Permit-Required Confined Space

            OSHA has a required standard, 29 CRF 1910.146, for all locations that meet the confined space criteria and then also require a permit to enter those areas.  Along with those specifications, there are other steps that need to be taken to ensure safe entry into possibly hazardous confined spaces.  The first step is to determine if the space being entered is a confined space by which a permit will be required.  According to OSHA, a space is designated as a confined space if it meets the following three criteria:

1.     The space is large enough for an employee to enter and complete the assigned responsibilities.

2.     The entry and exit from the space is restricted.

3.     The space is not originally planned for permanent occupancy.

The next step is to inform the employees of the space, along with its location and possible hazards.  Testing and other analysis will need to be done in the space to determine the possible hazards.   Due to the nature of the unsafe space, the employer will need to limit access to that confined space so that unauthorized personnel do not enter the space without proper training and permission. 

The first few steps are the general information on the confined space.  OSHA also then requires a confined space entry program.  This program lays out more of the details that are specific to the facility and the confined spaces being entered.  This program must also be available to employees to access.  The written program must cover the ways that the hazards within the confined space are being controlled for a safe entry.  It will also cover the requirements of the permit needed for entering such a space. The permit is very specific to each confined space.  Tests for hazards and personal protective equipment must be described on the permit.  The permit also designated trained personnel who are authorized to enter the confined space as well as attendants who are a line of safety for those inside the space.  As mentioned briefly above, the personnel and attendants must also be trained on how to safely enter the space.   Another topic the written program has to cover is an emergency plan.  The emergency plan gives information on the necessary steps to be taken in case of a rescue in an emergency.  Many times the fire department is called to assist with rescue, and it is important to coordinate with these services before they are needed to plan for the possible hazards involved. 

Many of the scenarios involving the Permit-Required Confined Space Standard also involve other standards.  One standard that may be referenced during a confined space entry may be the Lock Out Tag Out Standard, 29 CFR 1910.147.  This standard may be necessary if the space being entered involves hazardous energy.  The procedure in this standard covers the precautions that need to be taken to ensure that the hazardous power is shut off during maintenance and will not be able to be turned on while an employee is at risk of injury or death.  Another standard that may be needed during confined space entry is the HazardCommunication Standard, 29CFR 1910.1200.  This standard would be used to communicate the hazards of the confined space to the employees and personnel involved with confined space entry.  There may be engulfment hazards or asphyxiation hazards within the space that personnel need to be aware of and trained to work with.  

              Aside from this lengthy process of permit-required confined space entry, there is an alternative to a full permit for entering a confined space as described by OSHA.  An example where this alternative method would be acceptable is if the employer can show through samples and monitoring that the space is only potential hazardous atmosphere and nothing more, but can be fixed by clearing the space with continuous air ventilation, then they may be exempt from permits and attendants.  The employer must provide tests before entry and continuous air ventilation during the working process to avoid completing a full permit.