Safetip #124: Written Permit-Required Confined Space Program

April 25, 2018

This week’s Safetip is about developing and implementing a written permit-required confined space program before employees enter confined spaces.

What is a Permit-Required Confined Space?

Many work spaces are considered “confined” because they complicate the activities of workers who must enter in the confined space, work in it or exit from it. Confined spaces may also present hazards, such as entrapment, engulfment and hazardous atmospheric conditions.

OSHA’s 29 CFR 1910.146 standard says that a confined space:

  • Is large enough for an employee to enter fully and perform assigned work.
  • Is not designed for continuous occupancy by the employee.
  • Has a limited or restricted means of entry or exit.

Examples of confined spaces include underground vaults, tanks, storage bins, pits, vessels, silos, hoppers, etc.

A “permit-required confined space” (or “permit space”) refers to a space that meets OSHA’s definition of a confined space and has one or more of the following characteristics:

  • Contains or has the potential to contain a hazardous atmosphere.
  • Contains a material with the potential to engulf someone who enters the space.
  • Has an internal configuration that may cause an entrant to be trapped or asphyxiated by inwardly converging walls or by a floor that slopes downward and tapers to a smaller cross section.
  • Contains any other recognized serious safety or health hazards.

OSHA requires workers to have a permit to enter such confined spaces.

Elements of a Written Program

OSHA requires employers that allow workers to enter a permit space to develop and implement a written program for the space. The OSHA standard highlights the main elements of the program. Also, the Washington State Department of Labor & Industries outlines elements of a written program in its rule on Safety Standards for Confined Spaces.

A written program must be developed before employees enter confined spaces. The program describes the means, procedures and practices to use for the safe entry of permit-required confined spaces, and includes the following:

  • Documentation of permit entry procedures.
  • Designation of employees that have active roles, including attendants, competent persons, entrants, entry supervisors, rescuers, program administrator, or those who test or monitor the atmosphere in a permit-required space.
  • Identification of each designated employee’s duties.
  • Training employees on their designated roles.
  • How to identify and evaluate hazards.
  • Use and maintenance of equipment, including personal protective equipment.
  • How to prevent unauthorized entry.
  • How to coordinate entry with another employer.
  • How to rescue entrants.
  • If you intend to enter using alternative methods for entry, the procedures must address all measures used before entry to isolate and eliminate hazards from the space and control potential atmospheric hazards:
    • Identify the entry supervisor who authorizes the use of the alternative methods and has the responsibility for ensuring safe entry conditions.
    • Hazards of the space.
    • Methods used to eliminate hazards including verification.
    • Methods used to ensure that the hazards are eliminated.
    • Methods used to test and monitor the atmosphere within the space, where applicable, for all atmospheric hazards.
    • Methods used to determine if unsafe conditions arise before or during entry.
    • Criteria and conditions for evacuating the space during entry (like monitoring and test data).
    • Methods for training employees in these procedures.
    • Methods used to ensure employees follow these procedures.

Affected employees and their authorized representatives should be consulted when developing and implementing the program, which must then be made available to everyone. The written program must be updated if deficiencies have been identified. Both the program and entry procedures should be updated before allowing subsequent entries.

Finally, a confined space program administrator with overall responsibility for the program should be designated. The administrator must have sufficient training or experience with permit-required confined space entry to oversee program development, coordinate implementation, and evaluate program effectiveness.

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