Understanding OSHA’s Updated Rules on Confined Spaces
The Spray Polyurethane Foam Alliance (SPFA) recently alerted all industries
that OSHA has published a new fact sheet for Confined Spaces in Residential
Construction (OSHA FS-3914) that affects any business that employs workers
that regularly enter attics, crawlspaces and basements.
The good news is that, unlike last year, the new document designates that
most attics and crawlspaces ARE NOT likely to be considered permit-required
confined spaces if all hazards are properly mitigated. This could eliminate the need for atmospheric testing in every attic and
Here’s a quick overview of how each type of space most commonly used
by spray foam insulation contractors is regarded under the new OSHA standard:
Attics are generally not considered confined spaces if entry/exit are not
limited or restricted. For example, most pulldown stairs that do not require
hand-over-hand ascent/descent are considered to not impede egress. In
cases where an attic is considered a confined space, it typically would
still likely not be permit-required because potential hazards are not present.
However, in extreme heat, an attic may be considered a serious physical
hazard and would be considered a permit-required confined space, due to
the potential heat exhaustion that impedes the entrant’s ability
to exit the attic independently. OSHA has not quantified how hot it must
be to trigger the permit-required confined spaces requirements.
If a residential basement was designed for continuous occupancy by a homeowner
(e.g. has permanent stairs, a walk-out entry/exit or an egress window),
it is not considered a confined space.
Unless a physical hazard, such as exposed active electrical wires, are
present, residential crawl spaces will not typically trigger the majority
of the requirements of the standard.
Additionally, the OSHA Fact Sheet indicated that it is the Entry Employers’
(any employer who decides that an employee it directs will enter a permit-required
confined space) obligation to provide information, personal protective
equipment and training to its employees, as well as establish a system
for handling written entry permits and rescuing employees from permit-required
Confined Space rules can be confusing and open to different interpretations,
but, the bottom line is to protect employees from unforeseen hazards.
Whether in the field or back at the home office, take the time to train
employees on types of confined spaces, best application techniques, proper
PPE,and document a pre-job assessment.
For additional information see
OSHA’s Confined Spaces in Construction Fact Sheet at