Program Development & Support: Permit Required Confined Space

What is Permit Required Confined Space?

OSHA defines a confined space (§1910.146(b)) as an area that:

• • Is large enough and so configured that an employee can fully enter and perform assigned work,
  • Has limited or restricted means of entry or exit, and
  • Is not designed for continuous employee occupancy

Examples include tanks, silos, pits, manholes, tunnels, ductwork, pipelines, and underground vaults.

A permit-required confined space (PRCS) has one or more of the following hazards:

1. 1. A hazardous atmosphere or potential for one
   2. Materials capable of engulfing an entrant
   3. Internal configurations that could trap or asphyxiate workers
   4. Any other serious safety or health hazard

Spaces without these hazards may be classified as non-permit confined spaces.

Core Elements of Confined Space Entry Permits

Before entry, a signed permit must be posted or made available. This confirms that all pre-entry procedures are complete and entry conditions are safe. Each permit should include:

• • Name of permit space to be entered, authorized entrants, eligible attendants, and individuals authorized to be entry supervisors
  • Atmospheric test results and tester’s signature
  • Purpose of entry and known space hazards
  • Measures to be taken to isolate permit spaces and to eliminate or control space hazards
  • Communication procedures and emergency contact details
  • Duration of entry and acceptable entry conditions
  • Required PPE, alarms, or special equipment

Key Actions for Permit Required Confined Spaces

Before Entry

1. 1. Develop a Written Program
      1. Implement necessary measures to prevent unauthorized entry
      2. Identify and evaluate permit space hazards before allowing employee entry
      3. Test atmospheric conditions in permit space before entry
      4. Perform appropriate testing for following atmospheric hazards: oxygen, combustible gases or vapors, and toxic gases or vapors
      5. Establish and implement the means, procedures and practices to eliminate or control hazards necessary for safe permit space entry operations
      6. Establish and implement a system for preparation, issue, and use of entry permits
      7. Review established entry operations annually and revise the permit space entry program as necessary
   2. Identify & Evaluate Hazards – Document risks and control measures
   3. Designate Roles
      1. Coordinate entry operations when employees of more than one employer are working in permit space
      2. Ensure at least one attendant is stationed outside the permit space for duration of entry operations
      3. Authorized entrant: Know space hazards, use appropriate personal protective equipment (PPE), maintain communication with attendants and monitor the entrant’s status
      4. Attendant: Remain outside the permit space during entry operations unless relieved by another authorized attendant, perform non-entry rescues when specified by employer’s rescue procedure, maintain communication with and keep accurate account of those workers entering permit space
      5. Entry supervisor: Know space, verify emergency plans and specified entry conditions, terminate entry and cancel permits if operations are completed or new conditions exist, and ensure that entry operations remain consistent with entry permit and that acceptable entry conditions are maintained
   4. Prepare Equipment
   5. Issuing Permit & Post Warning Signs

During Entry

1. 1. Continuous Monitoring – Track atmosphere and conditions in real time
   2. Maintain Communication – Entrants and attendants remain in contact
   3. Manage Hazards – Control or eliminate risks as work progresses
   4. Rescue Readiness (i.e. Emergency Action Plan)
   5. Control Access – Prevent unauthorized personnel from entering

After Entry

1. 1. Terminate the Entry – The entry supervisor terminates the operation and cancels the permit when work is complete or when conditions change
   2. Review & Retain Permits– Keep completed entry permit for required duration
   3. Evaluate the Program – Periodically review the program

Four elements crucial to successful health and safety management:

• • Management leadership and employee involvement
  • Worksite analysis
  • Hazard prevention and control
  • Safety and health training

OSHA Standards for Confined Spaces

Confined spaces are addressed in multiple OSHA standards, including:

• • General Industry – 29 CFR 1910.146
  • Shipyard Employment – 29 CFR 1915 Subpart B
  • Construction – 29 CFR 1926 Subpart AA

Industry-specific rules also apply to telecommunications, grain handling, pulp and paper mills, and more.

Staying Ahead: Reclassification of permit Spaces

Employers may reclassify a permit-required confined space as non-permit confined space if they:

• • Test and confirm no hazardous atmospheres
  • Eliminate other hazards without entering space
  • Document the hazard elimination in a signed certification
  • Make the certification available to affected workers
  • Reassess regularly or when conditions change