Confined Space Reclass
Hey all,
I’m at a point of disagreement with my team on confined space reclassification.
My premise is this: any form of isolation is not truly elimination of a hazard (it is merely controlling the hazard) and thus, a permit space subjected to hazard isolation cannot be reclassified. The very fact of applying a control to any type of hazard means that the hazard is present, and that the control could fail.
The opposing view presented against mine is that OSHA uses the term isolation and elimination as synonymous. I don’t think that is the case nor the intent, though I will be honest in saying that even if that is OSHA’s position, I believe they are not the same. Confined space fatalities I think have unfortunately proved this out. Additionally, and this may be a charged comment, could OSHA do better here?
Upon searching other institutions, there seems to be plenty of folks who take the view that if you isolate, you can reclassify. Perhaps I’m way off base, so I’m curious to know what the collective here thinks.
Comments (5)
I teach confined space courses all the time and this discussion actually comes up quite often. It always generates some great discussions.
OSHA clearly states that "controlling" hazards is not the same as "elimination". As you said, the term "isolation" just means you're separating the worker from the hazard(s) by some type of engineering control method - the hazard (or potential for one) is still present.
The definition from 1910.146 is below and the key word is "protected":
"Isolation means the process by which a permit space is removed from service and completely PROTECTED against the release of energy and material into the space by such means as: blanking or blinding; misaligning or removing sections of lines, pipes, or ducts; a double block and bleed system; lockout or tagout of all sources of energy; or blocking or disconnecting all mechanical linkages."
1926.1202 (confined space definitions standard for construction industry) has a similar definition as 1910.146, but I think it paints a better picture of this (especially the last sentence of the definition):
"Isolate or isolation means the process by which employees in a confined space are completely protected against the release of energy and material into the space, and contact with a physical hazard, by such means as: Blanking or blinding; misaligning or removing sections of lines, pipes, or ducts; a double block and bleed system; lockout or tagout of all sources of energy; blocking or disconnecting all mechanical linkages; or placement of barriers to eliminate the potential for employee contact with a physical hazard."
There's also the following note from 1910.146(c)(7)(ii):
"Note: Control of atmospheric hazards through forced air ventilation does not constitute elimination of the hazards."
Like you said, controls can still fail. We actually just had a fatal confined space incident here in Kentucky a few months ago where a pipe plug (a form of isolation) failed, resulting in the engulfment hazard becoming present again and two workers drowning.
You're 100% correct on your stance. Although elimination and isolation may produce seemingly close results in the end (a "safe" space), the terms are NOT interchangeable. Isolation is a type of engineering control, so even if you look at the heirarchy of controls, they're clearly two different methods of mitigating a hazard.
I deal with this issue all the time. If you can isolate the hazard, it's controlled and the space by reasonable legal interpretation can be re-classified. It is not eliminated...so there is still potential. I believe your issue is also the morality of whether or not we should. There I agree with you also. Just because we can doesn't mean we should, it's a matter culture, risk all within the scope of your workplace. OSHA is a guidepost and a minimum...treating it as anything else during the work day does not help ones mental health. We all wish it was better, clear and perfect...but it's not.