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