Safetip #92: Develop a Code of Practice for Confined Space Entry

August 16, 2017
By Jean-Grégoire Manoukian

This week’s Safetip is about confined spaces and the development of a code of practice for confined space entry.

OSHA Requires an Entry Permit for Confined Spaces

OSHA’s 29 CFR 1910.146 standard defines a “confined space” as a space that:

  • Is large enough and so configured that an employee can bodily enter and perform assigned work.
  • 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).
  • Is not designed for continuous employee occupancy.

OSHA’s standard also requires an entry permit that documents compliance and authorizes entry to a permit space. The permit identifies the following information and others:

  • The permit space to be entered
  • The purpose of the entry
  • The date and the authorized duration of the entry permit
  • The authorized entrants within the permit space
  • The hazards of the permit space to be entered

A Code of Practice Documents Procedures

The Canadian province of Alberta requires employers to have a written Code of Practice for the procedures to be followed when a worker enters a confined space. Even if it’s not required by law in all jurisdictions, having a written Code of Practice is nevertheless a good best practice for any organization located in any country.

A Workplace Health and Safety Bulletin by the Alberta Ministry of Labour defines a code of practice as “a document that describes the procedures to be followed to ensure that workers safely perform work in a confined space”. The bulletin says that workers should be consulted about the content of the code of practice as they often have the best understanding of the hazards involved in the work. The code of practice must identify all existing and potential confined space work locations at a work site so that workers can be made aware of hazards and reminded of the applicable requirements. The code of practice must be maintained and periodically reviewed.

The bulletin describes the following three steps in preparing the code of practice:

1) Identify Confined Spaces at the Work Site

Confined spaces can be found at almost any workplace. The first step to preparing a code of practice for confined space entry is to inspect the workplace and identify all confined spaces that workers may be required to enter for planned or unplanned maintenance or in an emergency.

2) Identify Hazards in the Confined Spaces

To prepare a code of practice, the hazards present in the confined spaces must be known. A hazard assessment must be performed, reviewed on a regular basis and revised if conditions change at the work site, when new work processes are introduced or work processes or operations change. The employer must involve workers who may be affected by the hazards in the hazard assessment process. Hazards in confined spaces generally fall within four categories:

  • Atmospheric
  • Safety
  • Work-related
  • Human factors

3) Develop the Code of Practice

A code of practice for confined space entry contains more than just procedures for doing the entry itself. The code of practice must also include the following sections, as appropriate:

  • Description of confined space(s) at the work site.
  • Reasons for work involving entry into confined spaces.
  • Identification of hazards that may be present in the confined space(s).
  • Worker training requirements.
  • Entry permit system.
  • Procedures for each type of confined space entry and the work inside the confined space.
  • Testing the atmosphere.
  • Ventilation, purging and inerting.
  • Isolation of hazardous substances and energy.
  • Emergency response.
  • Roles and responsibilities of the tending worker.
  • Recordkeeping requirements.

Consult the Safety Bulletin for more information. The bulletin also includes a confined space hazards assessment work sheet and a code of practice work sheet.

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