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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