CONFINED SPACE ENTRY
Written Program Requirements
The Occupational Safety and Health Administration’s Permit Required Confined Spaces standard 1910.146 establishes requirements for safe entry into confined spaces. According to the standard, employers requiring workers to enter confined spaces must develop and implement a written permit space program. The written program should contain guidance on space identification, entry procedures, the permit system, employee training, rescue, and contractors.
Confined Space Identification
Each workplace is expected to identify confined spaces in their work environment. A confined space is:
Large enough and so configured that an employee can bodily enter and perform assigned work.
Has limited or restricted means of entry or exit.
Is not designed for continuous occupancy.
Permit required confined spaces have one or more of the following characteristics:
Contains or has the potential to contain a hazardous atmosphere.
Contains a material that has the potential to engulf an entrant.
Has an internal configuration such that an entrant could become trapped or asphyxiated by inwardly converging walls or by a floor which slopes downward and tapers to a small cross-section.
Contains any other serious safety or health hazard.
If the workplace contains permit spaces, the employer must inform exposed employees, by posting danger signs or by any other equally effective means, of the existence and location of and the danger posed by the permit spaces. A sign reading "DANGER - PERMIT-REQUIRED CONFINED SPACE, DO NOT ENTER" or using other similar language would satisfy the requirement for a sign.
Permit Space Procedures
Employers are required to develop and implement the means, procedures, and practices necessary for safe permit space entry operations. The procedures should be specific to each type of space that is entered. Even subtle differences in spaces can increase exposure to employees. Procedures need to define acceptable entry conditions, the means for isolating the space, requirements for purging, inerting, flushing or ventilating to control atmospheric hazards and the means to secure the space against pedestrians and vehicles. The procedures also need to identify the means to verify that conditions in the space are acceptable throughout the duration of the entry as well as the types of equipment needed for entry. This may include atmospheric monitors, personal protective equipment, communications equipment, intrinsically safe lighting, rescue, and emergency equipment.
The written program must include information regarding the permit system in place. This information instructs employees on the completion of the permit, roles and responsibilities of the entry team, the duration of entry, cancellation of the permit, and required documentation. The duration of a confined space entry must not exceed the time required to complete the assigned task or job identified. Permits must contain the following information at a minimum:
Space to be entered
Purpose of entry
Date and duration of the entry permit
Persons by name serving as attendants
Person by name serving as the entry supervisor
Measures used to isolate, eliminate, or control permit space hazards
Acceptable entry conditions
Results of initial and periodic tests as well as the person performing the tests
Rescue and emergency services and the means of contact
Communication procedures used by authorized entrants and attendant during entry
Required Equipment (PPE, testing, communications, rescue)
The employer must retain each canceled entry permit for at least one year to facilitate the review of the permit-required confined space program. Any problems encountered during an entry operation must be noted on the pertinent permit so that appropriate revisions to the permit space program can be made.
The written program must establish employee training requirements. Employees entering permit spaces must be trained and have the understanding, knowledge, and the skills necessary for safe entry. Employees must be trained prior to being assigned confined space entry duties or when there is a change in operations that may present a new hazard. Training documentation is critical and should include the name and signature of the trainees, the name and signature of the trainer and the date of training. It is also recommended that the types of information used be noted as well (videos, handouts, policies, permits, online courses, etc.).
The written program must address confined space entry rescue. An employer can train employees to perform rescue activities or utilize a trained third-party rescue service provider. This poses a challenge for many companies, particularly in rural locations. For this reason, it is advisable to identify means to eliminate entry or rely on non-entry rescue equipment.
The written program must include provisions for contractors. The host employer must inform the contractor that the workplace contains permit spaces and that permit space entry is allowed only through compliance with the written permit space program. The host employer is responsible for communicating the elements of the program including the hazards identified in each applicable space as well as any precautions or procedures that the host employer has implemented for the protection of employees working in or near permit spaces. In addition, the host employer is responsible for coordinating entry operations with the contractor and debriefing the contractor at the conclusion of entry operations regarding the permit space program followed and any hazards confronted or created in permit spaces during entry operations.
Confined space entry poses a significant exposure to employees. Developing and implementing an effective confined space entry program can eliminate, reduce, or control exposure. Review your program and ensure that it has the necessary elements to send employees home safely.
Joe Mlynek is a partner and subject matter expert at Safety Made Simple, LLC. He has over 20 years of experience in safety at the corporate level and as a consultant. He is a Certified Safety Professional (CSP) and Occupational Safety and Health Technician (OHST). Joe can be reached at email@example.com