Confined Space Fall Protection: Hazards, Highlights and How to Keep Workers Safe

Confined spaces present unique fall hazards, but these risks can be mitigated through proper assessment, effective fall protection solutions, and thorough training.

• By Philip Jacklin
• Sep 10, 2024

The risk of slipping, tripping or falling is prevalent in many facilities and job sites. In fact, falls are the second leading cause of occupational deaths, only surpassed by automobile accidents. Confined spaces carry similar risks and hazards but add to the complications with physically or atmospherically challenging environments for workers to perform their duties. A 2020 fact sheet published by the U.S. Bureau of Labor Statistics (BLS) reported that 1,030 occupational deaths were linked to work in confined spaces. Of those deaths, falls to a lower level accounted for 156 fatalities, second only to trench collapses.

To reduce the number of fall injuries & fatalities, it’s first necessary to start reducing the number of falls occurring. Confined spaces pose unique risks to workers, but fortunately, they can be mitigated just like any other workplace hazard. The Occupational Health & Safety Administration (OSHA) believes all falls are preventable, even falls in confined spaces. Let’s discuss some unique challenges in developing a confined space fall protection program, how to address fall hazards systematically and how to maintain a comprehensive program that keeps confined workers safe.

Definitions of Confined Spaces 

As far as OSHA compliance is concerned, a confined space is defined as a working environment with limited or restricted means of entry and exit, specifically an access point less than 24 inches in diameter. Examples of confined space work environments include underground vaults, tanks, storage bins, hoppers, ingot pits and diked areas, vessels, silos and other similar areas. Personnel working in confined spaces are often subjected to increased risk of entrapment, engulfment and hazardous atmospheric conditions.

Additionally, a permit for entry must be obtained if a confined space contains any of the following conditions: 

• A hazardous atmosphere (or one with the potential to become hazardous).

• Material that has the potential for engulfing an entrant.

• An internal configuration that could cause an entrant to be trapped or asphyxiated by inwardly converging walls or by a floor, which slopes downward and tapers to a smaller cross-section.

• Any other recognized serious safety or health hazard.

Permit-required confined spaces contain an increased risk of falls due to the hostile atmospheric conditions present. Respiratory protection gear should be properly fit-tested per manufacturer instructions while wearing fall protection equipment to ensure compatibility & worker safety.

Identify, Evaluate and Control Hazards

While confined spaces may contain elevated chances of risk or unique hazards not found elsewhere in a facility or job site, assessing and addressing the fall hazards should follow the same procedure per the fall protection program. Before any confined space work is performed, employers must conduct a hazard assessment to identify the fall hazards present and evaluate solutions to mitigate any found hazards. (Note: the hazard assessment should be performed in conjunction with the organization’s Competent Person to ensure compliance with OSHA and ANSI standards as well as any corporate safety policies).

A confined space fall hazard assessment should begin with a visual inspection of the work area. Employers may find it beneficial to include one or more workers working in the confined space to assist with the hazard assessment. Frontline workers can provide helpful insight into the potential effectiveness of proposed solutions. Hazard mitigation methods become useless if workers think them too cumbersome to comply. Sometimes, safety professionals can get too caught up in conjecturing standards and legal compliance and forget the most critical component of user compliance: the user. Often, the best safety solution is the one workers will use each time.

It is also imperative to attempt to eliminate the fall hazard before simply mitigating the risk. For example, solutions like guardrails are much more effective than fall arrest equipment in removing hazards and decreasing risk for the worker. Fall arrest solutions should only be considered once preventative solutions like guardrails or fall restraint systems are ruled out due to infeasibility.

The final component of controlling hazards is preparing for worst-case scenarios. Any job site with ongoing confined space work environments must also be equipped with appropriate OSHA-approved rescue equipment in the event that an employee is unable to exit the hazardous area without assistance. Emergency services, 9-1-1 and medical assistance should always be called if a fall incident occurs, but that does not relieve the employer of their duty to have equipment on hand to perform self-rescue methods before first responders arrive at the scene. Simulated rescue training practices can help ensure workers understand how to properly use rescue equipment and increase the chances of a successful rescue should one be necessary to perform.

Implementing Solutions and Personnel Training 

Once effective solutions are identified and implemented, the real work begins. Confined space work will likely necessitate training that goes above and beyond standard fall protection training. It would behoove employers to rehearse entering a confined space before performing the actual confined space work. While on-the-job training is an effective way for workers to gain valuable knowledge, proactive training will only reinforce those principles when it is time to get down to business and work must be performed. 

Any user entering a confined space should be prepared to perform pre-use inspections on their fall protection equipment and any other personal protective equipment (PPE) that will be used to perform their task. The organization’s Competent Person should train on the importance of verifying the integrity of safety equipment before work starts to prevent unanticipated injuries from occurring. Additionally, retraining should occur if an employee displays a lack of knowledge or a gap in understanding of the company’s written fall protection plan.

Conclusion 

Confined spaces bring unique challenges and elevated chances of risk to any job site, but their hazards can still be remedied by ordinary mitigation methods. As safety professionals, it is important to remember core principles that will help identify effective solutions and make the safety of the worker the top priority. Throughout this process, we must ensure that solutions will be effective enough to keep workers safe and simple enough to use that users will adopt them into normal work routines. With positive reinforcement and an emphasis on keeping users safe, we can make steady progress in achieving fewer falls, fewer injuries and fewer fatalities over time.

This article originally appeared in the September 2024 issue of Occupational Health & Safety.