Electrical Work in Confined Space
Electrical Work in Confined Space
Electrical Work in Confined Space
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18.40
Electrical Work
& Confined Space
Under WAC 296-45
& 296-809
Date Issued: September 18, 2006
I.
Background
In May of 2004, the state of Washington adopted the clear rule writing version of the
confined space standard, WAC 296-809, itself a re-write of the 1995 standard, which
substantially changed the definition of confined space. The 1995 revision also made
other significant changes, including the addition of a new requirement for permits in
certain confined spaces where hazards could not be eliminated.
Chapter 296-45 WAC (Safety Standards -- Electrical Workers) also contains some
specific enclosed space practices in WAC 296-45-205 for the coverage of electrical
construction work with regard to power distribution and transmission. In several areas
this standard exceeds the general standard or includes special provisions.
II.
WRD 18.40
III.
Page 2 of 3
Interpretive Guidance
Inspectors and consultants must cite code violations of Chapter 296-45 WAC and
Chapter 296-809 WAC, in reference to all confined space hazards, applying the standard
appropriate to the hazard being cited.
A.
What are the requirements for underground and underground residential
distribution electrical work?
WAC 296-45-205(6) makes it clear that all provisions of WAC 296-809, apply whenever
employees enter an enclosed space while it contains a hazardous atmosphere. For such
spaces, any violations must be cited using the specific provisions in WAC 296-809.
For other spaces where a hazard may exist, WAC 296-45-205(7) requires that for
underground and underground residential distribution electrical work an attendant
("watchman") shall be kept at the surface. For such spaces, DOSH staff must cite
violations for the lack of an attendant or for a failure to ensure that the attendant performs
properly using WAC 296-45-205(7). Violations related to attendant duties can be
supplemented by reference to the attendant duties in Chapter 296-809, but the
requirements of Chapter 296-45 must provide the basis for the citation.
B.
What are the requirements while work is performed on energized wires, cables, or
appliances?
WAC 296-45-65037(10) and WAC 296-45-65038(4)(a) require two or more competent
or qualified persons to be in the same manhole or subway while performing work on any
energized wire, electrical cable or electrical appliance carrying more than 300 volts of
electricity for underground and underground residential distribution.
C.
How should confined space requirements be applied to electrical workers where
electrical hazards are present?
Employers should be encouraged to eliminate all safety and health hazards for their
confined space work. However, at times the electrical systems will be energized in the
confined space due to the requirements of the electrical work in question.
a.
DOSH staff must not issue violations of Chapter 296-809 WAC, for the
failure of electrical lockout-tagout during electrical work by the electrical
contractor or utility. However, the appropriate violation under Chapter
296-809 WAC, must be issued for any other safety and health hazards not
eliminated or otherwise controlled so as to not pose a hazard to the
electrical workers.
b.
WRD 18.40
Page 3 of 3
D.
Are employers subject to Chapter 296-45 WAC required to use forced ventilation
and atmospheric testing when working underground?
Chapter 296-45-205(9) WAC allows forced ventilation or oxygen deficient testing prior
to entry into underground manholes or unvented vaults and during entry work.
Therefore, DOSH staff must not cite violations of Chapter 296-809 WAC, for a failure to
perform both tasks.
Approved: ______________________________________
Stephen M. Cant, CIH, Assistant Director
Department of Labor and Industries
Division of Occupational Safety and Health
For further information about this or other WISHA Regional Directives, you may contact
DOSH Compliance Operations at P.O. Box 44650, Olympia, WA 98504-4650 -- or by telephone at (360) 902-5460.
You also may review policy information on the DOSH website (http://www.lni.wa.gov/Safety/).