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).

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.

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.

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.

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.

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.

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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