Access and Egress Requirements in a Trench Excavation. Why?

First, here is the regulation found in 1926.651 (c)(2).

Means of egress from trench excavations. A stairway, ladder, ramp or other safe means of egress shall be located in trench excavations that are 4 feet (1.22 m) or more in depth so as to require no more than 25 feet (7.62 m) of lateral travel for employees.

The federal register offers the reason why access and egress would be required within 25 feet of employees in a trench excavation, but is not required to be within 25 feet of employees in non-trench excavations. The federal register commentary on the subject occurs in at least four different paragraphs.

On page 45895 of the federal register (in the introduction section) the topic comes up because they are explaining how the newly revised standard makes a clear distinction between those excavations which are trenches and those excavations which are not trenches.

“This Final Rule resolves the uncertainty left by these decisions and by the ambiguous language of the existing standards by establishing one set of requirements which are applicable to all excavations, including trenches. Where there are requirements intended to be applicable only to trenches—such as the requirement that ladders or equivalent means of egress be provided every 25 feet horizontally—the Final Rule makes it clear that the requirement applies only to those excavations which are also trenches (see 1926.651(c)(2)).”

The issue surfaces again on page 45913 where there is commentary regarding the definition of a trench found in 1926.650.

“The proposal and the Final Rule are formatted to indicate that most of the provisions of the standards apply to all types of excavations. However, some of the provisions of subpart P apply only to excavations that are trenches. For example, 1926.651(c)(2) sets forth special requirements for means of access and egress in trenches, and 1926.652(c)(1) sets forth the option of using Appendices A and C for determining the configuration of timber shoring in trenches. Those provisions in the proposal, and now the Final Rule, that apply only to trenches are clearly indicated by use of the word “trench” within the provision.”

There is additional information on page 45918 where there is a discussion pertaining to the access/egress regulations that are in 1926.651 (c)(2).

“After careful consideration of the record, OSHA has determined that a safe means of egress every 25 feet is necessary in trench excavations, but not in every excavation. The Agency notes that egress during an emergency in a large excavation does not pose the same problem as it would in the confines of a trench excavation.”

On the same page there is more.

“OSHA points out that this requirement is intended to provide employees working down in a trench with a safe means of escape from the trench in case of an emergency.”

The author’s take-away from this commentary is that since a trench (by definition) is deeper than it is wide, egress needs to be closer to employees in a trench than in a non-trench excavation in case of emergency. For example, if water were to suddenly begin flooding a trench excavation, it would logically reach a greater depth and create an emergency more quickly than in a non-trench excavation. Therefore, due to limited space, egress is to be no more than 25’ from employees in a trench. A non-trench excavation has more room for an employee to maneuver during an emergency than in a trench.

For more information on this and other excavation safety topics I invite the reader to check out “Jon Preston’s Trench and Excavation Safety by the Book” where the federal OSHA Excavation Safety Standards are explained from commentary found in the federal register.

This book is available on Amazon and at www.trenchandexcavationsafety.com

?Contact Jon Preston at [email protected] for more information such as available volume discounts.