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OSHA - Confined spaces in residential construction

image Joann Natarajan, Compliance Assistance Specialist, OSHA, Austin, TX

AUSTIN - Before beginning work on a residential homebuilding project, each employer must ensure that a competent person identifies all confined spaces in which one or more employees it directs may work, and identifies each space that is a permit-required confined space. The competent person does not have to physically examine each attic, basement or crawl space, if the competent person can reliably determine whether the spaces with similar configurations contain a hazard or potential hazard that would require the permit-space classification. The initial evaluation may be done using existing experience and knowledge of the space by the competent person and does not need to be documented.


    Spaces in a residential home may be considered confined spaces or permit-required confined spaces during the construction or remodeling process. However, the vast majority of the standard’s requirements only apply to permit-required confined spaces, and attics, basements, and crawl spaces in a residential home – three common spaces – will not typically trigger these requirements.
    Attics: In many instances, an attic will not be considered a confined space because there is not limited or restricted means for entry and exit. For example, an attic that can be accessed via pull down stairs that resemble the structure of a stationary stairway and do not require an employee to ascend/descend hand-over-hand would not be considered a confined space if there are no impediments to egress.
    Attics that are determined to be confined spaces would generally not be permit-required confined spaces because they typically do not contain the types of hazards or potential hazards that make a confined space a permit-required confined space (those that could impair an entrant’s ability to exit the space without assistance).
    However, extreme heat in an attic can be considered a serious physical hazard such that the attic could be considered permit-required confined space. OSHA has not quantified how hot it must be to trigger the permit-required confined spaces requirements. However, heat that is extreme enough to cause heat exhaustion (e.g., dizziness, headaches, severe sweating, cramps) may impede an entrant’s ability to exit the attic without assistance and would make a confined space permit-required.
    Basements: Basements in a residential home that are designed for continuous occupancy by a homeowner are not considered confined spaces under the standard, provided the basement is configured as designed (e.g., has permanent stairs, a walk-out entry/exit, or an egress window installed).
    Crawl Spaces: Crawl spaces in a residential home will not typically trigger the majority of the requirements of the standard unless they contain a physical hazard such as an exposed active electric wire.

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Reesa Doebbler reesa@constructionnews.net