Confined Space Entry Training

OSHA Confined Space Entry Training and Certification

Is Confined Space Hazard Awareness Training Required for Non-Authorized Employees?

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Blog Post #22 – Most employers are well aware that OSHA’s confined space standards for general industry and construction require extensive training for employees authorized to participate in permit-required confined space entry operations. We’ll explore that training in depth in future blog posts.

But what about workers at sites where confined spaces exist, yet some (or all) of employees are not assigned to work in those spaces? Is training for them mandatory?

What Do OSHA Standards Say About Training Unauthorized Workers on Confined Space Hazards?

Unauthorized entry into permit spaces—by employees or anyone else—cannot be tolerated. However, OSHA does not specifically state in the training section of their confined space standards that “all unauthorized workers must be trained to stay out of permit-required confined spaces.”

However, OSHA addresses this issue indirectly in other sections of its confined space standards, specifically in paragraph 1910.146(d)(1) of the general industry standards and paragraph 1926.1204(a) for construction. These sections clearly state that entry employers must implement measures to prevent unauthorized entry into any permit-required confined space.

Employers typically fulfill this requirement in several ways:

  • Including a clear policy in their written confined space program that forbids unauthorized entry.
  • Enforcing the policy through a disciplinary program.
  • Covering this policy during training sessions for entry supervisors, entrants, and attendants.

However, it has been my experience that very few employers actually take time to address this topic with training for their non-authorized employees.

Additionally, OSHA standard 1926.21(b)(2) requires that all workers be trained to recognize and avoid unsafe conditions at construction sites. Since unauthorized entry into confined spaces presents significant hazards, training workers to stay out of them aligns with this requirement.

Why Training Unauthorized Workers About Confined Space Hazards Is Necessary

Even though OSHA confined space standards do not specifically require this training, prudent employers should take the time to educate all unauthorized workers about this topic, including:

  • What permit-required confined spaces are.
  • The hazards these spaces present.
  • A list of actual or example permit spaces at their worksites.
  • The fact that entry into any permit space is strictly prohibited for unauthorized workers.

Too often, many employers fail to provide this training, and tragedy occurs. Here are two real-world examples from cases I’ve worked on as an expert witness where training could have helped prevent the incident:

Case #1: The Fatal Auger Shroud Incident

A two-man repair crew from an industrial services company was sent to a cattle feedlot to replace a worn auger in an 18-inch diameter, 15-foot-long discharge auger shroud connected to a large grain bin. No entry into the bin or shroud was anticipated, and neither crew member was trained as an entrant or attendant, nor were they trained to stay out of confined spaces.

When grain from the bin began seeping into the shroud after the old auger was extracted, thereby blocking the new auger’s insertion, the foreman attempted to clear it manually with a scoop welded on the end of a long piece of rebar. When that failed to work, he made the fatal decision to slide headfirst into the shroud with a rope tied around his waist, instructing his helper to pull him out if needed.

Tragically, he became trapped. The helper could not pull his co-worker out by hand. So, in a panic, he tied the loose end of the rope to the hitch of their crew truck and attempted to pull him out. The effort resulted in horrific injuries suffered by the foreman, and he did not survive.

Case #2: The Manufacturing Plant Tragedy

At a large manufacturing plant, a maintenance tech was dispatched to repair a faulty drainage valve affixed to the exterior of a process tank. Company policy dictated that employees would not enter tanks; outside contractors were hired for such tasks.

When the tech failed to report back, a helper was sent to check on him. The helper eventually found the tech’s toolbox near a tank, with tools scattered around. Climbing onto the tank, the helper noticed a raised hatch cover and, upon looking inside, saw the maintenance tech lying motionless on the tank floor.

The helper radioed for assistance but then made the deadly decision to climb inside the tank to help his coworker. Both men ultimately perished due to oxygen deficiency caused by evaporated chemical vapors inside the tank displacing breathable air.

Further investigation revealed that while employees knew they were not allowed to work inside tanks, many did not perceive merely entering an empty tank as a serious risk. Some even admitted to having done so before, unaware of the life-threatening dangers.

The Takeaway: Train Your Unauthorized Workers About Confined Space Hazards, and Document It

In both of these cases, and many more like them, lives were lost because unauthorized workers did not understand that entering these spaces—even for seemingly minor reasons—could be deadly. Had their employers explicitly informed them that entry into such spaces was never permitted under any circumstances, these tragedies could have been prevented.

Employers, take the time to train your unauthorized workers about confined space hazards. And document that training so you have tangible proof during safety audits and regulatory inspections. If you need assistance, scroll down to see how we can help you implement effective training

IMPORTANT NOTICE:

Here is an easy and effective way to send the message to your un-authorized workers about the dangers of permit spaces, and why it is crucial that they never enter one for any reason. Register them for our online “Confined Space Awareness Training Course for Unauthorized Workers.”

The online course is short and sweet, to the point, and can help keep your workers safe and your business OSHA compliant.

Why Choose This Awareness Level Confined Space Training  Course?

Flexible Learning: Employees can train at their own pace, logging in and out from any compatible device.

  • Convenient Registration: Employees can sign up individually, or you can enroll your team through a free Learner Manager account, which also enables you to track progress and manage certifications.
  • Proof of Compliance: Upon successful completion, employees receive a personalized training certificate, which serves as tangible proof of compliance during safety audits and regulatory inspections.

Click the button below be directed to our online confined space training page where you can read more and then sign up for this online Confined Space Hazard Awareness course. And while you are on our website, check out the comprehensive online courses we offer for entry supervisors, entrants, attendants, and the competent person.

CLICK HERE

Share Your Point of View About Confined Space Hazard Awareness Training

Does your company provide training to unauthorized workers on confined space hazards? If so, how is the message delivered, and how effective has it been? Or perhaps you have a story about an accident that occurred under similar circumstances?

Please share your thoughts in the comments section below. And if you find this information valuable, share this post with others who could benefit from it.

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