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
Here is a debate I got into…is the elevator car a confined space? Or would there be a situation that it could be considered a confined space or even a permit-required confined space?
Thank you.
Greg
Great question. I guess it would depend on a few factors. If the elevator car is fully functioning, then I would say no it is not a confined space, because it is designed for occupancy. But if the elevator car is not functioning, and must be entered in some method that is considered limited (such as the escape hatch on top), then I think it would be a confined space, but probably not permit required unless there was some sort of major hazard present inside the car.
An attic with a sub floor, and a wired light? Hmmm.
Chuck. You are thinking ahead. We state in the blog that “some” attic spaces may be classified as confined spaces. But certainly not all of them are. Good job.
What’s your take on garage service pits, where a company works on service and maintenance of tractor-trailers?
Thanks
Hello Chip. Great question. It depends a lot on its design. First consideration is entry/exit; If you have a pit accessed by a ladder only, or by a steep ships ladder, it would be a confined space. But if accessed by a regular stairway (that meets regular building code), then it most likely would not be considered a confined space. As for the third criteria of a confined space (designed for employee occupancy), in the event that the pit accessed by a ladder or steep ladder was designed with a ventilation system that would make it suitable to be occupied by a worker safely, then it most likely would not be a confined space. What are your thoughts?
Would a 6ft pipe culvert that is 47ft long be considered a confined space?
Hello Christopher. A six-foot pipe culvert would certainly meet two of the criteria to be considered a confined space (large enough to get your entire body inside, and, not designed for employee occupancy). So the key to answering your question is to determine whether or not the culvert pipe has a limited means of entry and/or egress. The OSHA confined space advisor clarifies OSHA’s definition of a limited means of entry or egress 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. So, look at your culvert, and if one or more of these conditions exists in the space, it should be classified as a confined space. And if none do exist, and there is no reasonable potential for one to develop while inside the space, then that particular culvert would not. Of course, each culvert should be evaluated independently, as conditions could be different from one to another. Please let me know your thoughts. Thanks, Curtis
Does an airport checkpoint X-ray meet the qualifications of being a confined space? The tunnels are about 4 feet long, open at both ends; however, there are rubber curtains, encapsulated with lead, that are in the tunnel, hanging, to keep the X-ray from exiting the machine.
Terry, I don’t think it does. The unit is designed to be occupied by people. Also, the curtains don’t really “restrict” entry or exit.
Hi, On my current job, safety is deeming underneath a bathroom trailer (no under pinning) a confined space. You can see all around the trailer from all sides looking underneath, and the trailer is roughly 3 to 3 1/2′ off the ground.
Is this a confined Space per OSHA ?
Hello Bryan. That is a first. I have not ever heard of anyone else designating such an area as a confined space. However, without seeing the exact setup it would be hard to say for sure. Also, keep in mind that even though you can see all the way through, there could be some obstacles that would prevent unrestricted egress.
Is a water tank with both manways on opposite side open and man ways are 4′ openings, along with a roof open be still considered a confined space? The tank is empty and no other hazards . Tank is approximately 25′ across
Hello Chris. Since the man-way openings are both 4 feet in diameter, the entrant(s) would have the bend down (and perhaps step up) to enter. That constitutes a limited means of entry. Therefore, based on the info you provided it sounds like the tank is a confined space. However, it may not need to be classified as a “permit-required” confined space if there are no serious health or safety hazards present (or reasonably expected to develop) inside the space. Hope this helps.
I have a dozen or so of the mobile materials hoppers with the tapered down chute. Topside dimensions are 5ft x 5ft and 46 inches deep. Tapered down with an adjustable chute to control the flow of material. I have several of the larger materials hoppers that certainly meet the definition of confined space with permitting required. So is a much shallower hopper a confined space?
Hello Jade. There is no hard and fast rule about how deep a space must be to be considered to have a restricted means of entry or exit. The criteria are very subjective. OSHA’s intent (according to their Confined Space Advisor) is 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 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. It sounds like you are probably there.
Would you consider a pit for a gas station sump a confined space? Top of pit is level to ground and Is ~30” diameter. Inside has a ledge that protrudes inward ~4” at about 10” deep, resulting a place to stand. At about 29” deep is the top of the tank and associated sensors, etc. person enters pit by standing on ledge, then stepping down onto tank top. They then work on sensors, pipe, pump, etc. environment needs to be evacuated of fumes before work ensues but would it meet the definition of a permit required confined space?
Thank you
Jason, based on the info you provided, this sump pit definitely sounds like a confined space. It is entered vertically, and easily big enough to bodily enter. And with the near proximity of gasoline or diesel vapors, it is most likely a permit space. Hope this helps.
Thank you for the quick reply.
My pleasure