Confined Spaces

14 Steps to Confined Spaces Compliance

Date First Published on SafetySmart Compliance: August 16th, 2012
Topics: Confined Spaces |

worker in a pit

Working inside a confined space makes a job 150 times more dangerous—not only to the workers inside but to potential rescuers sent in to help them in an emergency. The OSHA Permit-Required Confined Spaces standard, Sec. 1910.146, sets out the safety measures employers must take to protect workers from confined spaces dangers. It’s also a frequent source of OSHA citations. Here’s an overview of the 14 things you must do to comply.

The first thing you must do is determine if you have any confined spaces at your workplace. You then must classify the confined spaces you identify as either:

  • Non-permit confined spaces, i.e., spaces that don’t contain or potentially  contain hazards capable of causing death or serious harm to entrants; and
  • Permit confined spaces, i.e., spaces that do contain actual or potential hazards, which you must either seal off so no one can enter or establish a confined space entry program to ensure safe entry.

You must reassess non-permit spaces and decide whether to reclassify them as permit spaces when there are changes to the configuration of the space or the work done inside it. You can also reclassify permit as non-permit spaces if you can demonstrate that it no longer contains the actual or potential hazards that led you to classify it as a permit space.

More Help Identifying, Classifying & Reclassifying Confined Spaces

If you discover any permit confined spaces in your workplace, you need to secure the entrance using physical barriers, locks, warning devices or a combination to bar unauthorized entry and notify workers of the existence, location and dangers of the space by posting warning signs or other effective means of communication. You then have to make a fundamental decision about how you’re going to handle the space going forward. Your options: Seal off the space so nobody can enter it, or implement a confined spaces entry program to ensure safe entry into the space.

Instructions: The rest of this Compliance Plan explains how to implement an appropriate confined spaces entry program for permit spaces. If you bar all entry into permit spaces, you can stop reading.

For More Help Barring Permit Space Entry

The confined spaces entry program must specify acceptable atmospheric conditions, i.e., the atmospheric conditions that must exist prior to and sustained during entry into permit spaces.

More Help Defining Atmospheric Conditions for Permit Space Entry

The confined spaces entry program must require atmospheric testing of permit spaces

before entry and as often as necessary during entry to verify that acceptable atmospheric conditions are still present. It must also require workers to evacuate the space immediately if atmospheric conditions no longer meet the specified acceptability standards and ban re-entry after evacuation until new testing verifies that the atmosphere is safe again. The OSHA standard contains specific rules about testing methods, sequences, instruments and personnel.

For More Help with Atmospheric Testing

The confined spaces entry program must list the engineering controls used to manage hazardous atmospheres in the permit space. Acceptable methods include:

  • Ventilation, i.e., mechanical systems that force fresh air into the confined space and/or exhaust contaminated air while workers are inside it;
  • Purging, i.e., introducing substances such as an inert gas, steam or water into a confined space to displace or flush out contaminants before workers enter the space;
  • Inerting, i.e., introducing an inert (un-reactive) gas such as nitrogen or carbon dioxide into a confined space to completely displace all oxygen; and
  •  Isolation, i.e., disconnecting, blanking or blinding or using an equivalent engineered system to prevent a hazardous substance contained in adjacent pipelines from seeping or leaking into the permit space.

For More Help with Atmospheric Testing

The confined space entry program must list the methods used to ensure workers authorized to enter the space (referred to as “authorized entrants”) can get in and out of the permit space safely for routine entry and emergency evacuation. Such methods may include furnishing ladders and other equipment, providing for lighting inside the space and protections against pedestrian and vehicular traffic outside the space, e.g., erecting barriers around manholes to protect authorized entrants working inside.

For More Help with Entry, Exit & Traffic Safety Controls

Entry must be overseen by an “entry supervisor” who gives the green light after ensuring all the safety measures have been carried out. The confined space entry program should require designation of an entry supervisor for each permit space entry, list the qualifications an entry supervisor must have and describe the entry supervisor’s duties.

For More Help with Entry Supervisor Requirements

For each entry, there must be one or more “attendants” who remain outside the space near the entrance to keep an eye on the entry, communicate with the authorized entrants inside and provide help in case of an emergency. The confined space entry program should require assignment of attendants, describe attendants’ qualifications and list their specific responsibilities.

For More Help with Attendant Requirements

The confined space entry program must contain an entry procedure to ensure the entry is carried out safely and in accordance with OSHA requirements. At a minimum, the entry procedure must list the safety measures required by the standard, e.g., hazard assessment, verification of acceptable conditions of entry and use of engineering controls to eliminate or control atmospheric hazards. You must review the entry procedure at least once a year and more frequently any time you have reason to believe it’s not providing entrants the necessary safety. Triggers for review include near misses or injuries, unauthorized entries, detection of new or unpermitted hazards inside the space, changes in the space’s use or configuration and worker complaints.

For More Help with Entry Procedures

One of the critical elements of a confined spaces entry program is the establishment of an entry permit system. Entry permits must be issued by the entry supervisor before entry and posted at the entry site at all times when authorized entrants are inside the space. Entry permits must list essential information about the entry and steps taken to ensure its safety. In essence, the permit serves as a checklist for verifying that entry conditions are acceptable and all required safety measures, equipment, etc. are in place.

For More Help Writing & Implementing a Confined Spaces Entry Permit System

Another key requirement to address in your confined spaces entry program is equipment. You must furnish authorized entrants the equipment they need at your expense, including PPE (personal protective equipment) like respirators and hardhats, rescue or retrieval systems and gear and communication equipment. In addition to specifying the equipment used, your program should require proper inspection, use, care, maintenance and storage of PPE and safety equipment.

For More Help with Confined Spaces PPE & Safety Equipment

The confined spaces entry program must provide for rescuing authorized entrants if emergencies arise after they enter the permit space. An estimated 80% of confined space fatalities are suffered not by the original entrants but the individuals sent in to rescue them. Accordingly, the preferred method is to use retrieval systems that make it unnecessary to send in rescue personnel. If retrieval systems wouldn’t be effective and you must rely on rescue personnel to enter the space, you must take steps to ensure rescue operations are as safe as possible.

For More Help with Confined Space Rescue & Emergency Response

If you let your contractors or subcontractors enter permit spaces at your site, you must also take measures to protect those workers and make sure the contractor/subcontractor’s confined space entry procedures don’t undermine your own.

For More Help Coordinating Confined Spaces Safety Programs with Contractors

Last but not least, the confined space entry program must provide that all personnel involved in permit space entry receive training necessary to be “proficient” before they’re actually allowed to carry out those duties. Confined spaces safety training must be provided to 4 groups:

  • Authorized entrants;
  • Attendants;
  • Entry supervisors; and
  • Rescue personnel.

For More Help Providing Confined Spaces Safety Training & Training Tools

Reviewing Your Confined Spaces Entry Program

Use cancelled permits to review the permit entry program within a year after each entry and revise it as necessary to ensure that workers are properly protected. Perform a single annual review covering all entries performed during a 12-month period—unless no entries have occurred over the period. You also need to review the program any time you have “reason to believe” it may not be effective.  Triggers for review include near misses or injuries, unauthorized entries, detection of new or unpermitted hazards inside the space, changes in the space’s use or configuration and worker complaints.

Model Confined Space Entry Programs from OSHA