01/08/2004

Confined Spaces in Funeral Homes and What to Do if You Have One

by: Kathleen Murdock, Industrial Hygienist, Safex, Inc.

Many workplaces contain spaces that the employees may consider "confined," such as small conference rooms or work areas. However, many of these types of spaces are not considered "confined spaces" by the Occupational Safety and Health Administration (OSHA). In order to be considered a "confined space" per OSHA, a space must:

1. Be large enough for a person to enter and perform work;
2. Have limited or restricted means of entry and/or exit; and
3. Not be designed for continuous human occupancy.
Examples of confined spaces include storage tanks, ventilation ducts and wells.
A permit required confined space is a confined space that has one or more of the following characteristics:

1. Contains or has a potential to contain a hazardous atmosphere;
2. Contains a material that has the potential for engulfing an entrant;
3. Has an internal configuration such that an entrant could be trapped or asphyxiated by inwardly converging walls or by a floor which slopes downward and tapers to a smaller cross-section; or
4. Contains any other recognized serious safety or health hazard.

Examples of spaces in a funeral home that may be permit-required confined spaces include crematory retorts and remains refrigerators. Some hazards that may be encountered in these spaces include:

Flammable Atmospheres
A potential flammable atmosphere can arise from oxygen-enriched atmospheres, vaporization of flammable liquids, byproducts of work, chemical reactions and concentrations of combustible dusts. A gas leak in a crematory retort, for example, could produce a flammable atmosphere.

Toxic Atmospheres
Toxic substances include gases, vapors, and airborne dust. Exposure to toxic substances can occur in a funeral home if employees use chemicals or cleaning solutions in a confined space.

Asphyxiating Atmospheres
The normal atmosphere is composed of approximately 20.9% oxygen, 78.1% nitrogen, and 1% argon with small amounts of various other gases. Reduction of oxygen in a confined space is a suffocation hazard. A gas line in a crematory retort that is leaking or was not shut off can cause excess gas to build up and displace the oxygen. Asphyxiation can also occur if an employee is trapped in an airtight space, such as a remains refrigerator, and consumes all the available oxygen.

Mechanical
The unexpected activation of electrical or mechanical equipment can cause injury. Each piece of equipment should be locked out before workers enter a confined space to prevent accidental start-up. A crematory retort can be inadvertently activated while an employee is inside the retort if it is not shutdown and locked out properly.

Physical
These hazards include thermal effects (heat and cold), noise, vibration, radiation, and fatigue while working in a confined space. For example, burns may occur if an employee opens a retort door before the end of the cool down process, and an employee may suffer hypothermia if they are trapped in a remains refrigerator.
If you have a confined space in your funeral home you must do the following:
* Identify it with a label or sign.
* Develop a written confined space entry program. See your OFDA OSHA Compliance Manual for assistance.
* Provide training to employees who enter the space(s).

If you have a permit required confined space in your funeral home, you must perform the three activities listed above and you must develop and use a permit system. A confined space permit identifies and evaluates potential hazards; identifies the individuals who are involved in the entry; describes rescue procedures; designates personal protective equipment needed for entry into the space; and details post-entry procedures. The permit must be completed prior to entry and it is good for only the duration of the task for a maximum of one work shift. Permits must be filed internally and maintained by the employer for a period of one year.

Some permit required confined spaces may be reclassified to either an alternate space or a non-permit required confined space. Whether they can be reclassified depends upon the hazards of the space and how those hazards will be controlled. For example, a permit required confined space might be considered an alternate space if the only hazard posed by the space is an actual or potential hazardous atmosphere. Also, a permit required confined space may be reclassified as non-permit if the permit space does not pose any atmospheric hazard and all other hazards (electrical, mechanical, etc.) are eliminated without entry into the space.

If you have any questions about confined spaces or any other environmental, health or safety topic, please call us toll-free, at 866-364-5342.