Confined spaces can present conditions that are immediately dangerous to workers if not properly identified, evaluated, tested, and controlled. This fact sheet highlights many of the confined space hazards associated with crawl spaces and attics and how employers can protect their workers in these environments.
OSHA has developed a new construction standard for Confined Spaces (29 CFR 1926 Subpart AA) — any space that meets the following three criteria:
A space may also be a permit-required confined space if it has a hazardous atmosphere, the potential for engulfment or suffocation, a layout that might trap a worker through converging walls or a sloped floor, or any other serious walls or a sloped floor, or any other serious safety or health hazard.
Confined space hazards in crawl spaces and attics have led to worker deaths. Several tragic incidents in crawl spaces and attics have included:
The new Confined Spaces standard requires employers to ensure that their workers know about the existence, location, and dangers posed by each permit-required confined space, and that they may not enter such spaces without authorization.
Employers must train workers involved in permit-required confined space operations so that they can perform their duties safely and understand the hazards in permit spaces and the methods used to isolate, control or protect workers from these hazards. Workers not authorized to perform entry rescues must be trained on the dangers of attempting such measures.
The new Confined Spaces standard includes several requirements for safe entry.
Preparation: Before workers can enter a confined space, employers must provide pre-entry planning. This includes:
Ongoing practices: After pre-entry planning, employers must ensure that the space is monitored for hazards, especially atmospheric hazards. Effective communication is important because there can be multiple contractors operating on a site, each with its own workers needing to enter the confined space. Attendants outside confined spaces must also make sure that unauthorized workers do not enter them. Rescue attempts by untrained personnel can lead to multiple deaths.
Crawl spaces and attics can be both confined spaces and permit-required confined spaces under the new standard. For instance, working in an attic and applying a large amount of spray foam (or another chemical) in a short period of time can expose a worker to low oxygen levels or a hazardous atmosphere.
In addition, changes to the entry/exit, the ease of exit, and air flow could create a confined space or cause the space to become permit-required.
Crawl spaces can present many confined space hazards, including:
Working in attics can also present confined space hazards, such as:
Personal protective equipment: Employers should assess the work site to determine what personal protective equipment (PPE) is needed to protect workers. Employers should provide workers with the required PPE and proper training on its use and about any related hazards before the work starts.
Contact Lapolla for additional OSHA safety advice and
to purchase proper PPE equipment:
1-888-4-LAPOLLA or e-mail us at CustomerService @ lapolla.com
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OSHA’s Confined Spaces in Construction Standard (29 CFR 1926 Subpart AA)
Confined Spaces: OSHA Construction Industry Topics by Standard
OSHA Fact Sheet: Procedures for Atmospheric Testing in Confined Spaces
Confined Spaces: NIOSH Workplace Safety and Health Topics Page
State Plan Guidance: States with OSHA approved state plans may have additional requirements for confined space safety.
This is one in a series of informational fact sheets highlighting OSHA programs, policies or standards. It does not impose any new compliance requirements. For a comprehensive list of compliance requirements of OSHA standards or regulations, refer to Title 29 of the Code of Federal Regulations. This information will be made available to sensory-impaired individuals upon request. The voice phone is (202) 693-1999; teletypewriter (TTY) number: 1-877-889-5627.
