We have auditors that assist homeowners in working with utilities to upgrade their homes to be more energy efficient. Our auditors climb into homeowners attics to inspect insulation and take pictures of upgrades. Does climbing into attics fall under OSHA confined space regs? If so, what section refers to this type of activity? We have this being done in multiple states, not just Pennsylvania.
The confined spaces in general industry standards (29 CFR 1910.146) address attics in this OSHA letter of interpretation, stating that if the attic space in your building fits the definition of a confined space, then attics are confined spaces. But, attic spaces that are determined to be confined spaces should generally fall into the category of non-permit confined spaces because they have either natural or mechanical ventilation that would prevent accumulation of hazardous atmosphere and because other hazards would not normally be present.
However, under OSHA’s new confined spaces in construction standards (29 CFR 1926 Subpart AA), attics can be considered confined spaces and permit-required confined spaces. According to OSHA, attics present hazards such as:
- Atmospheric hazards (e.g., poor ventilation)
- Heat stress
- Mechanical hazards (e.g., attic ventilators, whole house fans)
- Electrical hazards (e.g., damaged or frayed wires, open electrical boxes)
- Slip, trip, and fall hazards
- Asbestos insulation
The standards go into effect August 3, 2015.
States without OSHA-approved state-plans are covered by the federal standards. State-plan states must adopt standards comparable to 29 CFR 1926 Subpart AA within 6 months of publication of the final rule in the Federal Register (May 4, 2015).