“Effective, reliable communication equipment is essential in relaying information to attendants, entry supervisors, and other authorities regarding potentially dangerous changes in the PRCS [Permit-Required Confined Space] conditions. Such information is critical to assess the hazards within the space and to provide information regarding methods appropriate for protecting or removing employees from those hazards.”
Beautifully said. Too bad I’m not the one who said it. This is a direct quote from page 25,423 of the Federal Register that features Confined Spaces in Construction; Final Rule.
Confined space communication challenges rank right up there with breathing and claustrophobia. On average, 92 workers die in confined space incidents every year. Common types of accidents include these examples:
- Engulfment: A maintenance worker at a furniture manufacturing company slipped and fell through a manhole into a sawdust storage silo.
- Asphyxiation: Two workers died of hydrogen sulfide inhalation after entering a manhole to repair a pipe. In an all-too-common scenario with confined space incidents, the successive fatalities resulted when the would-be rescue worker entered the manhole to save the first victim but ultimately succumbed to the same problem.
- Drowning: An inflatable sewer plug gave way, allowing water to flow back into a sewer wet well and drowning a maintenance worker.
Confined Space Parameters
Personally, I think a cubicle should qualify, but OSHA has a stricter standard. A confined space has to be big enough for an employee to fully enter, isn’t designed for continuous occupancy (that’s where they get me on my cubicle notion), and has limited or restricted means of entry or exit. If the space has the potential to contain a hazardous atmosphere, engulfment material, converging walls or “other recognized serious safety or health hazards,” then it’s characterized as a permit-required confined space (PRCS).
Examples include but are not limited to condenser pits, manholes, ventilation ducts, tanks, sumps, containment cavities, vaults, vessels, and silos. The video below details a rescue involving a water treatment plant worker that fell into a 40-foot well.
5 Communication Imperatives
If a space is so tight that only one worker can fit, then dependable communication equipment is absolutely essential. Aside from mandatory PPE that workers need to complete their job (e.g., respirator, hardhat, goggles, air monitoring equipment, etc.), a method of uninterrupted team communication must also be incorporated. According to Confined Spaces in Construction; Final Rule: “Paragraph (d)(3). Final § 1926.1204(d)(3), which is substantively identical to § 1910.146(d)(4)(iii), requires an employer to provide all communications equipment necessary to ensure that an attendant can communicate effectively with entrants in accordance with §§ 1926.1208(c) and 1209(e).”
For optimal situational awareness, the communication method should be:
- Hands-free: Maneuvering is more difficult in confined spaces. Workers shouldn’t have to push-to-talk (PTT) or dial a smartphone. Besides, if a worker is asking for help while losing consciousness, she may not be able to engage PTT in time.
- Wireless: Workers in confined spaces have enough to worry about without adding extra wires from lapel mics, battery packs or earbuds. They introduce the likelihood of entanglement.
- Full duplex: Don’t risk being locked out of precise directions, alerts about changes, or shouts of alarm. Full-duplex communications act as early-warning systems by allowing all parties connected on a communication system to listen and transmit at will, even if another party is in the middle of a transmission. They also fulfill the Final Rule’s information-exchange requirement, which “applies to activities outside the permit space that could foreseeably result in a hazard within the permit space, either alone or in conjunction with the activities inside the space.”
- Independently powered: Using communication systems that rely on a local power supply or generator puts your crew at risk of losing communications in the event of a power loss or generator failure. According to the Final Rule, “Unexpected loss of power can endanger entrants, particularly if the permit plan relied on the use of ventilation, monitoring, controls, communication with the attendant, or egress that would be affected by the loss of power.” Even if the lights go out and the winch won’t work, you want to keep communications live to facilitate a manual rescue from the confined space.
- Integrated with hearing protection: Any communication system has to be able to function despite noise. The Final Rule states that noise constitutes “a physical hazard if it is loud enough to substantially reduce the efficiency of the entrant’s ears to process communications from the attendant or entry supervisor regarding exit instructions or other emergency information, thereby impairing the ability of the employee in the permit space to exit the space safely.”
With the right communication system, crews can improve safety and efficiency while maintaining compliance to OSHA’s confined spaces rule.
Bring a Team When There’s Only Room for 1
Back country skiers wear avalanche beacons. Hikers set up supply drops and register for permits so friends, family and National Forest employees know they’re out there. Pilots log a flight plan. Boaters file a float plan. See where I’m going with this?
Never go in alone, even if you have to go in alone. Don’t enter the confined space until you know that you’re in a team member’s ear.
Editor’s note: Our thanks to FFIII Michael Jordan and the Anne Arundel County Fire Department for the use of their photo and video of the well rescue incident.