Confined Space Entry Training

OSHA Confined Space Entry Training and Certification

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