Confined Spaces: When a Permit is Needed

A confined space can pose a serious threat in the workplace if an employee becomes trapped or exposed to toxins. Under certain conditions the Occupational Safety and Health Administration (OSHA) requires the employer to implement a permit program to ensure only properly trained personnel enter a confined space.

OSHA Defines a Confined Space

According to OSHA, a confined space meets the following three conditions:

• large enough and properly configured for employee entry and to accomplish work,
• limited entry and/or exit means,
• an area not designed for continuous occupancy.

OSHA bases its definition on 29 Code of Federal Regulations (CFR) 1910.146(b). Some examples of this include:

• manholes,
• pipelines,
• pits,
• silos,
• storage bins,
• tanks,
• underground vaults.

Permit vs. Non-permit Required

OSHA also specifies the difference between a confined space that requires a permit and one that does not. To qualify as a space requiring a permit, it must fit only one of the following criteria:

• an existing or potentially hazardous atmosphere,
• contains material with potential for engulfing a person,
• has actual or potentially inwardly converging walls capable of trapping or asphyxiating a person,
• may or does contain any "serious physical hazards,"
• has an actual or potential "recognized safety or health hazard."

A confined space that doesn't require a permit for entry doesn't contain or have the potential to contain any hazard that could cause serious physical injury or death.

Developing a Confined Space Program

You need a permit program if your business has a confined space that fits the description of one needing a permit for entry. You must post signs outside the confined space entry warning of the danger to entry in that area that read: "DANGER--PERMIT-REQUIRED CONFINED SPACE, DO NOT ENTER."

You and your employees could benefit from an OSHA Outreach General Industry Training Program that helps you learn more about confined space safety and proper precautions. It helps you learn about and meet the specific requirements of a permit program for confined space areas, as well as related topics. At a minimum, your company's written program must:

• analyze all workspaces to determine confined spaces before allowing entry,
• evaluate each space and its hazards,
• develop a way to prevent unauthorized entry,
• develop and use a way to eliminate or control hazards to ensure safe entry,
• set entry conditions,
• isolate the space,
• provide a method of safely eliminating or controlling atmospheric hazards,
• require, provide and maintain personal protective equipment (PPE) and other necessary safety equipment,
• conduct atmospheric testing before entry
• monitor atmospheric conditions during entry,
• station at least one attendant outside while in use,
• institute emergency procedures for attendants who monitor multiple spaces for when an event occurs in one,
• coordinate with hired contractors,
• establish rescue procedures,
• establish a written system for entry permits,
• annually review and revise the permit system.

In addition to the suggested general training, OSHA requires job-specific safety training for confined space duties. It also requires updated training when an employee changes jobs or changes to the permit program occur. It requires rescue training. Besides rescue methods, this training must include basic medical treatments including first aid and cardiopulmonary resuscitation (CPR).

One member of the company's rescue team must obtain and retain certification in both CPR and first aid. OSHA mandates specific program requirements for any permit system. A review of its web page on confined areas provides specific needs, but safety managers creating their first such permit program benefit from formal training in the topic. These programs provide templates for program development and practice opportunities for safety managers.