Confined Space Entry Training

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Requirements for Confined Space Entry Permits

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Confined space entry permit

Blog Post #21 – If one or more employees will enter a permit-required confined space without using the alternate or reclassification procedures discussed in our previous blog posts, their employer must designate an entry supervisor to complete, sign, and post a confined space entry permit before entry operations begin.

Purpose of the Confined Space Entry Permit

The purpose of the entry permit is to document information about the hazards within the permit space and verify the completion of all required measures that must be implemented before allowing employees to enter. The entry permit will also list additional details, such as the emergency response procedures to follow if medical or rescue assistance is needed.

Common Misconception About Confined Space Entry Permits

So, where does one obtain a confined space entry permit? Many people mistakenly believe that an employer must apply to OSHA for a permit authorizing their workers to enter a permit-required confined space. While understandable, this belief is incorrect. Confined space entry permits are generally created by the entry employer, then completed and posted at the confined space by a designated entry supervisor.

The Confined Space Entry Permitting Process

Before allowing workers to enter a permit-required confined space, the entry employer must implement a permitting process that meets the requirements of OSHA standard 1910.146, section E (for general industry) or 1926.1205 (for construction). As part of that permitting process, OSHA requires the entry employer to prepare an entry permit per the requirements listed in standard 1910.146(f) for general industry, or 1926.1206 for construction.

Required Information on a Confined Space Entry Permit

The information required on the confined space entry permit is detailed in 1910.146, subparagraphs (f)(1) through (14) for general industry, and in 1926.1206, paragraphs (a) through (o) for construction. This includes, where applicable:

  • The identity of the permit space to be entered;
  • The specific purpose of the entry;
  • The date and authorized duration of the permit;
  • The identity of all authorized entrants in the space, listed by name or other means (e.g., rosters or tracking systems) to allow the attendant to quickly determine which authorized entrants are inside the permit space. Note: This requirement does not mandate that entrants place their signature on the entry permit;
  • The name of each designated attendant monitoring the entrants and entry area;
  • Identification of any and all hazards associated with the space. This includes any existing hazards, and those that could potentially develop in or near the permit space during entry operations;
  • Measures to isolate, control, or eliminate hazards in the confined space. Examples include:
    • Implementing lock-out/tag-out procedures for switches or valves;
    • Installing a pipe blank or blind or disconnecting a section of line;
    • Purging or pumping contents from inside the space;
    • Flushing residual contents from inside the confined space;
    • Installing ventilation equipment; and/or,
    • Inerting a flammable atmosphere.
  • Acceptable entry conditions, including the range for atmospheric hazards associated with the space being entered. For example, the permit must state that oxygen levels must be between 19.5% and 23.5% by volume, where applicable;
  • Initial test results for air monitoring, and results of any post-ventilation tests. Note that actual test results must be documented on the permit, rather than noting only “okay” or “safe.” The permit must also show the time and location of tests conducted and the name or initials of the person conducting the testing;
  • The method for detecting increases in atmospheric hazards during entry operations. OSHA’s standard requires conducting continuous monitoring when commercially feasible; otherwise, periodic checks are acceptable;
  • The identity of, and means to summon, designated emergency medical and rescue services;
  • Communication methods between entrants and the attendant;
  • Required equipment for entry operations, which may include;
    • Personal protective equipment (PPE);
    • Air monitoring devices;
    • Ventilation equipment;
    • Communication equipment;
    • Alarm systems; and/or,
    • Rescue equipment.
  • Any other information needed for safe entry, if applicable, must also be documented on the permit. Also, additional required permits, such as hot work permits, may be referenced or attached to the entry permit to prevent redundancy.

Finally, the designated entry supervisor must add their name and signature to the confined space entry permit after verifying that all necessary precautions and procedures have been implemented, and that all required information is documented.

All details listed above that are applicable to an entry are required by OSHA to be documented on the permit. And employers are free to include additional information on their entry permits if they wish. However, any items listed above that are irrelevant to a particular entry do not need to appear on the permit. For instance, if only physical hazards are present in a permit-required confined space, with no possibility of atmospheric hazards, then atmospheric testing need not be conducted or documented on the entry permit.

Confined Space Permit Posting Requirements

After completion and signing by the entry supervisor, the entry permit must be posted at or near the confined space entry point, accessible for review by authorized entrants and their representatives. Entry operations are limited to the time and tasks listed on the permit.

OSHA’s Formatting Requirements for Confined Space Entry Permits

As previously noted, the entry permit does not have to follow a particular format or order. Some permits are open form with sections to fill in, such as our confined space entry permit template (long version) provided with the course materials for our comprehensive online confined space entry training courses. Alternatively, some entry permits are customized for entering specific spaces, with pre-filled information and check-boxes for the entry supervisor to verify before signing and posting. The main thing is to make certain there is a means to clearly document all necessary information required to be on the entry permit.

Termination, Suspension, and Retention of Confined Space Entry Permits

The entry supervisor must terminate entry operations and cancel the confined space entry permit when entry operations are completed. Employers must also retain canceled permits for at least one year to facilitate an annual review by the employer of their confined space entry program.

If the job duration, scope, or hazards change during entry, or if any conditions that do not align with the permit arise in or near the permit space, the entry supervisor must temporarily suspend or terminate entry operations. Then, they must reevaluate hazards and conditions in the space, take any measures needed to ensure safe entry operations, revise the permit as necessary, and then reissue the permit before entry operations can resume.

Carefully preparing an entry permit for confined space entry is essential for worker safety. Missing steps in entry preparation or during operations can have serious consequences.

Where to Get a Free Template for a Confined Space Entry Permit

Sample confined space entry permits are available from various sources, including our free confined space entry permit template (Word) provided here. A template is also provided with the course materials provided with our online confined space training courses. Of course, any sample or template for an entry permit must be revised as necessary to reflect actual conditions and entry procedures needed at the job-site.

Please share any comments or questions in the section below, and stay tuned for our next posts, where we will discuss additional requirements for implementing a comprehensive permit-required confined space entry program.

Finally, feel free to share a link to this post with others in your network who may benefit from this information.

Thanks,  Curtis Chambers – Confined Space Expert

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OSHA Alternate Entry Procedures for Permit-required Confined Spaces

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OSHA Alternate Entry Procedures for Confined Space Entry

Blog Post #20 – Some permit-required confined spaces qualify to be entered under the alternate entry procedures listed in 1910.146(c)(5) of the general industry standards for permit-required confined spaces, and in 1926.1203(e) of the confined spaces in construction standards. These procedures, which allow entry into permit spaces that contain only atmospheric hazards which the employer demonstrates can be sufficiently controlled with forced air ventilation alone, differ from those discussed in the previous blog post, which explained how and when you can temporarily reclassify a permit space to non-permit space status.

The advantages to utilizing the alternate entry procedures listed in section 1910.146(c)(5) and 1926.1203(e) are that once the permit space has been certified as safe for entry under these procedures, the following elements of a full permit entry are not required:

  • No written confined space entry procedure or entry permit is required for workers to enter the space, only a brief written certification;
  • It is not mandatory to have an attendant stand by the entry point to the confined space during entry operations;
  • Workers in the space do not have to receive the extensive training required for a permit space entrant;
  • No entry supervisor is required to oversee all entry operations during alternate entry procedures; and,
  • A confined space rescue team is not required to be on standby during this entry.

As you can see, the benefits of utilizing these alternate confined space entry procedures, when allowed, can make entry into eligible spaces quicker and more cost-effective, while still maintaining a safe work environment for entrants.

When do the OSHA Alternate Entry Procedures for Permit-required Confined Spaces Apply?

The OSHA 1910 general industry confined space standards for alternate entry, which were published in the early 1990’s, state that they apply to permit spaces with actual or potential atmospheric hazards only, and in which continuous forced air ventilation alone can maintain the atmosphere inside the space safe for entry. The wording of this general industry standard does not make it clear if that means the space must never present any non-atmospheric (physical) hazards at any time (pre and post entry) to qualify for entry under the alternate procedures, or if any such hazards must simply be addressed before entry is allowed.

Fortunately, the wording of the 1926 confined spaces in construction standard rule differs slightly, clarifying that alternate entry procedures can be utilized in those permit spaces where continuous, forced air ventilation can maintain the atmosphere inside the confined space safe for entry, and all other unsafe conditions (if any) which are non-atmospheric in nature are eliminated or isolated before the cover on the space is removed.

Recall that in the previous blog post, we explained OSHA’s definition of the term “isolation,” which means the process by which a permit space is removed from service and completely protected against the release of energy and material into the space.

Defining “Safe for Entry” in the OSHA Alternate Entry Standards

As stated above, these alternate entry procedures both require that continuous, forced air ventilation can maintain the atmosphere inside the confined space “safe for entry.” However, neither standard define what that term means.

Fortunately, the preamble to the 1910 general industry standard (see accompanying excerpt from page 4488 of Federal Register / Volume 58, No. 9) sheds some light on the meaning of this terminology.

Alternate Entry OSHA Federal Register Excerpt Safe for Entry

This particular section of the Federal Register states that the atmospheric hazards must remain at no more than one-half (50%) their regulated levels to be considered “safe for entry” when using the alternate entry procedures.

So, as an example, flammable gas in the atmosphere is considered hazardous by Federal OSHA when it exceeds 10% of its LEL, so “safe for entry” would be an atmosphere maintained by forced air ventilation at levels not exceeding 5% LEL. And the Federal OSHA PEL for carbon monoxide is 50 ppm, so “safe for entry” would be an atmosphere containing no more than 25 ppm CO. Note: some State Plan OSHA programs have lower PELs for certain atmospheric hazards such as CO; refer to state regulations when applicable to your workplace.

Requirements for Forced Air Ventilation Utilized During Alternate Entry Operations

When using the alternate entry procedure, forced air ventilation (e.g. a hose blower or similar ventilation equipment), must be installed and operating efficiently and continuously before and throughout entry. The blower hose must be directed to ventilate the immediate areas where an employee is present, or will be present, within the space, and must continue to operate until all employees have exited the space.

The ventilation system should provide an adequate volume of air needed to allow enough time for all entrants to escape the confined space without overexposure should the ventilation system unexpectedly stop working. Determining what would be an adequate time for escape, in turn, is a function of the concentration the contaminant, the rate of generation or introduction of the contaminant into the space, and the distance to the exit. Because of the complexities of making such an evaluation, only a technically qualified person should make this determination.

Also, the employer must ensure the source of make-up air for ventilation equipment is clean and safe. So, make sure there are no sources of contamination, such as open drums of hazardous chemicals or pieces of equipment with an internal combustion engine running near the air intake of any confined space ventilation equipment.

Additional Requirements When Utilizing OSHA Alternate Entry Procedures

There are a few additional conditions that must be met if an employer chooses to utilize the alternate entry procedures listed in both OSHA confined space standards, including making sure other unsafe conditions are eliminated or isolated before the cover on the space is removed. This could include measures such as making certain to bleed off any pressure that may have built up inside of a confined space before opening the lid or removing its cover, where applicable, as the pressure could cause the lid or cover to fly off and strike someone.

Also, once the lid or cover has been removed, the opening into the space being entered under alternate procedures must be immediately guarded so that no person or object can fall into the confined space, where applicable. Devices such as portable barricades with toe-boards are available to help meet this requirement.

Then, the internal atmosphere in the space must be tested before entry using a calibrated, direct reading instrument, for oxygen, LEL, and toxics, in that order (the reason for using this specific testing order will be explained in a later blog post about atmospheric testing). Atmospheric testing is necessary to determine that the atmosphere inside the space is “safe for entry” before entry operations, and additional testing must be conducted as needed throughout entry to ensure the atmosphere is maintained. Furthermore, the employer must develop and maintain adequate monitoring and inspection data that demonstrates the ventilation system can maintain the atmosphere at safe levels throughout entry.

In those instances where it is necessary for a worker to conduct initial atmospheric testing or isolate a physical hazard from inside the space, this initial entry must be made under a full entry permit program until the hazards are isolated and the atmosphere has been deemed safe for entry. 

Moreover, any activities carried out within or outside of the space must not create new atmospheric (or non-atmospheric) hazards. This includes introducing into the space any hazardous amounts of flammable or toxic substances, or performing hot work within the space, as they could introduce risks that were not considered when determining that the atmosphere inside the confined space is safe for entry.

Finally, if any hazardous atmosphere is detected during entry during alternate entry procedures, all entrants must immediately evacuate the confined space. Then the entry employer must make certain to reevaluate the space to determine why the hazardous atmosphere developed, and then implement adequate corrective measures to protect employees before any subsequent entry takes place.

OSHA Requirements for Safe Entry and Egress of Personnel

Employers must also provide a safe method of entering and exiting the space during alternate entry operations. If a hoisting system is used, it must be designed and manufactured for personnel hoisting; this requirement was clarified by OSHA in their newer confined spaces in construction standard. However, a job-made hoisting system is permissible if it is approved for personnel hoisting by a registered professional engineer, in writing, prior to use.

Documentation Requirements When Using Alternate Entry Procedures

An employer utilizing this alternate entry procedure is not required to prepare a regular confined space entry permit. Instead, the employer must simply verify that the space is safe for entry, and that all required measures have been taken prior to entry, by preparing a written certification. This written certification must identify the location of the space, the date of entry, and the signature of the person certifying the space is safe, per the OSHA confined space standards for alternate entry.

This written certification must be made available to affected employees or their designated representatives before entry by posting it at or near the entry point of the confined space for the duration of entry operations.

What if Alternate Entry into a Permit Space is Not Feasible?

If a permit required confined space cannot, or will not, be entered under the alternate entry procedures listed in OSHA standards (or if it cannot be reclassified as a non-permit space under the procedures discussed in a previous blog post), then the space must be entered under a full permit-required confined space entry program (which will be covered beginning in the next blog post).

Remember also that the space must be returned to permit-required status when the work is completed, or if at any time during entry under alternate entry procedures a hazardous atmosphere develops inside the space.

Closing

As you can see, OSHA’s alternate entry procedures, when allowed and properly implemented, can result in safer, more efficient, and compliant management of eligible confined space entries because the relatively-lower risks associated with these type spaces can easily be controlled.

Please provide any comments or questions about the OSHA alternate entry procedures in the COMMENTS section appearing at the bottom of this page. And be sure to come back soon to see our next blog posts, which delve into the requirements for implementing a full permit-required confined space entry program.

Last but not least, I encourage you to share a link to this Confined Space Training Blog post with others in your network so they can benefit from this information. Thanks – Curtis

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How to Reclassify a Permit Required Space to a Non-permit Space Through Hazard Isolation

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Post #19 – While entry into a permit-required confined space typically requires implementation of a full permit system and program, there are some permit spaces where that may not be necessary. That is because OSHA provides special procedures to reclassify certain permit-required confined spaces temporarily to non-permit required status through hazard isolation. Those reclassification procedures are found in 1910.146, paragraph (c)(7) of the general industry confined space entry standards, and for construction work in 1926.1203(e)(1).

Benefits of Reclassifying a Permit Space to Non-permit Status

So, what are the benefits of reclassifying a permit-required confined space to a non-permit space? By reclassifying the permit space as non-permit required under the procedures set out in 1910.146 (c)(7) for general industry, or in 1926.1203(e)(1) for construction, entry can be made without having to implement all of the steps required to enter under a full confined space entry permit program while still providing a high degree of worker safety.

Under the reclassification procedures, no formal entry permit is necessary, only a brief written certification (explained later in this post); workers entering the non-permit space do not have to receive specialized training as a permit space entrant; no attendant is required to stand by at the entry point to the space during entry operations; no entry supervisor is required to oversee entry operations; and, no confined space rescue team is required to be on standby during the entry.

Applicability of OSHA’s Confined Space Reclassification Procedures

It is important to note that entry under these paragraphs only apply to permit spaces that pose no actual or potential atmospheric hazard, and where all other non-atmospheric hazards present in the space can be eliminated or isolated to make it safe for entry.

As an example of one such permit space that might qualify for reclassification to non-permit status under these procedures, consider a large industrial mixer that contains no actual or potential atmospheric hazards but does have high speed mixing blades inside the mixing chamber that could cut or crush an entrant if they were working inside the space and the mixer motor was unexpectedly started. So, the goal would be to make this particular permit space safe for entry by eliminating or isolating the physical hazard of being crushed by the moving mixing blades before entry. If this is done, the employer may temporarily reclassify it as a non-permit space for as long as any and all physical hazards remain isolated.

What is “Isolation” of a Confined Space Hazard?

When choosing this entry option, it is imperative that you understand OSHA’s definition of the term “isolation.” OSHA’s definition of the term “isolation” means the process by which a permit space is removed from service and completely protected against the release of energy and material into the space or potential employee contact with a physical hazard.

One way this can be achieved in spaces containing physical hazards such as mixing blades, fan blades, agitators, rollers, turbines, conveyor belts, elevator cars, or even exposed live electrical circuits, is by locking out and tagging all sources of hazardous energy at their energy isolation device(s), per OSHA’s lock-out/tag-out standard (1910.147). In other cases, mechanical hazards may be isolated by disconnecting mechanical linkages, or by blocking all moving parts.

For some permit spaces, isolation can be achieved by blanking or blinding pipes or lines so that any potentially harmful agent such as compressed air, steam, liquid, gas, or other material is prevented from flowing into a confined space. This involves breaking into the inlet pipe or line at a flange and inserting a plate specifically designed to block the flow. Another option to isolate a permit space from similar hazards is to disconnect and misalign, or completely remove, a section of line, pipe, or duct on the inlet side to prevent flow into the space.

One more method to isolate a confined space from the flow of energy or materials via pipes or lines is by use of a double block and bleed system (see image). Valves can potentially leak, so in OSHA’s eyes, turning off a single valve does not achieve total isolation of the space from the potential hazard. A double block and bleed system, where two valves in series are closed and the space between them bled off, would meet the requirements for isolation as long as each valve is secured per the OSHA lock-out/tag-out standard.

double block and bleed to isolate confined space for reclassification<br />

Another option listed by OSHA in their confined spaces in construction standard’s definition of the term “isolation” is, “the placement of barriers to eliminate the potential for employee contact with a physical hazard.” One example of isolation of a hazard OSHA discusses in the preamble to that particular construction standard is placing padding around low overhead hazards such a beam that an entrant may strike their head on in the dark and become disoriented or unconscious. Once that is completed, the hazard within that space is considered to be isolated.

The OSHA confined space standards for general industry and construction do require that if it is necessary for a worker to enter into a permit-required confined space to eliminate or isolate a hazard from inside the space, entry must first be made under the full requirements of the permit-required confined space standard, which will be discussed in a later blog post. Then, reclassification of that space to non-permit required status can be made after the hazard has been eliminated or isolated from inside the space.

Here is one such example of when it would be necessary to enter a space under a permit system so as to be able to isolate a hazard; A large air handling unit has been classified by the employer as a permit-required confined space, due to the high-speed rotating fan blades located inside the unit representing a potential recognized serious safety hazard. If the worker de-energized the fan motor by turning off and locking out the motor for the fan blades at its energy isolation device, they would still need to enter the space to secure the sharp fan blades in place to prevent them from rotating and possibly cutting the entrant should a strong draft pass through the unit. So that task would need to be conducted under a full entry permit. Then, after securing the fan blades so they will not move, this permit space could be temporarily reclassified as a non-permit required confined space for as long as the hazards remain isolated.

In all cases when utilizing the OSHA procedures to reclassify a permit space to a non-permit space, the employer must ensure that all inspection and testing necessary to confirm all non-atmospheric hazards inside the space are eliminated or isolated are completed. Once that is confirmed, the space can be temporarily reclassified as a non-permit required confined space for as long as the hazard(s) remain eliminated or isolated.

Certification Requirements for Confined Space Reclassification

Once the OSHA procedures for reclassification to a non-permit space are completed, no formal permit-required confined space entry permit is required for workers to enter the space. However, OSHA does require the employer to document in writing that the steps needed to reclassify the space as non-permit required have been taken by preparing a written certification. This brief written certification must include the identity of the space to be entered and the date of entry, and must provide positive confirmation that all steps needed to eliminate or isolate the hazards in the space have been taken. Then, the person certifying that all steps were taken and the space is safe for entry must sign the written certification and post it at or near the entry point to the space, where it must remain there for the duration of entry operations.

Confined Space Reclassification is Temporary

Remember that the reclassification of a space from permit-required to non-permit required status is temporary, and the space must be returned to permit-required status once any hazard in the space is no longer eliminated or isolated. The OSHA reclassification procedures also stipulate that should any unexpected hazard arise during entry operations, all entrants must exit the space immediately. Then, the employer must reevaluate the space to determine why that hazard(s) was not adequately isolated, and implement whatever corrective measures must be taken to continue entry with the space temporarily reclassified as a non-permit space; If this is not feasible, entry must instead be made under a full confined space entry permit program.

Obviously, not all permit-required confined spaces qualify for entry under these special reclassification procedures, and may need to be entered by following the OSHA requirements for entering a space under a full confined space entry permit program. But before we delve into what those procedures entail, the next post to the Confined Space Training Blog will expound upon OSHA’s alternate entry procedures for entering permit-required confined spaces that contain an actual or potential hazardous atmosphere that can be controlled through continuous forced air ventilation alone.

Please provide any comments or questions about the OSHA procedures to temporarily reclassify a permit-required confined space to a non-permit space below. And last but not least, I encourage you to share a link to this Confined Space Training Blog post with others in your network so they can benefit from this information. Thanks – Curtis

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When it is Necessary to Reclassify Non-permit Confined Spaces as Permit-required Confined Spaces

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Reclassification of Non-permit required confined space to a permit-required confined space

Blog Post #18 – In the previous blog posts, we discussed how there are two categories of confined spaces; non-permit required confined spaces, and permit-required confined spaces. But one of the hardest things for many people to get their head around is that the classification of a confined space can change due to various factors. So, the focus of this blog post is why and when non-permit spaces must be reclassified as permit-required spaces.

When Must You Reassess a Non-permit Required Confined Space?

By definition, a non-permit required confined space is a space that meets all three of the elements of a confined space, but does not meet any of the requirements of a permit-required confined space. If a confined space is classified by an employer as a non-permit required confined space, that space does not have to be identified with a warning sign, no permit is required to be filled out prior to entering the space, and no precautions listed in the permit-required confined space standard need be taken for their employees to enter, with this one exception; each entry employer must have a person (more specifically, a competent person per the construction standards) re-evaluate a non-permit required confined space if there are any changes to the use or configuration of that space that might increase the hazards to entrants, or if there is some indication that the initial evaluation of the space may not have been adequate.

Reclassifying a Non-permit Confined Spaces as a Permit Required Space

If an actual or potential serious health or safety hazard is subsequently identified in a non-permit space, the space must be reclassified as a permit-required confined space for as long as the hazard(s) remain. The requirements to conduct this reassessment are found in 1926.1203(f) for construction, and 1910.146(c)(6) for general industry.

Below is one example of when a non-permit required confined space would have to be reclassified as a permit-required confined space.

A new stainless steel process tank is installed in a manufacturing facility. This tank has never contained any material, has no mechanical hazards such as an agitator, no fill lines attached, and no other safety hazards present; therefore, this tank was classified by the employer as non-permit required confined space. However, before turning the equipment over to the customer, an employee must enter the tank to conduct a final inspection. Before leaving the tank, the entrant must then decontaminate the interior of the tank by wiping the entire interior surface with isopropyl alcohol. This creates a potentially hazardous atmosphere due to the flammable and toxic properties of the isopropyl alcohol. Therefore, this tank must be reclassified as a permit-required confined space and entry made under a permit, at least while this hazard-producing task is being performed.

As you can imagine, there are many other possible scenarios where non-permit required confined spaces would need to be reclassified as permit-required confined spaces due to similar circumstances. If you wish, feel free to provide an example in the comments section below. You can also use the comments section to ask questions about this topic.

Be sure to come back later and read our next blog post about the converse of this topic, when we discuss OSHA’s procedures for temporary reclassification of a permit-required confined space to non-permit required status. Last but not least, I encourage you to take a moment and spread the word about our confined space training blog by sharing a link to this post with others in your network, so they too can benefit from this information. Thanks – Curtis

OSHA Requirements for Signage and Notifications for Permit-required Confined Spaces

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Confined space signs and notification requirements

Blog Post #17 –The OSHA 1910 and 1926 confined space entry standard requirements address one of the employers’ first responsibilities at worksites where permit-required confined spaces are identified in the workplace; Informing affected workers and others of the existence and dangers of the permit spaces. Be aware that there are multiple ways this can, or must, be accomplished.

OSHA Requirements for Signs at Permit-required Confined Spaces

Paragraph 1910.146(c)(2) of the general industry standard for permit-required confined spaces and paragraph 1926.1203(b) of the confined spaces in construction standard states if the workplace contains one or more permit-required confined spaces, the employer who identifies, or who receives notice of, a permit space must inform exposed employees by posting danger signs, or by any other equally effective means, of the existence and location of, and the danger posed by, the permit spaces. This requirement must be met even if the employer will not have any of its workers enter any of the permit spaces. Both standards go on to note that a sign reading “DANGER – PERMIT-REQUIRED CONFINED SPACE, DO NOT ENTER” or other similar language would satisfy the requirement for a sign.

Alternatives to Posting Signs at Permit-required Confined Spaces

Due to their location or configuration, it may not be practical or possible to place a sign on some permit-required confined spaces. Therefore, the OSHA standards allow the employer to use “any other equally effective means” as an alternative to a sign. The goal of the OSHA standards is to ensure workers know of the existence, location, and danger of the permit-required confined spaces in the work place. And the preamble to the 1910 general industry permit-required confined space standard provides some guidance in this area that may be useful. It states that, as an alternative to a sign, employers can provide sufficient training to all employees to ensure they are aware of the location and hazards of the permit-required confined spaces at the jobsite. However, OSHA clearly states their preference for use of a sign where possible.

One other option presented in the 1910 preamble is to secure the entry porthole to the confined space with a lock or special fastener. Then, only employees who have been trained and authorized to enter the permit-required confined space would possess the key or tool needed to access the space.

Other Notification Requirements Regarding Permit-required Confined Spaces

In addition, those employers having permit spaces on site must inform, in a timely manner and in a manner other than posting, its employees’ authorized representatives, which are essentially their union representative, where applicable, of the existence and location of, and the danger posed by, each permit space. And the construction standard also requires employers who identify permit spaces at a construction site to also notify the Controlling Contractor at the site. Per OSHA definitions listed in this standard, the Controlling Contractor is the employer that has overall responsibility for construction at the worksite. This generally applies to the General Contractor, but this responsibility could fall to the host employer when no General Contractor is utilized.

Controlling Contractors at construction sites may or may not even have employees entering permit spaces, or they may not even be on the site at all times. But OSHA makes it very clear in the preamble to the construction standards for confined space entry that they consider the controlling contractor to be the “information hub for confined-spaces information sharing and coordination” at a construction site. More on the specific responsibilities of the Controlling contractor will be presented in later blog posts.

And for general industry worksites, 1910.146(c)(8) states that when an employer (host employer) arranges to have employees of another employer (contractor) perform work that involves permit space entry, the host employer shall inform the contractor that the workplace contains permit spaces and that permit space entry is allowed only through compliance with a permit space program meeting the requirements of this section. They must also apprise the contractor of the elements, including the hazards identified and the host employer’s experience with the space, that make the space in question a permit space.

What if No Employees Will Enter Confined Space?

Once affected employers have identified all of the permit-required confined spaces at their job-site, they are each presented with two options. Option one, an employer decides the employees it directs are NOT authorized to enter a permit space, or, option two, the employees they direct WILL enter a permit space. If an employer decides its employees will NOT enter a permit-required confined space, they still must comply with the requirements of Paragraph 1926.1203(c), which requires the employer to take effective measures to prevent its employees from entering the permit space.

So, even if an employer does not authorize their workers to enter permit spaces, they must still ensure that required danger signs are posted at permit spaces, and they must inform their employees and their designated representatives of the existence and hazards of the permit spaces. They must also inform employees and their designated reps of the company’s No Entry policy, where applicable. Last but not least, employers must inspect for compliance and enforce that policy.

Re-evaluation and Reclassification of Non-permit Required Confined Spaces

In addition, employers who have employees working in or near non-permit spaces must remember the requirements of paragraphs 1910.146(c)(6) and 1926.1203(f). They both require employers or their designated competent persons must reevaluate any non-permit confined space when there is a change to the use or configuration that might increase the hazards to entrants, as well as when there is some indication that the initial evaluation of the space may not have been adequate. And if a serious safety or health hazard is detected, the space must be reclassified as a permit-required confined space (with sign posted near points of entry) if necessary.

Comments About Communication and Signage Requirements for Permit Spaces

Please post your comments and questions about signage and notification requirements for permit-required confined spaces in the comments section below. You can also ask questions there as well. Then, be sure to come back later and read our next blog post, which addresses the steps that can be taken to temporarily reclassify permit-required confined spaces in the workplace to non-permit status; a big time-saver when working in eligible permit spaces. Last but not least, I encourage you to take a moment and spread the word about our confined space training blog by sharing a link to this post with others in your network, so they too can benefit from this information. Thanks – Curtis

Permit Space Triggers – Other Recognized Serious Safety or Health Hazards

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Other Serious Safety Health Hazards OSHA Confined Spaces

Blog Post #16 – In this post to The Confined Space Training Blog, we examine the fourth and final criteria listed in OSHA’s definition of a permit-required confined space. And that is, any confined space that contains any other recognized serious safety or health hazard.

OSHA Definition of Other Recognized Serious Safety or Health Hazards

In the OSHA confined space standards for general industry or construction, there is no specific definition for the phrase “other recognized serious safety or health hazard.” However, in the preamble to the Confined Spaces in Construction standard, OSHA explains they are taking about “hazards that could impair the ability of an entrant to exit the space without aid.” They continue on in that preamble to state that “The key determination is the likelihood that death or serious harm will occur IF an accident or exposure occurs.”

Examples of Other Recognized Serious Safety or Health Hazards

Based on the above-mentioned statement made by OSHA in the preamble, one example of a serious safety hazard present in confined spaces at many general industry and construction worksites is mechanical hazards such as unguarded fan blades. The same can be said about agitators and mixing blades present inside of a confined space such as a mixer or agitator. Other similar hazards include moving gears, belts and pulleys, or chains and sprockets. Also covered would be equipment that could move and crush a person, such as an elevator car. And, exposed live electrical equipment and uninsulated conductors inside of a confined space could also present a serious safety hazard to entrants. 

A confined space with a high internal temperature, such as a furnace, oven, or boiler, could represent a serious safety hazard to an employee working inside. So would a confined space containing a steam line or related equipment that could burn or scald an employee who is working on it. And any confined space containing water or some other liquid deep enough for an employee to potentially drown is also a serious safety hazard.

Hazardous equipment used in many work activities conducted inside confined spaces must also be considered for the potential to serious harm a confined space entrant. For example, high-pressure abrasive blasting equipment (e.g.: sand blasting), large abrasive-wheel grinders, and saws with large blades could all cause an entrant to suffer deep cuts or lacerations accompanied by heavy bleeding.

Another example of a potentially serious safety hazard inside a confined space is the presence of highly caustic or corrosive materials that could cause injury to an entrant. Biological or radiation hazards present in high levels inside a confined space could also be dangerous in some situations. Even a reasonable potential for venomous snakes and other dangerous animals or insects must be considered in some work environments, as they could represent a serious safety hazard to an entrant.

There is one more potential safety hazard that OSHA discusses at length in the preamble to the OSHA construction standard for confined space entry, and which could also be applicable in some general industry spaces. That is a low-hanging object, such as a beam or piece of angle iron, that a worker could strike their head on and becoming disoriented, or even being rendered unconscious.

So, when you are evaluating confined spaces for “other recognized serious safety or health hazards,” remember that OSHA explains in the preamble to the standard that their concern here is “any hazards that could impair the ability of an entrant to exit the space without aid.”

Additional Examples of Recognized Serious Safety or Health Hazards in Confined Spaces?

There is no doubt many other examples of recognized serious safety or health hazards that could reasonably be expected to be present inside of confined spaces. So, please provide other examples of “other recognized serious safety or health hazards” with a reasonable potential to be present in confined spaces in the comments section below. You can also ask questions there as well.

Then, be sure to come back later and read our next blog post about steps to be taken when you identify permit-required confined spaces in the workplace; this includes steps that need to be taken even if you or your employees do not enter into permit-required confined spaces.

Last but not least, I encourage you to take a moment and spread the word about our confined space training blog by sharing a link to this post with others in your network, so they too can benefit from this information. Thanks – Curtis

Confined Space Hazards – Trapped by Inwardly Converging Walls or Floors

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Confined Space Inwardly Converging Walls or Floors

Blog Post #15 – In this post to The Confined Space Training Blog, we examine one more reason a confined space in the workplace must be classified as a permit-required confined space. And that is when a confined space has walls that converge inward or floors that slope downward and taper into a smaller area which could trap or asphyxiate an entrant. OSHA explains in their documentation this would occur primarily by compressing the torso of the trapped entrant, making it difficult to escape or to breath.

Examples of Confined Spaces with Potential Entrapment Hazards

Some examples of confined spaces where entrapment such as this could occur include, but are not limited to cyclones, hoppers, and similarly constructed discharge chutes on some storage silos. Large industrial baghouses are another type of confined space that, depending on how they are constructed, could also fit into this category. And in a few cases, relatively large ductwork configured to transition down to a smaller size could create an entrapment issue for an entrant. One final example of where this hazard could be present is in underground stormwater collection and retention systems constructed with floors that slope down toward a small-sized drain opening.

Ironically, many of the hazardous situations for entrapment are not exposed until precautions are taken to eliminate another serious hazard inside of a confined space; engulfment. For example, when emptying the contents of a cone-shaped hopper to eliminate an engulfment hazard, we may expose the entrant to an entrapment hazard in the now-empty space. So, always remain aware that sometimes, we create or expose hazards when we eliminate others.

In review, a confined space having walls that converge inward or floors that slope downward and taper into a smaller area which could trap or asphyxiate an entrant must be classified as a permit-required confined space. Entry into such a space requires confined space training for all affected workers and a permit entry system be in place.

Please provide your feedback and/or questions about this blog post on entrapment hazards in confined spaces in the comments section below. And if possible, please provide some other examples where this particular type of hazard could be present in the workplace. Then, be sure to come back later and read our next blog post (#16), where we will discuss the final category of hazards that can trigger the designation of a permit-required confined space.

And as always, I ask that you take a moment to spread the word about our confined space training blog by sharing a link to this post with others in your network so they can benefit from this information. Thanks – Curtis

Confined Space Engulfment Hazards

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Confined space engulfment hazards

Blog Post #14 – In this post to The Confined Space Training Blog, we will examine another reason a confined space identified at your workplace should be classified as a permit-required confined space. And that is when a confined space contains a liquid or material that could potentially engulf the entrant.

What is Engulfment in a Confined Space?

The Federal OSHA definition of engulfment can be found in 1910.146 paragraph B, and includes confined spaces where the entrant could suddenly be surrounded or captured by liquid, trapped inside the space, and drown in the liquid.

Engulfment in liquid sewer confined space

Engulfment by liquid could occur in sanitary and storm sewers, as well as in any pipelines, utility vaults, or process tanks that could suddenly be filled with liquid.

One other form of engulfment is possible whenever a confined space contains a finely divided solid material, such as pellets, chips, grains, granules, dusts, or powders, that can be aspirated by the entrant once engulfed. his could cause death by filling or plugging the respiratory system. In other cases, the material surrounding the trapped entrant can exert enough force on the body to cause death by strangulation, constriction, or crushing. Regardless of the mode of engulfment, these are all a gruesome way to die!

Confined spaces that contain potential engulfment hazards include, but are not limited to, grain elevators and storage bins, as well as other confined spaces that contain materials such as flour, sawdust, powdered cement, or finely pelletized materials.

How Does Engulfment in a Solid Material Occur Inside a Confined Space?

The illustration below demonstrates how a finely divided material can appear from the top to fill a confined space when, in actuality, a hollow void area could develop beneath the surface. This condition is often referred to as “bridging.”

Engulfment - Material bridging inside a confined space

The weight of the employee can cause the bridged material to collapse, and the worker can fall into the void area and be covered by the flowing material.

In this second illustration, the employee is engulfed when the material, which has clung to the side of the wall inside the confined space, collapses and covers the employee.

OSHA definition of engulfment in a confined space

Recap of Engulfment in a Confined Space

So in review, any confined space containing, or with the reasonable potential to be quickly filled with, a liquid or finely divided material that can engulf the entrant must be treated as a permit-required confined space.

Please provide your feedback and/or questions about this blog post on engulfment hazards in confined spaces in the comments section below. Then be sure to come back later and read our next blog post (#15), where we will discuss additional hazards that can trigger the permit-requirements in confined spaces.

And as always, I ask that you take a moment to spread the word about our confined space training blog by sharing a link to this post with others in your network so they can benefit from this information. Thanks – Curtis

Definition of a Hazardous Atmosphere – Immediately Dangerous to Life or Health (IDLH)

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IDLH

Blog Post #13 – In this post to The Confined Space Training Blog, we will examine the fifth and final category listed in the Federal OSHA definition for a hazardous atmosphere in a confined space, which is an atmosphere that is Immediately Dangerous to Life or Health, or IDLH.

What Does IDLH Mean?

IDLH stands for “Immediately dangerous to life or health”. This term is defined in the Federal OSHA confined space standards as “any condition that would interfere with an individual’s ability to escape unaided from a permit space and that poses a threat to life, or that would cause irreversible adverse health effects.” OSHA goes on to qualify their definition of IDLH by adding that certain substances, like hydrogen fluoride gas and cadmium vapor, can cause immediate, temporary effects that may not require medical intervention, even if they are severe. However, after exposure to high levels of these substances when the affected individual may appear to have fully recovered from the initial symptoms, these diminished effects are followed by a sudden and potentially fatal collapse within twelve to seventy-two hours of over-exposure. Therefore, materials with these characteristics present in hazardous amounts are also categorized as immediately hazardous to life or health (IDLH) by OSHA.

For further context, the term IDLH is also found in the Federal OSHA respiratory protection standard at 1910.134, where it is defined as “an oxygen deficient atmosphere, or, any atmosphere of unknown composition.” And in the Federal OSHA HazWoper standard (1910.120), IDLH is defined as “an atmospheric concentration of any toxic, corrosive or asphyxiant substance that poses an immediate threat to life or would cause irreversible or delayed adverse health effects or would interfere with an individual’s ability to escape from a dangerous atmosphere.”

NIOSH IDLH Values

Federal OSHA does not quantify IDLH levels or concentrations of specific airborne toxic substances in 1910 Subpart Z like they do for their permissible exposure limits (or PELs). However, other agencies and groups do list IDLH values for specific chemicals; the primary one in the USA being NIOSH, aka the National Institute for Occupational Safety and Health. NIOSH defines IDLH as an atmospheric concentration of a specific airborne substance “that poses a threat of exposure to airborne contaminants when that exposure is likely to cause death or immediate or delayed permanent adverse health effects or prevent escape from such an environment.”

NIOSH considered two factors while determining their IDLH limits. Firstly, they wanted to ensure workers would be able to exit the area where they came into contact with dangerous chemicals without enduring lasting harm to their health. And secondly, they wanted workers to be able to escape without experiencing severe eye or respiratory tract irritation (or other conditions) that could hinder their ability to evacuate.

NIOSH currently lists IDLH values for more than 380 substances. Here is a table displaying a dozen common substances and their assigned NIOSH IDLH values as originally assigned in 1994, and as updated, where applicable, in 2016.

IDLH NIOSH

Many of these substances listed above have a Federal OSHA PEL based on an 8-hour time-weighted average (TWA), but do not have a short-term exposure limit (STEL), which is based on a 15-minute average exposure, or a ceiling limit (C), which is based on instantaneous exposure. Therefore, in some cases brief exposures to certain substances (Carbon Monoxide being one of them) may not exceed the OSHA PEL, but could exceed the NIOSH IDLH value.

Other Types of IDLH Atmospheres

Last but not least, some of the other types of “hazardous atmospheres” discussed in the preceding blog posts could also be considered to be IDLH if present in high enough quantities. For example, an atmosphere that is oxygen deficient would certainly be classified as IDLH, as would an atmosphere containing a flammable gas or vapor at levels exceeding 10% of its LEL (or LFL); see Ethyl alcohol on the NIOSH list for one such example. And in certain cases, it could be possible that an atmosphere that is extremely hot (from steam or other heat sources) could incapacitate a person should super-heated air damage their lungs or trachea when inhaled.

Review of OSHA’s Definition of a Hazardous Atmosphere

In review, a confined space containing a hazardous atmosphere, or with a reasonable potential for a hazardous atmosphere to develop, is considered a permit-required confined space. And OSHA lists five different categories of potentially hazardous atmospheres inside a confined space.

The first one is when any flammable gas, vapor, or mist is present in a quantity greater than 10% of its LFL; Next is when airborne combustible dust is present at quantity greater than, or equal to, its LFL; A hazardous atmosphere also exists when the atmospheric oxygen concentration drops below 19.5%, or rises above 23.5%; as well as when a toxic substance is present in a quantity greater than it’s permissible exposure limit, or PEL. Finally, the atmosphere in a confined space is classified as hazardous whenever it is determined to be immediately dangerous to life or health, or IDLH.

Please provide your feedback and/or questions about this blog post on IDLH atmospheres, or about any of the other type(s) of hazardous atmospheres, in the comments section below. Then be sure to come back later and read our next blog post (#14), where we will discuss engulfment hazards in confined spaces. And as always, I ask that you take a moment to spread the word about our confined space training blog by sharing a link to this post with others in your network so they can benefit from this information. Thanks – Curtis

Definition of a Hazardous Atmosphere – Toxic Substance Exceeding the OSHA PEL

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OSHA Hazardous Atmosphere Toxic PEL

Blog Post #12 – In this post to The Confined Space Training Blog, we will examine the fourth category listed in the Federal OSHA definition for a hazardous atmosphere, which is an atmosphere that contains any toxic substance present in quantity greater than its permissible exposure limit, or PEL.

Before moving on, make certain to pay close attention to an important footnote to this definition in the OSHA definition section for this standard. OSHA states that this category of hazardous atmosphere only applies “if the topic substance can cause death, incapacitation, impairment in ability to self-rescue, injury, or acute illness due to its health effects.”

For example, exposure to ammonia in the atmosphere at levels above its PEL for an extended period of time would cause the entrant to experience burning eyes and throat, difficulty breathing, and make it extremely difficult to function normally; exposure to extremely high levels could even lead to death. This condition would meet the definition of a hazardous toxic atmosphere in the confined space standards. However, exposure to silica or asbestos at levels over their respective PELs, although harmful in the long term, would typically not cause any immediate reaction. So, overexposure to those particular substances would not meet the definition of a hazardous atmosphere as defined in the OSHA confined space standard (although normal protective measures required by other OSHA standards would still be applicable).

What are OSHA PELs?

The term PEL represents the maximum exposure level for a particular contaminant that an employee may be exposed to at work, averaged over a specified period of time, without suffering negative health effects or needing to take protective measures such as use of a respirator. PELs for various contaminants are established by Federal OSHA and are listed in different parts of the OSHA code of federal regulations.

Part 1910 lists the PELs that apply to general industry worksites. Part 1926 for construction and Part 1915 for shipyards also have PELs, and some of those may differ from those listed in Part 1910. In addition, many states operate their own OSHA approved state program. Some have adopted the federal OSHA PELs, but a few states have established their own PELs, some which are lower than federal OSHA’s.

In addition to the mandatory OSHA PELs, there are some other voluntary limits that you may hear mentioned. For example, The American Conference of Governmental Industrial Hygienists, or ACGIH, has developed threshold limit values, or TLVs, for many substances. And The National Institutes of Occupational Safety and Health, or NIOSH, developed recommended exposure limits, or RELs, for many substances. These are based on more recent research than the OSHA PELs in many cases, and may be set lower (or higher) than the OSHA PEL for some substances.  Employers MAY voluntarily choose to utilize these lower limits instead. Also, these voluntary limits are often utilized when OSHA has not established a mandatory PEL for a specific substance.

The permissible exposure limits for most individual substances in gas and vapor form are presented as parts per million, or PPM, which is a way to measure very small quantities of toxic air contaminants at a molecular level. The more toxic the substance, the lower the PEL. For example, the 1910 General Industry permissible exposure limit for ammonia is 50 ppm.

To help visualize the concept of substances being measured in parts per million, or ppm, consider this; if a contaminant evenly dispersed in a space makes up one half of the total atmosphere in that space, it would be measured at 500,000 ppm. If the substance made up 5% of the total atmosphere, it would be measured at 50,000 ppm, and if a substance made up 1% of the total atmosphere, it would measure at 10,000 ppm. A substance making up one tenth of 1% of the total atmosphere would measure at 1,000 ppm, and a substance making up one one-hundred-thousandth of a percent would be measured at 10 ppm. And a few substances are so toxic, their permissible exposure limits are actually measured in parts per billion, or PPB.      

The table below shows the federal OSHA PELs for a few common toxic substances found in some confined spaces.

OSHA Permissible Exposure Limits Confined Spaces

Different Types of OSHA PELs

Unless noted otherwise, OSHA permissible exposure limits are based on an “eight-hour time-weighted average,” also known as TWA.  8-hour TWA means that the employee exposure to the substance is averaged over an eight-hour work shift. For example, the OSHA PEL for acetone is listed as 1,000 ppm, which is averaged over 8 hours.

Some permissible exposure limits are appended with a designation of ST or STEL, which stands for “short term exposure limit.” This is an exposure limit that is averaged over a shorter, 15-minute time period, as opposed to the 8-hour period. For example, the PELs for benzene are listed as 1 ppm based on an 8-hour TWA, but a STEL of only 5 ppm.

A few other substances are marked with the letter C, which stands for ceiling limit. For example, the PEL for chlorine is a ceiling limit of only 1 ppm. This limit is instantly reached any time the employee is exposed to the substance at the level specified.

It is important for employers to identify the toxic substances that employees may be exposed to when entering confined spaces. It is also important for entrants and attendants to know about the modes of exposure, as well as the signs and symptoms of overexposure, to toxic substances. This information can usually be obtained from each substance’s safety data sheet, or SDS.

Toxic Atmospheres in Confined Spaces

So, in review, a hazardous atmosphere exists where a toxic substance is present in a quantity greater than its permissible exposure limit (PEL). This can occur in confined spaces such as, but not limited to, tanks and vessels where a toxic product has been stored or is being utilized, and in underground spaces, such as crawl spaces, utility vaults and sewers, where a hazardous substance such as hydrogen sulfide (H2S) can migrate into the space.

Also, toxic gases such as CO can be created by equipment such as generators, chop saws, and compactors that are powered by internal combustion engines. As a reminder, if there is a hazardous substance for which OSHA has not established a PEL, refer to that substance’s safety data sheet, or SDS, for exposure recommendations and guidelines.

In our next blog post (#13), we will examine the fifth and final criteria of a hazardous atmosphere that could be present inside of a confined space (any other IDLH atmosphere). In the meantime, please provide your feedback to this blog post about toxic atmospheres in the comments section below.

And as always, I hope you will take a moment to spread the word about our confined space training blog by sharing a link to this post with others in your network so they can benefit from this information. Thanks – Curtis

Definition of a Hazardous Atmosphere – Oxygen Deficiency or Enrichment

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Oxygen deficient atmosphere

Blog Post #11 – In this post to The Confined Space Training Blog, we will examine the third category listed in the Federal OSHA definition for a hazardous atmosphere, which is an atmospheric concentration of oxygen less than 19.5%, or greater than 23.5%.

Atmospheric Composition

Oxygen is critical to support human life. However, under normal conditions, over 78 percent of the air we breathe is actually comprised of nitrogen, which is an inert gas. And oxygen, commonly referred to as O2, makes up approximately 20.9% of the atmosphere.

OSHA hazardous atmosphere oxygen enrichment or oxygen deficiency

If oxygen levels were to fluctuate slightly, there would most likely be no ill effects on a healthy person. However, a greater decrease or increase in oxygen levels could prove to be harmful; even deadly.

So, OSHA sets the threshold for an oxygen deficient atmosphere at anything less than 19.5% oxygen, and the threshold for an oxygen enriched atmosphere is reached when the O2 levels exceed 23.5%.

What Can Cause an Oxygen Deficient Atmosphere?

One way an atmosphere may become oxygen deficient is if the oxygen gets consumed. One cause of oxygen consumption is flames. A flame must have adequate oxygen to burn. As the flame burns, the oxygen is consumed. That is why the flame on a small candle will slowly extinguish if you cover the candle with a glass, preventing it from getting more oxygen. Similarly, a poorly ventilated confined space in which there has been a flash fire, or where flame producing equipment is present, could become oxygen deficient.

Oxidation is another cause of oxygen deficiency. When metal rusts, that process, called oxidation, consumes oxygen. So does the process of concrete curing. Therefore, confined spaces with a rusty interior surface, or confined spaces formed with freshly poured concrete, could also become oxygen deficient over time.

An oxygen deficient atmosphere can also be created by displacement of the atmosphere, which can occur if another gas fills up the confined space and supplants the oxygen. This happens inside sewers and underground vaults quite often, when naturally-occurring Methane gas seeps into the space. Another way for this to occur is when another gas is accidentally introduced into a confined space through a leaking pipe, cracked hose, or partially open valve. For example, a leaking hose containing Argon or other inert shield gases used during some welding processes is one potential cause of oxygen displacement inside a confined space.

In relatively rare cases, an inert gas is introduced into a confined space purposely, to displace oxygen. This can help prevent materials inside the space from oxidizing. Purging the space with an inert gas can also prevent a highly-flammable atmosphere from igniting during entry operations.

Another way oxygen can be displaced is when certain chemicals are mixed inside of a confined space. For example, mixing vinegar and baking soda creates a bubbly concoction that releases carbon dioxide gas when the bubbles burst. When these or other reactive chemicals are present in great enough quantities, the resulting chemical reactions could release gases that eventually build up to levels high enough to displace oxygen in the confined space.

A less common cause of oxygen deficiency is adsorption. Some manufacturing processes utilize activated charcoal filters to capture unwanted gases. Sometimes a portion of the oxygen adheres to the activated charcoal, which can result in lower oxygen levels in the air.

Effects of Oxygen Deficiency

The effects of oxygen deficiency on a person vary as the level of oxygen drops. In reality, most people in good health would probably not perceive much, if any, ill effect when oxygen levels drop to 19.5%, the threshold of oxygen deficiency. However, when oxygen levels drop to around 16%, the entrant may start suffering the symptoms of hypoxia, where they find it harder to breathe and start to become nauseous and drowsy. When oxygen levels drop to 12% or less, the entrant will become unconscious, and when oxygen levels drop to 6% or less, brain cells begin to deteriorate, and death occurs through asphyxiation.

What is an Oxygen Enriched Atmosphere?

When oxygen levels inside a confined space exceed 23.5% by volume, an oxygen enriched atmosphere is present. One common reason this occurs is because pure oxygen is introduced into the space, either accidentally or on purpose.

Leaking hoses, pipes, or valves on equipment that utilize pure oxygen can result in an oxygen enriched atmosphere inside a confined space. That is why the OSHA welding and cutting standards require an oxy-fuel cutting torch be removed from inside a tank or other enclosed space when not in use.

In other cases, pure oxygen is used to ventilate a confined space with an oxygen deficient atmosphere. This should never be done, as the result can be the introduction of too much oxygen into the confined space. To control an oxygen deficient confined space, blow fresh air into the space using a ventilation fan or blower stationed outside the space. And never place oxygen cylinders, or any other gas cylinders, inside of a confined space, as their contents could leak into the space and adversely affect oxygen levels.

Effects of Oxygen Enrichment

So, why is too much oxygen a bad thing? Primarily, it is because oxygen accelerates the combustion process. In an oxygen enriched atmosphere, the oxygen can saturate the worker’s clothing or other combustible materials inside the space. Then, a single spark from a grinder, torch, or even static electricity can ignite the oxygen-saturated items, which will cause them to burn rapidly.

OSHA Requirements for Oxygen Levels in a Confined Space

In review, an oxygen deficient atmosphere occurs when oxygen levels drop below 19.5% of the atmosphere by volume, and an oxygen enriched atmosphere occurs when oxygen levels exceed 23.5% of the atmosphere by volume.

Oxygen deficiency can occur in many confined spaces, including, but not limited to, tanks and similar vessels that have contained a product whose vapors could displace the oxygen, or that are subject to having the inside purged with an inert gas such as nitrogen. These conditions could also occur inside sewers and underground utility vaults where methane or other naturally occurring gases could collect and displace the oxygen. And oxygen enrichment can occur inside confined spaces into which oxygen accidentally leaks, or where it is introduced into the space on purpose.

In our next blog post (#12), we will examine the fourth criteria of a hazardous atmosphere that could be present inside of a confined space (a toxic atmosphere). In the meantime, please provide your feedback to this blog post about oxygen deficient and oxygen enriched atmospheres in the comments section below.

And as always, I hope you will take a moment to spread the word about our confined space training blog by sharing a link to this post with others in your network so they can benefit from this information. Thanks – Curtis

Definition of a Hazardous Atmosphere – Airborne Combustible Dust =/> LFL

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Combustible dust LFL

 Blog Post #10 – In this post, we will examine the second category listed in the Federal OSHA definition for a hazardous atmosphere, which is an atmosphere with airborne combustible dust at a concentration that meets or exceeds its LFL (which stands for Lower Flammable Limit). LFL represents the minimum quantity of combustible dust that must be suspended in the air within the space to be able to cause a flash fire or dust explosion if ignited. In these conditions, the airborne dust is considered to have met or exceeded its lower flammable limit, or LFL.

OSHA’s 5-foot Rule of Thumb for Dust Measurement

The LFL of combustible dusts depends on many factors, including the type of material that makes up the dust, the size of the dust particles, the moisture content in the dust particles, and the density of the dust particles within the airspace.

There are instruments available that can measure the amount of combustible dust in the air to determine if it meets or exceeds its Lower Flammable Limit (LFL). However, for airborne dust measurement purposes, OSHA’s definition of a hazardous atmosphere due to airborne combustible dust refers to the use of the “5-foot rule of thumb”. That means that if the combustible dust suspended in the air is so dense that the entrant cannot see more than five feet from the end of their nose, there is a high risk of a flash fire or dust explosion.

In cases where this condition exists, or is likely to exist, inside of a confined space at any time during entry operations, it must be classified as a permit-required confined space.

Examples of Combustible Dusts

Here are examples of some, but not all, of the various types of airborne combustible dusts that could be present inside of some confined spaces during entry operations: Aluminum powder, dust from animal feed, coal dust, corn starch, cosmetic powders, dry fertilizer dust, dust from dry food and spices (coffee, tea, flour . . .), grain dust, powdered metal, plastic dust, powdered chemicals, rubber dust, sugar dust, textile fibers, and wood dust.

How Dust Fires and Explosions Occur

Combustible dust flash fires, a process called deflagration, is a rapid combustion process that produces a flame front which can quickly spread through a dust cloud if the concentration of combustible dust in the air is dense enough. And in some cases where the airborne dust fire is contained within a confined space, pressure quickly builds and an explosion can occur.

Here is a brief overview of the steps leading up to a combustible dust flash fire and explosion inside a confined space:

  1. A cloud of combustible dust is created in the air within a confined space, either through a process like grinding, mixing or other material handling activities, or by a settled dust being disturbed by other work activities such as cleaning with compressed air.

  2. A small portion of dust within the cloud is then ignited by a spark, flame, or other ignition source. Even static electricity must be considered as an ignition source.

  3. If the airborne combustible dust cloud is dense enough, the burning dust particles spread to others nearby, and those in turn ignite other airborne particles, resulting in a fire quickly spreading through the dust cloud. This process is called deflagration.

  4. The rapid spread of burning dust particles not only causes temperature inside the confined space to rapidly rise, it also creates a pressure wave that increases the internal pressure within the confined space.

  5. In the right conditions, the pressure wave can cause an explosion, leading to severe damage to the structure of the confined space.

  6. The burning dust cloud can continue to burn and expand. And the percussion from additional explosions may lead to more combustible dust inside the space being introduced into the air, adding even more fuel to the fire.

When a dust fire or explosion occurs, it can obviously lead not only to structural damage, but possible injury or death to anyone nearby. See an example of a dust explosion in this YouTube video showing a grain elevator explosion.

Classify All Confined Spaces with Potential for Airborne Dust Fires or Explosions as Permit-required Confined Spaces

So, consider the confined spaces present at your workplace, and take care to identify those with an actual or reasonable potential for a dense cloud of airborne combustible dust developing during entry operations, as those spaces will have to be classified as permit-required confined spaces.

Here are examples of some, but not all, types of confined spaces that, depending on materials they have contained, could produce heavy levels of airborne combustible dust during entry operations:

  • Conveyor systems
  • Cyclone separators
  • Duct work and air-handling systems
  • Dust collectors and bag houses
  • Grain storage bins, elevators, and silos
  • Hoppers and chutes
  • Mixers and blenders
  • Ovens and furnaces
  • Powder processing equipment such as mills and pulverizers
  • Truck and rail-car hoppers and tanks

In our next blog post (#11), we will examine the third criteria of a hazardous atmosphere that could be present inside of a confined space (oxygen deficiency or enrichment). In the meantime, please provide your feedback and questions to this blog post about airborne combustible dust at levels exceeding its lower flammable limit, or LFL, in the comments section below.

And as always, I hope you will take a moment to spread the word about our confined space training blog by share a link to this post with others in your network so they can benefit from this information.  Thanks – Curtis

Definition of a Hazardous Atmosphere – Flammable Gas, Vapor or Mist >10% LFL

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Hazardous atmosphere flammable gas vapor or mist greater than 10% LFL or LEL

 Blog Post #9 – In previous blog posts, we discussed how to identify confined spaces, and provided several examples of such spaces. Next we will examine the factors that determine whether or not each confined space identified at your workplace must be classified as a permit-required confined space, starting with a hazardous atmosphere that contains a flammable gas, vapor, or mist in excess of 10% of its lower flammable limit, or LFL.

 OSHA Definition of a Permit-required Confined Space

The Federal OSHA definition of a permit-required confined space for general industry can be found in 1910.146, paragraph B, titled definitions, and in 1926.1202, also titled definitions, for the construction industry. That is where OSHA lists the four types of hazards that require a confined space be classified as a permit required confined space. Those four types of hazards are:

  • The space contains an actual or potential hazardous atmosphere;

  • The space contains a material with the potential to engulf the entrant;

  • The space is configured to trap or asphyxiate the entrant; or;

  • The space contains some other recognized serious safety or health hazard.

 What is a Hazardous Atmosphere?

 The Federal OSHA definition for “hazardous atmosphere”, the first classification listed above, is also found in 1910.146, paragraph B, definitions, for general industry, and in 1926.1202, definitions, for the construction industry.

There are five different types, or classifications, of hazardous atmospheres, listed in these two OSHA definitions. Those classifications, which are nearly identical in the two standards, are:

 (1) – Flammable gas, vapor, or mist in excess of 10 percent of its lower flammable limit (LFL);

 (2) – Airborne combustible dust at a concentration that meets or exceeds its LFL;

 (3) – Atmospheric oxygen concentration below 19.5 percent or above 23.5 percent;

 (4) – Atmospheric concentration of any substance for which a dose or a permissible exposure limit is published in subpart G, Occupational Health and Environmental Control, or in subpart Z, Toxic and Hazardous Substances, of this part and which could result in employee exposure in excess of its dose or permissible exposure limit;

 (5) – Any other atmospheric condition that is immediately dangerous to life or health.

 The balance of this particular blog post focuses on the first category of a hazardous atmosphere listed above, which is a flammable gas, vapor, or mist greater than 10% of its lower flammable

Greater Than 10 Percent Lower Flammable Limit (LFL)

 OSHA includes this type hazard because they do not want employers to wait until conditions are ripe for a flash fire or explosion to occur inside of a confined space before taking precautionary measures. Atmospheric conditions inside a confined space that contain a low level of flammable gas, vapor, or mist could quickly change for the worse. Therefore, OSHA regulations classify a flammable gas, mist, or vapor present inside a confined space at levels over 10% of its LFL as a hazardous atmosphere. Once that level is reached inside a confined space, or if there is a reasonable probability that it will develop within the space during entry operations, that space must be classified as a permit-required confined space.

 Lower Flammable Limit (LFL) Explained

 So, what is LFL? It stands for Lower Flammable Limit. The LFL is the minimum amount of a particular flammable gas, vapor, or mist that must be present in the atmosphere to ignite and burn. If you introduce an extremely small amount of a flammable gas, vapor, or mist into the atmosphere of a confined space, it might not ignite when exposed to an ignition source (such as a spark or flame) because there is not enough of the material present to form a flammable mixture in the air. How much flammable gas, vapor, or mist is needed in the atmosphere for a fire or explosion to occur? That depends on the gas, vapor, or mist present inside either space, as they all have a different LFL.

 What is LEL?

Be aware the term “LFL” is also referred to as “LEL”, or Lower Explosive Limit. The terms LFL and LEL are basically interchangeable. While OSHA uses LFL in their confined space standards, LEL is commonly used by many gas detection equipment manufacturers, as well as in many written confined space entry programs. Also, I may on occasion use the term LEL throughout future blog posts.

 LFLs of Common Flammable Gasses

The LELs of a few common combustible materials are listed in the chart below. An LEL is expressed as a percentage of the atmosphere within the confined space that is comprised of a particular combustible gas, vapor, or mist. For example, the LEL of Methane gas, with the chemical identifier of CH4, is 5% of the atmosphere at any given point. As you can see, the LELs of various gases differ quite a bit. 

Upper and lower flammable limits of common gasses

What does UFL mean?

Note that each of the combustible materials listed in the chart also have their own UFL, or Upper Flammable Limit (expressed in the chart as an UEL). If a flammable gas, vapor, or mist is present in the atmosphere in quantities greater than its UFL, it will not ignite and burn. I bring up this term because while OSHA does not regulate UFLs, they do come into play when we discuss gas detection equipment in later blog posts.

Flammability Characteristics of Methane Gas

As mentioned earlier, the LFL of Methane gas is 5%. So, if Methane gas is present in a confined space, but it does not make up at least 5% of the atmosphere at any point within the space, there will be no flash fire or explosion if there is a spark or other source of ignition. And the upper flammable limit, or UFL, of Methane gas is 15%; So, a confined space containing higher levels of Methane would not burn or explode either. However, if the amount of Methane gas increases or decreases to fall somewhere between its LFL and UFL at any point inside a confined space and there is any source of ignition in that same area, a fire or explosion will occur.

Since Methane gas has an LFL of 5% of the atmosphere, a hazardous atmosphere as defined by OSHA would be present inside a confined space if the amount of Methane gas in the atmosphere exceeds 10% of that level. The presence of that level of Methane gas, which equates to just 0.5% of the total atmosphere, means the space would have to be classified as a permit-required confined space.

Other Hazards Associated with Methane Gas

Before moving on, let’s take a moment to discuss Methane gas, or CH4, a little more, as this is a hazardous gas commonly found in a variety of confined spaces. Methane is a colorless, tasteless gas that has no odor, so its presence cannot be detected by your senses alone. But too much Methane gas inside of a confined space creates not only a potentially flammable atmosphere, as previously discussed, it can also displace oxygen in the space, creating a deficiency of oxygen for an entrant to breathe. Fortunately, while Methane is a highly flammable gas that can also displace oxygen, it is one of the few flammable gases that is not toxic.

Where is Methane Gas Commonly Found?

Methane is created when organic matter decomposes. Therefore, it is commonly found in potentially harmful quantities within confined spaces such as sewers and related facilities, manure pits, and in silos that have held grain or similar materials that has rotted. Methane is also commonly found in confined spaces such as underground utility vaults, especially those located near landfills (the rotting trash creates Methane). Therefore, these spaces are typically classified as permit-required confined spaces.

More Examples of Confined Spaces With Potentially Flammable Atmospheres

Other examples of confined spaces with a reasonable potential to contain an atmosphere containing a flammable gas, vapor, or mist above 10% of its LFL include pipelines, tanks and other vessels that have contained fuels or other flammable or combustible materials, even when they have been emptied of their contents. Also, confined spaces where work processes such as cutting with an oxy-acetylene torch or painting with flammable paints and solvents is taking place inside could potentially contain a hazardous atmosphere. And confined spaces such as vaults or tunnels in which there are leaking valves or piping used to transport flammable gas could also contain a hazardous atmosphere. As such, each of these spaces would also likely be classified as a permit-required confined space.

So, in review, any confined space with an actual flammable gas, vapor, or mist present at levels greater than 10 percent of its lower flammable limit, or LFL, is considered to have a hazardous atmosphere. And that means the space must be classified as a permit-required confined space. The same is true for any confined space in which that level of a flammable atmosphere could reasonably be expected to develop during entry operations. You may also hear the term LEL, which stands for lower explosive level, being used to describe a hazardous flammable atmosphere inside a confined space, as that term is synonymous with LFL.

In our next blog post (#10), we will examine the second criteria of a hazardous atmosphere that could be present inside of a confined space (combustible dust). In the meantime, please provide your feedback and questions to this blog post in the comments section below. And as always, I urge you to share a link to this confined space training blog post with anyone in your network who could benefit from this information. Thanks – Curtis

Difference Between Permit Required Confined Spaces and Non-Permit Required Confined Spaces

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Difference between permit-required confined space and non-permit-required confined space

 Blog Post #8 – In this post to The Confined Space Training Blog, we will discuss the differences between a confined space that meets the Federal OSHA definition of a permit-required confined space versus one that can be classified as a non-permit required confined space.

Why make the distinction between permit and non-permit required confined spaces? Because entry into that space classified as a permit-required confined space is only allowed under an entry program meeting all pertinent requirements of the OSHA permit-required confined space entry standard. However, confined spaces that do not meet the OSHA definition of a permit space, which are called non-permit required confined spaces, may be entered without having to follow those additional precautions.

Criteria of a Permit-required Confined Space per the OSHA Definition

According to OSHA, a space is classified as a permit-required confined space if it meets one or more of the following characteristics:

  1. The space contains an actual or potential hazardous atmosphere;

  2. The space contains a material with the potential to engulf the entrant;

  3. The space is configured to trap or asphyxiate the entrant; or;

  4. The space contains some other recognized serious safety or health hazard.

We will break down each one of these four characteristics in subsequent blog posts. But for now, just be aware that it only takes one of these characteristics to be present, or reasonably expected to be present, for a confined space to be classified as a permit required confined space. Also, a permit-required confined space may contain two or more of these characteristics, and they all need to be identified so the hazards can be adequately addressed before entry operations begin.

What is a Non-permit Required Confined Space?

But what if the confined space does not meet any one of the four characteristics listed above? Then it could be classified as a non-permit space. According to the OSHA definitions in 1910.146 and in 1926 subpart AA, a non-permit required confined space is “a space that meets the definition of a confined space, but does not meet the requirements for a permit-required confined space, as outlined by the OSHA standard.”

When Re-evaluation of a Non-permit Space is Necessary

Keep in mind, however, that an employer must re-evaluate a non-permit required confined space if there are any changes to the use or configuration of that space that might increase the hazards to entrants, or if there is some indication that the initial evaluation of the space may not have been adequate. And if an actual or potential hazard is identified, the space must be reclassified as a permit-required confined space at that time.

For example, if a stainless-steel process tank is newly installed and has never held any material, and it has no agitators inside the tank or fill lines attached, it could be classified as a non-permit required confined space because it does not contain any health or safety hazards. However, if an employee needs to enter the tank to conduct an inspection and must decontaminate the inside of the tank before exiting by wiping it with isopropyl alcohol, which is flammable and toxic, the tank must be temporarily reclassified as a permit-required confined space during the performance of this task.

Reclassification of a Permit-required Confined Space to a Non-permit Confined Space

Last but not least, there are some opportunities where an employer who needs to enter into a permit-required confined space can implement steps to isolate the space from its hazards, allowing it to be temporarily reclassified as a non-permit confined space for as long as those hazards remain eliminated. More on that subject in a later blog post (#19).

Why it is Important to Properly Classify All Confined Spaces

Again, employers need to evaluate each confined space at their worksites to distinguish if it must be classified as a permit-required confined space, which requires implementation of a full permit-required confined space entry program, or if it can be classified as a non-permit required confined space. In the latter case, the space does not have to be identified with a warning sign, no permit is required to be filled out prior to entering the space, and no precautions listed in the OSHA permit-required confined space standards need be taken unless changes to the space or entry operations present an actual or potential hazard.

In our next blog post (#9), we will start examining what constitutes a hazardous atmosphere inside of a confined space. In the meantime, please provide your feedback and questions to this blog post in the comments section below. And as always, I urge you to share a link to this blog post with anyone in your network who could benefit from this information. Thanks – Curtis

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Examples of Confined Spaces Per OSHA Definitions

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Examples of confined spaces per OSHA definitions

Post #7 – In the previous post to the Confined Space Training Blog (#6), we examined the OSHA definition of a confined space, with in-depth explanations of the three criteria that make up a confined space per the definitions in the OSHA 1910 and 1926 confined space regulations. In this post, we will follow up by providing several examples of potential confined spaces you may find in the workplace; some expected, and some not.

Keep in mind that while these examples list below are but a few of the different types of confined spaces that could be present in the workplace, they may or may not be examples of permit-required confined spaces. We will discuss how to make that determination beginning in our next blog post.

Tanks, Bins, and Silos

Tanks of various types and sizes that are large enough to be bodily entered, and which are entered through a portal or other restricted opening on the bottom, side, or top, would be considered confined spaces. This includes many fuel tanks, water tanks, and even elevated water towers which are often entered vertically through a portal on top.

Silos that are large enough to be bodily entered through a man-way or hatch on the top, side, or bottom could be considered a confined space, as would be similarly constructed storage bins and hoppers.

Various types of tanks that are mounted on trailers are often considered confined spaces if they are large enough to be bodily entered and have a restricted means of entry or exit, as are many such tanks that are mounted directly onto a truck chassis. The same applies to similarly-configured tank rail cars that are pulled by locomotives and hopper cars of certain configurations. And concrete mixers would qualify as a mobile type confined space as well.

Industrial Equipment and Fixtures

Large furnaces and related equipment, which are constructed in certain configurations that make them hard to get into and out of, could also be considered confined spaces if they are large enough to be bodily entered by a worker. Some smokestacks and chimneys associated with furnaces, as well as incinerators and other burning processes, would be considered confined spaces if the worker must bodily enter them through a hatch, ladder, or other restricted means of entry.

Some pieces of fixed equipment, such as a large industrial mixing vat that can be bodily entered and has a restricted means of entry or exit, are considered confined spaces. In addition, many large boilers that are configured to be bodily entered through a restricted means of entry or exit are also considered confined spaces.

One commonly overlooked type of confined space is large air handlers, where the worker bodily enters through an access panel and climbs inside to perform work. Other examples of confined spaces include the associated ductwork if it is large enough for a worker to bodily enter through an access panel or hatch, or where the worker crawls through an open end to travel into the duct.

Conveyor tunnels that are large enough to be bodily entered and have a limited means of entry or exit would be considered a confined space, too. And don’t overlook trash or materials compactors, balers, and crushers that are configured as confined spaces.

Pits

Open-top pits that are deep enough to require the worker to enter or exit by a ladder or similar methods, or are too deep for the worker to easily step out of would be considered a confined space. And many escalator pits that are large enough for the worker to bodily enter, and that are deep enough that a worker would have difficulty getting in or out once the cover over the pit has been removed to facilitate entry, would also be considered confined spaces.

Many elevator shafts and pits are confined spaces that are deep enough or otherwise configured to require the worker to enter and exit on a ladder or via some other restricted means of entry or exit, are confined spaces.

Large dock levelers that are designed with a front cover or top that opens enough to allow a worker to crawl inside the pit beneath to perform maintenance or repairs on that equipment would be considered confined spaces.

Sewers, Vaults, and Other Underground Installations

Sanitary sewers which are large enough to be bodily entered qualify as confined spaces, as are many related facilities like sewer digesters, and some sewer lift stations.

Similarly, storm sewers that are large enough to be bodily entered and have a restricted means of entry or exit are considered confined spaces, as are many drainage culverts.

A related example of a confined space is a septic tank that is large enough for the worker to enter and has a restricted means of entry and exit. The same applies to many larger grease traps.

Most in-ground utility vaults that are entered via a hatch or manhole opening and that have not been designed for continuous occupancy are typically considered a confined space, as would be many wells.

Most pipelines, whether underground or not, are large enough to be bodily entered and have a restricted means of entry or exit, such as a portal, man-way, or an open-end small enough to require the worker to crawl or stoop to enter, qualify as a confined space. And even when a large bore pipeline has an open end and the worker can enter and exit upright, the pipeline would still be considered a confined space if the worker must travel a distance far enough to where they might not be able to get out in time should an emergency develop, thereby creating a restricted means of exit.

Tunnels and Crawl Spaces

Utility tunnels that have pipes, ducts or similar obstructions that require the entrant to crawl under or over them to exit the space could be considered a confined space, as would a long utility tunnel that requires the entrant to travel a great distance to get to the nearest means of egress.

Many crawl spaces located beneath buildings, floors, equipment, in between walls, and above some ceilings are also considered confined spaces.

Are Attics Confined Spaces?

If an attic space requires the worker to climb a ladder and squeeze through an opening to get inside it could be classified as a confined space.

Examples of Confined Spaces

These are but a few examples of confined spaces, and there are many others that were not mentioned here. If you take a few moments to think about it, you can probably come up with a list of all of the different types of confined spaces typically present at your workplace. And remember, it’s not just confined spaces that are part of the facilities, but also mobile confined spaces such as tanks transported by trucks and railcars, as well as confined spaces that are created during manufacturing or construction processes.

In our next post, we will begin exploring the criteria that determine whether or not each of these confined spaces (and others) must be categorized as a permit-required confined space, or if they are what OSHA calls a non-permit confined space.

Please add your comments to this post in the section provided. And please spread the word about our blog by sharing this post with others in your network. Thanks – Curtis

Understanding the OSHA Definition of a Confined Space

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OSHA Confined Space Definition

Post #6 – Why is it paramount that you understand the OSHA confined space definition? Because OSHA regulates entry into permit-required confined spaces, and the only way to know if you have a permit-required confined space is to first understand whether or not you are even dealing with a confined space as defined by OSHA in their standards.

As you dig deeper into the OSHA confined space standards, you will come to realize that, in addition to the common question of what is the OSHA definition of a confined space, you will no doubt find yourself asking several other questions, such as:

  • What does OSHA mean by “bodily enter”?
  • Does a “limited or restricted means for entry or exit” mean there is only one way in and out of the confined space? and,
  • If there are no hazards present in the space, does that mean it does not meet the definition of a confined space?

Answers to these questions and more are forthcoming in this blog post.

OSHA’s Confined Space Definitions

The OSHA definition of a confined space appears in both the 1910.146 confined space standards for general industry (see section (b) – definitions), as well as in the 1926 Subpart AA confined space standards for construction (see 1926.1202 – definitions). These two definitions are essentially the same, so we will focus on the definition of a confined space found in the general industry rules for now.

According to the OSHA definition of a confined space found in 1910.146(b), a confined space is characterized by three distinct criteria. The standard states that a confined space is a space that:

(1) Is large enough and so configured that an employee can bodily enter and perform assigned work; and,

(2) Has limited or restricted means for entry or exit (for example, tanks, vessels, silos, storage bins, hoppers, vaults, and pits are spaces that may have limited means of entry.); and,

(3) Is not designed for continuous employee occupancy.

Be mindful that all three of these criteria must be in place to meet the OSHA definition of a confined space.  Also, keep in mind that whether or not a hazard is present inside the space is not relevant at this point. You are only trying to determine whether or not you have a confined space at your work site.

The Meaning of “Bodily Enter”

The first criteria listed in OSHA’s definition of a confined space is that the space is large enough and so configured that an employee can bodily enter and perform assigned work. The operative term here is “bodily enter”, which, unfortunately, OSHA does not define in their standards. However, OSHA clarifies on page 4477 of the preamble to the final rule for the 1910.146 confined space standards [Federal Register / Vol. 58, No. 9 / Thursday, January 14, 1993] that the term “bodily enter” means the employee can fit entirely inside the space, and that their confined space rule was intended to cover only spaces that are large enough for the entire body of an employee to enter.

So, to reiterate, if the space is not large enough or configured to where it can be bodily entered, or in other words, if the employee cannot get their entire body inside of the space, then it does not meet the OSHA definition of a confined space. And the OSHA confined space entry standards are only intended to apply to spaces large enough and configured so that the entire body of an employee can fit inside the space.

What is meant by bodily enter in OSHA confined space standard

That being said, don’t buy into the false assumption that entry into a confined space begins only after a person gets their entire body inside of the space, because that is not the case. The OSHA definition of “entry” states that entry is considered to have occurred as soon as any part of the entrant’s body breaks the plane of an opening into the confined space. So, if your space meets the definition of a confined space that can be bodily entered (which means the employee being able to fit their entire body into the space), entry into that confined space is considered to have occurred as soon as any part of their body crosses any plane of entry into that space. Conversely, if the space cannot be bodily entered, then it is not a confined space, regardless of whether or not a worker is able to stick some part of their body into the space.

One final word of caution regarding this topic; don’t think that just because a space cannot be bodily entered and is therefore not covered by the confined space entry standards, that it is exempt from all other OSHA safety or health regulations. For example, we now know that a tank with an entry portal that is too small for a person to bodily enter is not a confined space. However, if the portal is still large enough for a person to stick their head inside, and the tank contains a deadly atmosphere, they could be seriously injured, or perhaps even die; they just wouldn’t have died inside of a confined space. In the case of this particular tank, there are other OSHA regulations pertaining to respiratory protection that would apply to protect the worker who sticks their head inside the tank; those rules just wouldn’t be part of the OSHA confined space entry standards.

OSHA Definition: “Limited or Restricted Means for Entry or Exit”

The second criteria listed in OSHA’s definition of a confined space is that the space has limited or restricted means for entry or exit. There is no definition for this term in the OSHA 1910 permit-required confined space entry standard. Therefore, many people believe the term means that there is only one way in and out of the space. But that is not correct; a confined space may have one entry point, or it may have a dozen.

The OSHA confined space advisor clarifies OSHA’s intent by explaining that a limited or restricted means for entry or exit exist where the occupant must crawl, climb, twist, be constrained in a narrow opening, follow a lengthy path, or otherwise exert unusual effort to enter or leave, or where the entrance may become sealed or secured against opening from inside. Also, the newer 1926 confined spaces in construction standard does include a definition for the term “limited or restricted means of entry or exit” in 1926.1202. That definition states it means “a condition that has a potential to impede an employee’s movement into or out of a confined space”. The definition goes on to explain that examples of a limited means of entry or exit include, but are not limited to, trip hazards, poor illumination, slippery floors, inclining surfaces, and ladders, all conditions which could make it difficult to escape the space should an emergency arise.

Based on the previous information, here is a non-exhaustive list of examples of conditions where a limited or restricted means for entry or exit could exist:

  • Portals where the entrant must squeeze through to enter or exit the space horizontally, as well as where entry is made vertically;
  • Hatches of a size or location requiring the entrant to climb or squeeze through;
  • Manholes that the entrant must pass through an opening to get into or out of the space;
  • A pipeline of a size that requires the worker to crawl to get through the pipe;
  • Spaces such as open top pits or attics where the worker must climb up or down on a ladder to enter or exit the space;
  • Spiral staircases, which can be difficult to climb or descend, which are used to access a space;
  • Steep stairways, such as ships ladders and other non-standard stairways, used to access a space;
  • Tight crawlspaces, such as beneath equipment, under floors, between walls, and above some ceilings; and;
  • An underground utility tunnel where the worker must travel a long distance to get to the nearest exit point.

Is a Door Considered a Limited Means of Entry or Exit?

The question often arises as to whether or not OSHA considers a standard size doorway to be a limited or restricted means of entry or exit. This topic is not specifically addressed in the OSHA 1910 permit required confined space entry standard.  However, In the preamble to the 1910 general industry permit-required confined space standard, OSHA states that “doorways and other portals through which a person can walk are not to be considered a limited means of entry or exit.” However, the preamble goes on to explain that a space containing such a door or portal may still be deemed a confined space if an entrant’s ability to escape from inside the space in an emergency would be hindered.

OSHA further clarifies their position about doorways in a later amendment to the 1910 standard published in the Federal Register, where they state that “even if the door or portal of a space is of sufficient size, obstructions could make entry into or exit from the space difficult. The Agency intended that spaces which otherwise meet the definition of confined spaces, and which have obstructed entry or exits even though the portal is a standard size doorway, be classified as confined spaces.” In other words, a space with a standard doorway (which is a doorway at least two feet wide and at least six and one-half feet in height, according to OSHA’s FAQs page for their confined spaces in construction standard) would be considered to have a limited means of entry or exit if, inside that space, there are pipes, duct work, equipment, or other obstructions or obstacles that would make it difficult for a worker to access the door to escape in the case of an emergency, or if the door could lock and trap the person inside the space.

One more thing to keep in mind at some manufacturing and construction environments is that a large structure being constructed may not have a limited means of entry or exit – at least not initially.

But it may become a confined space with a limited means of entry or exit at a later point during the fabrication or construction process.  For example, an employee can easily walk into and out of a large diameter, horizontally-oriented steel vessel being fabricated if one or both ends are wide open, because no restricted entry or exit exists at that particular point in time. However, once the ends of the vessel are installed and employees must enter and exit the vessel through a portal or similar small opening, a limited means of entry and exit would then exist.

Third Criteria for the OSHA Definition of a Confined Space: Not Designed for Continuous Employee Occupancy

 The third and final criteria listed in OSHA’s definition of a confined space is that the space is not designed for continuous employee occupancy. For example, most underground utility vaults are not designed and outfitted with any safeguards to control a potentially hazardous atmosphere, nor are most underground vaults outfitted with an adequate light source. So, at a minimum, workers would most likely have to utilize a portable blower, auxiliary lighting, and a portable gas detector to safely enter and work inside such vaults.

 On the other hand, there are some underground utility vaults that has been engineered and constructed with a built-in ventilation system, lighting system, and gas detection system to maintain a safe atmosphere. Because such a vault has been designed by engineers for employees to enter and work without the need to implement any safeguards during the duration of their time inside the space, this particular utility vault would not meet this third criteria of the OSHA definition of a confined space, and therefore would not be considered a confined space.

Recap of the Three Criteria of the OSHA Confined Space Definition

 So, in review, here is a recap of the three criteria listed in OSHA’s definition of a confined space:

 Number 1 – the space is large enough and so configured that an employee can bodily enter and perform assigned work (that means the worker can get their entire body inside of the space);

Number 2 – the space has limited or restricted means for entry or exit (that means it would be hard to get into or out of in case of an emergency); and,

Number 3 – the space has not been designed for continuous employee occupancy.

 As a reminder, all three of the criteria listed above must be present for the space to meet the OSHA definition of a confined space. Also, remember that all confined spaces are not necessarily permit-required confined spaces; that is to be determined later.

In our next blog post (#7), we will provide numerous examples of confined spaces, including a few that you might not have thought about. Then, beginning with post #8, we will take a very deep dive into how to determine whether or not the spaces meeting OSHA’s definition of a confined space are to be subsequently classified as permit-required confined spaces, or non-permit confined spaces.

 Final Note: Do you find our confined space entry training blog to be helpful? If so, please send a link to our blog to others in your network who could benefit from this kind of information. Thanks, Curtis

 

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OSHA Requirement for a Competent Person to Identify Permit Required Confined Spaces

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Confined Space Competent Person

Post #5 – The success of an organization’s confined space entry program is ultimately predicated on having a competent person with the ability to identify and evaluate the confined spaces at their work sites to determine whether or not they meet the OSHA definition of a permit-required confined space. And that takes a person with sufficient training and experience to do the job right. But exactly whose job is it to identify and evaluate confined spaces?

Here’s what the OSHA confined space regulations say about that.

OSHA Requirements to Evaluate Confined Spaces

The first paragraphs from the general requirements sections of the OSHA confined space entry standards for general industry and construction, respectively, are listed below:

GENERAL INDUSTRY

1910.146(c)(1) – The employer shall evaluate the workplace to determine if any spaces are permit-required confined spaces.

CONSTRUCTION

1926.1203(a) – Before it begins work at a worksite, each employer must ensure that a competent person identifies all confined spaces in which one or more of the employees it directs may work, and identifies each space that is a permit space, through consideration and evaluation of the elements of that space, including testing as necessary.

As you see, both of these performance-based confined space standards place the onus on employers, either individually or through a designated Competent Person, to evaluate their workplaces to determine if any confined spaces are present. Then, they must determine if any of those confined spaces are to be categorized as a permit required confined space, or alternatively, as a non-permit-required confined space.

Special Qualifications or Certifications Needed to  Evaluate Confined Spaces?

While OSHA requires employers to ensure the confined spaces at their worksites are identified and evaluated, their standards do NOT require the completion of any specific training class or “competent person certification” for confined spaces for the person conducting the evaluations. Instead, an OSHA compliance officer would simply speak with whomever the employer has appointed as their competent person to perform the confined space evaluations, and determine if they seem to have adequate experience, training certification, and knowledge needed to do the job competently.

Duties of the Competent Person Evaluating Confined Spaces

The competent person who is designated to evaluate the confined spaces at a worksite to determine whether or not they are permit spaces must be capable of effectively performing the following three tasks for the worksite in question:

  • Identify all confined spaces at the worksite after consideration of all facets of the OSHA definition of a confined space;
  • Determine if each confined space identified at the site will be categorized as a permit-required confined space, or as a non-permit confined space;
  • When conditions demand, re-evaluate (and possible reclassify) a non-permit confined space, should the configuration of that space change in a manner that could cause it to become a permit-required confined space (especially true during progression of the construction process when building a confined space such as a tank). Re-evaluation of a non-permit required confined space must also be performed every time there is a work process or activity taking place inside of, or near, any non-permit confined space which could potentially introduce new hazards that require the non-permit space be reclassified as a permit-required confined space.

In many cases, an employer also will have the person designated as their competent person for confined space identification to serve as the entry supervisor for their confined space entry crew. However, doing so is not a strict requirement of the confined space standards, as those two roles could be filled by different personnel.

OSHA Documentation Requirements for Confined Space Evaluations

In case you were wondering, there is no requirement in the federal OSHA confined space entry standards requiring the employer to document their confined space evaluations; however, some employers may choose to do so anyway.

Identifying Permit-Required Confined Spaces at Multi-employer Worksites

OSHA gives employers working at a multi-employer job-site such as but not limited to construction sites the option to collaborate on identifying permit spaces at a worksite, by agreeing to use one designated competent person to perform the initial surveys. Or they can choose to use their own designated competent person to perform the surveys. But either way, each employer who has an employee who will enter into a confined space is ultimately responsible for compliance with the requirements of the OSHA confined space entry standards, and must therefore utilize due diligent before deciding to count on another employer’s competent person to perform the evaluations.

Designation of a Person Competent to Identify Permit-required Confined Spaces

Obviously, the wide variety in types of confined spaces and the assortment of potential hazards inside of those spaces will vary greatly from site to site. So, a competent person with training and experience in dealing with only one specific type of confined space may be capable of evaluating the spaces in a worksite if it only contains the same types of spaces with which they are already familiar. But that same person may or may not be suitable for evaluating the confined spaces of a type they have not experienced before. Only the employer can decide, based upon his or her knowledge of, and experience with permit required confined spaces, who is adequately prepared and able to be designated as being their competent person responsible for identifying permit-required confined spaces at the workplace.

Coming up in the next blog post (#6); we will start a deep dive into understanding the OSHA definition of a confined space.

Final Note: Thanks for reading the blog. Please help spread the word about our confined space entry training blog by sending a link to the blog to others in your network who could benefit from this information. Thanks – Curtis

Understanding the Scope and Application of OSHA’s Various Permit Required Confined Space Entry Standards

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Which OSHA Confined Space Entry Standards Apply

Post #4 – As mentioned in an earlier blog post (#2), OSHA has three different sets of confined space entry standards; one applies to construction work, and another applies to general industry work. OSHA also have a standard that applies to confined space work conducted in the Maritime industry, but that standard will not be discussed in this blog post.

It is imperative that you understand which of the OSHA standards apply to your particular confined space entry operations, and conversely, which one does not, as the requirements of each standard differ. And the way to make sure you understand is to refer to the sections that list the scope and the application for each of the OSHA confined space entry permit requirements.

Scope of the OSHA Confined Space Entry Standards Applicable to General Industry

1910.146(a) lays out the scope of the OSHA permit-required confined space entry standards for general industry workplaces. It states:

“This section contains requirements for practices and procedures to protect employees in general industry from the hazards of entry into permit-required confined spaces. This section does not apply to agriculture, to construction, or to shipyard employment (parts 1928, 1926, and 1915 of this chapter, respectively).”

To reiterate information provided in post #2, general industry work typically consists of activities performed during the manufacturing of goods or products, including those at chemical plants and refining operations. General industry work also includes most general maintenance activities. Service industries such as telephone and cable companies, restaurants, coffee shops and bakeries are also covered by the OSHA 1910.146 general industry standards for confined space entry, as are warehousing and logistics operations and the healthcare industry. 1910.146 would even apply to work involving entry operations at establishments such as bowling allies and amusement parks.

Scope of the OSHA Confined Space Entry Standards Applicable to Construction

For the construction industry, 29 CFR 1926, paragraph 1201(a) explains the scope of the confined spaces in construction standards. This paragraph states the following:

“This standard sets forth requirements for practices and procedures to protect employees engaged in construction activities at a worksite with one or more confined spaces.”

According to 1910.12(b), work regulated under 1926 subpart AA construction standards applies only to confined space entry operations related to construction, alterations, and/or repairs, which include painting and decorating. This would include, but is certainly not limited to, confined space entry work involved in the construction of a brand-new structure, major renovation or repair of all or part of an existing structure, repainting portions or all of a structure, and demolition work. 

Which Confined Space Standard Takes Precedence?

Here is the tricky part; while the 1926 subpart AA confined spaces in construction standard does not apply to general industry work, that standard does apply to construction work conducted inside of a confined space that happens to be located at a general industry worksite.

Consider the following hypothetical of how entry into a tank, which as we will see in an upcoming blog post is usually considered a confined space, could feasibly be regulated by both the OSHA confined space entry standards for construction and also the confined space standards for general industry, switching back-and-forth over the course of time. Notice how the determination depends on the work activities that are taking place, and not the location.

  1. A large tank is fabricated in the shop at a manufacturing company, including having a protective lining sprayed onto the interior tank surfaces by a worker: this work is regulated under 146 General Industry requirements for confined space entry.
  2. The tank is erected at a chemical plant expansion project, where workers enter the tank to install fill lines and drain pipes: this work is regulated under 1926 Subpart AA Construction requirements for confined space entry.
  3. After the chemical plant is up and running in normal production, entry is made into the tank once a year to conduct an inspection of the protective lining on the interior surfaces of the tank to determine its general condition: this preventive maintenance work is regulated under 146 General Industry requirements for confined space entry.
  4. After an annual inspection discovers damage to the lining caused when the tank was previously struck by a forklift, a lining crew enters the tank to blast out the old lining and reapply a new tank lining: this repair work is regulated under 1926 Subpart AA Construction requirements for confined space entry.
  5. Subsequent annual entries are made to conduct inspections of the interior lining to determine its general condition: this preventive maintenance work is regulated under 146 General Industry requirements for confined space entry.
  6. After 30 years of use, the tank has been deemed obsolete, and is scheduled to be demolished. A crew enters the tank to cut loose interior braces and baffles as part of the tank demolition process; this demolition work is regulated under 1926 Subpart AA Construction requirements for confined space entry.

As the previous set of scenarios demonstrate, the over-riding factor to determine which set of OSHA confined space entry permit requirements apply to a given situation is usually the type of work (general industry or construction) being performed inside the confined space, as opposed to the location where the confined space work happens to be taking place.

Application – Workplaces Where OSHA Confined Space Standards Do Not Apply

I will wrap up this blog post by touching certain employers to whom the OSHA confined space entry permit requirements do not apply. The OSH Act of 1970, which establishes coverage of federal OSHA standards, was originally written to apply only to private sector employers in the U.S. and its territories. That means public employers like state and local government agencies (e.g.: municipalities and counties) are not regulated by the OSHA standards, including those for confined space entry operations, unless they happen to be located in one of the states or territories operating under a State Plan OSHA program, as explained in a blog post #2.

Also exempt from coverage by the OSH Act, and therefore exempt from the federal OSHA confined space entry standards, are workplaces for which other federal agencies have laws that regulate employee safety in certain operations. For example, entry into underground mines, which logically seem to be confined spaces, are actually covered by the Mine Safety and Health Administration (MSHA) regulations, and are therefore exempt from OSHA standards for confined space entry. And construction work conducted at worksites overseen by the U.S. Army Corp of Engineers must follow the EM-385-1-1 requirements for confined space entry.

Do Federal Confined Space Entry Requirements Apply to the Feds?

One last interesting factoid; the OSH Act originally did not apply to Federal agencies, meaning federal employers were not required by Congress to follow OSHA’s confined space entry standards; in fact, not even OSHA was required to follow their own confined space entry regulations! However, because of an executive order issued in 1980, federal agencies do now have limited coverage by OSHA standards, and must therefore comply with applicable OSHA confined space entry requirements (and all other applicable OSHA standards) during their entry operations.

Additional Information and Training on Confined Spaces

Hopefully this blog post helps clarify which OSHA confined space entry requirements apply to work being conducted at your site. Or, it may make you realize OSHA lacks jurisdiction over confined space entry operations at your worksite, and that you must figure out what alternate set of regulations may apply. You can learn more about this and other topics by taking one of the online confined space training courses available on our website.

In the next blog post (#5), we will address exactly who is responsible for making sure all permit-required confined spaces at the worksite are properly identified.

Final Note: Thanks for reading the blog. Please help spread the word about our confined space entry training blog by sending a link to the blog ( https://confinedspacetraining.net/confined-space-training-blog/ ) to others in your network who could benefit from this information.

Thanks, – Curtis

Key References Needed to Understand the OSHA Confined Space Entry Standards

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OSHA confined space standards preamble in federal register and letters of interpretation plus CSE FAQs

Post #3 – In the previous post to the confined space training blog, I identified various OSHA standards governing confined space entry work for construction and general industry work (as well as the maritime industry). However, many of the terms used in these confined space standards are not well defined, if defined at all, whereas other parts of these standards are vague and seem to be open to interpretation. These issues often lead to uncertainty about whether or not you are in compliance with the requirements of the OSHA confined space entry standard.

Fortunately, OSHA provides many key documents that expand on their various confined space entry requirements, offering much needed information that helps clarify their standards. (Note: from this point forward in my blog posts, I will focus primarily on the OSHA confined space entry standard for general industry and construction, and not on the OSHA maritime regulations for confined spaces). The following is a recap of some of the more helpful OSHA documents.

Appendices to the OSHA 1910 Permit-required Confined Space Entry Standards

The permit-required confined space entry standard for general industry has several appendices that provide useful information when developing or evaluating your confined space entry program. Below is a listing of those appendices:

1910.146 App A – Permit-required Confined Space Decision Flow Chart

1910.146 App B – Procedures for Atmospheric Testing

1910.146 App C – Examples of Permit-required Confined Space Programs

1910.146 App D – Confined Space Pre-Entry Check List

1910.146 App E – Sewer System Entry

1910.146 App F – Non-Mandatory Appendix F — Rescue Team or Rescue Service Evaluation Criteria

Currently, the Confined Spaces in Construction standards have no appendices. However, those provided with the general industry standard will also prove to be informative for people in the construction industry when setting up their permit-required confined space entry programs.

Federal Register Preambles to The OSHA Confined Space Entry Standard

When OSHA sets out to create a new or revised standard, they must first publish it in the form of a proposed rule in the Federal Register. This is done so interested parties can review the proposed standard and provide written or verbal feedback during a mandatory public comment period. Then, OSHA will review these comments for consideration when they formulate a final rule. When OSHA publishes the final rule, again in the Federal Register, that document includes not only the text of the new standard, but also a very valuable section of the preamble titled “Summary and Explanation of the Standard” (usually in section III). The preambles to the final confined space entry rules for construction and general industry are available for access at https://www.osha.gov/laws-regs/preambles.

The “Summary and Explanation of the Standard” section of the preambles lists the verbiage of each paragraph of the proposed rule as it was originally written, comments, if any, submitted about each proposed paragraph gathered during the public comments period for the new or revised rule, and OSHA’s responses, if any, to those comments. The preamble also includes OSHA’s final reasoning and determination regarding any revisions to the final language of each paragraph of the final rule. It is in OSHA’s responses to those public comments that you can glean very valuable information about how OSHA interprets and/or plans to enforce each paragraph of a new or revised standard.

The preamble to the OSHA 1910 general industry permit-required confined space entry standard was published in Federal Register volume 58, number 9 on January 14, 1993, beginning on page 4462. The preamble to the 1926 Subpart AA confined spaces in construction rule was published in Federal Register volume 80, No. 85 on Monday, May 4, 2015. I will point out helpful information appearing in specific portions of these documents in many future blog posts.

OSHA Compliance Directive (CPL) for 1910.146 Permit-required Confined Space Entry Standard

OSHA occasionally issues a compliance directive (CPL) or standard directive (STD) on some of their more complex standards or policies. These directives are primarily intended to be used as instruments for OSHA compliance officers and directors to refer to during inspections, helping ensure uniform understanding and enforcement of the associated standard or policy.

On May 5th, 1995, OSHA issued Instruction CPL 2.100, which is a compliance directive on the subject of the “Application of the Permit-Required Confined Spaces (PRCS) Standard, 29 CFR 1910.146”. OSHA updated that particular CPL on September 1 of 2015. There is a wealth of information in the directive that employers and other interested persons can use to better understand how OSHA interprets and enforces the 1910.146 standard. And much of that same information can also be applied to the 1926 Subpart AA construction standard.

Letters of Interpretation – OSHA Confined Space Entry Standards for General Industry and Construction

OSHA receives thousands of inquiries about their various standards every year, with several of those posing questions about the OSHA confined space entry standards for construction or for general industry. In many cases, OSHA formally responds to those inquiries via a “letter of interpretation”, often referred to as a LOI. Because these letters of interpretation are considered public records, OSHA makes them available to the general public (like you and me) for review on their website.

The OSHA letters of interpretation for the 1910.146 general industry standards for permit-required confined space entry and for the 1926 Subpart AA confined spaces in construction standard are all accessed through OSHA’s LOI search page. Be aware that OSHA letters of interpretation for their confined space standards are only intended to apply to the specific circumstances discussed in that letter, and that they should not be applied to other circumstances, no matter how similar. Also, OSHA letters of interpretation are occasionally withdrawn because OSHA changed their mind; these letters will be marked as withdrawn, but are still available for reference as archived material.

Frequently Asked Questions and Answers (FAQs) for OSHA Confined Space Entry in Construction Standards

Anticipating questions about their (then) newly-promulgated 1926 Subpart AA confined spaces in construction standard, OSHA published on their website a “Frequently Asked Questions” (FAQ) page about that standard. At the time of this post, there were more than 70 questions and associated answers available on the OSHA confined spaces in construction FAQ page. Readers can get a much better understanding of the OSHA confined space entry requirements not only for the construction industry from these FAQs, but also for many of the similar confined space requirements for general industry workplaces.

OSHA Confined Space Advisor

OSHA developed a resource titled “Confined Space Advisor” on their website. This online tool is essentially a decision flow chart that asks the user questions, and based on their answers, guides them through the various steps of identifying permit-required confined spaces, and subsequently, developing and implementing a permit-required confined space entry program.

The OSHA confined space advisor e-tool is pretty basic in its coverage, and in my opinion, does not adequately answer questions about all confined space entry standards and terms that are vague. However, it does, on occasion, clearly indicates how OSHA defines or interprets a few of them; in fact, there are a couple of instances where I incorporate information taken from the online advisor in the online confined space training courses available on our website.

State OSHA Standards and Requirements for Confined Space Entry

Last but not least; it would be remiss of me not to mention that several states and US territories have opted to form their own State Plan OSHA program, covering most private and public employers in some of these states, and just the public employers in other states. All of these State Plan OSHA programs are required to either adopt the equivalent of the Federal OSHA regulations, or develop and publish their own state regulations that meet or exceed the protections offered in the associated Federal OSHA standards.

In most cases, the Federal OSHA standards for confined space entry in construction and for general industry were adopted verbatim by the various State Plan programs (reference all State Plan program rules at https://www.osha.gov/stateplans/statestandards). However, a few of the state programs created similar standards with a few slight tweaks to reflect other state-specific standards referenced within their rules. For example, the confined space entry standards promulgated by the state of California State Plan program (often referred to as Cal-OSHA) are nearly the same as those published by Federal OSHA, although CA did utilize a different numbering system when they codified their standards. But in the definitions for a “hazardous atmosphere”, which is one of the triggers for classifying a confined space as “permit required”, the CA state rule is slightly different (see both definitions below):

DEFINITION (for both Federal and Cal-OSHA confined space entry standards) –

“Hazardous atmosphere means an atmosphere that may expose employees to the risk of death, incapacitation, impairment of ability to self-rescue (that is, escape unaided from a permit space), injury, or acute illness from one or more of the following causes:

FEDERAL OSHA –

(4) Atmospheric concentration of any substance for which a dose or a permissible exposure limit is published in subpart D of this part (Occupational Health and Environmental Control), or in subpart Z of this part (Toxic and Hazardous Substances), and which could result in employee exposure in excess of its dose or permissible exposure limit;

Cal-OSHA –

(4) Atmospheric concentration of any substance for which a dose or a permissible exposure limit is published in Article 4 of the Construction Safety Orders and Group 16 of the General Industry Safety Orders;”

This slight difference in language can make a huge difference in how these two varying standards are applied. For example, the permissible exposure limit (PEL) for carbon monoxide (CO) incorporated by reference in the 1910 Federal OSHA standard is 50 parts per million (PPM). However, the PEL for CO incorporated by reference in the Cal-OSHA state standard is only 25 PPM. This represents a big variance between the Federal and Cal-OSHA thresholds for when a confined space containing CO is considered to contain a hazardous atmosphere, and therefore classified as a permit-required confined space.

OSHA Confined Space Training Resources

In closing, remember that it is important to be thoroughly familiar with the language contained in the actual OSHA confined space entry standards that apply to your operations. However, there are also many other important OSHA documents available that provide a wealth of information and guidance on how these confined space standards should be interpreted, implemented, and ultimately enforced in the workplace. Links to the resources outlined above, as well as many other valuable resources for confined space entry programs, are available via the course materials tabs associated with the online confined space entry training certification courses for entry supervisors and the competent person offered on our website.

Final Note: Please help spread the word about our confined space entry training blog. Send a link to this blog post to others in your network who could benefit from this information. Thanks, Curtis

OSHA Requirements for Confined Space Entry

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OSHA Requirements for Confined Space Entry

POST #2 – Special care and attention must be given when determining which OSHA requirements for confined space entry apply to your specific work situation. Federal OSHA health and safety regulations pertaining to confined space entry operations can be found in the 29th Code of Federal Regulations, or CFR. More specifically, the Federal OSHA confined space entry standards are located in three different parts of the CFR. Those are:

  • The Part 1910.146 confined space standards, which apply to general industry operations;
  • The Part 1915 confined space standards, which apply to the maritime industries; and,
  • The Part 1926 subpart AA confined space standards, which apply to the construction industry.

OSHA Confined Space Standards for General Industry

The worksites regulated under the Federal OSHA permit-required confined space entry standards for general industry found in 1910.146 include, but are not limited to, most fabrication and manufacturing operations, chemical and processing plants, transportation and warehousing operations, and most service industries. Be aware, however, that there are many other sections of the 1910 General Industry standards for confined space entry that could also apply to work conducted inside confined spaces at general industry worksites, and which must not be overlooked. These include, but are not limited to, 1910 Subpart I, which contain the standards for Personal Protective Equipment, also known as PPE. That subpart also contains the standards for implementing a Respiratory Protection Program to protect workers from hazardous atmospheres, where applicable.

1910 Subpart J contains the rules for “the Control of Hazardous Energy”. These standards, which are also known as the OSHA lockout-tagout standards, often come into play when isolating a confined space from certain hazards before entry. And 1910 subpart Z lists the various permissible exposure limits, or PEL’s, for general air contaminants. That subpart also includes the OSHA 1910.1200 Hazard Communication standard, which addresses Safety Data Sheets and other forms of communication about hazardous chemicals and products present in the workplace, including inside many confined spaces. Another 1910 general industry rule that could have application during work involving confined space entry include 1910.268 – Telecommunications, which addresses entry into underground tele-com vaults and manholes. In addition, section 1910.252(c)(4) of the OSHA welding standards apply to ventilation when welding inside of confined spaces.

OSHA Confined Space Standards for Construction

Federal OSHA also has health and safety standards that regulate the construction industries, and those are found in Part 1926 of the CFR. Originally, the construction rules did not contain a comprehensive confined space entry standard. But in 2015, which is more than 20 years after they published their confined space entry standard for general industry, OSHA finally published a new confined spaces in construction standard. It is located in Subpart AA of the OSHA construction standards. That standard applies not only to confined spaces found at new construction projects, but also to confined spaces at major renovation worksites, as well as those encountered at demolition work sites. The bulk of the newer 1926 construction standards for confined space entry are very similar to the previously-discussed 1910 confined space entry standards for general industry, but with a few major requirements when it comes to responsibilities of general contractors and the Competent Person at construction sites.

There are also a few 1926 construction standards outside of Subpart AA that apply to work conducted inside of confined spaces at construction sites. Those include, but are not limited to, 1926.59 – Hazard communication, 1926 Subpart E – Personal protective and lifesaving equipment, 1926.57 – Ventilation, 1926.55 – Gases, vapors, fumes, dusts, and mists, and 1926.353 – Ventilation and protection in welding, cutting, and heating.

OSHA Confined Space Entry Standards for Maritime

Last but not least, the OSHA CFR also has confined space standards which regulate the maritime industry. Part 1915, Subpart B, contains standards for confined space entry during ship building, ship-breaking operations, and all other areas of shipyard employment. There are also several other related standards sprinkled throughout the 1915 standards. Most of the shipyard standards are significantly different than the confined space standards for general industry and construction. For example, most work conducted inside confined and enclosed spaces in maritime operations is overseen by a Marine Chemist who is registered with OSHA, or by a Certified Industrial Hygienist. Furthermore, OSHA distinguishes between “confined spaces” and “enclosed spaces” in shipyards.

Exceptions to OSHA’s Confined Space Entry Standards

One other thing to know about this subject is, you should always read the section of OSHA confined space entry regulations that provides specific guidance on where a particular OSHA standard or subpart does, or does not, apply. For example, section 1926.1201(b) of the OSHA confined spaces in construction standard, which is titled “Exceptions”, states that the standard does NOT apply to the following: (1) Construction work regulated by subpart P, Excavations; (2) Construction work regulated by subpart S, Underground Construction, Caissons, Cofferdams and Compressed Air; and, (3) Construction work regulated by subpart Y, Diving.

Further Guidance on Confined Space Entry Standards and Requirements

Further guidance on the application of OSHA’s confined space entry standards can be obtained via our comprehensive online confined space entry training courses for construction and for general industry, or in an on-site class conducted by one of our confined space trainers.

Final Note: Please help spread the word about our confined space entry training blog. Send a link to this blog post to others in your network who could benefit from this information. Thanks, Curtis

 

Confined Space Entry Training Blog

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Welcome to our Free Confined Space Entry Training Blog

Blog for OSHA permit-required confined space entry training

POST #1 – Welcome to the very first post on our brand-new Confined Space Entry Training Blog. As the name implies, this free confined space training blog is dedicated to helping readers achieve a better understanding of the requirements of the Federal OSHA permit-required confined space entry standards. And not just a cursory understanding, but an in-depth understanding on a broad range of confined space-related topics. Areas covered in our free confined space training blog will include, but not be limited to, OSHA’s requirements for employers’ confined space entry programs, confined space entry permits, identifying and controlling hazards present within confined spaces, and the selection and use of confined space entry equipment. We will also go in-depth into the OSHA confined space training requirements for all workers involved in permit-required confined space entry operations, including the entrants who actually go into the spaces, the attendants stationed outside the space, the entry supervisor in charge of entry operations, rescue and emergency medical personnel, and gas detection equipment operators.

Why did I decide to start this new blog related to confined space entry training? Because there continue to be fatalities and serious injuries suffered by workers involved in all phases of confined space entry work. According to the Bureau of Labor Statistic’s National Census of Fatal Occupational Injuries published in 2020 (the latest data available at the time of this post), 1,030 workers involved in confined space entry work died in the U.S. between 2011 to 2018. While this overall number represents a relatively small percentage of all workplace fatalities, not many people work in confined spaces, so the rate of fatalities among confined space workers is high. Surprisingly, 60% of confined space-related fatalities were would-be rescuers who rush unprepared into a confined space to assist a coworker, and they died.

The Risks of Confined Space Work

So, why is confined space work often so dangerous? Because being inside of a confining area can easily compound the severity of hazards in the space. You’re often working in close proximity to hazards, so they’re difficult to avoid. And, it’s harder to escape from inside the space should you become incapacitated. Also, because you’re often out of sight of coworkers, you’re often out of mind as well, and no one checks on you until it’s too late. A good confined space entry program addresses hazards in a systematic manner that strives to eliminate confined space hazards when possible, or minimize them to a safer level, through a series of steps that are documented on an entry permit.

Confined Space Expert

By the way, my name is Curtis Chambers, and I am the author of this confined space training blog. I’m qualified to blog on this topic due to my 35+ years of working as an occupational safety and health manager, corporate director, safety officer in a State OSHA Consultation program, and prolific trainer on numerous health and safety topics, including permit-required confined space entry. I’ve even developed comprehensive online confined space entry training courses for entrants, attendants, entry supervisors, and the competent person in construction and general industry operations. I’m also a board certified safety professional (CSP) since 1993, have a Master of Science degree in Occupational Health and Safety from Southeastern Oklahoma State University, and am an OSHA-authorized Outreach trainer in both construction and general industry. I’ve also testified over 100 times as a recognized OSHA expert in legal matters related to, among other things, permit-required confined space related accidents, injuries, and fatalities.

Of course, I am not so naive as to think I have seen it all or know it all when it comes to this topic. That is why our blog is set up to receive comments from readers, including some who will no doubt share a wealth of knowledge and experience in confined space entry work from which others can benefit. So, please feel free to participate in a dialogue with me and with each other if you have any questions, or if you have something of value (be aware that comments are held until moderated, to prevent anything spammy) to share on a post.

Last but not least, know that the purpose of this free confined space training blog is not to provide legal advice, or replace the expertise of an on-site safety professional. Consult your safety manager, safety consultant, or other technically qualified person for guidance to ensure proper entry and emergency response/rescue procedures are in place, and that all necessary equipment is selected and in proper working order before conducting entry operations. Because ultimately, only the employer can decide, based upon his or her knowledge of, and experience with their permit spaces, what the best entry procedures, types of atmospheric testing instrument, ventilation system, and rescue procedure must be used for a specific entry operation.

Here’s to a productive and informative blog! – Curtis