July 2011- Confined Spaces

What is the definition of a “confined space” in the terms of the OSHA Permit-Required Confined Space standard?

A confined space has limited openings for entry or exit, is large enough for entering and working, and is not designed for continuous worker occupancy. Confined spaces include underground vaults, tanks, storage bins, manholes, pits, silos, underground utility vaults and pipelines.

What types of confined spaces are permit-required?

OSHA uses the term "permit-required confined space" (permit space) to describe a confined space that has one or more of the following characteristics: contains or has the potential to contain a hazardous atmosphere; contains a material that has the potential to engulf an entrant; has walls that converge inward or floors that slope downward and taper into a smaller area which could trap or asphyxiate an entrant; or contains any other recognized safety or health hazard, such as unguarded machinery, exposed live wires, or heat stress.

How would I determine if a confined space would be permit-required?

As an employer it is your duty to evaluate the workplace and determine if any spaces are permit-required confined spaces. OSHA provides a flowchart (Appendix A to section 1910.146) that would facilitate compliance with this requirement.

What types of hazards may be present in a confined space?

Once a space has been identified as confined, the hazards that may be present within the confined space must be identified. Confined-space hazards can be grouped into the following categories:
  • Oxygen-deficient atmospheres
  • Flammable atmospheres
  • Toxic atmospheres
  • Mechanical and physical hazard

If I have a permit-required confined space am I required to have a written program?

As an employer, if you decide that your employees will enter permit-required confined spaces, a written confined space entry program must be developed and implemented. It must be available for inspection by employees and their authorized union representatives. In this program, the employer must describe how he/she will comply with the requirements of the standard. The written program must include the following:

  • How the employer will implement the measures necessary to prevent unauthorized entry
  • Identification and evaluation of the hazards of permit spaces before employees enter them
  • Equipment needed to perform a safe entry operation, provided at no cost to the employees
  • Procedures for atmospheric testing of the space
  • Provision of at least one attendant outside the space
  • Provision for responding to emergencies if attendant is monitoring more than one space
  • Designation of all persons with active roles (e.g. entrants, attendants, persons who test and monitor) and provision of required training
  • Procedures for summoning rescue and emergency services
  • System for the preparation, issuance, use and cancellation of entry permits
  • The system developed and implemented for the closing off the permit space and cancellation of entry permits
  • Procedures to coordinate operation where more than one employer (such as a contractor) is involved
  • Procedure for evaluation and correction of entry operations when the employer has reason to believe that the program is not sufficiently protective
  • The mechanism by which the confined space permit entry program is reviewe
  • Do not enter permit-required confined spaces without being trained and without having a permit to enter.
  • Review, understand and follow employer’s procedures before entering permit-required confined spaces and know how and when to exit.
  • Before entry, identify any physical hazards.
  • Before and during entry, test and monitor for oxygen content, flammability, toxicity or explosive hazards as necessary.
  • Use employer’s fall protection, rescue, air monitoring, ventilation, lighting and communication equipment according to entry procedures.
  • Maintain contact at all times with a trained attendant either visually, via phone, or by two-way radio. This monitoring system enables the attendant and entry supervisor to order you to evacuate and to alert appropriately trained rescue personnel to rescue entrants when needed.

Disclaimer: These Regulatory Reminders are not intended to be an exhaustive source for all of your particular facility’s compliance issues. They are designed to address the basics requirements with which most companies are required to comply. Following the Regulatory Reminder’s deadlines and Monthly Focus will not guarantee your compliance as these reminders are simply designed to help in your environmental/safety compliance efforts. You should always refer to the federal and your state’s regulations for all your requirements. Ultimately, your compliance with federal and state regulations is your responsibility. E&SSG assumes no liability for your compliance or the resources provided in these “Reminders”.

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