Confined Spaces: How to Satisfy OSHA Compliance

While you may think of any small area as a confined space, the OSHA definition is slightly different. It is defined as any area that possesses all of these conditions:

• Is large enough for an employee to fully enter and perform assigned work
• Is not designed for continuous occupancy by the employee
• Has a limited or restricted means of entry or exit

Some examples include tanks, pits, tunnels, manholes, ducts, and vents

When does a confined space require a permit?

If a confined space possesses any of the following characteristics, it requires a permitting process:

• Contains or has the potential to contain a hazardous atmosphere
• Contains a material with the potential to engulf someone who enters the space
• Has an internal configuration that might cause an entrant to be trapped or asphyxiated by inwardly converging walls or a floor that slopes downward and tapers to a smaller cross-section
• Contains any other recognized serious safety or health hazards.

What employers need to do for compliance

If it's not by definition a permit-required confined space, then there are no special requirements. You just need to treat these spaces as you would any other workplace area, in order to satisfy OSHA.

If it's a permit-required confined space, you're going to have to do quite a bit to satisfy 29 CFR 1910.146. Though "permit-required" sounds like you have to file permits with a government office, the process is actually an onsite procedure, designed to make sure that the appropriate safety steps are taken when an employee enters these spaces.

If you are in the construction industry, you need to know about OSHA's new standard for confined spaces in construction.

Simple guide to OSHA compliance of permit-required confined spaces

1. Post signs

The signs must inform employees about the existence, location, and hazards of the permit spaces. 1910.146 gives an example of the wording that could be used to mark a permit-required confined space: “Danger - Permit-Required Confined Space, Do Not Enter.” The sign should follow the ANSI Z535 standards for a danger sign. If some of your employees don't speak English, be sure to post signs in all needed languages.

2. Prevent entry

Decide whether employees will be expected to enter permit-required confined spaces. If not, you must prevent them from doing so. This standard, 1910.146(c)(3), does not specify exact means, so you have some freedom to decide what will be most effective, such as a lock. If employees will enter those areas, proceed to the next step.

3. Prepare a written program

You'll have to prepare a written confined space permit program, and make it available to employees and their representatives.

OSHA requires the written program to:

• Describe measures taken to prevent unauthorized entry
• Identify and evaluate any hazards in the space
• Require testing the atmospheric conditions (for oxygen, combustible gasses or vapors, and toxi gases or vapors) prior to entry, and monitor the space during entry.
• Identify the specific tasks needed to complete the work in the confined space
• Require employees to use the appropriate personal protective equipment (PPE) and other safety equipment. (This equipment must be provided and maintained by the employer at no cost to the employee)
• Require at least one attendant to be stationed outside the space for the duration of the entry
• When employees of multiple employers are working in the permit space, coordinate their entry operations
• Describe procedures for summoning rescue and emergency services, and for preventing unauthorized people from attempting rescue
• Include procedures for the preparation, issue, use, and cancellation of entry permits
• Establish procedures in case an attendant monitoring multiple confined spaces must respond to an emergency in one or more of those spaces

4. Review the program at least annually

Set a date for review, or consider defining events that kick the program into automatic review, such as altered conditions, or a confined spaces-related injury or fatality. Revise the program as needed.

5. Prepare for entry into the space

Confined space entry permits must be available to the entrants and signed by the entry supervisor prior to each visit. The permit must verify that mandated pre-entry preparations have been completed. (Here is a sample permit, which includes a pre-entry checklist.) The duration of the entry permit must not exceed the time required to complete the work assignment.

Entry permits must include the following information:

• Name of the confined space
• Reason for entry
• Date and authorized duration of the entry
• Identities of authorized entrant(s) and attendants
• Name and signature of the supervisor who has authorized entry
  Identification of all known hazards in the space and measures to be taken to eliminate or control the hazards
• Acceptable entry conditions must be confirmed. Results of initial and periodic tests, along with the initials or name of the tester, and the times of the tests
• Identification of rescue and emergency services, and the means to summon those services (such as phone numbers or equipment to be used)
• Communication procedures and the equipment required to maintain contact during entry
• Identification of any special equipment and procedures that are needed, such as PPE or alarm systems
• Any additional required permits, such as those needed for energized electrical work that have been issued to authorize work in the permit space
• Any additional information needed to ensure employee safety

6. Procedure after work is completed

When the work assignment in the confined space is complete or the confined space conditions change, the entry supervisor must cancel the permit. Any new conditions must be noted on the canceled permit and used to revise the permit-required confined space program. All canceled entry permits must be kept on file for at least one year.

7. Provide worker training

You must provide all necessary training for every worker who is required to enter the space, prior to entry. In addition, you must ensure that the employees have learned and remember what was taught in the training, and that they know whatever is necessary to safely perform their duties.

Additional training is required when:

• Job duties change
• A change occurs in the permit space program, or the operation presents any new hazard
• An employee's job performance does not meet standards for permit-required confined space entry

Rescue team members must be trained in CPR and first aid. Employers must certify that this training has been provided.

A written record must be kept of completed permit-required confined space training. This record must be available to employees and their authorized representatives. The record must include the employee's name, the trainer's signature or initials and dates of the training.

For more in-depth information on confined spaces, request our free Confined Spaces Best Practice Guide, which includes a confined space assessment form, how to test atmospheric conditions, and more.