doesn’t fit the definition. Thanks!

Jennifer Cosgrove, ASP

Environmental, Health & Safety

1mo

So timely, Drew! I was just discussing this on a job site yesterday… sometimes classifications of confined space & permits/signage don’t line up with how the area is actually being used/entered. Perfect timing with this post to assist me with my deep dive, thanks!

I utilize a confined space assessment for all confined spaces. Cs permits lack enough detail To properly access the confined space. Great post

Jean Claude KAMGUE

Quality Health Safety and Environment Eng.

2mo

Do not forget wearing of specific PPE (safety helmet,...) set up continuous ventilation

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Great perspective!

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