Steady Rise in Confined Space Fatalities:

An Analysis of the Benefits Provided by

Visual Communication
Introduction
A confined space is defined as an enclosed area likely to present hazardous conditions upon
entry. Those conditions may be anything from entrapment, to the presence of a hazardous
atmosphere, to engulfment. Employees often enter these areas to perform tasks such as
cleaning operations, maintenance on machinery or electrical parts, or even hot work such as
welding. Unfortunately, the likelihood of an accident involving serious injury or death becomes
increasingly high in these environments if the proper protocol is not followed.
Many confined space related deaths begin with employees failing to recognize the space as
confined in the first place. With that being said, accurately identifying confined spaces is just
as important as preparing to enter one of these areas. To assist with that, OSHA has provided a
list of basic characteristics for confined space identification. If the following three questions are
true, then the area must be considered a confined space:

1. Is the area just large enough for a person to fully enter and perform a task?
2. Does the space have limited means of entry and exit?
3. Does the area prohibit continuous occupancy of personnel?

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While the above characteristics point to particularly dangerous areas, employees do not need
to seek a permit to enter them. However, permit-required confined spaces have the potential to
pose an immediate danger to life or health of the employee entering the space. For that reason,
confined spaces classified as permit-required must have all three of the previously mentioned
attributes, as well as any one of the following additional characteristics:

• Is there a hazardous atmosphere in this space?

• Does the space contain a material that has the potential to engulf a person?
• Is the space designed in a way that may cause entrapment or asphyxiation?
• Does the space contain any other safety of health hazards? This can be anything from
unguarded machinery to exposed wiring.

Only after answering those questions can the employer determine whether or not the area
requires a permit to enter. It must be noted that all confined spaces, permit or no permit, must
be treated with the utmost caution.
Many businesses require routine maintenance, as well as some instances of normal
operational procedure within confined spaces. However, despite the effort put in by regulatory
organizations to lay out best practice methods and requirements for this type of work, there
are still countless deaths every year due to confined space accidents. With that being said,
this whitepaper will be covering the dangers of confined spaces, summarize risks as described
by OSHA, provide information on regulations specifically made for properly marking confined
spaces, and discuss best practice methods involving effectively communicating the presence of
restricted areas and hazardous spaces to employees.

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The Problem: A Lack of Hazard Recognition
The Bureau of Labor Statistics and its Census of Fatal Occupational Injuries (CFOI) found that,
“from 2011 to 2018, 1,030 workers died from occupational injuries involving a confined space,”
(Bureau of Labor Statistics, 2020). The lowest yearly total occurred in 2012 at 88 deaths. Since
then, the years 2017 and 2018 recorded 166 and 148 deaths respectively, close to double
what was recorded in 2012. The evidence here shows that even with regulations and required
mitigation tactics, the number of deaths caused by confined space entry have not decreased.

Confined
Space Fatal
Injuries
(2020 BLS Data)

According to the data that the BLS has gathered as of 2020, the highest rate of confined space
deaths occurred in tanks, bins, and vats at 205 fatalities. Next, ditches, channels, trenches, and
excavations accounted for 203 fatalities. Underground mines, caves, and tunnels accounted
for 129 fatalities. Lastly, silo and grain bin interiors accounted for 107 deaths. There are other
environments where confined space entry resulted in death due to hazardous conditions, but
the four mentioned above have the highest death rates. Out of all those situations, engulfment
was the event that killed the most employees upon entry.
This issue of high fatality rates can be derived from several different scenarios. The first, and
most significant being a lack of communication. Written confined space procedures, one of the
most critical aspects of confined space safety and hazard communication, are often disregarded
or lacking from company protocol entirely. The U.S Department of Labor points to this fact in
their summary of OSHA’s permit-required confined space standard:

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“Many employers have not appreciated the degree to which the conditions of permit space
work can compound the risks of exposure to atmospheric or other serious hazards. Further,
the elements of confinement, limited access, and restricted air flow, can result in hazardous
conditions which would not arise in an open workplace… Unfortunately, in many cases,
employees have died because employers improvised or followed “traditional methods” rather
than following existing OSHA standards, recognized safe industry practice, or common sense,”
(U.S Department of Labor, n.d).
Neglecting to follow consensus standards and OSHA regulations becomes a problem of
ignorance in terms of safety protocol. This will more than likely lead to issues such as a
lack of effective communication between employers and employees, or ultimately allowing
unauthorized persons to enter a confined space. Each of these instances have the full potential
to result in a serious accident.
To belabor the point even further on the importance of communication between employers
and their employees, OHS has compiled relevant data from NIOSH recorded confined space
incidents. They have come up with the following statistics:

• 85% of the time a SUPERVISOR was present.

• 29% of the dead were SUPERVISORS.

• 31% had WRITTEN Confined Space Entry PROCEDURES.

• 0% used the WRITTEN PROCEDURES.

• 15% had Confined Space TRAINING.

• 0% had a RESCUE PLAN.

• 60% of “WOULD-BE” RESCUERS died.

• 95% were AUTHORIZED by supervision.

• 0% of the spaces were TESTED prior to entry.

• 0% were VENTILATED. (Koester, 2018)

The lack of communication around these environments is astounding by just taking a look at these
statistics. OSHA requires written confined space entry procedures and the consistent use of those
procedures. OSHA requires confined space training to be able to effectively identify hazardous
conditions and how to deal with them. OSHA also requires a rescue plan; in case the entrants and
attendants are faced with a situation that threatens their lives and health. Periodic testing for
ventilation purposes are required by law. All of these stipulations have one concept in common,
and that is the communication effort needed between the employer and their employees.

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Employers have a responsibility in keeping their employees safe from harm, which is why
neglecting to give employees all the information they need to stay safe violates efforts for
regulatory compliance, common sense, and general best practice methods.

Common Confined Spaces

Understanding where confined spaces are likely to occur is critical for hazard recognition and
communication. These dangerous spaces appear in a variety of different work environments
including the oil and gas industry, the agricultural sector, construction, manufacturing, etc.
Some examples of easily recognizable confined spaces include:

• Tanks
• Vats
• Manholes
• Silos
• Process Vessels
• Sewers
• Pipelines

Some of the more difficult to recognize areas that are classified as confined spaces include
mines, depending on how large they are, and the type of mining being done, as well as open top
spaces that are four feet or deeper such as pits, cisterns, and wells.

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Recognizing Confined Space Hazards
The hazards that lie within confined spaces can be quite obvious, but there are also instances
where employees may not realize they are in immediate danger. This can be for a number of
reasons such as they may not be trained well enough to recognize those hazards, or they did not
make an effort to keep monitoring the space for hazardous buildup of substances, to name a
few examples.
The following are some of the most common atmospheric hazards associated with confined
spaces. Each hazard listed often results in serious injury or death when the proper precautions
have not been taken:

• Toxic Atmosphere – The presence of toxic gases and vapors are some of the most dangerous
conditions a worker can experience while working within a confined space. This can be
anything from the presence of hydrogen sulfide gas, carbon monoxide, methane, volatile
organic compounds known as VOCs, etc. All of which can impair judgement and result in
unconsciousness or death depending on the atmospheric concentration.

• Oxygen concentration – An oxygen deficient environment has an oxygen concentration

below 19.5% which can cause impaired judgements, loss of consciousness, and even death.
On the other hand, an oxygen rich environment of above 23.5% poses a serious risk of a fire
or an explosion. These situations often occur where air is displaced by another gas during
operations and even biological processes that result in a chemical reaction. That includes
the development of rust, decomposition, hot work, etc.

• Flammable Material – Especially in an oxygen enriched environment, flammable materials

pose a serious risk of combustion or explosions within the confined space. Those materials
can include combustible dust, flammable chemicals, and explosive gases. When this occurs,
the structure may collapse along with the explosion.

Workers cannot assume that a space is safe before each time they enter. Even entries that occur
multiple times throughout a shift require periodic testing of atmospheric hazards that may have
developed while employees were away.

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The next section includes physical hazards that commonly exist within confined spaces. These
can be much easier to identify than that of atmospheric hazards which often require monitoring
equipment. However, it must be noted that monitoring equipment is absolutely required at all
times when entering a confined space.

• General Safety Hazards – This category of hazards includes falling objects, obstructions,
slips, trips, and falls. When paired with atmospheric hazards, these potentially minor
incidents can become deadly very quickly.

• Thermal Hazards – The use of PPE and other heavy-duty equipment may make already heated
environments even more dangerous regarding the possibility of heatstroke. Extreme cold
presents a different set of dangers, especially for hypothermia and frostbite.

• Engulfment – Becoming buried by grain or sawdust in a silo is incredibly dangerous.

Equating to essentially drowning in solid material, this hazard is particularly common in the
agricultural sector.

• Entrapment – This is often associated with mining and trench work. If the surrounding area has
the potential for collapse, there is a high possibility of workers being buried during an incident.

• Mechanical and Electrical Hazards – Moving parts that have the capability of crushing or
trapping employees in a confined space makes rescue effort extremely difficult. Likewise,
with electrical hazards in that they have the potential to create a devastating fire within the
confined space.

• Noise Hazards – Excessive noise can inhibit communication between employees within the
confined space and those outside monitoring conditions. This also makes rescue operations
much more difficult as well.

• Fire – This hazard can be the result of a number of different atmospheric or other physical
hazards. The addition of heat, smoke, and only limited routes of an exit make fires one of
the most dangerous conditions within a confined space.

It is incredibly important to know the relationship between all confined space hazards, as the
list has already noted a number of instances that may lead to another type of hazard entering
the scene.
The Solution: Increased Communication
Hazard communication is an excellent accident prevention tactic that should be used in all
environments where employee safety is compromised. Hazard communication is especially
critical for confined space related work. The lack of communication around confined space
environments can be devastating, as proven by the fatality statistics included in this document,
of which were initially gathered by NIOSH and BLS. With that being said, even if basic
communication requirements have been met according to OSHA, it’s always best to go above
and beyond where confined spaces are concerned.

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OSHA’s 1910.146 regulation specifies the need for visual
communication in certain situations. It states, “[i]f the
workplace contains permit spaces, the employer shall
inform exposed employees, by posting danger signs or by
any other equally effective means, of the existence and
location of and the danger posed by the permit spaces,�
(OSHA 2011). The same OSHA regulatory document
notes that something as simple as “DANGER -- PERMIT-
REQUIRED CONFINED SPACE, DO NOT ENTER” is perfectly
acceptable for regulation compliance.
While this is an important standard to uphold and
follow for the safety of all employees, it leaves out the importance of recognizing non-permit
required confined spaces. Without making an effort to provide thorough labeling and signage
for non-permit required confined spaces, employees may very well enter an area that poses an
immediate health risk by accident.
There are plenty of options when it comes to visually notifying employees of dangerous
confined spaces:

• Floor Signs – Use heavy duty vinyl floor signs to let employees know they are approaching a
confined space area. Put them in front of restricted areas or doors leading to that space.

• Wall Signs – Eye catching wall signs can help notify workers about confined spaces as well.
Use them to communicate to employees about the hazards they possess or reiterate that
only authorized personnel are allowed in the area.

• Labels – No matter the size, labels can be used to remind workers of the dangers of
confined spaces or even for a type of checklist that goes over necessary protocol.

• Hazard Floor Tape – This is another form of visual communication that can be used in these
environments. Use floor tape to create a barrier between normal foot traffic and the space
that attendants and entrants are allowed to enter for necessary confined space work.

Regardless of the chosen visual communication route taken, these reminders provide the
employees with consistent information on workplace protocol and hazards present. That can be
anything from needing a confined space permit, to the type of hazardous atmosphere present,
to completely barring employees from entering a space. The point of these signs is to initially
prevent emergency action from needing to be taken.

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Overall, this particular solution can help decrease the rate of accidents in both permit
required, and non-permit required confined spaces. The reason being because hazard
communication is an essential concept to everything regarding regulation compliance,
training, and initial hazard recognition.

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Gather an Experienced Team
Every time a task involving a confined space is needing to be performed, the employer must
assign a group of employees as the designated entry team. There are three different roles that
employees can play in this situation:

• The Entrant – This role is the one taken by the employee assigned with entering the confined
space. The entrant must be a trained employee who knows the PPE requirements, entry
procedures, and prohibited activities. The entrant must also recognize when they’re in
danger, know the dangerous qualities of the space, and above all else, obey commands for
evacuation procedures.

• The Attendant – This employee is tasked with the duty of maintaining visual and auditory
contact with the entrant from outside the confined space. This role does not allow the
employee to leave unless replaced by another attendant as well as prevents the entry of
unauthorized personnel. While monitoring the activities being performed by the entrant,
the attendant must also be monitoring the conditions in which the entrant is working in.
If the situation arises, the attendant must also be ready to either perform and emergency
rescue according to the predetermined rescue plan, if they are authorized to do so, or call
emergency responders.

• Entry Supervisor – This role applies to a supervisor that must be on site for any confined
space work to be performed. The supervisor is the authority that signs confined space
permits, cancels the permit once the task has been completed, and is responsible for the
prep work that must take place before entry. Ensuring a safe space for entrants during
the entire duration of the assigned task is their job and doing so requires them to be
familiar with all the hazard associated with that confined space as well as ensuring proper
atmospheric testing is done correctly.

• The Employer – While the employer doesn’t physically enter confined spaces, they are
in charge of creating the company’s confined space program. By working closely with the
supervisor, the employer helps to provide the appropriate PPE and equipment, informs
others such as contract workers of the program, establishes a rescue team and the
parameters of needed rescue.

Every person on this team must have a deep understanding of the hazards that exist within their
unique confined spaces. They must also be given the resources to be able to do their jobs safely.
This includes training and the appropriate PPE.

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Follow OSHA Regulations
Since confined spaces hold so much potential for hazardous situations to develop, OSHA
has established CFR 1910.146 for permit-required confined spaces. This in-depth regulatory
document details protective measures that must be followed to protect employees from the
dangers of confined spaces. The following is a list of some of the most pertinent rules to follow
when working around confined spaces:

• The employer is required to evaluate the workplace to determine if any spaces are permit-
required. Make sure to be familiar with the characteristics that define a confined space as
well as the hazards that may pose a risk to employees.

• If there are any permit required confined spaces, the employer must inform the employees
who will be exposed and place danger signs or any other equally effective means. The sign
must confirm its existence, where it’s located, and the type of danger that it poses to them.

• Employers must create a written confined space program and implement it. It must be
available for inspection by both the employees and authorized representatives.

• A rescue plan must be developed in case of an emergency. All employees participating in

confined space entry must receive the appropriate training for emergency rescues.

• A company procedure must be created regarding safe entry.

• Atmospheric testing is required before entry for oxygen content, flammable gases and
vapors, and toxic air contaminants in that order.

These are some of the most important components of following OSHA’s confined space
regulations. Employers and supervisors must familiarize themselves with these standards to
be able to provide the best safety instruction to employees. Doing so gives employees the best
chance at staying safe in these dangerous environments.

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Conclusion
Employees regularly face dangerous atmospheric conditions and physical hazards while they
work in confined spaces. However, even with enforced regulations and abundant best practice
methods, confined space fatalities are discouragingly high throughout the United States. To
change those numbers, employers need to provide the right training, tools, PPE, and establish a
well-rounded confined space program that includes a written protocol and an emergency plan.
Above all else, making an effort to establish a visual communication program for confined
spaces can help avoid accidental confined space entry. Visual communication has the full
potential to take out guesswork when it comes to confined space recognition. Signs, labels, and
floor tape are also an affordable option rather than dealing with thousands of dollars in lawsuits
and fines after workplace fatalities.

Citations:
U.S. Bureau of Labor Statistics. (2020, July 15). Fact sheet | Fatal occupational injuries Involving confined
Spaces | JULY 2020. U.S. Bureau of Labor Statistics. https://www.bls.gov/iif/oshwc/cfoi/confined-
spaces-2011-18.htm.

U.S Department of Labor. (n.d.). Summary of OSHA Permit-Required Confined Spaces Rule. Elaws - Osha
Confined Spaces Advisor. https://webapps.dol.gov/elaws/osha/confined/prcsgen.asp.

Koester, C. (2018, August 1). We must change the statistics of confined space injuries and fatalities.
Occupational Health & Safety. https://ohsonline.com/Articles/2018/08/01/We-Must-Change-the-
Statistics-of-Confined-Space-Injuries-and-Fatalities.aspx?Page=1.

1910.146 - Permit-required confined spaces. 1910.146 - Permit-required confined spaces | Occupational

Safety and Health Administration. (2011, December). https://www.osha.gov/laws- regs/
regulations/standardnumber/1910/1910.146.

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