Ensuring Safety in Construction Confined Spaces: Tips for Small Entities

Introduction

Let’s roll up our sleeves and get down to business. This little article of tips for small businesses that we’ve got here, it’s not just a bunch of fancy words. It’s a tool, a trusty sidekick for small businesses to navigate the labyrinth that is the Confined Spaces standard.

Now, I know what you’re thinking, “Compliance? That sounds like a lot of paperwork.” But let me tell you, it’s more than that. It’s about understanding the rules of the game, knowing your responsibilities, and making sure everyone gets home safe at the end of the day.

This guide, it’s got your back. It’s here to tackle the most common compliance issues you’ll face, providing enough detail to serve as a useful compliance guide. But remember, it’s not the be-all and end-all. It doesn’t cover every nook and cranny of the standard or change the responsibilities set forth in it.

So, where can you find the full standard? It’s published at 29 CFR §§ 1926.1200-1213, available on OSHA’s website and in the Code of Federal Regulations. That’s your go-to for all the steps that must be taken to comply with the standard.

Confined Spaces and Permit Spaces

Alright, let’s break this down. What exactly is a “confined space?” Well, it’s a space that checks off three key boxes:

It’s gotta be big enough and arranged in such a way that an employee can physically get inside.
It’s got limited or restricted ways to get in and out.
It’s not built for employees to be in there all the time.

Now, a space is considered to have limited or restricted means of exit if a person would have a tough time getting out quickly in an emergency. Here are some telltale signs that a workspace has limited or restricted ways to exit:

You need to use a ladder or movable stairs, or stairs that are narrow or twisted.
There’s a door that’s hard to open or a doorway that’s too small to walk out of upright.
There are obstructions like pipes, conduits, ducts, or materials that a worker would need to crawl over, under, or squeeze around.
You’d have to travel a long distance to get to safety.

And a space isn’t designed for continuous employee occupancy if it doesn’t have features like ventilation, lighting, and enough room to work and move around that are necessary if people are going to be in there all the time.

Confined spaces that may be found on construction sites include, but are not limited to:

Manholes (such as sewer, storm drain, electrical, communication, or other utility)
Sewers
Storm drains
Water mains
Lift stations
Tanks (such as fuel, chemical, water or other liquid, solid or gas)
Pits (such as elevator, escalator pump, valve or other equipment)
Bins
Boilers
Incinerators
Scrubbers
Concrete pier columns
Transformer vaults
Heating, ventilation, and airconditioning (HVAC) ducts
Precast concrete and other pre-formed manhole units
Drilled shafts
Enclosed beams
Vessels
Digesters
Cesspools
Silos
Air receivers
Sludge gates
Air preheaters
Transformers
Turbines
Chillers
Bag houses
Mixers/reactors
Crawl spaces
Attics
Basements (before steps are installed).

So, what’s a permit space? Picture this: a confined space that could contain a hazardous atmosphere, or a material that could engulf an entrant. Imagine a space where the walls converge inward or the floor slopes downward, tapering to a smaller cross-section, potentially trapping or asphyxiating someone inside. Or any space that contains a recognized serious safety or health hazard. That’s your permit space.

Now, it’s not enough to just know what these spaces are. Employers have a responsibility to protect workers in these spaces. That means taking effective steps to prevent workers from entering these spaces unless they’re authorized to do so. It’s about ensuring safety first, always.

Scope of the Confined Spaces Standard

When it comes to construction work in confined spaces, the Confined Spaces standard is your playbook. But, like any good rule book, it’s got its exceptions. There are certain construction activities that have their own confined space provisions in other OSHA construction standards. So, what’s off the table for this standard? We’re talking about:

Diving – That’s covered by 29 CFR Part 1926 subpart Y.
Excavations – You’ll find that in 29 CFR Part 1926 subpart P.
Underground Construction, Caissons, Cofferdams, and Compressed Air – That’s all in 29 CFR Part 1926 subpart S.

But here’s the kicker. Even if you’re engaged in these activities, you still have to comply with the Confined Spaces standard if your workers are exposed to confined space hazards that aren’t addressed by the standards listed above. Let’s say you’re working in a trench, which is a type of confined space. The Excavation standard protects workers against the hazards associated with the trench itself. But what if you’ve got workers inside a sewer line that’s installed in an open trench? The Excavation standard won’t cover the confined space hazards associated with the sewer line. That’s when you’ve got to comply with both the Excavation standard for the trench and the Confined Spaces standard for the sewer line.

And let’s not forget about other activities in confined spaces. If you’re dealing with Process Safety Management, Hazardous Waste Operations, or Welding and Cutting, you’ve got to comply with other applicable OSHA standards, such as:

Process Safety Management: 29 CFR § 1926.64.
Hazardous Waste Operations: 29 CFR § 1926.65.
Welding and Cutting: 29 CFR § 1926 Subpart J.

So, remember, folks, when it comes to safety in confined spaces, it’s not just about following one set of rules. It’s about knowing all the rules that apply to your work and making sure you’re ticking all the right boxes.

Responsibilities

Employer Responsibilities: For anyone who calls the shots in the construction business, there are two things you gotta do. First, scout your work site, pick out any of those snug areas we refer to as confined spaces. Secondly, decide whether these spaces are permit-required or not. If your folks are going to be working in permit-required spaces, they must be shielded from any potential dangers lurking there. To ensure this, the Confined Spaces rulebook hands out specific responsibilities to what we call “entry employers,” “host employers,” and “controlling contractors.”

If you, as an employer, know that a permit-required space exists on your work site, it’s your job to alert your team about the location and risks associated with each space. Posting warning signs could be an effective way to get this done. Moreover, if there’s no work for your team in the space, you must make sure they steer clear of it. A good method to ensure this is to train your workers to recognize permit space warning signs and understand what they indicate.

An “entry employer” is the one who makes the call that an employee under their direction will step foot into a permit space. There could be multiple entry employers if workers from different employers need to enter the space. Each entry employer must comply with all the rules in the Confined Spaces rulebook, except those which are specifically directed towards the controlling contractor and host employer.

A “controlling contractor” is the employer who holds the reins of the overall construction at the worksite. It’s their job to coordinate entry operations when there’s more than one entry employer or when other activities on site could stir up trouble in the permit space. Also, they’re expected to share any information they have regarding any permit space hazards and previous safety measures used in the space.

A “host employer” is the employer who owns or manages the property where the construction work is happening. If the host employer has intel about any permit space hazards on the site, they’re required to share that information with the controlling contractor, who then passes it on to other employers on site.

In all cases, there will be just one host employer. If the property owner has a deal with another employer to manage the property and has provided them with relevant information about permit spaces, then this managing employer becomes the host employer. Without such an agreement, the owner remains the host employer. If the controlling contractor owns or manages the property, they’re both the controlling contractor and the host employer.

Employer Categories and Their Corresponding Responsibilities

All Employers

Identify all confined spaces where their workers may be working and figure out if any require permits. If workers are supposed to enter permit spaces, then the employer becomes an “entry employer.”
Employers who aren’t “entry employers” must ensure their workers stay out of any permit spaces on the site unless entry is authorized.

Entry Employers

Protect workers from permit space hazards by following the standard.
Keep the controlling contractor informed about the safety procedures used and any hazards encountered in permit spaces.

Controlling Contractors

Share any information they have about permit space hazards with entry employers and other employers whose activities could potentially cause hazards in the permit space.
Coordinate entry operations when more than one entry employer is involved.
Manage operations when permit space entry occurs during other activities on site that could create a hazard in the space.

Host Employers

Share any information they have about permit space hazards with the controlling contractor.

Overview of the Standard

The standard provides a comprehensive framework for the identification and classification of permit spaces, the procedures to be followed, and the measures to be taken to ensure the safety of workers. The standard provides general provisions that employers must follow. These include the identification and evaluation of permit spaces, the implementation of necessary measures to prevent unauthorized entry, and the development of a written permit space program if workers are to enter the permit spaces. To ensure workers are protected from confined space hazards, employers need to follow these steps.

First off, have a knowledgeable and trustworthy individual, a “competent person,” identify all confined spaces where your employees may be working. A competent person is someone who can sniff out existing and potential hazards in the environment or working conditions that may be unsanitary, dangerous, or hazardous to employees, and has the authority to swiftly take corrective actions. They don’t necessarily have to be an employee of any specific employer. Multiple contractors on site might choose to use the same individual for this role.

If confined spaces are found, the employer needs the competent person to figure out if these confined spaces require permits, or in other words, if they’re “permit spaces.”

A permit space is characterized by one or more of the following:

Has or may develop a hazardous atmosphere,
Contains a material with potential to engulf a worker,
Is designed in such a way that a worker could be trapped or suffocated by inwardly converging walls or a downward sloping floor tapering to a smaller cross section,
Holds any other recognized serious safety or health hazard.

The section on Identifying Permit Spaces elaborates on how to decide if a confined space is a permit space.

If the workplace has a permit space, the entry employer is obligated to protect its workers against the lurking dangers. The necessary protection varies depending on the type and severity of hazards present in the permit space.

Permit spaces that don’t qualify for one of the two exceptions.

If the employer’s workers are going to venture into the space, a written permit-required confined space program, or permit space program, must be devised and followed. This program should lay out how the employer will control worker entry into permit spaces and tackle permit space hazards. The section, Content of Permit Space Program, lays out what a permit space program must entail.
Every employer needs to inform their workers about the whereabouts and risks of each permit space (think about putting up signs), and take extra measures to prevent workers from entering permit spaces if they’re not authorized to do so.

Exception 1: Spaces containing only physical (non-atmospheric) hazards. If the physical hazards are eliminated or isolated and no longer pose a threat, the space can be reclassified as a non-permit space, with no further precautions required. Check out Reclassifying a Permit Space as a Non-Permit Space section for more.

Exception 2: Spaces harboring an atmospheric hazard that can be neutralized with continuous forced air ventilation. As long as the atmospheric hazard is controlled by continuous forced air ventilation and any physical hazards are eliminated or isolated, alternate procedures are listed in the section for Alternate Procedures for Certain Permit Spaces and can be used instead of full permit space procedures, although the space still retains its permit space status.

The entry employer needs to train workers who are going to be working in a permit space. The workers authorized to enter the space, an attendant who’s duty-bound to stay outside the space and keep an eye on the workers within, and an entry supervisor with the overall responsibility of ensuring that the program is followed, all need to be identified. The roles of these workers are discussed in the section about Entrants, Attendants, and Entry Supervisors. All workers covered by the permit space program, including entrants, attendants, entry supervisors, and rescue workers, must be trained to have the understanding and skills necessary to identify confined space hazards and safeguard themselves and their co-workers from permit space hazards. The Worker Training section explains what kind of training these workers need to receive.

The entry employer must also make arrangements for rescuing entrants who can’t leave the space on their own. The employer has to ensure that a worker who falls ill or gets injured in a permit space can be safely and promptly rescued. Their permit space program must detail whether the employer plans to use their own workers, a rescue team from another on-site employer, or an outside rescue service if a rescue situation arises. Chapter 11 details the requirements for rescue and emergency services.

Identifying Permit Spaces (Section 1203(a))

This undertaking isn’t a mere walk in the park – it’s the main act that determines whether precautions need to be rolled out before employees brave the murky depths of the confined space. Neglect this crucial step and you’re courting disaster, where even the costliest error comes with a steep price – the life or serious injury of hardworking folks.

In the previous section we showcased how each employer must entrust the essential task of identification to a competent person. A person who’s got the right blend of knowledge and authority to spot all confined spaces where workers could possibly work within their worksite. But identifying the spaces is just the opening act. The main event is evaluating each space, weighing them against the criteria of what defines a permit-required confined space – or as we like to call it, a “permit space”.

When faced with a confined space, this competent person has a four-question quiz to solve. If even one of those questions has a “yes” for an answer, then congratulations are in order – you’ve got yourself a permit space. Let’s dive right in and take a closer look at these questions.

Does the space contain or have the potential to contain a hazardous atmosphere?

Many a worker has met their untimely end or suffered grievous injuries in the bowels of confined spaces, their fate sealed by atmospheric hazards. These vile villains include oxygen deficiencies and a toxic or flammable cocktail of chemicals. Our competent person, like a vigilant guard, must evaluate, even resorting to testing if needed, whether these threats lurk within the space before workers step foot into it.

These hazards take various forms:

An oxygen-deficient environment where oxygen levels dip below 19.5 percent or an oxygen-rich one where levels shoot above 23.5 percent.
An alarming concentration of any flammable gas, vapor, or mist that exceeds 10 percent of its lower explosive limit.
A storm of airborne combustible dust with a concentration that equals or trumps its lower explosive limit.
The presence of any substance in the atmosphere that could spell death, incapacitation, or impairment of self-rescue abilities, leading to injury or sudden illness.

Take a moment to catch your breath because we’re about to delve deeper into the subject of atmospheric hazards. The competent person, our eyes and ears on the field, must consider two factors: (1) the hazards present in the space before the arrival of any workers; and (2) whether the planned work within the confines of the space could unleash a horde of toxic, flammable, or combustible air contaminants, or provoke an imbalance in oxygen levels.

To perform this task successfully, the competent person needs to be as familiar with the work that’s to be done within the space as they are with the potential for that work to invite atmospheric hazards. Here’s an illustration: a confined space could initially be a picture of safety, but the situation could take a grim turn if inert gas welding inside the space causes a sweeping displacement of oxygen in the worker’s breathing zone, transforming the once-safe environment into a potential death trap.

Note: Toxic Chemicals Regulated by OSHA, Subparts D and Z of Part 1926 serves as a directory of chemicals for which OSHA has set airborne permissible exposure limits (PELs). Don’t jump the gun and classify a confined space as a permit space just because a substance listed in Subpart D or Z is present at a concentration exceeding a PEL. The space earns the dubious honor of being a permit space only if the concentration of the substance is potent enough to cause death, incapacitation, impairment of self-rescue abilities, injury, or sudden illness. Of course, exposure to a concentration exceeding a PEL would still violate Subpart D or Z, even if it doesn’t breach the Confined Spaces standard.

The competent person must also weigh in chemicals for which OSHA hasn’t set any PEL. If a product’s label or the safety data sheet issued by the manufacturer raises a red flag that the product could be harmful if inhaled and should be used only with adequate ventilation, the competent person must evaluate if using that product in a confined space necessitates classifying the space as a permit space.

Note: Oxygen-Deficient Spaces, These are confined spaces’ deadliest killers. Asphyxiation due to insufficient oxygen is the grim reaper responsible for most deaths during construction work in confined spaces. This insidious threat doesn’t discriminate between the workers assigned to enter the space and any would-be rescuers who venture in without proper gear and training. So, when a competent person evaluates a confined space to decide if it’s a permit space, they should pay special attention to whether the space is a potential home to an oxygen concentration of less than 19.5 percent. A space that’s been sealed off from the outside atmosphere for a period of time could turn into an oxygen-deficient environment. It’s crucial to measure the oxygen concentration to ascertain whether the space should be deemed a permit space. Direct reading instruments that measure the oxygen concentration in the air stand ready for this purpose. To ensure reliable results, these devices must be calibrated correctly and used judiciously.

Does the space contain a material with the potential to engulf an entrant?

The term “engulfment” paints a harrowing picture of a person enveloped and effectively captured by a liquid or a finely divided (flowable) solid substance. This silent predator can cause death either by filling or plugging the respiratory system or by exerting enough force on the body to cause death by strangulation, constriction, crushing, or suffocation.

The competent person needs to contemplate whether any liquid or flowable solid, like sand, could find its way into the space. Any pipe or manhole in an operating water or sewer system where a worker toils could be a confined space that holds the grim possibility of engulfing an entrant. It should thus be treated with the gravity it deserves – as a permit space.

Does the space have an internal configuration such that an entrant could be trapped by inwardly converging walls or by a floor that slopes downward and tapers to a smaller cross section?

Confined spaces with small cross-sections could give birth to hazardous atmospheres if ventilation is lacking. Moreover, a space of this design could prove a formidable obstacle for an injured worker trying to escape and could also complicate rescue operations.

Does the space contain any other recognized serious safety or health hazard(s) that pose an immediate danger to a worker’s life or health or would impair the worker’s ability to escape from the space in the event of injury?

The competent person’s radar should pick up on a variety of hazards, such as fire and explosion hazards, mechanical, electrical, hydraulic and pneumatic energy, extreme temperatures, radiation, noise, corrosive chemicals, and biological hazards (like venomous animals or insects).

If a workplace contains one or more permit spaces, the employer carries the responsibility of educating workers in the vicinity about the location and risks associated with each space. This can be accomplished through posting warning signs at every possible point of entry or by any other method that’s equally effective.

In addition to putting up warning signs, an employer who discovers the existence of a permit space must also inform its employees’ authorized representative and the controlling contractor about the location and dangers of the space. The controlling contractor, in turn, must inform other employers on the site whose activities could create a hazard in the permit space about the existence, location, and associated hazards of these spaces before workers set foot in them.

If the employer has decided that their workers are not authorized to enter a permit space, they must take additional measures apart from posting the above warnings to prevent workers from crossing the threshold of the space. This can be achieved through effective training on, and enforcement of, a work rule against entry.

If an employer’s workers are going to enter a permit space, the employer must develop a written permit space program, and entry is only allowed in accordance with the terms of the program. Exceptions to the permit space program requirement exist for spaces where all physical hazards are eliminated or isolated, and where any atmospheric hazards are kept at bay by continuous forced air ventilation, which are discussed in Chapters 7 and 8, respectively. The employer, acting as the “entry employer” under the standard, must keep any unauthorized persons from entering the permit space, and if any such persons do manage to enter the space, they must be promptly removed.

Content of Permit Space Program (Sections 1204-1206)

Think of a permit space program as a blueprint, a detailed plan of action. It’s not just a checklist, but a comprehensive strategy. This includes identifying and evaluating permit spaces, devising procedures for safe entry, and setting up measures to prevent unauthorized entry. It’s about creating a systematic approach for issuing permits, testing conditions within the space, and coordinating entry operations when multiple employers are involved. It’s about having a rescue and emergency plan in place, and ensuring that everyone involved is adequately trained.

So, what does a permit space program need to do? Here’s a little checklist for you:

Lay down the law to stop any Tom, Dick, or Harry from sauntering in;
Make sure you know your dragons before stepping into the den;
Keep a finger on the atmospheric pulse before you step in, and while you’re in there;
Kick off the atmosphere testing with a trio: oxygen, then combustible gases or vapors, and lastly toxic gases or vapors;
Devise your game plan to tame or handle any lurking hazards for a safe trot into the confined space;
List out what everyone’s supposed to be doing;
Fork out for the gear necessary to keep your workers safe (at no cost to them, mind you), and make sure everyone knows how to use it;
Have a sentry, an attendant, to keep watch while workers venture into the space;
Plan out your strategy for that inevitable moment when an attendant has to keep an eye on more than one space in an emergency;
Play nice with others (with the helping hand of the controlling contractor) when more than one employer’s team is in the confined space; and last but not least,
Plan your SOS — how to call for help in an emergency and how to keep any untrained heroes from rushing in.

It’s not a “set it and forget it” kind of thing, this program. It needs a good look-see every now and then to ensure it’s doing its job — protecting your team. If you spot a mishap, near miss, unexpected guests, new hazards, anything that isn’t written in the permit, or complaints about the effectiveness of the program, it’s time for a review. And don’t forget your annual check-up, using the cancelled permits as a report card to tweak the program for the safety of your crew.

Unless we’re talking about those exceptions mentioned later in this article, entry is only granted through a written entry permit. This permit is like the checklist before a NASA launch:

Name of the permit space to be entered, authorized entrant(s), current attendants, and current entry supervisors;
Purpose of entry;
Date and authorized duration of entry;
Means of detecting an increase in atmospheric hazard levels;
Name and signature of supervisor who authorizes entry;
Known hazards in the space;
Measures to be taken to isolate permit spaces and to eliminate or control space hazards;
Acceptable entry conditions;
Test results, date and time of test(s), and tester’s initials or signature;
Name and telephone numbers of rescue and emergency services and means to be used to contact them;
Communication procedures and equipment to maintain contact during entry;
Any special gear or processes, including personal protective equipment and alarm systems;
Any other information needed to ensure employee safety; and
Additional permits, such as for hot work, that have been issued authorizing work in the permit space.

This permit needs to be pinned up at the entry or readily available to the authorized entrants and their representatives at the time of entry. For a sample of what this should look like, take a gander at Appendix B — it’s got a permit that covers all the bases required by the standard.

Canceling Entry Permits

The employer needs to ensure the entry supervisor declares a permit’s retirement when the task is done or new conditions arise. Once a permit is retired, it’s game over for entry under it. Make a note of the new conditions on the retired permit — they’ll be handy when it’s time to revise your permit space program. And don’t forget to hold onto your retired permits for at least a year.

Suspending Entry Permits

In the event of a temporary hiccup that doesn’t spell the end of a permit, the entry supervisor might just put the permit on hold. Once everything’s back to normal and it’s not expected to go haywire again, the permit can be brought back into service. This can only happen if the supervisor gives the green light, confirming that the conditions match up with those on the permit.

Reclassifying a Permit Space as a Non-Permit Space (Section 1203(g))

Sometimes, a permit space is just a tough nut to crack, filled with nothing but physical obstacles that seem more like a puzzle to be solved. Good news, though — there are cases where you can take a permit space and simplify it down to a non-permit space. This magical transformation can happen in two scenarios: (1) if you can remove or isolate the physical challenges without setting a foot in the place, or (2) if you can brave the space using permit space protocol to tackle the physical problems. Now, when we talk about physical hazards, we’re referring to any nuisance that isn’t an atmospheric one. That could mean anything from hidden explosives (apart from explosive atmospheres, of course), to a broad spectrum of energy types — mechanical, electrical, hydraulic, pneumatic — to radiation, extreme temperatures, potential engulfment, noise, surfaces that slope inward, and even chemicals that are nasty to your skin or eyes (not through your lungs, mind you).

Let’s paint a picture to illustrate: Say you’ve got a confined space that’s home to some electrical machinery. The machinery presents a twofold hazard — a mechanical one and/or a risk of electric shock. Now, if you’re able to shut down these hazards by simply flipping a switch and locking up the machinery at an electrical panel outside the space, then congratulations, you’ve just turned a permit space into a non-permit space. The caveat here is that the equipment must stay powered down and locked up. If you need to step into the space to power down and lock the equipment, you’ll need to do that dance following a full permit program. Once that’s done, though, you’re free to reclassify the space as a non-permit space.

Every time you manage to downgrade a permit space to a non-permit space, there’s some paperwork to take care of. The entry employer needs to write up a certification explaining why the space is now hazard-free. This document needs to include the date, the location of the space, and the signature of the person making the call. Make sure this certificate is available to every worker entering the space, or to their authorized representative.

Now, let’s say you’re working in a downgraded permit space and a hazard pops up. It’s time to get everyone out of the space, pronto. The entry employer then has to take a fresh look at the space and figure out the next steps. If the new hazards are physical ones that can be nipped in the bud or isolated, then the employer can once again demote the space to a non-permit space. If the new challenge is an atmospheric one, but it can be managed with continuous forced air ventilation, then it’s time to follow the procedures laid out in Chapter 8. In any other case, it’s back to square one: any further entry requires a full permit space program.

Alternate Procedures for Certain Permit Spaces (Section 1203(e))

A space that holds only physical challenges is one thing, but a space packing an atmospheric hazard is another beast entirely. You can’t take that atmospheric hazard and wave a wand to turn it into a non-permit space. However, if you can wrangle that atmospheric risk in a permit space using forced air ventilation, then the employer has the green light to use less complex procedures instead of the full permit space methods for when workers step into the space. These alternate procedures can be put into action if the employer can prove three things:

All physical hazards have been eliminated or isolated;
The sole risk is an actual or potential hazardous atmosphere that can be tamed and indeed is made safe for entry via continuous forced air ventilation; and
If the ventilation system throws in the towel, workers can leave the space without a hitch.

Now, an employer who decides to take this alternate route must justify the decision with solid reasons and data that show the three criteria are met. This documentation must be at the ready for each worker venturing into the space or for their authorized representative.

So, what does these alternate procedures look like? Let’s take a peek:

Entry and Exit

Before even thinking about moving an entrance cover, any conditions that make it unsafe to do so must be dealt with.
Once those entrance covers are off, the opening needs to be instantly safeguarded by a railing, temporary cover, or some other barrier that’ll stop an accidental tumble through the opening and keep any foreign objects from gatecrashing the space.
Prior to a worker stepping into the space, the internal atmosphere needs to be given a thorough check. That means using calibrated, direct-reading instruments to test for oxygen content, flammable gases and vapors, and potential toxic air contaminants, in that order. The testing must show the atmosphere in the space poses no hazard. Any worker about to enter the space, or their authorized representative, should be given a chance to watch the pre-entry testing.
The employer has to confirm that the space is safe to enter and that the pre-entry steps discussed above have been taken. This is done via a written certification that has the date, the location of the space, and the person providing the certification’s John Hancock. The certification needs to be made prior to entry and be accessible to every worker entering the space or to their authorized representative.
The employer needs to offer workers a safe way to get into and out of the space. If any hoisting system is used, it must either (1) be purpose-built for personnel hoisting, or (2) get a thumbs up for personnel hoisting from a registered professional engineer before it’s put to use.

Ventilation Requirements

Continuous forced air ventilation is a must. (Sorry, but exhaust ventilation won’t cut it as a replacement for forced air ventilation.)
If the forced air ventilation stops for any reason, the workers inside have to exit the space immediately.
The forced air ventilation must be angled to ventilate the immediate areas where each worker is or will be in the space, and it has to keep going until all workers have left the space.
The air supply for the forced air ventilation needs to come from a clean source and not add any more hazards to the space.

During Entry

The atmosphere inside the space has to be continually monitored to confirm that the forced air ventilation is doing its job to prevent the buildup of a hazardous atmosphere. This monitoring has to be done constantly unless the entry employer can show that continuous monitoring equipment isn’t commercially available or that periodic checks are enough to ensure the atmosphere stays hazard-free. Employers must give any worker entering the space, or their authorized representative, a chance to watch the testing required by this clause.
If a hazard shows up during entry, employers have three jobs: (A) Ensure every worker leaves the space immediately; (B) Evaluate the space to figure out how the hazard came about; and (C) Put into action measures to protect workers from the hazard before anyone goes back into the space.

Chapter 9: Entrants, Attendants, and Entry Supervisors (Sections 1208-1210)

In the theater of permit space work, there’s a three-part harmony that drives the action: the authorized entrants, the attendants, and the entry supervisors. The puppet master behind the scenes, known as the entry employer, is tasked with making sure these performers play their parts to the letter.

An authorized entrant is the one who’s given the green light by the entry supervisor to take that step into the known – and sometimes unknown – territory of a permit space.

The attendant, the watcher on the walls, is positioned on the outskirts of one or more permit spaces, with the job of monitoring the conditions within those spaces and acting as the first line of defense against unauthorized entry.

An entry supervisor is a figure of authority and competence, be it the employer, the foreman, or the crew boss, who is given the reigns to manage entry operations. This individual can also wear the hat of an attendant or serve as an entrant, as long as they’ve been trained and equipped as per the requirements of this standard for each role they take on. The mantle of entry supervisor can change hands from one person to another during an entry operation.

For the Authorized entrants, their to-do list is as follows. They are required to:

Get well-acquainted with the hazards within the space, including how exposure can happen, say via inhalation or skin contact, and what signs or symptoms might emerge.
Suit up in the right personal protective gear and know the drill for using it.
Stay connected with attendants, so the attendants can keep tabs on their status and signal them to exit when necessary.
Beat a hasty retreat from the permit space at the drop of a hat when: instructed by the attendant or entry supervisor; they spot any warning signs or symptoms of exposure; a forbidden condition arises; or an automatic alarm springs into action.
Give the attendant a nudge when a prohibited condition comes into play or when exposure warning signs or symptoms are noticed.

As for the attendant, their duties entail:

Keeping their post outside the permit space during entry operations, unless another authorized attendant steps in to take their place.
Carrying out non-entry rescues as directed by the employer’s rescue plan.
Gaining a solid understanding of current and potential hazards, including exposure mechanisms, signs or symptoms, potential consequences, and behavioral effects that might occur following exposure.
Staying in communication with, and keeping an accurate tally of those workers venturing into the permit space.
Keeping a sharp eye on the conditions inside and outside the space and ordering an evacuation if: a forbidden condition is detected; a worker starts behaving oddly due to hazard exposure; a situation arises outside the confined space that could endanger the entrants; or when they can’t safely or effectively fulfill their duties.
Calling upon rescue and other necessary services during an emergency.
Making sure that unauthorized individuals maintain a safe distance from permit spaces or make a swift exit if they’ve wandered into the permit space.
Alerting the entrants and the entry supervisor if an unauthorized person sneaks into the permit space.
Avoiding tasks that could distract from their primary responsibilities.

And finally, the entry supervisors are tasked to:

Familiarize themselves with the space’s hazards, including exposure mechanisms, signs or symptoms, and potential consequences.
Confirm that all entry conditions, including permits, tests, procedures, and equipment are up to scratch before giving the go-ahead for entry.
Bring an end to the entry and cancel or suspend permits when entry operations are all done, or if a condition arises that’s not part of the permit deal.
Verify that rescue services are available and that the means for summoning them are operable
Take appropriate measures to remove unauthorized entrants; and
Ensure that entry operations remain consistent with the entry permit and that acceptable entry conditions are maintained.

Worker Training (Section 1207)

Before any worker even thinks about stepping into a permit space, the entry employer has a job to do – and that’s to provide comprehensive training. We’re talking about authorized entrants, attendants, entry supervisors, and other employees with duties under the standard, like those who test and monitor the atmosphere in a permit space. They need to get the lowdown on the hazards in the permit space and the methods used to keep those hazards at bay. And if a worker isn’t cleared to perform entry rescues, the training needs to shine a spotlight on the dangers of trying to pull off such rescues. And here’s the kicker – all this training doesn’t cost the workers a dime.

Once the training wraps up, the employer needs to make sure that the workers have the understanding, knowledge, and skills to safely do their jobs. This isn’t a one-shot deal. The training needs to be in a language and vocabulary that the worker can understand, and it needs to happen before the worker is first assigned duties under this standard, and before there’s a change in the worker’s assigned duties. Training also needs to happen again whenever there’s a change in permit space entry operations that brings a new hazard into the mix that the worker hasn’t been trained on before, or whenever the worker’s actions show that they’re not up to snuff in their knowledge or use of entry procedures.

And we can’t forget about the rescue personnel. As we’ll get to in the next section of this article, they need to be trained to do their jobs too.

Keeping a record of this training is a must. The employer needs to jot down that the required worker training has been done. This record needs to have the worker’s name, the trainer’s signature or initials, and the dates of the training. And this isn’t just for show. The employer needs to make this record available for inspection by workers and their authorized representatives. It’s all about keeping things above board and holding everyone accountable.

Now, if you’re interested in some help with your training program we may have a solution for you: our “Confined Space Entry” training products. These aren’t just a bunch of DVDs and online courses. They’re tools, designed to provide employees with the information they need to stay safe in Permit Spaces and help employers stay in compliance with OSHA requirements, whether they’re doing “general industry” or “construction” type work.

These products cover a range of topics that are integral to employees’ understanding of these issues. We’re talking about reducing risk with a Permit Space Program, the ins and outs of the Entry Permit, testing for hazardous atmospheres, making a space as safe as possible, a step-by-step approach to safe entry, the role of attendants and evacuation procedures, and dealing with “special” situations. And the best part? All “Confined Space Entry” products are available in English and Spanish.

For those who like to dive deep, we’ve got a detailed course outline in PDF format. And for those who prefer bite-sized learning, our “Confined Space Entry” MicroLearning curriculum includes a series of 3 – 5 minute courses covering key topics. So, whether you’re a seasoned pro or a newbie to the world of confined spaces, we’ve got you covered. Click on the link below for more information:

Confined Space Entry – Online Safety Training

Rescue and Emergency Services (Section 1211)

Provision of rescue and emergency services: When it comes to rescue and emergency services, it’s all about being prepared. You see, before anyone sets foot in a permit space, the employer needs to ensure that rescue and emergency services are readily available. This isn’t about calling 911 and hoping for the best. It’s about having a dedicated team on standby, ready to spring into action at a moment’s notice. And if the employer decides to use an outside rescue service, they need to coordinate with the service to ensure they can respond promptly and are familiar with the permit spaces at the site.

Duties and responsibilities in emergency situations: Now, in an emergency, everyone has a role to play. Authorized entrants need to be aware of the potential hazards of the permit space and be able to recognize the signs of exposure to these hazards. They need to maintain communication with the attendant, so they can monitor the entrant’s status and alert the rescue team if needed.

The attendants, they’re the eyes and ears on the outside. They need to keep an eye on the entrants and order evacuation if they spot a problem. They’re also responsible for summoning the rescue team if an entrant shows signs of hazard exposure or if a prohibited condition arises.

And then there’s the rescue team. These folks need to be trained and equipped to perform assigned rescue duties. They need to know how to assess the situation, how to use their equipment, and how to safely extract entrants from the permit space.

Sewer System Entry

Among the myriad forms of confined spaces, sewer systems stand as some of the most frequent and dangerous battlegrounds. Over the years, countless workers have found themselves in a tragic tale of life-threatening injuries or worse, due to hazards lurking within sewer manholes, pipelines, and lift stations. This section serves as a guide for employers in sewer work, shining a light on the protective measures they need to put in place for their workforce.

A venture into the sewer system is a unique beast, set apart from other permit entries by three fundamental aspects. First, you’ve got a stretch of a continuous system that you’re trying to isolate – not an easy feat, if not entirely impossible. Second, since isolation is far from perfect, the environment within can flip on a dime, becoming fatally hazardous with a toxic, flammable, or explosive atmosphere due to factors out of the hands of both the entrant and the employer. Thirdly, there’s the risk of being swallowed by material flowing through the sewer system. Yet, despite these daunting challenges, veteran sewer workers are adept at entering and navigating their permit spaces, given their regular encounters with such spaces. In contrast to other jobs where permit space entry is a rare and extraordinary occurrence, for sewer workers, a permit space is their usual stomping ground.

OSHA firmly believes that the potential perils of sewer work can be effectively managed, and employees shielded from the unpredictable hazards, if employers earnestly reinforce and follow the following four procedures:

(1) Procedure adherence. Employers should only tag employees as entrants if they’ve been drilled in the employer’s sewer entry procedures and can prove they follow these procedures to a T when undertaking sewer entries.

(2) Atmospheric monitoring. Entrants need to be trained in the use of, and kitted out with, atmospheric monitoring gear that not only provides a visual readout but also sounds an audible alarm. The atmospheric conditions they will often need to monitor include oxygen concentrations below 19.5 percent or above 23.5 percent; flammable gas or vapor at 10 percent or more of the lower flammable limit (LFL); or hydrogen sulfide or carbon monoxide at or above 10 ppm or 35 ppm, respectively, calculated as an 8-hour time-weighted average. To ensure reliable readings, the monitoring equipment needs to be calibrated following the manufacturer’s guidelines. The oxygen sensor/broad range sensor is a go-to choice in scenarios where the actual or potential contaminants haven’t been identified, as unlike substance-specific sensors, broad range sensors can provide an overall snapshot of the hydrocarbons (flammables) present in the space.

However, these sensors only give a heads up that a hazardous threshold of a class of chemicals has been breached. They don’t provide the exact contamination levels of specific substances. That’s where substance-specific devices, which measure the actual levels of specific substances, come in handy, especially when the actual or potential contaminants have been identified. The measurements captured by substance-specific devices are crucial for employers when they need to decide on the necessary protective measures for entrants (like ventilation or personal protective equipment) and the establishment and achievement of appropriate entry conditions.

But here’s the rub – the environment within a sewer can change abruptly and unpredictably. This means that substance-specific devices might not pick up on potentially deadly atmospheric hazards that may creep into the sewer environment.

While OSHA deems the information and guidance given above to be fitting and helpful for most sewer entry situations, the agency stresses that each employer has to consider the unique circumstances, including the predictability of the atmosphere, of the sewer permit spaces at their workplace while preparing for entry. It’s up to the employer, with their knowledge of and experience with permit spaces in sewer systems, to determine the best type of monitoring equipment for each specific entry operation.

In sewer line work, the selected monitoring equipment needs to be used by the entrant to continuously check the atmosphere in their environment, and in the direction they’ll be heading, to alert the entrant to any deterioration in atmospheric conditions. When several entrants are working together in the same immediate location, one instrument, used by the lead entrant, is acceptable.

(3) Surge flow and flooding. Employers should strive to develop and maintain a connection, as far as possible, with the local weather bureau and the area’s fire and emergency services. This way, sewer work can be postponed or halted and entrants can be evacuated whenever sewer lines might be suddenly flooded due to rainfall or fire-fighting activities, or whenever flammable or other hazardous materials are released into sewers during emergencies brought about by industrial or transportation accidents. In addition, employers should train workers in the use of, and ensure they use, an early-warning system positioned far enough upstream of the work area to give crews sufficient warning of a surge to exit the space safely.

(4) Special equipment. For entries into large bore sewers, special equipment might be required. This equipment could include items like self-contained breathing apparatus (SCBA) with at least a 10-minute air supply (or other NIOSH-approved self-rescuer), waterproof flashlights, and might also include boats and rafts, radios, and rope stand-offs for pulling around bends and corners as needed.

Example of a Permit-Required Confined Space Program

The following text is a detailed example of a permit-required confined space program

Workplace: Sewer entry.

Potential hazards: The employees could be exposed to the following:

Engulfment.

Presence of toxic gases. Equal to or more than 10 ppm hydrogen sulfide measured as an 8-hour time-weighted average, and equal to or more than 35 ppm carbon monoxide measured as an 8-hour time-weighted average. If the presence of other toxic contaminants is suspected, specific monitoring programs will be developed.

Presence of explosive/flammable gases. Equal to or greater than 10% of the lower flammable limit (LFL).

Oxygen deficiency. A concentration of oxygen in the atmosphere equal to or less than 19.5% by volume.

A. Entry Without Permit/Attendant

Certification. Confined spaces may be entered without the need for a written permit or an attendant provided that the space can be maintained in a safe condition for entry by mechanical ventilation alone, as provided in §1926.1203(e). All spaces must be considered permit-required confined spaces until the pre-entry procedures demonstrate otherwise. Any employee required or permitted to pre-check or enter an enclosed/confined space must have successfully completed, at a minimum, the training as required by the following sections of these procedures. A written copy of operating and rescue procedures as required by these procedures must be at the work site for the duration of the job. The Confined Space Pre-Entry Check List must be completed by the LEAD WORKER before entry into a confined space. This list verifies completion of the items Protecting Construction Workers in Confined Spaces 3 9 listed below. This checklist must be kept at the job site for the duration of the job. If circumstances dictate an interruption in the work, the permit space must be re-evaluated and a new checklist must be completed. Control of atmospheric and engulfment hazards.

Pumps and lines. All pumps and lines which may reasonably cause contaminants to flow into the space must be disconnected, blinded and locked out, or effectively isolated by other means to prevent development of dangerous air contamination or engulfment. Not all laterals to sewers or storm drains require blocking. However, where experience or knowledge of industrial use indicates that there is a reasonable potential for contamination of air or engulfment into an occupied sewer, then all affected laterals must be blocked. If blocking and/or isolation requires entry into the space the provisions for entry into a permit-required confined space must be implemented.

Surveillance. The surrounding area must be surveyed to avoid hazards such as drifting vapors from the tanks, piping, or sewers.

Testing. The atmosphere within the space will be tested to determine whether dangerous air contamination and/ or oxygen deficiency exists. Detector tubes, alarm-only gas monitors and explosion meters are examples of monitoring equipment that may be used to test permit space atmospheres. Testing must be performed by the LEAD WORKER who has successfully completed the Gas Detector training for the monitor he or she will use. The minimum parameters to be tested are oxygen deficiency, LFL, and hydrogen sulfide and carbon monoxide concentrations. A written record of the pre-entry test results must be made and kept at the work site for the duration of the job. The supervisor will certify in writing, based upon the results of the preentry testing, that all hazards have been eliminated. Affected employees must be able to review the testing results. The most hazardous conditions must govern when work is being performed in two adjoining, connecting spaces. Occupational Safety and Health Administration.

Entry Procedures. If there are no non-atmospheric hazards present and if the pre-entry tests show there is no dangerous air contamination and/or oxygen deficiency within the space and there is no reason to believe that any is likely to develop, entry into and work within may proceed. Continuous monitoring of the atmosphere in the immediate vicinity of the workers within the space must be accomplished. The workers will immediately leave the permit space when any of the gas monitor alarm set points are reached as defined. Workers will not return to the area until a SUPERVISOR who has completed the gas detector training has used a direct reading gas detector to evaluate the situation and has determined that it is safe to enter.

Rescue. Arrangements for rescue services are not required where there is no attendant. See the rescue portion of section B., below, for instructions regarding rescue planning where an entry permit is required.

B. Entry Permit Required

Confined Space Entry Permit. All spaces must be considered permit-required confined spaces until the preentry procedures demonstrate otherwise. Any employee required or permitted to pre-check or enter a permit-required confined space must have successfully completed, at a minimum, the training as required by the following sections of these procedures. A written copy of operating and rescue procedures as required by these procedures must be at the work site for the duration of the job. The Confined Space Entry Permit must be completed before approval can be given to enter a permit-required confined space. This permit verifies completion of the items listed below. This permit must be kept at the job site for the duration of the job. If circumstances cause an interruption in the work or a change in the alarm conditions for which entry was approved, a new Confined Space Entry Permit must be completed. Protecting Construction Workers in Confined Spaces 4 1 Control of atmospheric and engulfment hazards.

Surveillance. The surrounding area must be surveyed to avoid hazards such as drifting vapors from tanks, piping or sewers.

Testing. The confined space atmosphere must be tested prior to entry to determine whether dangerous air contamination and/or oxygen deficiency exists. A direct reading gas monitor must be used. Initial testing must be performed by the SUPERVISOR who has successfully completed the gas detector training for the monitor he will use. The minimum parameters to be tested are oxygen deficiency, LFL, hydrogen sulfide concentration and carbon monoxide concentration. A written record of the preentry test results must be made and kept at the work site for the duration of the job. Affected employees and their representatives must be able to review the results. The most hazardous conditions must govern when work is being performed in two adjoining, connected spaces.

Space Ventilation. Mechanical ventilation systems, where applicable, must be set at 100% outside air. Where possible, open additional manholes to increase air circulation. Use portable blowers to augment natural circulation if needed. After a suitable ventilating period, repeat the testing. Entry may not begin until testing has demonstrated that the hazardous atmosphere has been eliminated.

Early-warning system. Whenever the possibility of engulfment is present at the work site, an employee must be stationed far enough upstream with a two-way radio to alert entrants at the first sign of an approaching flood hazard, or an alarm activated by remote detector(s) placed to detect an approaching flood hazard must be used, so the entrants have time to exit the space safely.

Entry Procedures. The following procedure must be observed under any of the following conditions: (1) Testing demonstrates the existence of dangerous or deficient conditions and additional ventilation cannot reduce Occupational Safety and Health Administration 4 2 concentrations to safe levels; (2) The atmosphere tests as safe but unsafe conditions can reasonably be expected to develop; (3) It is not feasible to provide for ready exit from spaces equipped with automatic fire suppression systems and it is not practical or safe to deactivate such systems; or (4) An emergency exists and it is not feasible to wait for preentry procedures to take effect.

All personnel must be trained. A self-contained breathing apparatus must be worn by any person entering the space. At least one worker must stand by the outside of the space ready to give assistance in case of emergency. The standby worker must have a self-contained breathing apparatus available for immediate use. There must be at least one additional worker within sight or call of the standby worker. Continuous powered communications must be maintained between the worker within the confined space and standby personnel.

If at any time there is any questionable action or nonmovement by the worker inside, a verbal check will be made. If there is no response, the worker will be moved immediately. Exception: If the worker is disabled due to falling or impact, he/she must not be removed from the confined space unless there is immediate danger to his/her life. Local emergency services must be notified immediately. The standby worker may only enter the confined space in case of an emergency (wearing the self-contained breathing apparatus) and only after being relieved by another worker. A safety belt or harness with an attached lifeline must be used by all workers entering the space with the free end of the line secured outside the entry opening. The standby worker must attempt to remove a disabled worker via his lifeline before entering the space.

When practical, these spaces must be entered through side openings—those within 3 1/2 feet (1.07 m) of the bottom. When entry must be through a top opening, the safety belt must be of the harness type that suspends a person upright and a hoisting device or similar apparatus must be available for lifting workers out of the space.

In any situation where their use may endanger the worker, use of a hoisting device or safety belt and attached lifeline may be discontinued. (See the rescue section below.)

When dangerous air contamination is attributable to flammable and/or explosive substances, lighting and electrical equipment must be Class 1, Division 1 rated as per National Electrical Code and no ignition sources must be introduced into the area.

Continuous gas monitoring must be performed during all confined space operations. The minimum parameters to be monitored are oxygen deficiency, LFL, hydrogen sulfide concentration and carbon monoxide concentration. If alarm conditions change adversely, entry personnel must exit the confined space and a new confined space permit issued.

Rescue. Use of harnesses, lifelines, and a winch outside the space is the preferred method of rescue. Entrants and attendants will be trained in proper use of harnesses and rescue equipment. If harnesses and lifelines may not be used due to the configuration of the space, or could expose workers to greater hazards than entry rescue, call the local emergency services (or other rescue service) and evaluate them for entry rescue capability, informing them of the nature and exact location of the space and the anticipated hazards within. Where immediate hazards to injured personnel are present, workers at the site must implement emergency procedures to fit the situation.

Conclusion

Well folks, we’ve reached the end of the line on this journey through the world of confined and permit spaces. This piece has been all about arming you with the knowledge to keep your workers safe in these potentially tricky environments. It’s given us the lowdown on what these spaces are – places not exactly designed for people, but just right for workers to get in there and get the job done, even if getting in and out isn’t always a breeze.

But this piece didn’t just stop at telling us what these spaces are. It went the extra mile, laying out the work covered by the standard, spelling out what the bosses need to do, and giving us a bird’s eye view of the standard. It’s all about making sure everyone knows their part in keeping these spaces as safe as can be. It’s even got tips on spotting permit spaces, what goes into a permit space program, and how to switch a permit space to a non-permit space.

At the heart of it all is keeping our workers safe. This piece is a reminder that safety isn’t just about following the rules – it’s about looking out for each other. It’s a shining example of OSHA’s dedication to keeping workers safe and sound in confined and permit spaces.

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