Confined Space Entry Training

OSHA Confined Space Entry Training and Certification

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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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 – 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