Confined Space Entry Training

OSHA Confined Space Entry Training and Certification

How to Reclassify a Permit Required Space to a Non-permit Space Through Hazard Isolation

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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).

Benefits of Reclassifying a Permit Space to Non-permit Status

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.

Applicability of OSHA’s Confined Space Reclassification Procedures

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.

What is “Isolation” of a Confined Space Hazard?

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.

One more method to isolate a confined space from the flow of energy or materials via pipes or lines is by use of a double block and bleed system (see image). Valves can potentially leak, so in OSHA’s eyes, turning off a single valve does not achieve total isolation of the space from the potential hazard. A double block and bleed system, where two valves in series are closed and the space between them bled off, would meet the requirements for isolation as long as each valve is secured per the OSHA lock-out/tag-out standard.

double block and bleed to isolate confined space for reclassification<br />

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.

Certification Requirements for Confined Space Reclassification

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.

Confined Space Reclassification is Temporary

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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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

OSHA Requirements for Signage and Notifications for Permit-required Confined Spaces

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Confined space signs and notification requirements

Blog Post #17 –The OSHA 1910 and 1926 confined space entry standard requirements address one of the employers’ first responsibilities at worksites where permit-required confined spaces are identified in the workplace; Informing affected workers and others of the existence and dangers of the permit spaces. Be aware that there are multiple ways this can, or must, be accomplished.

OSHA Requirements for Signs at Permit-required Confined Spaces

Paragraph 1910.146(c)(2) of the general industry standard for permit-required confined spaces and paragraph 1926.1203(b) of the confined spaces in construction standard states if the workplace contains one or more permit-required confined spaces, the employer who identifies, or who receives notice of, a permit space must inform exposed employees by posting danger signs, or by any other equally effective means, of the existence and location of, and the danger posed by, the permit spaces. This requirement must be met even if the employer will not have any of its workers enter any of the permit spaces. Both standards go on to note that a sign reading “DANGER – PERMIT-REQUIRED CONFINED SPACE, DO NOT ENTER” or other similar language would satisfy the requirement for a sign.

Alternatives to Posting Signs at Permit-required Confined Spaces

Due to their location or configuration, it may not be practical or possible to place a sign on some permit-required confined spaces. Therefore, the OSHA standards allow the employer to use “any other equally effective means” as an alternative to a sign. The goal of the OSHA standards is to ensure workers know of the existence, location, and danger of the permit-required confined spaces in the work place. And the preamble to the 1910 general industry permit-required confined space standard provides some guidance in this area that may be useful. It states that, as an alternative to a sign, employers can provide sufficient training to all employees to ensure they are aware of the location and hazards of the permit-required confined spaces at the jobsite. However, OSHA clearly states their preference for use of a sign where possible.

One other option presented in the 1910 preamble is to secure the entry porthole to the confined space with a lock or special fastener. Then, only employees who have been trained and authorized to enter the permit-required confined space would possess the key or tool needed to access the space.

Other Notification Requirements Regarding Permit-required Confined Spaces

In addition, those employers having permit spaces on site must inform, in a timely manner and in a manner other than posting, its employees’ authorized representatives, which are essentially their union representative, where applicable, of the existence and location of, and the danger posed by, each permit space. And the construction standard also requires employers who identify permit spaces at a construction site to also notify the Controlling Contractor at the site. Per OSHA definitions listed in this standard, the Controlling Contractor is the employer that has overall responsibility for construction at the worksite. This generally applies to the General Contractor, but this responsibility could fall to the host employer when no General Contractor is utilized.

Controlling Contractors at construction sites may or may not even have employees entering permit spaces, or they may not even be on the site at all times. But OSHA makes it very clear in the preamble to the construction standards for confined space entry that they consider the controlling contractor to be the “information hub for confined-spaces information sharing and coordination” at a construction site. More on the specific responsibilities of the Controlling contractor will be presented in later blog posts.

And for general industry worksites, 1910.146(c)(8) states that when an employer (host employer) arranges to have employees of another employer (contractor) perform work that involves permit space entry, the host employer shall inform the contractor that the workplace contains permit spaces and that permit space entry is allowed only through compliance with a permit space program meeting the requirements of this section. They must also apprise the contractor of the elements, including the hazards identified and the host employer’s experience with the space, that make the space in question a permit space.

What if No Employees Will Enter Confined Space?

Once affected employers have identified all of the permit-required confined spaces at their job-site, they are each presented with two options. Option one, an employer decides the employees it directs are NOT authorized to enter a permit space, or, option two, the employees they direct WILL enter a permit space. If an employer decides its employees will NOT enter a permit-required confined space, they still must comply with the requirements of Paragraph 1926.1203(c), which requires the employer to take effective measures to prevent its employees from entering the permit space.

So, even if an employer does not authorize their workers to enter permit spaces, they must still ensure that required danger signs are posted at permit spaces, and they must inform their employees and their designated representatives of the existence and hazards of the permit spaces. They must also inform employees and their designated reps of the company’s No Entry policy, where applicable. Last but not least, employers must inspect for compliance and enforce that policy.

Re-evaluation and Reclassification of Non-permit Required Confined Spaces

In addition, employers who have employees working in or near non-permit spaces must remember the requirements of paragraphs 1910.146(c)(6) and 1926.1203(f). They both require employers or their designated competent persons must reevaluate any non-permit confined space when there is a change to the use or configuration that might increase the hazards to entrants, as well as when there is some indication that the initial evaluation of the space may not have been adequate. And if a serious safety or health hazard is detected, the space must be reclassified as a permit-required confined space (with sign posted near points of entry) if necessary.

Comments About Communication and Signage Requirements for Permit Spaces

Please post your comments and questions about signage and notification requirements for permit-required 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, which addresses the steps that can be taken to temporarily reclassify permit-required confined spaces in the workplace to non-permit status; a big time-saver when working in eligible permit 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