Rats, mice, snakes, spiders, used syringes, raw sewage and standing water are just a few of the unsavory hazards Mike Starner encountered while working in manholes as a troubleshooter for Baltimore Gas & Electric.

More recently, as NECA’s director of outside line safety, he advocates for line contractors to understand and follow OSHA guidelines to keep employees safe while working in confined and enclosed spaces.

“You really have to be prepared for anything,” Starner said. “The most common enclosed spaces are manholes. Some sit there for years without anybody going into them.”

Beyond things that could bite, wound or sicken, the most serious threats faced by underground lineworkers, substation technicians, meter installation crews and service crews working in confined and enclosed spaces are electrical hazards and hazardous atmospheric conditions, including flammable gases, toxic fumes and oxygen deficits. Other formidable threats include fall risk, flooding and traffic. As the electrical industry pushes to upgrade infrastructure, transitions to renewable sources of power and responds to power outages in the wake of devastating weather events, it’s important for workers to take proper precautions.

Enclosed or confined

The place to start, Starner said, is realizing the differences between the terms “enclosed” and “confined” spaces. An enclosed space pertains to a working space such as a manhole, vault, tunnel or shaft with limited egress or entry. These are designed for periodic employee entry.

“Under normal conditions, an enclosed space does not contain a hazardous atmosphere, but it can under abnormal conditions,” he said.

Confined space is configured for entry, but offers limited or restricted means for entry and exit, such as an underground utility vault. Confined spaces are not designed for continuous occupancy and frequently occur in construction settings where atmospheric conditions and other variables may not be known.

“Confined spaces come with many different layers, moving parts and more unknowns,” Starner said. “Hazards must still be detected and discovered.”

He believes OSHA standards for enclosed spaces are less rigorous for the electric transmission and distribution industry than for confined spaces occurring in a wider range of work settings.

“There’s a trap where people can let their guard down by only following enclosed spaces OSHA standards (1926.950, 1926.952 and 1926.953),” he said. “These aren’t as prescriptive as the other standards for confined spaces (1926.1203– 1926.1213 and 1926.961).”

Take precautions seriously, because “hazards can develop without notice,”Starner said.

Whether working in a confined or enclosed space, Starner said, certain best practices apply:

• Evaluating the space before and after entry
• Atmospheric testing for oxygen, flammable gases and toxic fumes
• Proper ventilation
• Attendants who are not distracted by other duties
• Rescue training and rescue plans
• Permitting

Permits are needed for confined spaces when a potential hazard is detected and for known hazards, such as the presence of materials that threaten to engulf or asphyxiate the entrant or converging walls that prevent self-rescue.

For safety’s sake, coordination, transfer and sharing of information is crucial (OSHA 1926.952). Before work begins, the contract employer must advise the host employer of any unique hazardous conditions presented by the contract employer’s work. The contract employer must advise the host employer of any unanticipated hazardous conditions found within two working days after discovery. Daily employee briefings also are required.

For permit-required spaces, entry supervisors must be qualified employees and be prepared to implement a rescue plan.

“This means people who have training and certification, not simply ‘competent’ employees,” Starner said.

He insists line contractors must fully comprehend regulations and their responsibility to provide a safe work setting.

“Just because your routine work falls under 1926 Subpart V or 1910.269, that doesn’t mean that other regulations don’t apply or won’t apply if conditions evolve,” Starner said.

Line contractors also must be familiar with 1926.950, which pertains to underground electrical installations. Starner additionally recommends looking to the NFPA’s 350 standard and the ANSI/American Society of Safety Professionals confined space standard Z117.1.

“These articles give a bit more clarity,” Starner said. “OSHA gives guidelines, but not a lot of detail.”

An online refresher on working in enclosed and confined spaces for Q4 2021 is available at www.neca-neis.org/powerlinesafety/ training/quarterly-refreshers.