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OSHA has specific requirements for manholes and the removal of manhole covers. Even before a manhole cover is removed, these relevant OSHA requirements come in to play. What are these manhole entry requirements? How does one comply with them?
OSHA section 1910.146 (General Industry) and 1926.953 (Construction) cover the safety requirements for confined space manholes. As you will see momentarily, we are citing both of these standards because the General Industry standard is vague on one important point.
The 1910.146 General Industry confined space standard states that, "Any conditions making it unsafe to remove an entrance cover shall be eliminated before the cover is removed." This is vague. The standard doesn't go on to define "unsafe" or give examples. Is it talking about fall hazards or atmospheric hazards, or both?
However, in the 1926.953 Construction Standard for confined space, OSHA is far more specific. OSHA states that before a manhole cover can be removed, even for routine maintenance, three potential hazards need evaluation where relevant. The three are (1) atmospheric pressure build up, (2) temperature build up, or (3) hazardous atmosphere.
So if we take the Construction Standard as defining what "unsafe" means, then for most of our customers, entry into street manholes is the most likely hazard. This hazard is checked for with a Confined Space 4-Gas Detector. Atmospheric pressure build up or temperature build up are more common in manholes with sealed entry ways in vessels used to store liquids or gases.
Even before the manhole is opened, it is your responsibility to determine if any of these potential hazards are present and have a plan to mitigate them. Note that not all hazards can me mitigated before removing the manhole cover. For example, the presence of a hazardous atmosphere will required the introduction of forced air ventilation.
OSHA requires that "a railing, temporary cover, or other barrier" be erected around the manhole immediately after the manhole is safely removed. This is to prevent accidental falls into the space and to protect employees who enter the space from objects falling on them from above.
OSHA is not clear on what constitutes an "other barrier". Generally, either a manhole guard rail or even a confined space tripod system are adequate. Even pennant flagging can be used to cordon off the manhole entry way in most cases.
OSHA also states that: "Before an employee enters the space, the internal atmosphere shall be tested, with a calibrated direct-reading instrument, for oxygen content, for flammable gases and vapors, and for potential toxic air contaminants, in that order. " In other words, as stated earlier, atmospheric testing with a confined space gas meter is required before entry is made.
So here is the gist: before opening a manhole, evaluate for potential hazards, including a hazardous atmosphere. We are recommending this based on the Construction Standard because the General Industry standard is too vague.
After the manhole cover is removed, be sure to erect some sort of barrier to demarcate the manhole. It goes without saying that falling into a manhole could result in serious injury or even be fatal. And, again, before the plane of a manhole is broken by a human being, the atmosphere is to be tested with a 4-gas personal confined space meter.
These requirements are simple and easy to follow. They represent OSHA's best practices for opening up manholes.
One final and very important point: if entry into a manhole is done after the above guidelines are followed, OSHA's confined space standard 1910.126 is applicable. Before entry can be made, all of 1910.126's requirements must be understood and acted upon. This includes providing fall protection and rescue, continual gas detection, and possible force air ventilation. If you have an questions or need assistance, don't hesitate to reach out to us.