Permit Required Confined Spaces vs. Non-Permit Required Confined Spaces

Tuesday, May 5, 2020 Tiffany Bartz

According to OSHA, a confined space is a space that meets the following criteria:

1) being large enough for an employee to enter and perform work;

2) has limited or restricted means for entry or exit; and

3) is not designed for continuous occupancy.

Workers come across such spaces daily. Some of the common examples are tanks, vessels, silos, storage bins, hoppers, vaults, pits, manholes, tunnels, equipment housings, ductwork, pipelines, etc.

A permit-required confined space will contain all the above, plus one or more of the following:

a substance that has the ability to engulf or asphyxiate the entrant
a potentially hazardous atmosphere
spaces with inwardly converging walls within the space or a floor that slopes downward, tapering to a small cross-section
contains any other serious safety or health hazard

Once a confined space has been identified as having any one of the above four potential hazards, there needs to be a written program developed that outlines and instructs on the proper safety procedures for working around and occupancy of these confined spaces. Employers should follow the requirements in OSHA standard 1910.146.

Any of the confined spaces that contain one of the above-mentioned hazards must be marked as dangerous by the employer. The employers must mark such places with the help of a sign or any other means that effectively communicates the hazard. Apart from that, training materials and instructions must be provided to the workers who have to enter these spaces and work there. Employers must develop proper procedures for working in and around these spaces.

OSHA provides the following guidance for the workers who must work inside such confined spaces.

Workers must not enter a permit required confined space without having the training and entry permit.
Workers must review and understand the employer procedures before they enter the permit required confined spaces. Workers must have a proper understanding of entry and exit from confined spaces.
Workers must identify any type of physical hazards that may be inside such spaces.
Workers must test and monitor the oxygen content of these spaces before entering. They should also test for inflammability, toxicity and for hazardous chemicals just as necessary.
Moreover, the workers must use employer’s fall protection, rescue, air-monitoring, ventilation, lighting and communication equipment per the entry procedures.
Workers must maintain contact with an attendant all the while through a two-way phone, any other visual or telephonic means. Such monitoring systems allow the attendants to conduct appropriate evacuation if necessary.

Non-permit required confined spaces can be continually accessed by workers but are still associated with inherent difficulties stemming from the tight spaces. Signage is not required by OSHA, but workers should still exercise a great deal of caution. Employers must ensure that these areas can be safely accessed, and proper procedures still need to be in place.

Employers with permit-required and non-permit required confined spaces will also need to assess the presence of any additional hazards that may exist and create protective measures to be put in place to protect employees against any other identified hazard.

Other hazards to consider for spaces may include: