Of the four classifications under the proposed change, the Continuous System-Permit-Required Confined Space designation is the most regulated. It was developed especially for sewer systems. Such spaces are defined as “a confined space that is a part of, and contiguous with, a larger confined space … that the employer cannot isolate from the larger confined space.”

OSHA is emphasizing sewers because — as confined spaces — they deserve special attention from other confined spaces covered by the general industry standard. The agency acknowledges that special precautions are necessary in sewer systems to ensure adequate protection of employees.

For example, the proposed standard would mandate an “early-warning requirement for upstream hazards in sewer-type spaces.” Such systems could be as simple as radio communication among employees, but they also could be alarms activated by remote sensors.

“Public works departments may have to purchase some equipment under this proposal,” Brown says. “There's no early-warning requirement for upstream hazards in the current general industry standard.”

Because the proposed standard doesn't specify the type of early-warning system that would be required, departments may satisfy the requirement with simple radio communications. But Brown advises public works directors to be careful: “Many radios don't work as well at certain depths, so until they can find the type of automated system they can afford, they will have to test their current communications devices in all kinds of circumstances before work could commence.”

Although public works departments should have most of the required equipment, Brown advises that they conduct an inventory to ensure that they would be covered if the proposed changes are implemented.

“They should have enough retrieval equipment, monitors, respirators, and communications equipment already,” she says. “They shouldn't buy inexpensive one-time-use equipment meant for emergency extraction if they are going to be using it regularly. They also should consider shock-resistant, damp-resistant monitors and communication devices. It could be a substantial investment if they don't already have those.”

Among the estimated $77 million cost of compliance is $6 million to isolate hazards and provide sufficient ventilation; $11.7 million for atmospheric monitoring; $14 million to provide an attendant or someone to monitor entrance and exit from the confined spaces; $10 million to provide a complete respiratory-protection program; and $9.6 million to provide rescue capability.


In Fernley, Nev., Lowell Patton intends to incorporate the language of the proposed change into the city's training ahead of final approval “since it just makes sense” even though the state wouldn't incorporate the change into its policy until it is adopted at the federal level.

Currently, Fernley's Operations and Maintenance Division of the Public Works Department addresses existing manholes as confined spaces, but the department's Construction Services Division, which consists of the city engineer, quality assurance, and capital projects offices, will soon adopt the same policy.