Many job sites have small, confined spaces in which employees work. Some of these spaces have OSHA regulations attached to them that create obligations for your company and the employees that work within the spaces.
This article will help you understand the differences between confined spaces and permit-required confined spaces. We’ll also let you know what obligations you must adhere to as a business if you have some of these spaces on your job sites.
Table of Contents
What is considered a confined space?
In order for an area to be classified as a permit-required confined space, it must first be classified as a confined space. OSHA sets the definition for confined spaces. They say that a confined space must possess all three of these traits:
- The space is large enough for workers to be inside of it, doing their jobs
- The space has limited or restricted entries and exits
- The space isn’t designed for continuous occupancy
Simple confined spaces don’t have any obligations attached to them. An example of one would be a closet. People can go in and out of closets on your job sites freely without any restrictions.
Examples of confined spaces include tanks, vessels, silos, storage bins, hoppers, vaults, and pits. These are common in industries ranging from construction and manufacturing to utilities and agriculture. These spaces are primarily intended for storage, maintenance, or specific tasks rather than regular work activities.
Many confined spaces possess potential atmospheric hazards due to the accumulation of toxic or flammable gases, or oxygen-deficient/enriched environments. OSHA requires that air quality within confined spaces be tested before entry to ensure it is safe for workers.
When is a permit required to work in a confined space?
If you have a confined space, it may or may not be a permit-required confined space. The critical deciding factor is whether or not the space poses a hazard to the employees who enter it.
OSHA estimates that about 2.1 million workers enter PRCS annually. OSHA says that a confined space rises to the level of a permit-required confined space when it has one or more of the following traits:
- The potential for a hazardous atmosphere (or an actual hazardous atmosphere)
- It contains material that could potentially engulf an entrant
- It has a configuration that could trap an entrant inside
- Contains other severe health or safety hazards
Sewage entries are an excellent example of this. Employees entering one could become trapped and be exposed to a hazardous atmosphere. In these situations, an employee must complete confined space training before entering the space.
OSHA requires employers to review their confined space entry program using canceled permits within one year following each entry. This review is to ensure that all procedures and permits are up to date and reflect the current conditions and practices at the worksite. Adjustments to the program must be made if any inadequacies are identified during the review.
What are the OSHA requirements to work in a confined space?
If you have a permit-required confined space on your premises, you need to start by creating a permit-required confined space program, a written document detailing how you, as an employer, will keep your employees safe while working in a confined space.
Under OSHA regulations, your program must include a hazard analysis and a permitting plan.
A hazard analysis must list every potential hazard an employee could encounter in a confined space. You must also outline specific steps that you’re going to take, as an employer, to keep these hazards at bay so that your employees can work in confined spaces safely.
You also need to be assigned a confined space entry permit, which you can get by satisfying all of the requirements for a permit plan. To get this, you need to:
- List authorized entrants, supervisors, and attendants
- Show that you’ve addressed all of the hazards that you listed in the previous step
- Ensure that the proper personal protective equipment is being used
- Take care of any other lingering safety issues that could impact your employees in the confined space
When confined spaces are adjacent to areas where hazardous substances are handled or stored, OSHA requires the implementation of an early warning system to alert entrants of the release of these substances. This system is crucial for ensuring that workers have sufficient time to evacuate the space safely in case of an unforeseen release of hazardous materials.
In addition to the confined space entry permit, any hot work (e.g., welding, cutting, or burning) in a PRCS requires a separate hot work permit as per OSHA standards.
Who is authorized to work in a confined space?
An employer’s job in relation to permit-required confined spaces isn’t complete after they’ve received a permit. They also still need to ensure that everyone who enters the space has a confined space certificate and training for confined spaces that allow them to do so.
OSHA details the specifics of what confined space training must look like in 29 CFRÂ 1910.146. But the bottom line is that all employees must receive training for all their duties within the confined space.
There are three significant positions listed on a confined space entry permit. Understanding these should help you develop a proper training plan for your team, so we’ll cover them below.
Attendant
An attendant is someone who monitors the entrants to a permit-required confined space and ensures no one gets in without the proper training.
Attendants are also responsible for any of the duties that were assigned in the permit plan. For example, an attendant may also be responsible for ensuring the confined space is locked at the end of the day or keys for the entryway are tracked.
Attendants must maintain constant communication with entrants inside the PRCS to monitor conditions and the status of the entrants. This can involve the use of two-way radios, signals, or other effective means of communication.
OSHA explicitly prohibits attendants from entering a PRCS to perform rescue operations unless they are also trained and equipped as rescuers and there is another attendant present outside the PRCS.
Authorized Entrant
An authorized entrant is an employee with the training necessary to enter a permit-required confined space.
This training includes, but is not limited to, atmospheric hazards, mechanical hazards, and the potential for entrapment or engulfment.
While the primary focus is on preventing hazardous situations, Authorized Entrants are trained in self-rescue techniques in case an immediate exit from the confined space is necessary.
Authorized Entrants must follow specific entry and exit procedures designed to ensure their safety. This includes checking in and out with the Attendant and adhering to all entry permit requirements.
A crucial part of an Authorized Entrant’s training involves the recognition of new hazards that may arise during entry. They must be able to assess their environment continuously and recognize signs of danger, including changes in atmospheric conditions or the stability of the space.
Entry Supervisor
An entry supervisor is an employee responsible for ensuring that the permit-required confined space is safe to enter. A foreman or a crew chief often assumes this role.
The entry supervisor will typically look over the permit-required confined space and check for hazards before allowing any authorized entrants to go inside of the space that day.
The Entry Supervisor must ensure that an effective emergency response plan is in place and that all necessary rescue and emergency equipment is available and in proper working condition. This includes confirming that external rescue services, if used, are available and have been briefed on the confined space’s hazards.
The Entry Supervisor coordinates all aspects of the confined space entry operation, including communication among team members, ensuring that entry is timed to minimize exposure to hazards, and that operations within the space do not introduce new hazards.
After the completion of entry operations, the Entry Supervisor is responsible for debriefing the team, reviewing the effectiveness of the entry procedures, and noting any deviations or issues that occurred during entry. This review helps in updating safety protocols and improving future entry operations.
AOTC Can Help
Confined spaces can be hazardous to your employees. That’s why OSHA is so specific about what you need to do before your employees are able to go into these spaces and complete their jobs.
But sending your staff to external training courses can be costly and time-consuming. That’s why hiring AOTC could be your best option.
We can send our licensed instructors to your job site to ensure that your personnel is trained to work in permit-required confined spaces.
Our instructors can also help you with rescue procedures, supervisor training, and entry attendant training. That way, your team can get the work done that it needs to complete in confined spaces in the safest and most efficient ways possible.
If you’d like to learn more about how we can help, reach out to us. We’re happy to answer your questions and help you develop the right plan for your permit-required confined spaces training.