Identify All Confined Spaces Across All Work Sites – Safetip #225

Safety Tip and Best Practice
December 16, 2020

Our latest Safetip is about identifying all confined spaces, including those requiring a permit, across all work sites.

What is a Confined Space?

There are many definitions of a “confined space”. OSHA’s standard on permit-required confined spaces (1910.146) defines it as a space that:

  1. Is large enough and so configured that an employee can bodily enter and perform assigned work; and
  2. Has limited or restricted means for entry or exit (for example, tanks, vessels, silos, storage bins, hoppers, vaults, and pits are spaces that may have limited means of entry.); and
  3. Is not designed for continuous employee occupancy.

The Agency also makes a distinction between a confined space and a permit-required confined space. The OSHA standard says that a “permit-required confined space” is a confined space that has one or more of the following characteristics:

  • Contains or has a potential to contain a hazardous atmosphere.
  • Contains a material that has the potential for engulfing an entrant.
  • Has an internal configuration such that an entrant could be trapped or asphyxiated by inwardly converging walls or by a floor which slopes downward and tapers to a smaller cross-section.
  • Contains any other recognized serious safety or health hazard.

Inspect and Identify

Confined spaces can be dangerous, which is why a permit is required to start work in such areas. OSHA also requires that employers issue permits if some conditions are met, as seen above.

It is therefore imperative to identify accurately all confined spaces throughout all work sites across the enterprise. It’s a matter of both safety and compliance.

The first step is to inspect all plants and identify all confined spaces where workers may be required to enter for planned maintenance or repair activities, or for unplanned emergencies.

Second, identify the hazards for each confined space. Assess for the different types of hazards, including:

  • Atmospheric hazards: toxic gases and vapors, low oxygen, smoke, dust, etc.
  • Safety hazards: inwardly converging walls, floor that slopes downward, problematic entries or exits, machinery, pipes, residual chemicals, electricity, slippery surfaces, temperature extremes, etc.
  • Task-related hazards: hot work, use of chemical-based products (cleaners, paint), cutting, noise, etc.
  • Human factor hazards: claustrophobia, fear of heights, heat stress, fatigue, etc.

A document from the Government of the Canadian province of Alberta, “Guideline for Developing a Code of Practice for Confined Space Entry”, has a comprehensive list of hazards and a useful flowchart to help decide if an area is a confined space.

Third, categorize each confined space as either a “permit-required confined space” or “non-permit confined space” based on the hazard assessment.

It’s important to note that conditions can change due to new processes, operational procedures, equipment, or materials. These changes can turn a non-permit confined space into a permit-required one, which is why organizations should conduct inspections periodically, review hazard assessments regularly, and establish a robust Management of Change process. And if applicable, new permits must be issued.

Finally, consider the use of Permit to Work software to have a proper work preparation and rigid permit to work process, minimize risk, provide access to electronic work permits on mobile devices, and ensure safe work execution.

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Jean-Grégoire Manoukian

Content Thought Leader - Wolters Kluwer | Enablon