Ask the Expert, Personnel Safety, Q&A

Q&A: Lighting in Confined Spaces

Recently, a subscriber asked the following question:

Is there an OSHA requirement that if lighting and power requirements cannot be met by the use of battery lights, reduced voltage lighting at a maximum of 12 volts must be used?

“Higher voltages may be used only with a ground fault circuit interrupter (GFCI). The ground fault circuit interrupter, transformer and disconnects must be located outside of the confined space.” I cannot find where this is required in OSHA except in regards to portable lighting in 1926.405. Is this a requirement under other standards? Is this just best practice? Is this more of something better covered under an electrical safety policy as opposed to confined space?

This was our response:

OSHA’s confined space rule for general industry 29 CFR 1910.146 and construction 1926.1203 do not prescribe the level of detail for lighting requirements described in your policy, because it is up to the employer to evaluate the space to determine the specific hazards and establish the specific controls to protect workers and rescue personnel from those hazards. If the atmospheric or other hazards in your particular space require the electrical controls your policy states in order to adequately protect entrants, then they must be included in your written permit. If the hazards in a particular space do not require that level of electrical hazard control to prevent injury, then those controls may not be appropriate for that space.

The policy you provided is a best practice from an OSHA compliance perspective. OSHA offers a sample written Permit-required Confined Space (PRCS) program that includes the following statement:

“When natural lighting is not sufficient, additional lighting will be provided. It must not exceed 12 volts in damp conditions and will be equipped with a ground fault circuit interrupter. In hazardous atmospheres, explosion-proof lighting will be required.”

Perhaps your policy was copied from OSHA’s sample and then modified. You can download the OSHA sample plan at https://www.osha.gov/dte/grant_materials/fy09/sh-18796-09/confinedspace.pdf

As you note, the electrical safety rule for general use in construction applies to temporary wiring and portable electric lighting, and 120-volt lights may be used if protected by a ground-fault circuit interrupter.

It also states that temporary lighting may be used in explosive atmospheres as long as it meets all the requirements stated in the National Electrical Code (NEC) NFPA 70. Check the NEC standard for more guidance. BLR cannot provide specific guidance on NFPA 70 because we do not have copyright permission from NFPA to excerpt or interpret the standard.

The policy may be appropriate for the specific area or activity where it prevents exposure to hazards it addresses. It may be appropriate for an electrical safety policy if it is meant to control specific hazards in areas other than a confined space.