Every employer is required to survey their facility to determine whether they have “confined spaces” or “permit required confined spaces” on-site. What is a confined space? When does a confined space become a permit required confined space? And if an employer has a permit required confined space on-site, are there specific requirements they need to follow? We answer those questions in this blog post.

WHAT IS A CONFINED SPACE?

To understand a permit required confined space, it’s important to first understand how OSHA defines a confined space. OSHA defines a confined space as having three traits:
  • The space is large enough for workers to enter and perform assigned jobs
  • There are limited or restricted means for entry and exit
  • The space is not designed for continuous occupancy
A common example of a confined space is a closet. A janitor who is going in and out of the closet to do his job is entering a confined space, but there is no hazard in the closet that can hurt him. He can enter that space with no restrictions.

WHEN IS A CONFINED SPACE A PERMIT REQUIRED CONFINED SPACE?

If a confined space could pose a hazard to an employee assigned to enter it, it becomes a permit required confined space. According to OSHA, a permit required confined space (“permit space” for short) is a confined space that meets one or more of the following criteria:
  • It has actual or potential for a hazardous atmosphere
  • It contains a material that has the potential for engulfing an entrant
  • It has an internal configuration that could trap an entrant
  • It contains any other recognized serious safety or health hazard
An example of a permit required confined space is a sewer entry. The employees could be exposed to toxic or flammable gases (a hazardous atmosphere), engulfment, and oxygen deficiency (serious health hazard). Proper procedures must take place before the entry.

EMPLOYER RESPONSIBILITIES

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Permit Required Confined Space Program

If there is a permit required confined space on site, the employer is required to develop a written Permit Required Confined Space Program. This program outlines how the employer will control the potential permit required confined space hazards and, where applicable, protect employees against them. The program includes a Hazard Analysis and a Permitting Plan for each permit space.

Hazard Analysis

In the Hazard Analysis, the employer must list out every potential hazard in a permit space and outline steps to make the space safe for employee entry. Steps may include lock-out, tag-out or personal protective equipment. We’ve provided a Hazard Analysis template for you to use. Click here to download!

Permitting Plan

Before an employee enters a permit required confined space, a Confined Space Entry Permit must be issued. The permit documents that all steps listed in the Hazard Analysis have been done to make the space safe for entry, or that the proper personal protection equipment is being used to protect the employee. The permit also lists the personnel assignments for Authorized Entrants, Authorized Attendants, and Entry Supervisors. Click here to download our Confined Space Entry Permit template! As part of the Permitting Plan, when the work in the permit pace is complete, the Confined Space Entry Permit is properly closed by the Supervisor. It is then turned in, usually to the safety department, to be reviewed, looking for any conditions that may have changed in the space and corrective measures taken to protect the employees.

REQUIRED CONFINED SPACE TRAINING

OSHA requires that all employees working in permit required confined spaces be trained to know the potential hazards and how to protect themselves. (Regulations: 29 CFR 1910.146) Employees must be trained for any position listed on the Confined Space Entry Permit and all duties they are required to perform. The three positions listed on a Confined Space Entry Permit are:
  • Attendant
    • OSHA defines this role as the individual who monitors the authorized entrants and performs all attendant’s duties assigned in the employer’s permit space program.
  • Authorized Entrant
    • According to OSHA, this is the employee who is authorized by the employer to enter a permit space.
  • Entry Supervisor
    • OSHA defines this role as the person responsible for determining whether acceptable entry conditions are present at a permit space where entry is planned, for authorizing entry and overseeing entry operations, and for terminating entry. This could be the employer, a foreman, or crew chief.
Permit required confined space entry training is required for any employee that is expected to be an Authorized Entrant or function as an Attendant or Entry Supervisor for an entry into a permit required confined space. HazMat Solutions offers customized in-person confined space training to meet all OSHA requirements for the employees at your facility. After completing our training, employees will be able to function as an Attendant, Entrant, or Supervisor during confined space entry operations. If you have any questions, give us a call at 616-393-0866 or contact us for a quote!