While you may think of any small area as a confined space, the OSHA definition is slightly different. It is defined as any area that possesses all of these conditions:
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:
What employers need to do for compliance
If it's not by definition a permit-required confined space, then there are no special requirements. You just need to treat these spaces as you would any other workplace area, in order to satisfy OSHA.
If it's a permit-required confined space, you're going to have to do quite a bit to satisfy 29 CFR 1910.146. Though "permit-required" sounds like you have to file permits with a government office, the process is actually an onsite procedure, designed to make sure that the appropriate safety steps are taken when an employee enters these spaces.
If you are in the construction industry, you need to know about OSHA's new standard for confined spaces in construction.
Simple guide to OSHA compliance of permit-required confined spaces
1. Post signs
The signs must inform employees about the existence, location, and hazards of the permit spaces. 1910.146 gives an example of the wording that could be used to mark a permit-required confined space: "Danger - Permit-Required Confined Space, Do Not Enter." The sign should follow the ANSI Z535 standards for a danger sign. If some of your employees don't speak English, be sure to post signs in all needed languages.
2. Prevent entry
Decide whether employees will be expected to enter permit-required confined spaces. If not, you must prevent them from doing so. This standard, 1910.146(c)(3), does not specify exact means, so you have some freedom to decide what will be most effective, such as a lock. If employees will enter those areas, proceed to the next step.
3. Prepare a written program
You'll have to prepare a written confined space permit program, and make it available to employees and their representatives.
OSHA requires the written program to:
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:
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
You must provide all necessary training for every worker who is required to enter the space, prior to entry. In addition, you must ensure that the employees have learned and remember what was taught in the training, and that they know whatever is necessary to safely perform their duties.
Additional training is required when:
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.
For more in-depth information on confined spaces, request our free Confined Spaces Best Practice Guide, which includes a confined space assessment form, how to test atmospheric conditions, and more.