When it comes to confined entry, we often have trouble understanding when to apply the rules; not to mention which rule is appropriate. For example, many of us don't know the difference between "confined entry space" and "permit required confined space." That makes it hard to determine if hazards really exist.
What kinds of hazards might exist in a confined space? An oil-filled transformer is one example of a permit-required confined space with a potentially hazardous atmosphere. The nitrogen blanket above the oil is potentially life threatening because it displaces oxygen. Even if you remove the oil, the nitrogen may still be there. You may need to work in splicing pits, vaults, or manholes. Perhaps you need to enter large gas breakers, oil circuit breakers, or oil-filled transformers. Working in any of these spaces requires special procedures and training.
How do you evaluate confined spaces with confidence and determine if any special requirements or training is necessary? Let's start by looking at what defines a "confined entry space." It is:
• Any space large enough to enter and perform work;
• One with limited entries and exits;
• A space not designed for continuous occupancy; or
• A space where you might expose any body part to a hazard upon entry.
This differs from a permit required confined space, which is a space with one or more of the following characteristics:
• A hazardous or potentially hazardous atmosphere;
• Contains a substance that could engulf and asphyxiate an entrant;
• An internal configuration that could trap or asphyxiate an entrant by inwardly converging walls or by a floor that slopes downward and tapers to a smaller cross section; or
• Contains any other serious safety or health hazard.
When hazards exist within a confined space, that space must have a label that reads: "Permit Required," andit must have controlled access.
When you evaluate a confined space, you have to start with the worst scenario and "prove your way backward." This means all confined spaces require a permit until proven otherwise. OSHA's catchall statement, "a space that contains any other serious safety or health hazard," covers hazards such as exposed electrical equipment or equipment with stored energy (e.g., hydraulic). If you plan to work in a space like this, you must first release stored energy and de-energize electrical energy, or put appropriate barriers in place. Everyone should also follow lockout/tagout procedures.
If you hire a contractor to do the work, insist on seeing their training records. Ask how they will conduct a confined space entry into each specific type of confined space they may encounter at your site. Then, work cooperatively with the contractor to meet safety requirements.
What if you have a permit required confined space at your facility? Must everyone have confined entry training, and must you evaluate every hazard in that space? It depends. First, decide whether anyone on your team must enter that space. If not, tell your employees and contractors about the space, put a sign on it, and lock it. You've met the OSHA requirements.
All parties should be aware of the potential hazards of any permit-required confined space prior to entry. If you must enter a permit-required confined space, sit down with someone who knows that space or a similar space and brainstorm on what hazards may be present. Document all concerns. You are creating your OSHA-required confined space program as you do this.
Now that you've identified all of the potential hazards, document how to control them. Picture the kind of work people will be doing and determine what kind of Personal Protective Equipment (PPE) they will need. At this point, you're developing what OSHA calls the conditions of entry. The idea here is nobody can enter a permit-required confined space before you've identified and eliminated or controlled all the hazards.
To enter a permit-required confined space, you must have a written permit. OSHA 1910.146 Appendix C, "Examples of Confined Space Programs," provides two sample permits that fulfill all of its requirements. The worker must post the fully completed permit outside the permit-required confined space during the entry. This allows others involved with the space to inspect and read the permit.
OSHA notes four roles for a permit required confined space entry: entry supervisor; entrant; attendant; and rescue services. These roles apply to contractors and owners of permit required confined spaces. OSHA requires people fulfilling these roles to attend annual training.
Making it simple. In the confined space standard, OSHA provides the following methods for simplifying your entry into the permit-required confined space. 1. Demonstrate that the only hazard in the permit-required space is a hazardous or potentially hazardous atmosphere you can eliminate by continuous forced air ventilation. With each entry, you must demonstrate (and document) this hazard elimination by conducting atmospheric testing. 2. Reclassify a permit-required confined space to a non-permit-required confined space. The flow chart in OSHA 1910.46 Appendix A provides guidance on this. You can reclassify the space by eliminating all the potential hazards within the permit-required confined space. But there's a catch. You must eliminate these hazards without entering the permit-required confined space.
Reclassification does not mean an end to your effort. When you reclassify, approach the space as if you are making a permit-required confined space entry. You still must train all of the people involved. You still must issue completed permits for each worker. By filling out the permit, you are addressing each of the expected potential hazards in that space and documenting how you eliminated those hazards.
Each worker verifies de-energization, release of mechanical energy, lockout/tagout, removal of any substance that could engulf an entrant, and atmospheric testing. Each person issued a permit should run through the list of safety items and ensure everything is correct; just as if the area did not go through declassification.
When you've completed all of these tasks and controlled or eliminated all hazards for the duration of the entry, you can reclassify the permit-required confined space to a non-permit-required confined space. If you are a contractor, the owner of the space must authorize this reclassification. You must do each of these steps every time you enter a permit-required confined space.
Why reclassify? With all this work, why bother reclassifying a confined space? The advantage is you eliminate some of the requirements. The first step is to fill out the permit (completely), write "Reclassified" across it, and post it outside the space. The entry that required three people to fulfill four roles now requires only two people. When an attendant can perform non-entry rescue, this is satisfactory for a non-permit-required confined space; and it may cut training costs.
A non-permit-required confined space doesn't have a requirement for a dedicated attendant. However, that does not mean no attendant. Should an eliminated hazard reappear or an unexpected hazard appear, the entrant may need help. Thus, someone should be in close proximity and maintain good communication with the entrant.
In the case of a reappearing or new hazard, you must once again view the confined space as permit-required until you eliminate that hazard. When this happens, note it on the permit. This allows the next person reviewing the permit to have an update on the hazards.
When work is complete in a reclassified confined space, the entry supervisor documents this on the permit. This terminates the permit and returns the confined space into a permit-required space. No one can re-enter the confined space after terminating the permit, unless you issue a new permit.
Some people try to get around this rule by writing "blanket" or "open" permits. This practice is wrong and dangerous. A permit cannot extend beyond the time necessary to complete the work in the confined space. You must issue new permits for new conditions or new people. This ensures the people working in and around the space participate in eliminating the hazards and the declassification of the permit required confined space.
Keep in mind, this article does not cover every detail of OSHA 1910.46. If you think there are confined spaces on your property or in your work area, seek help from a person qualified in confined space assessment. Anyone working in or near a confined space should have annual training on confined spaces, including non-entry rescue. If you have questions, contact an OSHA consultation branch through your state's Division of Industrial Safety Consulting.
Rutter is a Safety Engineer with Electro-Test, Inc., Reno, Nev.