OSHA requirements Archives - Confined Space Entry Training

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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Post #5 – The success of an organization’s confined space entry program is ultimately predicated on having a competent person with the ability to identify and evaluate the confined spaces at their work sites to determine whether or not they meet the OSHA definition of a permit-required confined space. And that takes a person with sufficient training and experience to do the job right. But exactly whose job is it to identify and evaluate confined spaces?

Here’s what the OSHA confined space regulations say about that.

OSHA Requirements to Evaluate Confined Spaces

The first paragraphs from the general requirements sections of the OSHA confined space entry standards for general industry and construction, respectively, are listed below:

GENERAL INDUSTRY

1910.146(c)(1) – The employer shall evaluate the workplace to determine if any spaces are permit-required confined spaces.

CONSTRUCTION

1926.1203(a) – Before it begins work at a worksite, each employer must ensure that a competent person identifies all confined spaces in which one or more of the employees it directs may work, and identifies each space that is a permit space, through consideration and evaluation of the elements of that space, including testing as necessary.

As you see, both of these performance-based confined space standards place the onus on employers, either individually or through a designated Competent Person, to evaluate their workplaces to determine if any confined spaces are present. Then, they must determine if any of those confined spaces are to be categorized as a permit required confined space, or alternatively, as a non-permit-required confined space.

Special Qualifications or Certifications Needed to Evaluate Confined Spaces?

While OSHA requires employers to ensure the confined spaces at their worksites are identified and evaluated, their standards do NOT require the completion of any specific training class or “competent person certification” for confined spaces for the person conducting the evaluations. Instead, an OSHA compliance officer would simply speak with whomever the employer has appointed as their competent person to perform the confined space evaluations, and determine if they seem to have adequate experience, training certification, and knowledge needed to do the job competently.

Duties of the Competent Person Evaluating Confined Spaces

The competent person who is designated to evaluate the confined spaces at a worksite to determine whether or not they are permit spaces must be capable of effectively performing the following three tasks for the worksite in question:

Identify all confined spaces at the worksite after consideration of all facets of the OSHA definition of a confined space;
Determine if each confined space identified at the site will be categorized as a permit-required confined space, or as a non-permit confined space;
When conditions demand, re-evaluate (and possible reclassify) a non-permit confined space, should the configuration of that space change in a manner that could cause it to become a permit-required confined space (especially true during progression of the construction process when building a confined space such as a tank). Re-evaluation of a non-permit required confined space must also be performed every time there is a work process or activity taking place inside of, or near, any non-permit confined space which could potentially introduce new hazards that require the non-permit space be reclassified as a permit-required confined space.

In many cases, an employer also will have the person designated as their competent person for confined space identification to serve as the entry supervisor for their confined space entry crew. However, doing so is not a strict requirement of the confined space standards, as those two roles could be filled by different personnel.

OSHA Documentation Requirements for Confined Space Evaluations

In case you were wondering, there is no requirement in the federal OSHA confined space entry standards requiring the employer to document their confined space evaluations; however, some employers may choose to do so anyway.

Identifying Permit-Required Confined Spaces at Multi-employer Worksites

OSHA gives employers working at a multi-employer job-site such as but not limited to construction sites the option to collaborate on identifying permit spaces at a worksite, by agreeing to use one designated competent person to perform the initial surveys. Or they can choose to use their own designated competent person to perform the surveys. But either way, each employer who has an employee who will enter into a confined space is ultimately responsible for compliance with the requirements of the OSHA confined space entry standards, and must therefore utilize due diligent before deciding to count on another employer’s competent person to perform the evaluations.

Designation of a Person Competent to Identify Permit-required Confined Spaces

Obviously, the wide variety in types of confined spaces and the assortment of potential hazards inside of those spaces will vary greatly from site to site. So, a competent person with training and experience in dealing with only one specific type of confined space may be capable of evaluating the spaces in a worksite if it only contains the same types of spaces with which they are already familiar. But that same person may or may not be suitable for evaluating the confined spaces of a type they have not experienced before. Only the employer can decide, based upon his or her knowledge of, and experience with permit required confined spaces, who is adequately prepared and able to be designated as being their competent person responsible for identifying permit-required confined spaces at the workplace.

Coming up in the next blog post (#6); we will start a deep dive into understanding the OSHA definition of a confined space.

Final Note: Thanks for reading the blog. Please help spread the word about our confined space entry training blog by sending a link to the blog to others in your network who could benefit from this information. Thanks – Curtis