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February 10, 1999
Are Respirators Necessary For Confined Space Work? Part One of a Special Bulletin Series on the New Respiratory Standard
Many CSRMA members conduct work activities that require their employees to enter confined spaces. A confined space is defined in CCR Title 8, Section 5156 (b)(1) as: "A confined space is a space that is large enough and so configured that an employee can bodily enter and perform assigned work, has limited or restricted means for entry and exit and is not designed for continuous employee occupancy" One type of confined spaces that people in the wastewater industry routinely encounter are permit-required confined spaces. That is,
they contain or have the potential to contain a hazardous atmosphere. CalOSHA requires that prior to entering any permit-required space that the atmosphere be tested for hazardous
conditions. If conditions are acceptable, employees may enter the space to perform the work assignments. However, many permit-required spaces have transient atmospheres that can change rapidly over a very short time, and
employees working inside the space may be overcome and require life-saving rescue. Some confined spaces are so configured to allow the overcome employee to be retrieved without
sending another employee into the space to rescue him. However, it is entirely foreseeable that even in instances where this method of rescue should
work that the overcome employee may become entangled, making non-entry rescue impossible or unsafe. Because this type of situation is foreseeable, a legal duty has been created to anticipate and plan for its
occurrence. CalOSHA intended for employers that have employees entering permit-required confined spaces to plan for this occurrence by requiring them to develop a confined space
program. An integral component of this plan is the development and implementation of procedures for rescuing entrants from permit spaces. These include having the correct rescue equipment on site and emergency
services available. Because time is of the essence when rescuing an injured employee in a space with an atmosphere that has become hazardous, a fundamental piece of rescue equipment that needs to be immediately available is a
supplied air respirator (SAR). This also requires that a person trained and designated to make a rescue be at the site. The question was posed to CalOSHA if
dialing 911 for fire department assistance is an adequate level of rescue and emergency protection. CalOSHA responded by stating, "Just dialing 911 is not an adequate level of rescue and emergency protection"
. CalOSHA went on to say that, "…at least one person must be trained, equipped and available for immediate rescue service". Further, CalOSHA stated that, "
…offsite services like 911 are intended to be a secondary or backup service". One of the reasons for this is that local emergency services cannot
guarantee that they will be immediately available at all times. Because this, too, is foreseeable, the primary responsibility and obligation for ensuring the safety of employees entering permit spaces lies directly with the employer.
CalOSHA has made it abundantly clear that if an employer requires its employees to enter a space that has the potential to have a hazardous atmosphere, then the employer has a
responsibility to ensure that the equipment and personnel necessary to perform both entry and non-entry rescue under any foreseeable circumstances are immediately available.
This, of course, means that a supplied air respirator and a person trained on its use, as well as entry rescue techniques, are immediately available to save the life of an overcome coworker.
If you currently have operations that require entry into permit spaces and would like assistance in developing a confined space rescue or respiratory protection program, please contact David Patzer at
(415) 371-5430 or at
The next Bulletin in this special series on the new Respiratory Standard will provide an over view of the standard and the changes it will bring to your current respiratory protection program.
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