OSHA's Confined Space Standard is one of the most complex safety regulations to implement.  Developing procedures for training, entry, and rescue should be done by someone knowledgeable in not only the OSHA standard, but also in your facility engineering and storage systems.  The purpose of the program is to protect employees who may enter confined spaces by providing the necessary training, equipment and supervision to prevent injury or death.

Program Management

The first step in managing a confined space program is to decide if any of your company employees will ever have a need to enter "Permit Required Confined Spaces" (PRCS).  Even if your company does contract all PRSC work, you are required by OSHA to provide detailed information on specific confined spaces to contractors before entry.

Written Program should include the responsibilities of management, supervisors, and employees.  Additionally, you should include company policy on contractor entry, use of permits, prohibited operations and means by which hazards will be identified and controlled.

The OSHA standard requires employers to reevaluate any non-permit space when there are changes in the use or configuration that might increase the hazard to entrants and to look at any procedures taking place in the non-permit space.

Training certification must contain each employee's name, the signatures or initials of the trainers, and the dates of training.  Employees who will enter confined spaces, act as entry supervisors or entry attendants must be properly trained before any entry.  Rescue teams must conduct annual proficiency rescue training.

The training content must cover the employee's duties as a Supervisor, Entrant, Attendant or Rescue Team Member.  This includes general confined space hazards and control, use of equipment, communications and monitoring gear as well as specific confined space hazard controls.

Records you should keep, in addition to training records, include information on each confined space, inventory of entry and rescue equipment, calibration data on air monitoring equipment. All entry permits should be kept for the required annual program evaluation.  This review should be documented and signed by the responsible manager.  Maintain a copy of all audits and reviews, including changes made and the reasons for the changes.

Signs.  Ordinarily, information about permit spaces is most effectively and economically communicated through the use of signs. Consequently, signs would be the principal method of warning under the standard. Alternative methods, such as additional training, may be used where they are truly effective in warning all employees who could reasonably be expected to enter the space. It is the employer's obligation to assure that an alternative method is at least as effective as a sign. In some cases, employers may have to provide training in addition to signs, to protect employees who do not speak English or who would have difficulty understanding or interpreting signs.

If a space has a locked entry cover or panel, or an access door that can only be opened with special tools, the use of sign's may be unnecessary. If the employer ensures that all affected employees are informed about such spaces and know that they are not to be opened without taking proper precautions, including temporary signs, to restrict unexpected or unknowing entry.

Program Development

The development of a Permit Required Confined Space Program should be conducted by a person knowledgeable of your facility engineering systems, confined space hazards, rescue procedures & equipment and OSHA Standard 1910.146.

OSHA requires that employers consult with affected employees and their authorized representatives on the development and implementation of all aspects of the permit space program.

Step 1 - Determination - do you have any Permit Required Confined Spaces?

"Confined space" means 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.

A "Permit Required Confined Space" is:

"Permit-required confined space (permit space)" means a confined space that has one or more of the following characteristics:

(1) Contains or has a potential to contain a hazardous atmosphere;

(2) Contains a material that has the potential for engulfing an entrant;

(3) 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; or

(4) Contains any other recognized serious safety or health hazard.

The best way to start is to take a walk through of your facility and look for any equipment or confined spaces that could be classified as a permit required space.  Use a checklist like the following

Entry Possible? - OSHA considers entry to occur "as soon as any part of the entrant's body breaks the plane of an opening into the space"

Limited Access? - Basically any access other than a normal doorway designed for human traffic can be considered limited access - manhole covers, hand holes, hatches,  top or bottom entry points are examples.

Designed for Human Occupancy? - this is the architectural requirements for ventilation, lighting and geometry and space design.

Potential Atmospheric Hazards? - an atmosphere that may expose employees to the risk of death, incapacitation, impairment of ability to self-rescue, injury, or acute illness from one or more of the following causes:

(1) Flammable gas, vapor, or mist in excess of 10 percent of its lower flammable limit (LFL);

(2) Airborne combustible dust at a concentration that meets or exceeds its LFL; This concentration may be approximated as a condition in which the dust obscures vision at a distance of 5 feet (1.52 m) or less.

(3) Atmospheric oxygen concentration below 19.5 percent or above 23.5 percent;

(4) Atmospheric concentration of any substance for which a dose or a permissible exposure limit is published in Subpart G, Occupational Health and Environmental Control, or in Subpart Z, Toxic and Hazardous Substances, and which could result in employee exposure in excess of its dose or permissible exposure limit;

(5) Any other atmospheric condition that is immediately dangerous to life or health.

Engulfment Hazard? - "Engulfment" means the surrounding and effective capture of a person by a liquid or finely divided (flowable) solid substance that can be aspirated to cause death by filling or plugging the respiratory system or that can exert enough force on the body to cause death by strangulation, constriction, or crushing.

Entrapment or Asphyxiation Hazard? - spaces that have uneven floors, small passageways, open holes or narrowing geometry.

Serious Safety or Health Hazard?  -  this includes electrical shock, moving equipment, high or low temperatures, radiation, noise, chemical contact and any other condition which could cause injury or illness.  OSHA has stated that if the exclusive hazard in a confined space is that of a fall from a height an entry permit is not required and the space is not defined as a permit required confined space.  Other OSHA standards apply to fall protection and ladder use.

 

Step 2 – Written Survey

Once you have determined that you have a Permit Required Confined Space conduct a detailed survey of the space to document the exact hazards and points of entry. 

Step 3  - Written Procedures

Written procedures must be developed to define the "Acceptable entry conditions" for each permit required confined space.  These are the conditions that must exist in a permit space to allow entry and to ensure that employees involved with a permit-required confined space entry can safely enter into and work within the space. Procedures should include the specific equipment, lines and instrumentation that must be Locked & Tagged.  Any special procedures required, such as atmospheric testing, draining, flushing, venting, inerting and ventilating must also be included.

Your program must designate which employees can act as "Entry Supervisor".  This person is responsible for understanding the entire confined space program, the hazards of the confined spaces, procedures for controlling the hazards, entry, and rescue.

An effective procedure should cover the following:

Description of the space, it's use and entry points
Each hazard and how they are controlled (removed or locked out)
Acceptable entry conditions
Communication procedures
Entry Equipment
Personal Protective Equipment
Ventilation requirements
Rescue procedures
Atmospheric testing & monitoring

Atmospheric Testing Procedures. The type of testing that needs to be performed within a permit-required confined space is dependant on the hazards that are present within the space; employers are not required to test substances which will not potentially be present. Test or monitor the permit space as necessary to determine if acceptable entry conditions are being maintained during the course of entry operations. 

When testing for atmospheric hazards, test first for oxygen, then for combustible gases and vapors, and then for toxic gases and vapors.  The order of testing is important. Many devices depend on the presence of adequate oxygen to give accurate results.

Step 4 - Entry Permits - establish a permit system for entry.

Entry supervisors are the only employees who can authorize entry, prepare and sign written permits, and cancel permits when entry is terminated. Permits are kept at the access point for review by any qualified employee entering the space. Keep all permits for at least one year so they can be reviewed during the annual audit

Entry permits must include:

• Confined Space Name
• Entry purpose with date & expected duration including permit expiration time & date
• List of authorized entrants
• List of entry attendants & entry supervisor
• Hazards in the permit required confined space
• Isolation procedures to eliminate or control all hazards
• Acceptable entry conditions
• All test results
• Rescue & emergency services available and the means to summon them
• Communication procedures for attendants & entrants
• Required entry equipment
• Other information necessary for safe entry
• Other additional permits - such as hot work

 

Step 5 – Equipment

Employees must be informed of all Permit Spaces by posting danger signs reading DANGER -- PERMIT-REQUIRED CONFINED SPACE, DO NOT ENTER (or other similar language) near all possible entrances.  Entryways should be locked or guarded at all times.

It is essential that your company have the proper equipment for both entry and rescue is employees enter any permit required confined spaces.  Possible equipment includes:

• Ventilation fans, trunks, & saddles
• Portable lighting
• Gas monitors
• Fall protection & fall arrest gear
• Respiratory equipment
• Protective clothing
• Communication equipment
• Rescue gear
  

Step 6 – Train employees

Provide proficiency training so that all employees who may enter a permit confined space have the understanding, knowledge, and skills necessary for safe entry.  Each employee must be trained:

• Before the employee is first assigned duties
• Before there is a change in assigned duties
• If there are any changes in permit space operations
• If there are any deviations from the permit space entry procedures
• If there are any inadequacies in the employee's knowledge

Training certification must contain each employee's name, the signatures or initials of the trainers, and the dates of training.

The training content must cover the employee's duties as a Supervisor, Entrant, Attendant or Rescue Team Member.  This includes general confined space hazards and control, use of equipment, communications and monitoring gear as well as specific confined space hazard controls.

Step 7 - Rescue Teams

For all rescue teams or services evaluation consists of two components:

Initial evaluation, in which employers decide whether a potential rescue service or team is adequately trained and equipped to perform permit space rescues of the kind needed and whether rescuers can respond in a timely manner

Performance evaluation, in which employers measure the performance of the team or service during an actual or practice rescue.

The Rescue team must

Have the capability to reach victim(s) within a time frame that is appropriate for the permit space hazard(s) identified;

Be equipped for and proficient in performing the needed rescue services;

Be knowledgeable of the hazards they may confront

Be provided access to all permit spaces from which rescue may be necessary so that the rescue service can develop appropriate rescue plans and practice rescue operations.

Be trained to perform assigned rescue duties.  At least one member of the rescue team or service must hold a current certification in first aid and CPR

Practice making permit space rescues at least once every 12 months, by means of simulated rescue operations in which they remove dummies, manikins, or actual persons from the actual permit spaces or from representative permit spaces.