Examples of Confined Spaces Per OSHA Definitions

December 31, 2022 by Curtis Chambers 30 Comments

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

Understanding the Scope and Application of OSHA’s Various Permit Required Confined Space Entry Standards

October 11, 2022 by Curtis Chambers Leave a Comment

Which OSHA Confined Space Entry Standards Apply

Post #4 – As mentioned in an earlier blog post (#2), OSHA has three different sets of confined space entry standards; one applies to construction work, and another applies to general industry work. OSHA also have a standard that applies to confined space work conducted in the Maritime industry, but that standard will not be discussed in this blog post.

It is imperative that you understand which of the OSHA standards apply to your particular confined space entry operations, and conversely, which one does not, as the requirements of each standard differ. And the way to make sure you understand is to refer to the sections that list the scope and the application for each of the OSHA confined space entry permit requirements.

Scope of the OSHA Confined Space Entry Standards Applicable to General Industry

1910.146(a) lays out the scope of the OSHA permit-required confined space entry standards for general industry workplaces. It states:

“This section contains requirements for practices and procedures to protect employees in general industry from the hazards of entry into permit-required confined spaces. This section does not apply to agriculture, to construction, or to shipyard employment (parts 1928, 1926, and 1915 of this chapter, respectively).”

To reiterate information provided in post #2, general industry work typically consists of activities performed during the manufacturing of goods or products, including those at chemical plants and refining operations. General industry work also includes most general maintenance activities. Service industries such as telephone and cable companies, restaurants, coffee shops and bakeries are also covered by the OSHA 1910.146 general industry standards for confined space entry, as are warehousing and logistics operations and the healthcare industry. 1910.146 would even apply to work involving entry operations at establishments such as bowling allies and amusement parks.

Scope of the OSHA Confined Space Entry Standards Applicable to Construction

For the construction industry, 29 CFR 1926, paragraph 1201(a) explains the scope of the confined spaces in construction standards. This paragraph states the following:

“This standard sets forth requirements for practices and procedures to protect employees engaged in construction activities at a worksite with one or more confined spaces.”

According to 1910.12(b), work regulated under 1926 subpart AA construction standards applies only to confined space entry operations related to construction, alterations, and/or repairs, which include painting and decorating. This would include, but is certainly not limited to, confined space entry work involved in the construction of a brand-new structure, major renovation or repair of all or part of an existing structure, repainting portions or all of a structure, and demolition work.

Which Confined Space Standard Takes Precedence?

Here is the tricky part; while the 1926 subpart AA confined spaces in construction standard does not apply to general industry work, that standard does apply to construction work conducted inside of a confined space that happens to be located at a general industry worksite.

Consider the following hypothetical of how entry into a tank, which as we will see in an upcoming blog post is usually considered a confined space, could feasibly be regulated by both the OSHA confined space entry standards for construction and also the confined space standards for general industry, switching back-and-forth over the course of time. Notice how the determination depends on the work activities that are taking place, and not the location.

A large tank is fabricated in the shop at a manufacturing company, including having a protective lining sprayed onto the interior tank surfaces by a worker: this work is regulated under 146 General Industry requirements for confined space entry.
The tank is erected at a chemical plant expansion project, where workers enter the tank to install fill lines and drain pipes: this work is regulated under 1926 Subpart AA Construction requirements for confined space entry.
After the chemical plant is up and running in normal production, entry is made into the tank once a year to conduct an inspection of the protective lining on the interior surfaces of the tank to determine its general condition: this preventive maintenance work is regulated under 146 General Industry requirements for confined space entry.
After an annual inspection discovers damage to the lining caused when the tank was previously struck by a forklift, a lining crew enters the tank to blast out the old lining and reapply a new tank lining: this repair work is regulated under 1926 Subpart AA Construction requirements for confined space entry.
Subsequent annual entries are made to conduct inspections of the interior lining to determine its general condition: this preventive maintenance work is regulated under 146 General Industry requirements for confined space entry.
After 30 years of use, the tank has been deemed obsolete, and is scheduled to be demolished. A crew enters the tank to cut loose interior braces and baffles as part of the tank demolition process; this demolition work is regulated under 1926 Subpart AA Construction requirements for confined space entry.

As the previous set of scenarios demonstrate, the over-riding factor to determine which set of OSHA confined space entry permit requirements apply to a given situation is usually the type of work (general industry or construction) being performed inside the confined space, as opposed to the location where the confined space work happens to be taking place.

Application – Workplaces Where OSHA Confined Space Standards Do Not Apply

I will wrap up this blog post by touching certain employers to whom the OSHA confined space entry permit requirements do not apply. The OSH Act of 1970, which establishes coverage of federal OSHA standards, was originally written to apply only to private sector employers in the U.S. and its territories. That means public employers like state and local government agencies (e.g.: municipalities and counties) are not regulated by the OSHA standards, including those for confined space entry operations, unless they happen to be located in one of the states or territories operating under a State Plan OSHA program, as explained in a blog post #2.

Also exempt from coverage by the OSH Act, and therefore exempt from the federal OSHA confined space entry standards, are workplaces for which other federal agencies have laws that regulate employee safety in certain operations. For example, entry into underground mines, which logically seem to be confined spaces, are actually covered by the Mine Safety and Health Administration (MSHA) regulations, and are therefore exempt from OSHA standards for confined space entry. And construction work conducted at worksites overseen by the U.S. Army Corp of Engineers must follow the EM-385-1-1 requirements for confined space entry.

Do Federal Confined Space Entry Requirements Apply to the Feds?

One last interesting factoid; the OSH Act originally did not apply to Federal agencies, meaning federal employers were not required by Congress to follow OSHA’s confined space entry standards; in fact, not even OSHA was required to follow their own confined space entry regulations! However, because of an executive order issued in 1980, federal agencies do now have limited coverage by OSHA standards, and must therefore comply with applicable OSHA confined space entry requirements (and all other applicable OSHA standards) during their entry operations.

Additional Information and Training on Confined Spaces

Hopefully this blog post helps clarify which OSHA confined space entry requirements apply to work being conducted at your site. Or, it may make you realize OSHA lacks jurisdiction over confined space entry operations at your worksite, and that you must figure out what alternate set of regulations may apply. You can learn more about this and other topics by taking one of the online confined space training courses available on our website.

In the next blog post (#5), we will address exactly who is responsible for making sure all permit-required confined spaces at the worksite are properly identified.

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 ( https://confinedspacetraining.net/confined-space-training-blog/ ) to others in your network who could benefit from this information.

Thanks, – Curtis

Confined Space Entry Training Blog

August 12, 2022 by Curtis Chambers 4 Comments

Welcome to our Free Confined Space Entry Training Blog

Blog for OSHA permit-required confined space entry training

POST #1 – Welcome to the very first post on our brand-new Confined Space Entry Training Blog. As the name implies, this free confined space training blog is dedicated to helping readers achieve a better understanding of the requirements of the Federal OSHA permit-required confined space entry standards. And not just a cursory understanding, but an in-depth understanding on a broad range of confined space-related topics. Areas covered in our free confined space training blog will include, but not be limited to, OSHA’s requirements for employers’ confined space entry programs, confined space entry permits, identifying and controlling hazards present within confined spaces, and the selection and use of confined space entry equipment. We will also go in-depth into the OSHA confined space training requirements for all workers involved in permit-required confined space entry operations, including the entrants who actually go into the spaces, the attendants stationed outside the space, the entry supervisor in charge of entry operations, rescue and emergency medical personnel, and gas detection equipment operators.

Why did I decide to start this new blog related to confined space entry training? Because there continue to be fatalities and serious injuries suffered by workers involved in all phases of confined space entry work. According to the Bureau of Labor Statistic’s National Census of Fatal Occupational Injuries published in 2020 (the latest data available at the time of this post), 1,030 workers involved in confined space entry work died in the U.S. between 2011 to 2018. While this overall number represents a relatively small percentage of all workplace fatalities, not many people work in confined spaces, so the rate of fatalities among confined space workers is high. Surprisingly, 60% of confined space-related fatalities were would-be rescuers who rush unprepared into a confined space to assist a coworker, and they died.

The Risks of Confined Space Work

So, why is confined space work often so dangerous? Because being inside of a confining area can easily compound the severity of hazards in the space. You’re often working in close proximity to hazards, so they’re difficult to avoid. And, it’s harder to escape from inside the space should you become incapacitated. Also, because you’re often out of sight of coworkers, you’re often out of mind as well, and no one checks on you until it’s too late. A good confined space entry program addresses hazards in a systematic manner that strives to eliminate confined space hazards when possible, or minimize them to a safer level, through a series of steps that are documented on an entry permit.

Confined Space Expert

By the way, my name is Curtis Chambers, and I am the author of this confined space training blog. I’m qualified to blog on this topic due to my 35+ years of working as an occupational safety and health manager, corporate director, safety officer in a State OSHA Consultation program, and prolific trainer on numerous health and safety topics, including permit-required confined space entry. I’ve even developed comprehensive online confined space entry training courses for entrants, attendants, entry supervisors, and the competent person in construction and general industry operations. I’m also a board certified safety professional (CSP) since 1993, have a Master of Science degree in Occupational Health and Safety from Southeastern Oklahoma State University, and am an OSHA-authorized Outreach trainer in both construction and general industry. I’ve also testified over 100 times as a recognized OSHA expert in legal matters related to, among other things, permit-required confined space related accidents, injuries, and fatalities.

Of course, I am not so naive as to think I have seen it all or know it all when it comes to this topic. That is why our blog is set up to receive comments from readers, including some who will no doubt share a wealth of knowledge and experience in confined space entry work from which others can benefit. So, please feel free to participate in a dialogue with me and with each other if you have any questions, or if you have something of value (be aware that comments are held until moderated, to prevent anything spammy) to share on a post.

Last but not least, know that the purpose of this free confined space training blog is not to provide legal advice, or replace the expertise of an on-site safety professional. Consult your safety manager, safety consultant, or other technically qualified person for guidance to ensure proper entry and emergency response/rescue procedures are in place, and that all necessary equipment is selected and in proper working order before conducting entry operations. Because ultimately, only the employer can decide, based upon his or her knowledge of, and experience with their permit spaces, what the best entry procedures, types of atmospheric testing instrument, ventilation system, and rescue procedure must be used for a specific entry operation.

Here’s to a productive and informative blog! – Curtis