Confined Spaces in Underground Construction
January 21, 2025
Confined spaces present unique challenges and risks in the field of underground construction. Recognizing these risks and implementing effective safety measures is not just a regulatory requirement but a critical component of protecting your workforce. Here’s what companies need to know, do, and educate about confined spaces.
What You Need to Know
Definition of Confined Space: A confined space is an area that:
- Is large enough for workers to enter and perform tasks.
- Has limited or restricted means of entry or exit.
- Is not designed for continuous occupancy.
Types of Confined Spaces:
- Non-permit confined spaces: These spaces do not pose significant hazards.
- Permit-required confined spaces: These involve hazards such as:
- Atmospheric dangers (e.g., oxygen depletion, toxic gases like hydrogen sulfide).
- Risks of engulfment.
- Entrapment or asphyxiation potential.
- Other serious health or safety threats.
Regulatory Requirements:
- OSHA mandates continuous atmospheric monitoring in confined spaces whenever possible.
- Permits must be issued for work in spaces with specific hazards, and companies must retain these permits for at least one year for potential OSHA review.
- A competent person must evaluate job sites to identify confined spaces and hazards.
What You Need to Do
- Develop a Confined Space Plan:
- Identify all confined spaces on job sites.
- Clearly label and communicate confined spaces to workers.
- Implement Monitoring and Equipment Protocols:
- Use continuous atmospheric monitors to detect hazards like oxygen depletion and toxic gases.
- Equip workers with proper safety gear, including harnesses and ventilation equipment.
- Establish Rescue Plans:
- Define protocols for self-rescue, non-entry rescue, and entry rescue.
- Train rescue personnel annually and ensure documentation is up to date.
- Avoid sole reliance on external emergency services, which can delay rescue operations.
- Assign Clear Roles:
- Designate entrants, attendants, and supervisors for confined space work.
- Ensure roles are well-defined and communicated to all team members.
What You Need to Educate
- Train Workers Effectively:
- Provide training in a language and vocabulary workers understand.
- Educate workers on the hazards of confined spaces, including atmospheric dangers and physical risks.
- Educate on Regulatory Compliance:
- Teach workers the importance of permits and the conditions under which they are required.
- Emphasize the role of competent persons and the responsibilities of controlling contractors.
- Promote Vigilance and Communication:
- Reinforce the importance of staying vigilant, even with repeated tasks.
- Foster a culture of clear communication among team members to identify and address hazards promptly.
- Highlight the Risks:
- Discuss specific risks, such as:
- Oxygen depletion due to curing concrete.
- Hydrogen sulfide buildup from degrading organic material.
- Engulfment dangers in unstable environments.
Conclusion
Understanding and addressing the risks of confined spaces in underground construction is an ongoing process. Companies must prioritize knowledge, action, and education to safeguard their teams. With proper planning, monitoring, and training, you can ensure compliance with regulations and, more importantly, protect the lives of your workers.
For more information, visit OSHA’s resources on confined spaces: Confined Spaces in Construction Regulations.
Key takeaways from OSHA’s Milwaukee Area Director on safety programs, inspections, penalties, and compliance resources for contractors.
Every year, OSHA releases its list of the most frequently cited violations. The 2025 list is out, and while many industries should pay attention, underground and utility contractors face unique risks that line up with several of the top violations. Here’s a breakdown of the most relevant items, along with trenching and excavation hazards that continue to be a top focus for OSHA inspectors. Fall Protection – General Requirements (1926.501) Falls remain the #1 most cited violation. For underground contractors, the risks aren’t always rooftops—they include falls around trenches, vaults, manholes, ladders, and uneven ground. Proper guardrails, harnesses, and safe working surfaces are essential. Hazard Communication (1910.1200) Chemicals are everywhere on utility jobs: fuels, solvents, coatings, and even the contents of pipes. Employers must ensure proper labeling, Safety Data Sheets (SDS), and worker training to stay compliant. Ladders (1926.1053) Climbing in and out of holes or accessing elevated work is common. Using damaged ladders, setting them up improperly, or failing to secure them leads to frequent citations—and serious injuries. Lockout/Tagout (1910.147) Whether shutting down pumps, isolating electrical lines, or dealing with hydraulic energy, contractors must properly control hazardous energy before starting work. Failure to do so can be fatal. Respiratory Protection (1910.134) Dust, silica, exhaust, and even gas leaks underground make respiratory protection critical. Employers must provide proper respirators, medical clearance, and fit testing. Fall Protection – Training (1926.503) Having equipment isn’t enough—workers must know how to use it. Training ensures employees recognize hazards and properly use fall protection systems. Scaffolding (1926.451) Though more common in building work, scaffolding is sometimes used in utility projects. Improper erection or use can lead to collapse and falls. Eye and Face Protection (1926.102) Flying debris, sparks, fluids, and dust are part of daily life in underground work. OSHA continues to cite employers who don’t provide or enforce PPE use. Trenching & Excavation Hazards – Always a Priority Beyond the top 10 list, OSHA has placed special emphasis on trenching and excavation safety because fatalities remain high. Utility contractors should pay close attention to: Cave-ins: Protective systems (sloping, benching, shoring, shielding) are required. A “competent person” must inspect trenches daily. Spoil piles and equipment placement: Keep soil and heavy equipment at least 2 feet from trench edges. Safe access/egress: Trenches 4 feet deep or more must have ladders, ramps, or stairs within 25 feet of workers. Atmospheric hazards: Test for low oxygen or hazardous gases before entry. Provide ventilation or respiratory protection if needed. Training & competency: Workers and supervisors must be trained to recognize trench hazards. Struck-by hazards: Protect workers from falling tools, materials, and equipment near trench edges. Utility strikes: Always identify and mark underground utilities before digging to avoid catastrophic incidents. Takeaway for Contractors Staying on top of OSHA’s most cited violations isn’t just about compliance—it’s about keeping crews safe and projects on track. Underground and utility contractors should: Refresh fall protection and ladder training. Update hazard communication programs. Review lockout/tagout procedures. Conduct fit testing for respirators. Enforce PPE requirements. Double down on trenching and excavation safety. By focusing on these areas, contractors can reduce risk, protect workers, and stay ahead of OSHA citations. Click Here for the Full Article, Top 10 OSHA Violations of 2025
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