Confined Space Entry Permit
Employers, are your employees required to work in confined spaces? The Occupational Safety and Health Administration (OSHA), outlines employer compliance requirements regarding confined spaces contained within their General Industry regulations 29CFR 1910.146 Permit Required Confined Spaces and also for Construction within 29CFR 1926.1200 (Subpart AA) Confined Spaces in Construction. There are also Maritime applications.
The Construction standard was officially introduced in 2015, having harmonization with the General Industry standard. As such, both standards should be consulted for compliance purposes.
From an OSHA definition standpoint, it's critical to first know the difference between a confined space and a permit-required confined space:
A confined space means a space that:
- Is large enough and so configured that an employee can bodily enter it;
- Has limited or restricted means for entry and exit; and
- Is not designed for continuous employee occupancy.
Some examples of confined spaces include tanks, vessels, silos, storage bins, vaults, hoppers, and pits.
Permit-Required Confined Space
Permit-required confined space (permit space) means a confined space that has one or more of the following characteristics:
- Contains or has a potential to contain a hazardous atmosphere;
- Contains a material that has the potential for engulfing an entrant;
- Has an internal configuration such that an entrant could be trapped or asphyxiated by inwardly converging walls or by a floor which slopes downward and tapers to a smaller cross-section; or
- Contains any other recognized serious safety or health hazard, such as unguarded machinery, exposed live wires, or cold/heat stress.
Whenever things go wrong inside a confined space, the results are almost always tragic, with death or serious injury to one or more workers. Many employers have adopted the policy of treating all confined spaces as permit required, especially when information about the space is uncertain or undetermined.
When it comes to permit required confined spaces, OSHA makes it clear that the employer develop and implement a written program, as detailed in section 29 CFR 1910.146(c)(4): If the employer decides that its employees will enter permit spaces, the employer shall develop and implement a written permit space program that complies with this section. The written program shall be available for inspection by employees and their authorized representatives.
A permit-required confined space program is defined as the employer's overall program for controlling, and, where appropriate, for protecting employees from permit space hazards, and for regulating employee entry into permit spaces. See Appendix C, Examples of Permit-required Confined Space Programs for more information.
Specific roles within the program include entrants, attendants (or monitors), supervisors, and rescue/emergency personnel.
Confined Space Entry Program
Consider the following elements of an effective confined space entry program:
Recognition. All personnel need to be aware of confined spaces and their associated hazards. Confined spaces are not always marked with signs and warnings. Identification may be aided with the use of Appendix A, Permit-Required Confined Space Decision Flow Chart.
Evaluation of Hazards. Confined spaces should be tested prior to entry and continuously during operations by trained qualified individuals using suitable instruments. Confined spaces may contain a variety of hazards, such an oxygen deficient atmosphere. Confined spaces containing less than 19.5 percent oxygen by volume may trigger worker asphyxiation. An oxygen enriched atmosphere containing more than 23.5 percent oxygen by volume could create a flammable or explosive condition if introduced to an ignition source, such as a spark or flame.
Equally of concern is the presence of flammable, explosive, or toxic gases, vapors, or dusts. Safety Data Sheets (SDS) and other reference sources may need to be reviewed to determine the exposure limits of hazardous materials. More information can be found within Appendix B, Procedures for Atmospheric Testing.
Control of Hazards. Certain procedures and precautions are required to allow for safe entry and may be controlled through engineering and safe work practices. An example would be utilizing a blower to continuously ventilate the confined space with fresh air while workers are in the space.
Communications. An effective means of communications between workers inside a confined space and the safety attendant/monitor must be used whenever conditions in the space require use of respirators or whenever entrants are out of sight of the safety attendant at any time. It is important that the communication system be tested before each use, and frequently thereafter, to ensure that it is working properly.
Confined Space Entry Permit. The Confined Space Entry Permit is utilized in assuring safety during operations within confined spaces with known hazards or with unknown or potentially hazardous atmospheres. The entry permit process guides the supervisor and workers through a systematic evaluation of the space to be entered. The permit should be used to establish appropriate conditions. Before each entry into a confined space, an entry permit will be completed by a qualified person, defined by OSHA as one who, by possession of a recognized degree, certificate, or professional standing, or who by extensive knowledge, training, and experience, has successfully demonstrated his ability to solve or resolve problems relating to the subject matter, the work, or the project.
The contents of the permit shall be communicated to all employees of the host employer and contractors involved in the operation and conspicuously posted near the work location. In addition, all personnel involved with the confined space entry shall be given a briefing before operations commence. A sample confined space permit can be found within Appendix D, Confined Space Pre-Entry Checklist.
Training. All personnel working in or around confined spaces shall receive initial and ongoing training to ensure continued competence. Training shall be provided for all host employer and contractor personnel associated with confined space entry operations and relative to their specific role and responsibilities. Training shall include criteria such as recognition and control of hazards, safe entry and emergency rescue procedures, and Personal Protective Equipment (PPE).
Emergency Rescue. No program is complete without emergency rescue procedures and associated personnel. Confined space statistics show many incident victims were improperly trained in emergency rescue. Entrants and attendants of confined spaces shall be properly trained on the proper use of safety and rescue equipment and emergency rescue procedures. Simply planning to dial 911 will not do!
Rescue personnel shall have all required emergency equipment and be trained in its use such as a body harness and attached lifeline used with a hoisting mechanism and a NIOSH-approved, Self-Contained Breathing Apparatus (SCBA) respirator.
As a guide, employers should consult Appendix F, Rescue Team or Rescue Service Evaluation Criteria.