Confined Spaces: How to Satisfy OSHA Compliance

While many may think of any small area as a confined space, the Occupational Safety and Health Administration (OSHA) definition is slightly different. It is defined as any area that possesses all of these conditions:

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

Some examples include tanks, pits, tunnels, manholes, ducts, and vents.

When Does a Confined Space Require a Permit?

If a confined space possesses any of the following characteristics, it requires a permitting process:

• 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 might cause an entrant to be trapped or asphyxiated by inwardly converging walls or a floor that slopes downward and tapers to a smaller cross-section
• Contains any other recognized serious safety or health hazards.

What Employers Need to do for Compliance

If it's not by definition a permit-required confined space, then there are no special requirements. These spaces must be treated like any other workplace area to satisfy OSHA requirements.

If it's a permit-required confined space, a significant amount of compliance is needed to meet 29 CFR 1910.146. Although "permit-required" may suggest filing permits with a government office, the process is actually an onsite procedure intended to ensure the appropriate safety steps are taken when employees enter these spaces.

1. Post signs

The signs must inform employees about the existence, location, and hazards of the permit spaces. OSHA standard 1910.146 provides an example of wording for marking a permit-required confined space: "Danger - Permit-Required Confined Space, Do Not Enter." The sign should comply with ANSI Z535 standards for a danger sign. If some employees do not speak English, signs should be posted in all necessary languages.

2. Prevent entry

Decide whether employees will be expected to enter permit-required confined spaces. If not, measures must be taken to prevent entry. OSHA standard 1910.146(c)(3) allows flexibility in choosing the most effective method, such as using a lock. If employees will enter those spaces, proceed to the next step.

3. Prepare a written program

A written confined space permit program must be prepared and made available to employees and their representatives.

OSHA requires the written program to:

• Describe measures taken to prevent unauthorized entry
• Identify and evaluate any hazards in the space
• Require testing the atmospheric conditions (for oxygen, combustible gasses or vapors, and toxic gases or vapors) prior to entry, and monitor the space during entry.
• Identify the specific tasks needed to complete the work in the confined space
• Require employees to use the appropriate personal protective equipment (PPE) and other safety equipment. (This equipment must be provided and maintained by the employer at no cost to the employee)
• Require at least one attendant to be stationed outside the space for the duration of the entry
• When employees of multiple employers are working in the permit space, coordinate their entry operations
• Describe procedures for summoning rescue and emergency services, and for preventing unauthorized people from attempting rescue
• Include procedures for the preparation, issue, use, and cancellation of entry permits
• Establish procedures in case an attendant monitoring multiple confined spaces must respond to an emergency in one or more of those spaces

4. Review the program at least annually

Set a date for review, or consider defining events that kick the program into automatic review, such as altered conditions, or a confined spaces-related injury or fatality. Revise the program as needed.

5. Prepare for entry into the space

Confined space entry permits must be available to the entrants and signed by the entry supervisor prior to each visit. The permit must verify that mandated pre-entry preparations have been completed (here is a sample permit, which includes a pre-entry checklist). The duration of the entry permit must not exceed the time required to complete the work assignment.

Entry permits must include the following information:

• Name of the confined space
• Reason for entry
• Date and authorized duration of the entry
• Identities of authorized entrant(s) and attendants
• Name and signature of the supervisor who has authorized entry
  Identification of all known hazards in the space and measures to be taken to eliminate or control the hazards
• Acceptable entry conditions must be confirmed. Results of initial and periodic tests, along with the initials or name of the tester, and the times of the tests
• Identification of rescue and emergency services, and the means to summon those services (such as phone numbers or equipment to be used)
• Communication procedures and the equipment required to maintain contact during entry
• Identification of any special equipment and procedures that are needed, such as PPE or alarm systems
• Any additional required permits, such as those needed for energized electrical work that have been issued to authorize work in the permit space
• Any additional information needed to ensure employee safety

6. Procedure after work is completed

When the work assignment in the confined space is complete or the confined space conditions change, the entry supervisor must cancel the permit. Any new conditions must be noted on the canceled permit and used to revise the permit-required confined space program. All canceled entry permits must be kept on file for at least one year.

7. Provide worker training

All necessary training must be provided for every worker required to enter the space before entry. It must also be ensured that employees have learned, retained, and understood the training, as well as know everything needed to safely perform their duties.

Additional training is required when:

• Job duties change
• A change occurs in the permit space program, or the operation presents any new hazard
• An employee's job performance does not meet standards for permit-required confined space entry

Rescue team members must be trained in CPR and first aid. Employers must certify that this training has been provided.

A written record must be kept of completed permit-required confined space training. This record must be available to employees and their authorized representatives. The record must include the employee's name, the trainer's signature or initials and dates of the training.

DuraLabel Solutions for Confined Spaces

DuraLabel offers reliable solutions for confined spaces to enhance safety and communication in challenging environments. With a variety of durable labels and signs, you can mark potential hazards, indicate entry restrictions, and highlight critical safety procedures. Our high-quality materials are built to withstand harsh conditions, ensuring clear and visible communication even in tough environments like tunnels, tanks, and manholes. 

DuraLabel’s Toro Max and Kodiak Max print systems allow you to create customized safety labels and signs on-site, making it easier to keep confined spaces properly marked. From compliant labels to warning signs, DuraLabel provides the tools you need to maintain safety and meet regulatory standards.

Download our free OSHA Signage Quick Start Guide to guarantee your facility meets OSHA standards for confined spaces. This comprehensive resource provides a detailed site inspection checklist to ensure your facility is OSHA compliant. 

OSHA Signage Quick Start Guide
Label in accordance with OSHA and ANSI standards.