Underground Construction - March 2020 - 22

Working in Confined Spaces: Be Safe, Not Sorry
Other points of confusion
Companies often fail to follow two other provisions of the new
standard. One is the competent person requirement.
The standard requires the presence of a "competent person"
onsite if a confined space will be entered. Many employers
make the mistake of thinking they can tap any veteran
employee for the role, but specialized knowledge is necessary
and often that means formal training. The competent person
must be able to identify existing and predictable hazards in a
confined space and the area around it, be knowledgeable about
appropriate testing, and be able to conduct initial testing as
necessary. He or she needs to know the maximum levels for
each type of gas. In addition, the designated person must have
the authority to take prompt, corrective action to eliminate any
hazards that are found.
The other, often-overlooked provision is the top-down
reporting requirement. The employer that owns or manages the
property where the construction work is taking place is required
to share any information it has about the hazards in the confined
space with the general contractor. Also, the general contractor
must pass this information down to any subcontractors doing
work in the space. This requirement ensures that those who
enter the space know the hazards they may face and can prepare
for them. When the entrants have exited the space, the findings
must be reported back up to the owner so that any new issues
may be documented for the next entry.

Cost of noncompliance
Companies that fail to comply with the appropriate standard
could be subject to citations and fines, which can impact their
reputations, their insurance premiums and their bottom line.
Of course, the real price to pay is the potential loss of life.
Company executives should familiarize themselves with both
confined-space standards and know when each applies, rather
than turn the keys over to their safety directors and hope for
the best. Safety directors should understand both standards
and what they require. And they should ensure that all field
personnel assigned the role of competent person receive the
training needed to live up to the title.
Contractors doing things like opening a manhole on a job
site and using their noses to evaluate the air is not effective.
In fact, simply opening the entrance cover to a confined space
may be dangerous if there's chance a hazardous gas could escape
(in which case, workers may need to insert a measuring device
before opening the cover).
Fatalities don't happen when you expect them; they happen
when you don't. The bottom line: rather than assume an
atmosphere is harmless, assume it isn't. Testing is the only way
to know for sure. *
BRUCE MAGEE is region product development manager for United Rentals.
With 39 years in the rental industry and the last 25 years in trench safety,
he has delivered more than 380 Competent Person classes. He has presented
on trench safety/confined space safety requirements at more than 100
engineering conferences, and trained construction safety professionals
and OSHA compliance officers across North America.

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Underground Construction - March 2020

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