CONFINED SPACES

National Association of Safety Professionals

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Permit-Required Confined Spaces - 1910.146

Introduction

Many workplaces contain spaces that are considered to

be "confined" because their configurations hinder the
activities of any employees who must enter into, work in,
and exit from them. In many instances, employees who
work in confined spaces also face increased risk of
exposure to serious physical injury from hazards such as
entrapment, engulfment, and hazardous atmospheric
conditions. Confinement itself may pose entrapment
hazards, and work in confined spaces may keep
employees closer to hazards, such as an asphyxiating
atmosphere, than they would be otherwise. For example,
confinement, limited access, and restricted airflow can
result in hazardous conditions that would not arise in an open workplace.

The term "permit-required confined space" (i.e., permit space) refers to those
spaces that meet the definition of a "confined space" and pose health or safety
hazards, thereby requiring a permit for entry.

A confined space has limited or restricted means of entry or exit, is large

enough for an employee to enter and perform assigned work, and is not
designed for continuous occupancy by the employee. These spaces may
include, but are not limited to, underground vaults, tanks, storage bins, pits and
diked areas, vessels, and silos.

A permit-required confined space is one that meets the definition of a

confined space and has one or more of these characteristics: (1) contains or
has the potential to contain a hazardous atmosphere, (2) contains a material
that has the potential for engulfing an entrant, (3) has an internal configuration

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that might cause an entrant to be trapped or asphyxiated by inwardly

converging walls or by a floor that slopes downward and tapers to a smaller
cross section, and/or (4) contains any other recognized serious safety or health
hazards.

Requirements of the Standard

General

In general, employers must evaluate the workplace to determine if spaces are

permit-required confined spaces. (See flow chart). If there are permit spaces
in the workplace, the employer must inform exposed employees of the
existence, location, and danger posed by the spaces. This can be
accomplished by posting danger signs or by another equally effective means.
The following language would satisfy the requirements for such a sign:

DANGER--PERMIT REQUIRED-CONFINED SPACE--

AUTHORIZED ENTRANTS ONLY

If employees are not to enter and work in permit spaces, employers must take
effective measures to prevent their employees from entering the permit spaces.

If employees are to enter permit spaces, the employer must develop a written
permit space program, which shall be made available to employees or their
representatives. Under certain conditions, the employer may use alternate
procedures for worker entry into a permit space. For example, if employers can
demonstrate with monitoring and inspection data that the only hazard is an
actual or potential hazardous atmosphere, which can be made safe for entry by
the use of continuous forced air ventilation alone, they may be exempted from
some requirements, such as permits and attendants. Even in such
circumstances, however, the internal atmosphere of the space must be tested

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first for oxygen content, second for flammable gases and vapors, and third for
potential toxic air contaminants before any employee enters.

Written Program

The employer who allows employee entry must develop and implement a
written program for permit-required confined spaces.

Among other things, the OSHA standard requires the employer's program to:

! Identify and evaluate permit space hazards before allowing employee

entry;

! Test conditions in the permit space before entry operations and monitor the
space during entry;

! Perform in the following sequence, appropriate testing for atmospheric

hazards: oxygen, combustible gases or vapors, and toxic gases or vapors;

! Implement necessary measures to prevent unauthorized entry;

! Establish and implement the means, procedures and practices --such as

specifying acceptable entry conditions, isolating the permit space,
providing barriers, verifying acceptable entry conditions, purging, making
inert, flushing, or ventilation of the permit space--to eliminate or control
hazards necessary for safe permit-space entry operations;

! Identify employee job duties;

! Provide, maintain, and require, at no cost to the employee, the use of

personal protective equipment and any other equipment necessary for safe
entry (e.g., testing, monitoring, ventilating, communications, and lighting
equipment; barriers, shields, and ladders);

! Ensure that at least one attendant is stationed outside the permit space for
the duration of entry operations;

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! Coordinate entry operations when employees of more than one employer

are to be working in the permit space;

! Implement appropriate procedures for summoning rescue and emergency

services;

! Establish, in writing, and implement a system for the preparation, issuance,

use, and cancellation of entry permits;

! Review established entry operations and annually revise the permit-space

entry program; and

! When an attendant is required to monitor multiple spaces, implement the

procedures to be followed during an emergency in one or more of the
permit spaces being monitored.

If hazardous conditions are detected during entry, employees must immediately

leave the space, and the employer must evaluate the space to determine the
cause of the hazardous atmospheres.

When entry to permit spaces is prohibited, the employer must take effective
measures to prevent unauthorized entry. Non-permit confined spaces must be
reevaluated when there are changes in their use or configuration and, where
appropriate, must be reclassified.

If testing and inspection data prove that a permit-required confined space no

longer poses hazards, that space may be reclassified as a non-permit confined
space. If entry is required to eliminate hazards and to obtain the data, the
employer must follow procedures as set forth under sections (d) through (k) of
the standard. A certificate documenting the data must be made available to
employees entering the space. The certificate must include the date, location
of the space, and the signature of the person making the certification.

Contractors also must be informed of permit spaces and permit space entry

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requirements, any identified hazards, the employer's experience with the space
(i.e., the knowledge of hazardous conditions), and precautions or procedures to
be followed when in or near permit spaces.

When employees of more than one employer are conducting entry operations,
the affected employers must coordinate entry operations to ensure that affected
employees are appropriately protected from permit space hazards. Contractors
also must be given and other pertinent information regarding hazards and
operations in permit spaces and be debriefed at the conclusion of entry
operations.

Permit System

A permit, signed by the entry supervisor and verifying that pre-entry

preparations have been completed and that the space is safe to enter, must be
posted at entrances or otherwise made available to entrants before they enter a
permit space.

The duration of entry permits must not exceed the time required to complete an
assignment. Also, the entry supervisor must terminate entry and cancel
permits when an assignment has been completed or when new conditions
exist. New conditions must be noted on the canceled permit and used in
revising the permit space program. The standard also requires the employer to
keep all canceled entry permits for at least 1 year.

Entry Permits

Entry permits must include the following information:

! Test results;

! Tester's initials or signature;

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! Name and signature of supervisor who authorizes entry;

! Name of permit space to be entered, authorized entrant(s), eligible

attendants, and individual(s) authorized to be entry supervisor(s);

! Purpose of entry and known space hazards;

! Measures to be taken to isolate permit spaces and to eliminate or control

space hazards, i.e., locking out or tagging of equipment and procedures for
purging, making inert, ventilating and flushing permit spaces;

! Name and telephone numbers of rescue and emergency services;

! Date and authorized duration of entry;

! Acceptable entry conditions;

! Communication procedures and equipment to maintain contact during

entry;

! Additional permits(s), such as for hot work, that have been issued to
authorize work in the permit space;

! Special equipment and procedures, including personal protective

equipment and alarm systems; and

! Any other information needed to ensure employee safety.

Training and Education

Before initial work assignment begins, the employer must provide proper
training for all workers who are required to work in permit spaces. Upon
completing this training, employers must ensure that employees have acquired
the understanding, knowledge, and skills necessary for the safe performance of
their duties. Additional training is required when (1) the job duties change, (2)
there is a change in the permit-space program or the permit space operation

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presents a new hazard, and (3) when an employee's job performance shows
deficiencies. Training also is required for rescue team members, including
cardiopulmonary resuscitation (CPR) and first-aid training (see Emergencies).
Employers must certify that training has been accomplished.

Upon completion of training, employees must receive a certificate of training

that includes the employee's name, signature or initials of trainer(s), and dates
of training. The certification must be made available for inspection by
employees and their authorized representatives.

In addition, the employer also must ensure that employees are trained in their
assigned duties.

Authorized Entrant's Duties

! Know space hazards, including information on the mode of exposure (e.g.,

inhalation or dermal absorption), signs or symptoms, and consequences of
the exposure;

! Use appropriate personal protective equipment properly (e.g., face and eye
protection, and other forms of barrier protection such as gloves, aprons,
and coveralls);

! As necessary, maintain communication (i.e., telephone, radio, visual

observation) with attendants to enable the attendant to monitor the
entrant's status as well as to alert the entrant to evacuate;

! Exit from permit space as soon as possible when ordered by an authorized

person, when the entrant recognizes the warning signs or symptoms of
exposure exist, when a prohibited condition exists, or when an automatic
alarm is activated; and

! Alert the attendant when a prohibited condition exists or when warning

signs or symptoms of exposure exist.

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Attendant's Duties

! Remain outside permit space during entry operations unless relieved by

another authorized attendant;

! Perform no-entry rescuers when specified by employer's rescue procedure;

! Know existing and potential hazards, including information on the mode of

exposure, signs or symptoms, consequences of the exposure, and their
physiological effects;

! Maintain communication with and keep an accurate account of those

workers entering the permit-required space;

! Order evacuation of the permit space when a prohibited condition exists,

when a worker shows signs of physiological effects of hazardous exposure,
when an emergency outside the confined space exists, and when the
attendant cannot effectively and safely perform required duties;

! Summon rescue and other services during an emergency;

! Ensure that unauthorized persons stay away from permit spaces or exit
immediately if they have entered the permit space;

! Inform authorized entrant's and entry supervisor of entry by unauthorized

persons; and;

! Perform no other duties that interfere with the attendant's primary duties.

Entry Supervisor's Duties

! Know space hazards including information on the mode of exposure, signs,

or symptoms and consequences of exposure;

! Verify emergency plans and specified entry conditions such as permits,

tests, procedures, and equipment before allowing entry;

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! Terminate entry and cancel permits when entry operations are completed
or if a new condition exists;

! Take appropriate measures to remove unauthorized entrants; and

! Ensure that entry operations remain consistent with the entry permit and
that acceptable entry conditions are maintained.

Emergencies

The standard requires the employer to ensure that rescue service personnel
are provided with and trained in the proper use of personal protective and
rescue equipment, including respirators; trained to perform assigned rescue
duties; and have had authorized entrant's training. The standard also requires
that all rescuers be trained in first aid and CPR and, at a minimum, one rescue
team member be currently certified in first aid and in CPR. The employer also
must ensure that practice rescue exercises are performed yearly, and that
rescue services are provided access to permit spaces so that they can practice
rescue operations. Rescuers also must be informed of the hazards of the
permit space.

Also, when appropriate, authorized entrants who enter a permit space must
wear a chest or full body harness with a retrieval line attached to the center of
their backs near shoulder level, or above their heads. Wristlets may be used if
the employer can demonstrate that the use of a chest or full body harness is
infeasible or creates a greater hazard. Also, the employer must ensure that the
other end of the retrieval line is attached to a mechanical device or to a fixed
point outside the permit space. A mechanical device must be available to
retrieve personnel from vertical type permit spaces more than 5 feet deep.

In addition, if an injured entrant is exposed to a substance for which a Material

Safety Data Sheet (MSDS) or other similar written information is required to be
kept at the worksite, that MSDS or other written information must be made

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available to the medical facility treating the exposed entrant.

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