#54:How Confined Space Reclassification Saves Money + How To Reclassify Confined Spaces

The episode opens with an acknowledgment of the contentious nature of confined space reclassification, noting its status as a highly debated topic within safety circles.
The host invites viewers to engage in a discussion, emphasizing the importance of exploring different perspectives and considerations surrounding this issue.
Key Points:

Motivations for Reclassification:
The episode highlights common motivations for reclassification, such as avoiding extensive training, labor issues, and the need for permits and rescue procedures.
The allure of simplifying processes through reclassification is discussed, particularly in industries where confined spaces are prevalent.

Challenges and Limitations:
Drawing from extensive industry experience, the host outlines the challenges and limitations associated with reclassification.
The episode emphasizes the scarcity of spaces suitable for reclassification, particularly in industries like food and meat manufacturing.

Risk Assessment and Control:
The importance of conducting thorough risk assessments before considering reclassification is underscored.
Viewers are reminded that simply controlling hazards is not sufficient for reclassification; hazards must be permanently eliminated to justify a change in classification.

Introduction of New Hazards:
Scenarios where new hazards may emerge post-reclassification are explored, prompting a reevaluation of classification status.
Examples such as the introduction of chemicals or welding activities are provided to illustrate potential risks.

Labor Issues and Training:
The episode addresses labor-related motivations for reclassification, highlighting the tendency for organizations to favor reclassification due to perceived cost savings.
However, the importance of prioritizing safety over convenience is emphasized, cautioning against compromising safety protocols.

Emergency Response Considerations:
The necessity of emergency response preparedness in reclassified spaces is stressed, particularly regarding the risks associated with employees working alone.
Robust safety protocols and communication mechanisms are advocated to ensure prompt response to emergencies.

Regulatory Compliance:
Viewers are reminded of the importance of regulatory compliance, with a focus on how emergency responders may interpret reclassified spaces.
The episode underscores the obligation to provide adequate training and safety measures, irrespective of reclassification status.

Keywords:
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#ergonomics 
#fallprotection 
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#OSHA
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#contractors 
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#reclassify  
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Transcript

Reclassification of Confined Spaces

Speaker 1 0:00

Confined space reclassification probably one of the most highly debated topics.

Speaker 2 0:04

Let's have some discussion.

Speaker 1 0:05

Let's talk, let's do it. All right, here we go.

Speaker 2 0:15

Reclassification of confined space. What does everybody say to me? I locked it out, I'm done, I don't have to do any kind of permit. No kind of rescue, no kind of procedures, no kind of anything. No kind of training yeah kind of procedures. No kind of anything. No kind of training.

Speaker 1 0:27

Yeah, so all that just goes off. One word Enormous benefit, like Joe's saying, to why there is a huge push to reclassify a space and typically the push is coming from folks who don't have a lot of confined space background, and part of it's because, yeah, we don't have to do the training, we don't have to have the labor issues of I need coverage.

Speaker 2 0:49

I'm doing this on the weekend, I don't need to buy no gear.

Speaker 1 0:51

Now I need to pay overtime because that's when we do this project. Yeah, I don't need to buy equipment or gear or meters or entry or rescue stuff I don't need to have.

Speaker 2 1:04

then if I do that, this is one magic piece of paper, and the frequency issue.

Speaker 1 1:08

So if I'm doing this hourly, daily, you know nightly, whatever that looks like, I don't need to fill out anything if I can call it reclassified. So there is a huge push for why this is faster and easier for the business if we can just reclassify it American Fine Space Training Company, and for 23 years we've done thousands of entries and we hardly ever reclassify.

Speaker 1 1:32

I'm going to tell you right now, our main bread and butter that we do is food manufacturing, meat manufacturing, poultry, all that stuff, real limited spaces you can reclassify in those locations so you know mills and farms and everything that kind of supports those we go to. All of that too, truck washes trailers, and I mean very limited in my career in the last 17 years of spaces that we have found that we can truly, genuinely reclassify. So that's first, right off the bat. Just know that going in.

Speaker 2 2:06

So I go to a management meeting. Jen says to me I want to reclassify and she tells me we're going to save money, we're going to do this as a manager. Sounds like a great idea.

Speaker 1 2:15

Sounds brilliant.

Speaker 2 2:17

Yeah, you save this money. And now Jen's going to get a bonus. Oh, yeah, All this stuff because she made cost savings. Which risk is convenient? We may hurt somebody, but the point is you didn't cost those.

Speaker 1 2:27

We're not going to talk about that.

Speaker 2 2:28

So that's part of the thing I think about too. You've got to watch the presentations of what people do.

Speaker 1 2:32

That sounds too good to be true, you guys.

Speaker 2 2:34

I've got a space and I've decided that it's confined space. I've done assessments. There's other episodes. We had assessments procedures, we've done all that stuff.

Speaker 1 2:42

Yep, we did it.

Speaker 2 2:43

Now I'm into, I want to reclassify this space. So what are we going to do?

Speaker 1 2:47

The argument is a lot of times, when I do my assessment, I'm eliminating or controlling. I'm coming up with elimination or control of hazards for the things that I listed as hazards on my assessment. Right, and so the push is always well then why would we ever have a confined space permit? If that's true, Because in order for me to even go in.

Speaker 1 3:06

I have to eliminate or control. I'll tell you a situation where a regulatory agency and one of the states said I see that your pre-entry readings on your meter is not fresh air. You shouldn't let them go in because you didn't eliminate or control the air hazards. Kind of a sound argument, I mean. That's true. You have to eliminate or control the hazards in order to go in. That doesn't mean that that now also allows you to reclassify, that's just to go in. You have to permanently eliminate those hazards to reclassify.

Speaker 2 3:35

Okay, so now we've decided we're going to reclassify, so we're going to permanently eliminate the hazard. Yep, are we going to double block and bleed or lock out anything?

Speaker 1 3:42

Nah, that's a control.

Speaker 2 3:43

Okay, how about if I disconnect the airlines or disconnect CO2 lines?

Speaker 1 3:47

Is that well, did I do the right ones?

Speaker 2 3:49

Oh, that's a good question. I don't know how am I?

Speaker 1 3:52

going to validate that. One of the things that we want to watch is that if something's dependent on a human being not making an error, then I don't consider that a permanent elimination. Okay, because I've got a lot of turnover and new employees happening. So if they are tired, or it's a long shift, or they're not on their A game, or they're just new and they don't know and they misread something.

Speaker 2 4:21

I don't want to be dependent on they knew perfectly what's going on to base whether my reclassification was okay. If we decide to use it, we really need to only have like three people that really know what's going on, that really know that space to say this program, because that's the only way they can reclassify it.

Speaker 1 4:30

That's. I would definitely tighten that down.

Speaker 2 4:32

It's got to be small and controlled.

Speaker 1 4:33

Very tight group that's highly trained to be, able to make those decisions and they have to understand that equipment very well.

Speaker 2 4:41

That makes sense to me, because we've got to be able to say this is what we're going to do. Okay, what if I'm going to introduce a new hazard, like maybe I introduce sanitation chemicals?

Speaker 1 4:50

Well, that's a hazard and I didn't eliminate or control it.

Speaker 2 4:53

You've already reclassified it because you didn't have a problem earlier.

Speaker 1 4:55

Right, so now we're back under a permit.

Speaker 2 4:58

Oh, so now I go back from reclassification back to a permit.

Speaker 1 5:00

Yep, or welding. That's a good point, that's another one and the reason we're bringing that up. Everybody is because we've seen that where they reclassify and then they do all this other work, but you can't, yeah, or like we reclassified it because we clean it every night.

Speaker 2 5:18

What? There's no air hazard until I put all the chemical in there.

Speaker 1 5:20

That's right, or burn or anything laying in the chemical that's burning me or whatever. Yeah, that's perfect.

Speaker 2 5:25

So that's another thing. So you may want to reclassify, but you still have to consider is there hazards going to be be going?

Speaker 1 5:32

into the space to do so. That's the biggest thing. So throwing this out there disclaimer yes, we train in confined space. Yes, this is one of our core subjects. Take this how you want, though You've got to do thorough risk assessment. So nothing we say is just the end. All You've got to assess and evaluate your site. So this is just our opinion.

Speaker 2 5:50

Some people say I fill out the reclassification form because it's easier than the permit. I will tell you I've done hundreds and hundreds and hundreds of permits and by the time I've timed people to fill out the permit and time to fill out the classification form.

Speaker 1 6:01

It's about the same yeah, it has pretty much the same data on it, so you're like maybe just, maybe just I think the reason people aren't classified sometimes is they don't want the labor.

Speaker 2 6:10

Yeah, it's, it's a labor issue.

Speaker 1 6:11

I don't have to have an attendant there. I don't want the labor. Yeah, it's a labor issue. I don't have to have an attendant there. I don't have to have a rescue team on standby. I don't have to do the training.

Speaker 2 6:17

I don't have to have the overtime. I would never send someone into a space, just go have lunch, and that's kind of what we're talking about. I would never do that and I come back and say, hey, jan, how you doing that would be weird. I'd be like I'm going to stay here, even if it's not required, because maybe I need to get a tool. There's still a buddy system thing that goes on. So we've talked about that too, that you may reclassify space.

Speaker 1 6:42

How do you know if somebody's having a problem in there?

Speaker 2 6:44

Whatever, it is they're working it. Because when you start talking reclassification, Rethinkifying, working alone protocols almost in my world could be space, that's kind of remote and you can't really see them, or no one's around, you can't see them, you can't hear them.

Speaker 1 6:58

Potentially no one knows that they're having an issue If they can't get to their radio or something went on. That person could be in that space for hours and we don't have any idea.

Speaker 2 7:08

So, yes, you can reclassify. Yes, there's a lot of things you may or may not be able to do. Very tight parameters. But what about fall? Now I'm going to go 15 feet down. I'm wearing a tripod and a winch. Why can't I reclassify that?

Speaker 1 7:20

Well, I guess it goes back to my number. One thing would be how did we permanently eliminate the fall hazard?

Speaker 2 7:26

Well eliminate by hooking up to a harness Well that's a control and with a hook that's a control okay still a control.

Speaker 1 7:36

Just climbing down a flat ladder using a ladder system?

Speaker 2 7:38

that's still a control and for those out there is because we've worked events and and you have to be able to winch the person out quickly and it goes back to again.

Speaker 1 7:46

You can call it whatever you want. You can call it. It's not a space, you can call it non-permit, you can call it reclassified and call whatever you want. But if your fire department and your EMTs will not go in because they called a confined space, I would just call it a confined space. We still owe that employee the right to get out, and so if we're going to require our employees to go in and do tasks, potentially get injured, we want to make sure that we're giving them the right training on the job tasks we expect them to do. So that's the biggest thing. So if you've got more questions, you can reference episode number 12 and 13. Otherwise, allensafetycoachingcom, there's an entire confined space module. It walks you through reclassification along with everything else, including how to do assessments, what should be in your program, how you pick a trainer, what should you be training on and all the different roles we are it.

Speaker 2 8:30

We're our only sponsor. Yes, that's it.

Speaker 1 8:32

So that's a really economical way If you're just dipping your toe into the confined space.

Speaker 2 8:37

Subject matter but you're excited about it.

Speaker 1 8:40

You can get a lot of education from there without having to feel like you're just blowing your budget to pieces. Otherwise, if you're like you know what we would really like to have somebody come walk through and do some assessments. Talk to us about this. Give us some assessments. Talk to us about this. Give us some training. Alan-safetycom, that's where you can find all of the services we do in regards to confined space determination, doing assessments and doing confined space training. That's our in-person services.

Speaker 2 9:04

If you go to training, you get one of these stand-up.

Safety Company Social Media Presence

Speaker 1 9:07

Yeah, you can also check out you can check out some of our merch that we give away for free if you attend a training class. If there's a topic you want us to cover, if you've got some other random questions, reach out. Alan safety llc is our handle on tiktok. We've got facebook. We've got instagram. Otherwise, joe and I are both on linkedin as well, so you can catch us at jen allen or joe allen on linkedin as well thank you again.

Speaker 1 9:27

Have a great week everybody. Thank you for listening to Safe, efficient, profitable a worker safety podcast. If you're looking for more in-depth discussions or step-by-step solutions on all of the different safety and regulatory topics, please visit us at wwwallensafetycoachingcom for web-based virtual coaching and training, or at wwwallensafetycom to book our team for onsite services, training sessions to order merchandise, to learn more about our team and what services. Thank you so much for your support. Thank you.