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Home | Spray Foam 411 | New OSHA Rule And Its Impact On Spray Foam Insulation Safety

New OSHA Rule And Its Impact On Spray Foam Insulation Safety

It’s a common sight in the spray foam industry: an applicator getting into an attic or crawl space to bolster a home’s insulation. While accessing these confined spaces, crewmembers are exposed to potential risks that could lead to workplace hazards, including low oxygen, fumes, and flash fires. To raise awareness and combat these risks, the Occupational Safety and Health Administration (OSHA) has developed a new rule revising a standard that protects workers in confined spaces, ensuring that safety is a priority while spraying foam inside a tight spot. OSHA’s new rule, the 29 CFR 1926 Subpart AA, will require documented safety plans purveyed to SPF contractors. The new rule will also require, on a case-by-case basis, the stationing of an additional crewmember outside the space to grant access.

“This rule will save lives of construction workers,” said Assistant Secretary of Labor for Occupational Safety and Health Dr. David Michaels in an announcement of the new provisions. “Unlike most general industry worksites, construction sites are continually evolving, with the number and characteristics of confined spaces changing as work progresses. This rule emphasizes training, continuous worksite evaluation and communication requirements to further protect workers’ safety and health.”


To protect crewmembers working in confined spaces from harm’s way, a safety plan that identifies the circumstances and solutions of the potential risks that could occur should be readily available, in accordance to the OSHA standard.

The OSHA rule will apply to sites posing potential hazards that meet all three of the following criteria

  • A space that is big enough to enter
  • A space that is not utilized for regular and continuous occupancy
  • A space that is difficult to exit

Furthermore, a space may also be deemed a permit-required confined space if it has any of the following characteristics:

  • A hazardous atmosphere
  • The potential for suffocation
  • A layout that might trap a worker through converging walls or a sloped floor
  • Any other serious safety or health hazard aside from attics and crawlspaces, some other examples of confined spaces are manholes, tanks, and sewers


Under the new rule, permits to access specific confined spaces on a particular job are granted by the employers of whatever crews that will require access; they are referred to as entry employers. There are safe entry procedures requiring planning and preparation by the contractor ahead of time before crewmembers are sent in to install foam.


Prior to sending in their crew into these sites, a qualified person ranging from the SPF project manager to the general contractor will evaluate the confined space by identifying if the hazards in the surrounding working conditions are unsanitary or dangerous.


The entry employer must post signs that indicate crewmembers aware of the existence, location, and danger of each confined space. For example, a sign that reads “DANGER: PERMIT–REQUIRED CONFINED SPACE, DO NOT ENTER” satisfies the requirement.


The entry employer is responsible for developing and posting permits. These permits will list the required entry conditions and the equipment required to enter the space. A crewmember must function as an entry supervisor to track whoever is working in the space at any given time.


The employer of the SPF contracting company is required to provide a written program conforming to OSHA’s new rule for confined spaces. The program stipulates what the entry employer will do to protect their applicators and attendants from the potential hazards of these confined spaces. The program should include:

  • The site evaluation for confined spaces and permit-required confined spaces
  • The steps taken to prevent unauthorized access of permit spaces
  • The posting of all permit spaces

Also, the program must include a thorough training on the OSHA standard and its revised procedures on how to prevent and eliminate hazards to all the SPF company’s crewmembers exposed to them. Specifically, the training provided must cover the existence, location, and dangers posed by each permit-required confined space.


As of August 3, 2015, OSHA’s 29 CFR 1926 Subpart AA rule is in full effect. Having been long applied to confined spaces like tunnels and manholes, the recent revision specifies crawlspaces and attics, which now impacts spray polyurethane foam installers directly. In order to stay safe and maintain building code compliance, spray foam contractors must adhere to OSHA’s new rule to perform their routine application tasks without incident. OSHA estimates the rule will prevent nearly 800 construction-related serious injuries per year.

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