Confined Space Entry Training

OSHA Confined Space Entry Training and Certification

Is Confined Space Hazard Awareness Training Required for Non-Authorized Employees?

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Hazard awareness training confined space

Blog Post #22 – Most employers are well aware that OSHA’s confined space standards for general industry and construction require extensive training for employees authorized to participate in permit-required confined space entry operations. We’ll explore that training in depth in future blog posts.

But what about workers at sites where confined spaces exist, yet some (or all) of employees are not assigned to work in those spaces? Is training for them mandatory?

What Do OSHA Standards Say About Training Unauthorized Workers on Confined Space Hazards?

Unauthorized entry into permit spaces—by employees or anyone else—cannot be tolerated. However, OSHA does not specifically state in the training section of their confined space standards that “all unauthorized workers must be trained to stay out of permit-required confined spaces.”

However, OSHA addresses this issue indirectly in other sections of its confined space standards, specifically in paragraph 1910.146(d)(1) of the general industry standards and paragraph 1926.1204(a) for construction. These sections clearly state that entry employers must implement measures to prevent unauthorized entry into any permit-required confined space.

Employers typically fulfill this requirement in several ways:

  • Including a clear policy in their written confined space program that forbids unauthorized entry.
  • Enforcing the policy through a disciplinary program.
  • Covering this policy during training sessions for entry supervisors, entrants, and attendants.

However, it has been my experience that very few employers actually take time to address this topic with training for their non-authorized employees.

Additionally, OSHA standard 1926.21(b)(2) requires that all workers be trained to recognize and avoid unsafe conditions at construction sites. Since unauthorized entry into confined spaces presents significant hazards, training workers to stay out of them aligns with this requirement.

Why Training Unauthorized Workers About Confined Space Hazards Is Necessary

Even though OSHA confined space standards do not specifically require this training, prudent employers should take the time to educate all unauthorized workers about this topic, including:

  • What permit-required confined spaces are.
  • The hazards these spaces present.
  • A list of actual or example permit spaces at their worksites.
  • The fact that entry into any permit space is strictly prohibited for unauthorized workers.

Too often, many employers fail to provide this training, and tragedy occurs. Here are two real-world examples from cases I’ve worked on as an expert witness where training could have helped prevent the incident:

Case #1: The Fatal Auger Shroud Incident

A two-man repair crew from an industrial services company was sent to a cattle feedlot to replace a worn auger in an 18-inch diameter, 15-foot-long discharge auger shroud connected to a large grain bin. No entry into the bin or shroud was anticipated, and neither crew member was trained as an entrant or attendant, nor were they trained to stay out of confined spaces.

When grain from the bin began seeping into the shroud after the old auger was extracted, thereby blocking the new auger’s insertion, the foreman attempted to clear it manually with a scoop welded on the end of a long piece of rebar. When that failed to work, he made the fatal decision to slide headfirst into the shroud with a rope tied around his waist, instructing his helper to pull him out if needed.

Tragically, he became trapped. The helper could not pull his co-worker out by hand. So, in a panic, he tied the loose end of the rope to the hitch of their crew truck and attempted to pull him out. The effort resulted in horrific injuries suffered by the foreman, and he did not survive.

Case #2: The Manufacturing Plant Tragedy

At a large manufacturing plant, a maintenance tech was dispatched to repair a faulty drainage valve affixed to the exterior of a process tank. Company policy dictated that employees would not enter tanks; outside contractors were hired for such tasks.

When the tech failed to report back, a helper was sent to check on him. The helper eventually found the tech’s toolbox near a tank, with tools scattered around. Climbing onto the tank, the helper noticed a raised hatch cover and, upon looking inside, saw the maintenance tech lying motionless on the tank floor.

The helper radioed for assistance but then made the deadly decision to climb inside the tank to help his coworker. Both men ultimately perished due to oxygen deficiency caused by evaporated chemical vapors inside the tank displacing breathable air.

Further investigation revealed that while employees knew they were not allowed to work inside tanks, many did not perceive merely entering an empty tank as a serious risk. Some even admitted to having done so before, unaware of the life-threatening dangers.

The Takeaway: Train Your Unauthorized Workers About Confined Space Hazards, and Document It

In both of these cases, and many more like them, lives were lost because unauthorized workers did not understand that entering these spaces—even for seemingly minor reasons—could be deadly. Had their employers explicitly informed them that entry into such spaces was never permitted under any circumstances, these tragedies could have been prevented.

Employers, take the time to train your unauthorized workers about confined space hazards. And document that training so you have tangible proof during safety audits and regulatory inspections. If you need assistance, scroll down to see how we can help you implement effective training

IMPORTANT NOTICE:

Here is an easy and effective way to send the message to your un-authorized workers about the dangers of permit spaces, and why it is crucial that they never enter one for any reason. Register them for our online “Confined Space Awareness Training Course for Unauthorized Workers.”

The online course is short and sweet, to the point, and can help keep your workers safe and your business OSHA compliant.

Why Choose This Awareness Level Confined Space Training  Course?

Flexible Learning: Employees can train at their own pace, logging in and out from any compatible device.

  • Convenient Registration: Employees can sign up individually, or you can enroll your team through a free Learner Manager account, which also enables you to track progress and manage certifications.
  • Proof of Compliance: Upon successful completion, employees receive a personalized training certificate, which serves as tangible proof of compliance during safety audits and regulatory inspections.

Click the button below be directed to our online confined space training page where you can read more and then sign up for this online Confined Space Hazard Awareness course. And while you are on our website, check out the comprehensive online courses we offer for entry supervisors, entrants, attendants, and the competent person.

CLICK HERE

Share Your Point of View About Confined Space Hazard Awareness Training

Does your company provide training to unauthorized workers on confined space hazards? If so, how is the message delivered, and how effective has it been? Or perhaps you have a story about an accident that occurred under similar circumstances?

Please share your thoughts in the comments section below. And if you find this information valuable, share this post with others who could benefit from it.

OSHA Alternate Entry Procedures for Permit-required Confined Spaces

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OSHA Alternate Entry Procedures for Confined Space Entry

Blog Post #20 – Some permit-required confined spaces qualify to be entered under the alternate entry procedures listed in 1910.146(c)(5) of the general industry standards for permit-required confined spaces, and in 1926.1203(e) of the confined spaces in construction standards. These procedures, which allow entry into permit spaces that contain only atmospheric hazards which the employer demonstrates can be sufficiently controlled with forced air ventilation alone, differ from those discussed in the previous blog post, which explained how and when you can temporarily reclassify a permit space to non-permit space status.

The advantages to utilizing the alternate entry procedures listed in section 1910.146(c)(5) and 1926.1203(e) are that once the permit space has been certified as safe for entry under these procedures, the following elements of a full permit entry are not required:

  • No written confined space entry procedure or entry permit is required for workers to enter the space, only a brief written certification;
  • It is not mandatory to have an attendant stand by the entry point to the confined space during entry operations;
  • Workers in the space do not have to receive the extensive training required for a permit space entrant;
  • No entry supervisor is required to oversee all entry operations during alternate entry procedures; and,
  • A confined space rescue team is not required to be on standby during this entry.

As you can see, the benefits of utilizing these alternate confined space entry procedures, when allowed, can make entry into eligible spaces quicker and more cost-effective, while still maintaining a safe work environment for entrants.

When do the OSHA Alternate Entry Procedures for Permit-required Confined Spaces Apply?

The OSHA 1910 general industry confined space standards for alternate entry, which were published in the early 1990’s, state that they apply to permit spaces with actual or potential atmospheric hazards only, and in which continuous forced air ventilation alone can maintain the atmosphere inside the space safe for entry. The wording of this general industry standard does not make it clear if that means the space must never present any non-atmospheric (physical) hazards at any time (pre and post entry) to qualify for entry under the alternate procedures, or if any such hazards must simply be addressed before entry is allowed.

Fortunately, the wording of the 1926 confined spaces in construction standard rule differs slightly, clarifying that alternate entry procedures can be utilized in those permit spaces where continuous, forced air ventilation can maintain the atmosphere inside the confined space safe for entry, and all other unsafe conditions (if any) which are non-atmospheric in nature are eliminated or isolated before the cover on the space is removed.

Recall that in the previous blog post, we explained OSHA’s definition of the term “isolation,” which 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.

Defining “Safe for Entry” in the OSHA Alternate Entry Standards

As stated above, these alternate entry procedures both require that continuous, forced air ventilation can maintain the atmosphere inside the confined space “safe for entry.” However, neither standard define what that term means.

Fortunately, the preamble to the 1910 general industry standard (see accompanying excerpt from page 4488 of Federal Register / Volume 58, No. 9) sheds some light on the meaning of this terminology.

Alternate Entry OSHA Federal Register Excerpt Safe for Entry

This particular section of the Federal Register states that the atmospheric hazards must remain at no more than one-half (50%) their regulated levels to be considered “safe for entry” when using the alternate entry procedures.

So, as an example, flammable gas in the atmosphere is considered hazardous by Federal OSHA when it exceeds 10% of its LEL, so “safe for entry” would be an atmosphere maintained by forced air ventilation at levels not exceeding 5% LEL. And the Federal OSHA PEL for carbon monoxide is 50 ppm, so “safe for entry” would be an atmosphere containing no more than 25 ppm CO. Note: some State Plan OSHA programs have lower PELs for certain atmospheric hazards such as CO; refer to state regulations when applicable to your workplace.

Requirements for Forced Air Ventilation Utilized During Alternate Entry Operations

When using the alternate entry procedure, forced air ventilation (e.g. a hose blower or similar ventilation equipment), must be installed and operating efficiently and continuously before and throughout entry. The blower hose must be directed to ventilate the immediate areas where an employee is present, or will be present, within the space, and must continue to operate until all employees have exited the space.

The ventilation system should provide an adequate volume of air needed to allow enough time for all entrants to escape the confined space without overexposure should the ventilation system unexpectedly stop working. Determining what would be an adequate time for escape, in turn, is a function of the concentration the contaminant, the rate of generation or introduction of the contaminant into the space, and the distance to the exit. Because of the complexities of making such an evaluation, only a technically qualified person should make this determination.

Also, the employer must ensure the source of make-up air for ventilation equipment is clean and safe. So, make sure there are no sources of contamination, such as open drums of hazardous chemicals or pieces of equipment with an internal combustion engine running near the air intake of any confined space ventilation equipment.

Additional Requirements When Utilizing OSHA Alternate Entry Procedures

There are a few additional conditions that must be met if an employer chooses to utilize the alternate entry procedures listed in both OSHA confined space standards, including making sure other unsafe conditions are eliminated or isolated before the cover on the space is removed. This could include measures such as making certain to bleed off any pressure that may have built up inside of a confined space before opening the lid or removing its cover, where applicable, as the pressure could cause the lid or cover to fly off and strike someone.

Also, once the lid or cover has been removed, the opening into the space being entered under alternate procedures must be immediately guarded so that no person or object can fall into the confined space, where applicable. Devices such as portable barricades with toe-boards are available to help meet this requirement.

Then, the internal atmosphere in the space must be tested before entry using a calibrated, direct reading instrument, for oxygen, LEL, and toxics, in that order (the reason for using this specific testing order will be explained in a later blog post about atmospheric testing). Atmospheric testing is necessary to determine that the atmosphere inside the space is “safe for entry” before entry operations, and additional testing must be conducted as needed throughout entry to ensure the atmosphere is maintained. Furthermore, the employer must develop and maintain adequate monitoring and inspection data that demonstrates the ventilation system can maintain the atmosphere at safe levels throughout entry.

In those instances where it is necessary for a worker to conduct initial atmospheric testing or isolate a physical hazard from inside the space, this initial entry must be made under a full entry permit program until the hazards are isolated and the atmosphere has been deemed safe for entry. 

Moreover, any activities carried out within or outside of the space must not create new atmospheric (or non-atmospheric) hazards. This includes introducing into the space any hazardous amounts of flammable or toxic substances, or performing hot work within the space, as they could introduce risks that were not considered when determining that the atmosphere inside the confined space is safe for entry.

Finally, if any hazardous atmosphere is detected during entry during alternate entry procedures, all entrants must immediately evacuate the confined space. Then the entry employer must make certain to reevaluate the space to determine why the hazardous atmosphere developed, and then implement adequate corrective measures to protect employees before any subsequent entry takes place.

OSHA Requirements for Safe Entry and Egress of Personnel

Employers must also provide a safe method of entering and exiting the space during alternate entry operations. If a hoisting system is used, it must be designed and manufactured for personnel hoisting; this requirement was clarified by OSHA in their newer confined spaces in construction standard. However, a job-made hoisting system is permissible if it is approved for personnel hoisting by a registered professional engineer, in writing, prior to use.

Documentation Requirements When Using Alternate Entry Procedures

An employer utilizing this alternate entry procedure is not required to prepare a regular confined space entry permit. Instead, the employer must simply verify that the space is safe for entry, and that all required measures have been taken prior to entry, by preparing a written certification. This written certification must identify the location of the space, the date of entry, and the signature of the person certifying the space is safe, per the OSHA confined space standards for alternate entry.

This written certification must be made available to affected employees or their designated representatives before entry by posting it at or near the entry point of the confined space for the duration of entry operations.

What if Alternate Entry into a Permit Space is Not Feasible?

If a permit required confined space cannot, or will not, be entered under the alternate entry procedures listed in OSHA standards (or if it cannot be reclassified as a non-permit space under the procedures discussed in a previous blog post), then the space must be entered under a full permit-required confined space entry program (which will be covered beginning in the next blog post).

Remember also that the space must be returned to permit-required status when the work is completed, or if at any time during entry under alternate entry procedures a hazardous atmosphere develops inside the space.

Closing

As you can see, OSHA’s alternate entry procedures, when allowed and properly implemented, can result in safer, more efficient, and compliant management of eligible confined space entries because the relatively-lower risks associated with these type spaces can easily be controlled.

Please provide any comments or questions about the OSHA alternate entry procedures in the COMMENTS section appearing at the bottom of this page. And be sure to come back soon to see our next blog posts, which delve into the requirements for implementing a full permit-required confined space entry program.

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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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

Definition of a Hazardous Atmosphere – Airborne Combustible Dust =/> LFL

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Combustible dust LFL

 Blog Post #10 – In this post, we will examine the second category listed in the Federal OSHA definition for a hazardous atmosphere, which is an atmosphere with airborne combustible dust at a concentration that meets or exceeds its LFL (which stands for Lower Flammable Limit). LFL represents the minimum quantity of combustible dust that must be suspended in the air within the space to be able to cause a flash fire or dust explosion if ignited. In these conditions, the airborne dust is considered to have met or exceeded its lower flammable limit, or LFL.

OSHA’s 5-foot Rule of Thumb for Dust Measurement

The LFL of combustible dusts depends on many factors, including the type of material that makes up the dust, the size of the dust particles, the moisture content in the dust particles, and the density of the dust particles within the airspace.

There are instruments available that can measure the amount of combustible dust in the air to determine if it meets or exceeds its Lower Flammable Limit (LFL). However, for airborne dust measurement purposes, OSHA’s definition of a hazardous atmosphere due to airborne combustible dust refers to the use of the “5-foot rule of thumb”. That means that if the combustible dust suspended in the air is so dense that the entrant cannot see more than five feet from the end of their nose, there is a high risk of a flash fire or dust explosion.

In cases where this condition exists, or is likely to exist, inside of a confined space at any time during entry operations, it must be classified as a permit-required confined space.

Examples of Combustible Dusts

Here are examples of some, but not all, of the various types of airborne combustible dusts that could be present inside of some confined spaces during entry operations: Aluminum powder, dust from animal feed, coal dust, corn starch, cosmetic powders, dry fertilizer dust, dust from dry food and spices (coffee, tea, flour . . .), grain dust, powdered metal, plastic dust, powdered chemicals, rubber dust, sugar dust, textile fibers, and wood dust.

How Dust Fires and Explosions Occur

Combustible dust flash fires, a process called deflagration, is a rapid combustion process that produces a flame front which can quickly spread through a dust cloud if the concentration of combustible dust in the air is dense enough. And in some cases where the airborne dust fire is contained within a confined space, pressure quickly builds and an explosion can occur.

Here is a brief overview of the steps leading up to a combustible dust flash fire and explosion inside a confined space:

  1. A cloud of combustible dust is created in the air within a confined space, either through a process like grinding, mixing or other material handling activities, or by a settled dust being disturbed by other work activities such as cleaning with compressed air.

  2. A small portion of dust within the cloud is then ignited by a spark, flame, or other ignition source. Even static electricity must be considered as an ignition source.

  3. If the airborne combustible dust cloud is dense enough, the burning dust particles spread to others nearby, and those in turn ignite other airborne particles, resulting in a fire quickly spreading through the dust cloud. This process is called deflagration.

  4. The rapid spread of burning dust particles not only causes temperature inside the confined space to rapidly rise, it also creates a pressure wave that increases the internal pressure within the confined space.

  5. In the right conditions, the pressure wave can cause an explosion, leading to severe damage to the structure of the confined space.

  6. The burning dust cloud can continue to burn and expand. And the percussion from additional explosions may lead to more combustible dust inside the space being introduced into the air, adding even more fuel to the fire.

When a dust fire or explosion occurs, it can obviously lead not only to structural damage, but possible injury or death to anyone nearby. See an example of a dust explosion in this YouTube video showing a grain elevator explosion.

Classify All Confined Spaces with Potential for Airborne Dust Fires or Explosions as Permit-required Confined Spaces

So, consider the confined spaces present at your workplace, and take care to identify those with an actual or reasonable potential for a dense cloud of airborne combustible dust developing during entry operations, as those spaces will have to be classified as permit-required confined spaces.

Here are examples of some, but not all, types of confined spaces that, depending on materials they have contained, could produce heavy levels of airborne combustible dust during entry operations:

  • Conveyor systems
  • Cyclone separators
  • Duct work and air-handling systems
  • Dust collectors and bag houses
  • Grain storage bins, elevators, and silos
  • Hoppers and chutes
  • Mixers and blenders
  • Ovens and furnaces
  • Powder processing equipment such as mills and pulverizers
  • Truck and rail-car hoppers and tanks

In our next blog post (#11), we will examine the third criteria of a hazardous atmosphere that could be present inside of a confined space (oxygen deficiency or enrichment). In the meantime, please provide your feedback and questions to this blog post about airborne combustible dust at levels exceeding its lower flammable limit, or LFL, 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 share a link to this post with others in your network so they can benefit from this information.  Thanks – Curtis

Examples of Confined Spaces Per OSHA Definitions

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Examples of confined spaces per OSHA definitions

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