Confined spaces in construction

Under 1926.1201(a), the confined spaces in construction standard sets forth requirements for practices and procedures to protect employees engaged in construction activities at a worksite with one or more confined spaces.

• The standard itself explains its scope: see 1926.1201(a).
• The note to paragraph (a) gives practical examples of locations that commonly qualify as confined spaces (for example: manholes, tanks, silos, HVAC ducts, sewers, drilled shafts, elevator pits). See 1926.1201 for the full list.

Under 1926.1201(b)(1), the confined spaces in construction standard does not apply to construction work regulated by Subpart P (Excavations).

• Where excavations are covered by Subpart P, employers follow the excavation requirements in 1926 Subpart P, not 1926.1201. See the explicit exception at 1926.1201(b)(1).
• If hazards overlap, ensure compliance with the specific Subpart P excavation rules that apply to the work being done.

Under 1926.1201(b)(2), the confined spaces in construction standard does not apply to construction work regulated by Subpart S (Underground Construction, Caissons, Cofferdams and Compressed Air).

• When work is subject to Subpart S, employers must follow those Subpart S requirements instead of 1926.1201; see the exception at 1926.1201(b)(2) and consult 1926 Subpart S for details.

Under 1926.1201(b)(3), the confined spaces in construction standard does not apply to construction work regulated by Subpart Y (Diving).

• Diving and related activities are excluded from 1926.1201 and are covered by 1926 Subpart Y instead; see the exception at 1926.1201(b)(3).

Under 1926.1201(c), you must comply with both the other OSHA standard that addresses the confined-space hazard and the applicable provisions of 1926.1201.

• The text states that where the standard applies and another OSHA provision addresses the same hazard, employers must meet both requirements: see 1926.1201(c).
• In practice, that means if you have a confined space that also involves asbestos, fall, or respiratory hazards, follow the confined-space rules and the specific standards for asbestos, fall protection, respiratory protection, etc., as applicable.

Under 1926.1201(a), manholes and HVAC ducts are explicitly listed as examples of locations where confined spaces may occur, so they fall within the kinds of spaces the standard covers.

• The standard’s note to paragraph (a) lists many examples, including manholes and HVAC ducts; see 1926.1201(a).
• Use the examples to help identify potential confined spaces on construction sites, then apply the procedures required by the standard and any other applicable OSHA requirements.

Under 1926.1201(c), if a confined space contains asbestos hazards you must comply with both the confined-spaces requirements and OSHA’s asbestos-in-construction requirements.

• OSHA has clarified that asbestos work in remediation and many construction contexts is covered by the construction asbestos standard [29 CFR 1926.1101]; see the asbestos interpretation at https://www.osha.gov/laws-regs/standardinterpretations/2024-11-14 and the requirement to follow multiple standards at 1926.1201(c).
• Practically, that means follow confined-space procedures and the respirator, monitoring, and work-practice requirements in [1926.1101] as applicable (see the interpretation at https://www.osha.gov/laws-regs/standardinterpretations/2024-11-14 for guidance).

Under 1926.1201(b)(1), yes—if the work is regulated by Subpart P (Excavations) you follow the Subpart P excavation rules rather than 1926.1201, even if the excavation otherwise meets a confined-space definition.

• The standard explicitly excludes construction work covered by 1926 Subpart P from 1926.1201; see 1926.1201(b)(1).
• Always review the specific excavation requirements in Subpart P to ensure you meet excavation-specific protections and procedures.

Under general OSHA practice, an employer must assess workplace hazards before selecting PPE for confined-space work, and document the assessment when PPE is required.

• OSHA’s interpretation on PPE hazard assessments explains that employers must evaluate the workplace to determine if hazards are present and prepare a written certification when PPE will be required (see the PPE hazard assessment interpretation at https://www.osha.gov/laws-regs/standardinterpretations/2024-03-28).
• In confined spaces, perform the hazard assessment before employees enter so you can select appropriate controls and PPE, and follow the hierarchy of controls rather than relying solely on PPE (see https://www.osha.gov/laws-regs/standardinterpretations/2024-03-28 and 1926.1201).

Under 1926.1201 and OSHA guidance, employers should not rely solely on PPE to control confined-space hazards and should use the hierarchy of controls where feasible.

• OSHA’s PPE interpretation emphasizes that employers should attempt engineering and administrative controls before relying on PPE, and that PPE selection must follow a proper hazard assessment (see https://www.osha.gov/laws-regs/standardinterpretations/2024-03-28).
• Also follow the applicable confined-space procedures in 1926.1201 and any other standards addressing hazards present in the space (see 1926.1201(c).

Under 1926.1201(c), you must comply with the confined-spaces requirements and any other OSHA standards that address fall or falling-object hazards, such as the scaffold and fall protection rules.

• OSHA’s scaffold/fall protection interpretation explains how falling-object and fall protection requirements apply to suspended work platforms and similar configurations; see the scaffold and fall protection interpretation at https://www.osha.gov/laws-regs/standardinterpretations/2023-12-05.
• Apply the confined-space procedures in 1926.1201 and also the relevant fall protection and falling-object provisions in the applicable Subparts (for example, Subpart L and Subpart M guidance referenced in the OSHA interpretation).

Under 1926.1201(a), elevator pits and similar equipment pits are included as examples of locations where confined spaces may occur.

• The note to paragraph (a) explicitly lists pits (such as elevator or escalator pits) among common confined-space locations; see 1926.1201(a).
• If your work requires entering these pits, follow the confined-space procedures in 1926.1201 and any other specific standards that apply.

Under 1926.1201(a), tanks and silos are listed as examples of locations where confined spaces may occur and the standard applies to construction activities involving those spaces.

• The standard’s note to paragraph (a) includes tanks and silos among typical confined-space examples; see 1926.1201(a).
• Treat those spaces as confined spaces for planning entry and controls and follow 1926.1201 plus any other applicable standards (for example, atmospheric monitoring or hazardous-material rules).

Under OSHA’s asbestos interpretation, remediation work involving asbestos-containing building materials in residences is covered by the construction asbestos standard [29 CFR 1926.1101], not the general industry asbestos standard.

• OSHA explained that most remediation activities involving asbestos in building repair or demolition fall under the construction asbestos rule; see the asbestos LOI at https://www.osha.gov/laws-regs/standardinterpretations/2024-11-14.
• If the residential work involves confined spaces, follow both the confined-space requirements in 1926.1201 and the applicable provisions of [1926.1101] as described in the interpretation (https://www.osha.gov/laws-regs/standardinterpretations/2024-11-14).

Under 1926.1201(c) and OSHA’s respirator guidance for asbestos, respirator selection must follow the applicable hazard-specific standard and its exposure-assessment requirements—employers must use the respirators required by that standard unless a proper negative exposure assessment allows use of other respirators per its rules.

• For asbestos in construction, OSHA’s respirator interpretation explains that Class I asbestos work requires specified supplied-air respirators or PAPRs depending on measured exposure and negative exposure assessments; see the respirator selection LOI at https://www.osha.gov/laws-regs/standardinterpretations/2024-01-04.
• Also comply with the confined-space provisions in 1926.1201 and the respirator and monitoring rules in the asbestos standard when both apply.

Under 1926.1201(a), step-up transformers, turbines, chillers and similar enclosed equipment are identified as examples of locations where confined spaces may occur, so employers should evaluate them as potential confined spaces.

• Those items are listed in the note to paragraph (a) as examples; see 1926.1201(a).
• If a space associated with that equipment meets your employer’s confined-space definition, apply the procedures required by 1926.1201 and any other applicable standards.

Under 1926.1201(c), when a confined space contains hazards covered by other OSHA standards, employers must comply with both the confined-spaces requirements and those other applicable standards.

• The standard explicitly requires compliance with multiple standards where applicable: see 1926.1201(c).
• For example, if the confined space has atmospheric hazards and asbestos, follow the confined-space provisions and the asbestos standard (see the asbestos LOI at https://www.osha.gov/laws-regs/standardinterpretations/2024-11-14) and other relevant standards (respiratory protection, PPE assessments, fall protection, etc.).

Under 1926.1201(a), concrete pier columns and precast concrete or other pre-formed manhole units are explicitly listed as examples of places where confined spaces may occur, so they should be treated as potential confined spaces.

• See the examples in the note to paragraph (a) at 1926.1201(a).
• Evaluate these structures before entry and apply the required confined-space procedures and any other relevant OSHA standards.

Under 1926.1201(c) and the explicit exceptions in paragraph (b), you must follow both standards when the confined space standard applies in addition to another standard that addresses the same hazard; however, if the work is expressly excluded by paragraph (b) because it is regulated by a Subpart (P, S, or Y), then you follow that Subpart instead.

• The standard states that where it applies and another standard addresses the hazard, employers must comply with both: see 1926.1201(c).
• Conversely, if the operation is specifically covered by Subpart P, S, or Y, the exceptions at 1926.1201(b) say 1926.1201 does not apply and you must follow the Subpart covering that work (see 1926 Subpart P, 1926 Subpart S, and 1926 Subpart Y).

Under 1926.1201(a), sewers, storm drains, and lift stations are explicitly included among the examples of locations where confined spaces may occur, so they are common confined-space types on construction sites.

• See the list of examples in the note to paragraph (a) at 1926.1201(a).
• Treat these areas as potential confined spaces and apply proper procedures and any additional applicable standards (for example, hazardous-atmosphere monitoring and PPE).

Under 1926.1201 and OSHA’s general guidance on hazard assessment and coordination, employers must ensure hazards are identified and that all contractors coordinate controls so every employer and employee on site is protected.

• The confined-spaces standard requires procedures to protect employees in construction confined spaces; see 1926.1201.
• OSHA’s PPE hazard assessment interpretation also emphasizes the employer’s responsibility to evaluate hazards and implement controls; see https://www.osha.gov/laws-regs/standardinterpretations/2024-03-28. Coordinate hazard assessments and control measures with other contractors so responsibilities and protections are clear.