Why Confined Space Rules Are Essential & Vitally Important

The Final Rule for Permit-Required Confined Spaces was published in the Federal Register on January 14, 1993, and became effective on April 15, 1993. The standard is based on years of gathering information on confined space fatalities and on testimony about the hazards of confined spaces from all sectors of industry and labor. Because it applies to all of general industry, a performance-oriented standard was developed rather than a specification standard. The rule citation is 29 CFR1910.146.

Many workplaces contain spaces which are considered “confined” because their configurations hinder the activities of any employees who must enter, work in, and exit them. For example, employees who work in process vessels generally must squeeze in and out through narrow openings and perform their tasks while cramped or contorted. For the purposes of this rulemaking, OSHA is using the term “confined space” to describe such spaces.

In addition, there are many instances where employees who work in confined spaces face increased risk of exposure to serious hazards. In some cases, confinement itself poses entrapment hazards. In other cases, confined space work keeps employees closer to hazards, such as asphyxiating atmospheres or the moving parts of a mixer, than they would be otherwise.

OSHA uses the term “permit-required confined space” (permit space) to describe those spaces which both meet the definition of “confined space” and pose health or safety hazards.

Asphyxiation is the leading cause of death in confined spaces. The asphyxiations that have occurred in permit spaces have generally resulted from oxygen deficiency or from exposure to toxic atmospheres. In addition, there have been cases where employees who were working in water towers and bulk material hoppers slipped or fell into narrow, tapering, discharge pipes and died of asphyxiation due to compression of the torso. Also, employees working in silos have been asphyxiated as the result of engulfment in finely divided particulate matter (such as sawdust) that blocks the breathing passages.

OSHA has, in addition, documented confined space incidents in which victims were burned, ground-up by auger type conveyors, or crushed or battered by rotating or moving parts inside mixers. Failure to deenergize equipment inside the space prior to employee entry was a factor in many of those accidents.

Many employers have not appreciated the degree to which the conditions of permit space work can compound the risks of exposure to atmospheric or other serious hazards. Further, the elements of confinement, limited access, and restricted air flow, can result in hazardous conditions which would not arise in an open workplace. For example, vapors which might otherwise be released into the open air can generate a highly toxic or otherwise harmful atmosphere within a confined space. Unfortunately, in many cases, employees have died because employers improvised or followed “traditional methods” rather than following existing OSHA standards, recognized safe industry practice, or common sense.

The failure to take proper precautions for permit space entry operations has resulted in fatalities, as opposed to injuries, more frequently than would be predicted using the applicable Bureau of Labor Statistics models. OSHA notes that, by their very nature and configuration, many permit spaces contain atmospheres which, unless adequate precautions are taken, are immediately dangerous to life and health (IDLH). For example, many confined spaces are poorly ventilated – a condition that is favorable to the creation of an oxygen deficient atmosphere and to the accumulation of toxic gases.

Furthermore, by definition, a confined space is not designed for continuous employee occupancy; hence little consideration has been given to the preservation of human life within the confined space when employees need to enter it.

It is your obligation as an employer to evaluate your workplace to determine if any spaces are permit-required confined spaces.

You must first determine whether a space is a confined space. If it is a confined space, then you must determine if it is a permit-required confined space. If it is a permit-required confined space, then you must determine whether full permit entry rules apply or less restrictive alternative entry rules apply.

REMINDER: A confined space is characterized by restricted means of entry/exit, size sufficient to contain a worker, and not specifically designed for worker occupancy. A permit-required space is a confined space that has a hazard to health or life associated with it. Hazards may be the result of atmosphere or materials in the space or the result of the shape of the space.

In general, the Permit-Required Confined Spaces Standard requires that you, the employer, evaluate the workplace to determine if any spaces are permit-required confined spaces. If permit spaces are present, and your workers ever are authorized to enter such spaces, you must develop and implement a comprehensive permit spaces program, which is an overall plan/policy for protecting employees from permit space hazards and for regulating employee entry into permit spaces. The OSHA standard includes detailed specification of the elements of an acceptable permit spaces program (29 CFR 1910.146(d)). Permit spaces must be identified by signs, and entry must be controlled and limited to authorized persons. An important element of the requirements is that entry be regulated by a written entry permit system, and that entry permits be recorded and issued for each entry in to a permit space. The standard specifies strict procedures for evaluation and atmospheric testing of a space before and during an entry by workers. The standard requires that entry be monitored by an attendant outside the space and that provisions be made for rescue in the event of an emergency. The standard specifies training requirements and specific duties for authorized entrants, attendants, and supervisors. Rescue service provisions are required, and where feasible rescue must be facilitated by a non-entry retrieval system, such as a harness and cable attached to a mechanical hoist.

The OSHA Permit-Required Confined Spaces Standard provides for alternative (less stringent than full permit procedures) entry procedures in cases where the only hazard in a space is atmospheric and the hazard can be controlled by forced air. The alternative procedure is allowed only in cases where specified requirements for substantiation and notification are met.

Special requirements apply to contractors whose employees work in spaces controlled by others. Employers who engage contractors to work in their permit-required confined spaces also have special obligations pertaining to that arrangement.

If certain kinds of work are done in a permit space, then additional OSHA rules may apply. These kinds of work include telecommunications, electrical (underground), paper/pulp milling, shipbuilding, longshoring and sewer work.

Construction, marine terminal, ship yard employment, and agriculture are not subject to the OSHA General Industry Permit-Required Confined Spaces regulation (29 CFR 1910.146). However, employers in those industries should be aware that their workers are covered when they do work that falls under the general industry category. For example, maintenance, repair, and refurbishing work is covered under general industry rules even though done by “construction” contractors.

You may be able to reclassify a permit-required confined space to non-permit space status if you can permanently eliminate the hazards affecting the space.

The OSHA Confined Spaces Advisor includes an option that will lead you through a series of simple questions to determine if a space is a permit-required confined space and what rule alternatives apply to your situation.

Appendix D to §1910.146 — Sample Permits

Appendix D-1

Confined Space Entry Permit
Date and Time Issued: _______________ Date and Time Expires: ________
Job site/Space I.D.: ________________ Job Supervisor:________________
Equipment to be worked on: __________ Work to be performed: _________

Stand-by personnel: __________________ ________________ _____________

1. Atmospheric Checks:  Time      ________
                        Oxygen    ________%
                        Explosive ________% L.F.L.
                        Toxic     ________PPM

2. Tester's signature: _____________________________

3. Source isolation (No Entry):  N/A   Yes   No
     Pumps or lines blinded,     ( )   ( )   ( )
     disconnected, or blocked    ( )   ( )   ( )

4. Ventilation Modification:     N/A   Yes   No
     Mechanical                  ( )   ( )   ( )
     Natural Ventilation only    ( )   ( )   ( )

5. Atmospheric check after
   isolation and Ventilation:
   Oxygen __________%           >    19.5   %
   Explosive _______% L.F.L     <    10     %
   Toxic ___________PPM         <    10     PPM H(2)S
   Time ____________
   Testers signature: _____________________________

6. Communication procedures: ________________________________________
_____________________________________________________________________

7. Rescue procedures: _______________________________________________
_____________________________________________________________________
_____________________________________________________________________
_____________________________________________________________________

8. Entry, standby, and back up persons:              Yes       No
   Successfully completed required
     training?
   Is it current?                                    ( )       ( )

9. Equipment:                              N/A       Yes       No
   Direct reading gas monitor -
     tested                                ( )       ( )       ( )
   Safety harnesses and lifelines
     for entry and standby persons         ( )       ( )       ( )
   Hoisting equipment                      ( )       ( )       ( )
   Powered communications                  ( )       ( )       ( )
   SCBA's for entry and standby
     persons                               ( )       ( )       ( )
   Protective Clothing                     ( )       ( )       ( )
   All electric equipment listed
     Class I, Division I, Group D
     and Non-sparking tools                ( )       ( )       ( )

10. Periodic atmospheric tests:
    Oxygen     ____%    Time ____  Oxygen     ____%    Time ____
    Oxygen     ____%    Time ____  Oxygen     ____%    Time ____
    Explosive  ____%    Time ____  Explosive  ____%    Time ____
    Explosive  ____%    Time ____  Explosive  ____%    Time ____
    Toxic      ____%    Time ____  Toxic      ____%    Time ____
    Toxic      ____%    Time ____  Toxic      ____%    Time ____

We have reviewed the work authorized by this permit and the
information contained here-in. Written instructions and safety
procedures have been received and are understood. Entry cannot be
approved if any squares are marked in the "No" column. This permit is
not valid unless all appropriate items are completed.

Permit Prepared By: (Supervisor)________________________________________
Approved By: (Unit Supervisor)__________________________________________
Reviewed By (Cs Operations Personnel) :
_________________________________   ____________________________________
      (printed name)                             (signature)

This permit to be kept at job site. Return job site copy to Safety
Office following job completion.

Copies:   White Original (Safety Office)
          Yellow (Unit Supervisor)
          Hard(Job site)
Appendix D - 2

                          ENTRY PERMIT

PERMIT VALID FOR 8 HOURS ONLY.  ALL COPIES OF PERMIT WILL REMAIN AT
JOB SITE UNTIL JOB IS COMPLETED

DATE: - -  SITE LOCATION and DESCRIPTION ______________________________
PURPOSE OF ENTRY ______________________________________________________
SUPERVISOR(S) in charge of crews   Type of Crew Phone #
_______________________________________________________________________
_______________________________________________________________________
COMMUNICATION PROCEDURES ______________________________________________
RESCUE PROCEDURES (PHONE NUMBERS AT BOTTOM) ___________________________
_______________________________________________________________________
* BOLD DENOTES MINIMUM REQUIREMENTS TO BE COMPLETED AND REVIEWED
PRIOR TO ENTRY*

REQUIREMENTS COMPLETED                            DATE           TIME
Lock Out/De-energize/Try-out                      ____           ____
Line(s) Broken-Capped-Blanked                     ____           ____
Purge-Flush and Vent                              ____           ____
Ventilation                                       ____           ____
Secure Area (Post and Flag)                       ____           ____
Breathing Apparatus                               ____           ____
Resuscitator - Inhalator                          ____           ____
Standby Safety Personnel                          ____           ____
Full Body Harness w/"D" ring                      ____           ____
Emergency Escape Retrieval Equip                  ____           ____
Lifelines                                         ____           ____
Fire Extinguishers                                ____           ____
Lighting (Explosive Proof)                        ____           ____
Protective Clothing                               ____           ____
Respirator(s) (Air Purifying)                     ____           ____
Burning and Welding Permit                        ____           ____
Note:  Items that do not apply enter N/A in the blank.

          **RECORD CONTINUOUS MONITORING RESULTS EVERY 2 HOURS
CONTINUOUS MONITORING**  Permissible  _________________________________
TEST(S) TO BE TAKEN      Entry Level
PERCENT OF OXYGEN        19.5% to 23.5% ___ ___ ___ ___ ___ ___ ___ ___
LOWER FLAMMABLE LIMIT    Under 10%      ___ ___ ___ ___ ___ ___ ___ ___
CARBON MONOXIDE          +35 PPM        ___ ___ ___ ___ ___ ___ ___ ___
Aromatic Hydrocarbon     + 1 PPM * 5PPM ___ ___ ___ ___ ___ ___ ___ ___
Hydrogen Cyanide         (Skin)  * 4PPM ___ ___ ___ ___ ___ ___ ___ ___
Hydrogen Sulfide         +10 PPM *15PPM ___ ___ ___ ___ ___ ___ ___ ___
Sulfur Dioxide           + 2 PPM * 5PPM ___ ___ ___ ___ ___ ___ ___ ___
Ammonia                          *35PPM ___ ___ ___ ___ ___ ___ ___ ___
* Short-term exposure limit: Employee can work in the area up to 15
minutes.
+ 8 hr. Time Weighted Avg.: Employee can work in area 8 hrs (longer
with appropriate respiratory protection).
REMARKS:_____________________________________________________________
GAS TESTER NAME       INSTRUMENT(S)        MODEL          SERIAL &/OR
  & CHECK #              USED           &/OR TYPE          UNIT #
________________     _______________    ___________      ____________
________________     _______________    ___________      ____________

      SAFETY STANDBY PERSON IS REQUIRED FOR ALL CONFINED SPACE WORK
SAFETY STANDBY   CHECK #   CONFINED              CONFINED
 PERSON(S)                  SPACE     CHECK #     SPACE      CHECK #
                          ENTRANT(S)            ENTRANT(S)
______________   _______   __________  _______   __________   _______
______________   _______   __________  _______   __________   _______
SUPERVISOR AUTHORIZING - ALL CONDITIONS SATISFIED____________________
                         DEPARTMENT/PHONE ___________________________
AMBULANCE 2800  FIRE 2900    Safety   4901  Gas Coordinator 4529/5387

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