Permit-Required Confined Spaces

Occupation Safety and Health Act

By: Steven R. Sawyer, ARM, MS, CSP

As many employers have learned over the last few years, employees are a valuable resource.  The ability to find and keep employees has become a challenge for many employers in a variety of industries, including food and beverage agriculture.  Therefore, keeping employees safe is a top priority.

  Employers in the food and beverage agriculture industry, like vineyards and wineries, may have multiple confined spaces in which employees encounter in their daily job tasks.  These include vats, tanks, storage bins, tunnels, duct work, pits, drain systems, and liquid tanks and containers.  Many industry employees are required to enter these spaces as part of their jobs.

  Occupational Safety and Health Administration (OSHA), in their Permit-Required Confined Spaces standard 29 CFR 1910.146, describes a confined space as a space that is large enough for an employee to bodily enter and perform assigned work tasks, has a limited or restricted means of entry or exit, and is not designed for continuous employee occupancy.  Additionally, OSHA defines a Permit-Required Confined Space as a confined space with one or more of the following characteristics:  the confined space contains or has the potential to contain a hazardous atmosphere; the confined space contains a material that has the potential for engulfing the entrant; the confined space has an internal configuration with inwardly converging walls or a floor that slopes downward and tapers to a smaller cross section which could trap or asphyxiate an entrant; and contains any other recognized serious safety or health hazard. (OSHA.gov)

  The first step in protecting employees from the hazards of confined spaces is to evaluate the workplace to determine if the workplace contains permit-required confined spaces.  An initial survey or workplace evaluation should be conducted to locate and identify all confined spaces.  This initial workplace evaluation should be conducted by a qualified person who is familiar with the hazards and types of confined spaces.  Although this is the initial step, workplace evaluation must be ongoing for confined spaces which may change over time with the addition of new processes, equipment, or facilities.

  Once a confined space is identified in the workplace, the confined space should be treated as a hazardous area until a qualified person can determine the specific hazards.  Additionally, the qualified person will determine if the confined space is a permit-required confined space or a non-permit confined space.  Hazards an evaluator will look for include atmospheric hazards such as oxygen deficient or toxic atmosphere, biological hazards, mechanical hazards, physical hazards, and chemical hazards.

  If the qualified person has found permit-required confined spaces at the workplace, the employer must notify the employees.  Employees must know their workplace contains permit-required confined spaces, where the spaces are located and the hazards associated with those spaces.  Then, the employer must post signage to inform the employees of the permit spaces.  This signage can read “Danger – Permit-Required Confined Space, Do Not Enter” or a similar statement.  The signs should be posted on the entrance or in close proximity to the entrance of the permit space.

  At this point, an employer has a decision to make about their Permit-Required Confined Spaces:  either allow employees to enter or do not allow employees to enter.  If the employer makes a decision to not allow employees to enter permit spaces, then the employer should take effective measures to secure the spaces.  Some examples of securing permit spaces to prevent entry are padlocks, bolts, chains, and wire cables.

  If entry is necessary for employees to service or clean permit-required confined spaces, the employer must develop and implement a written permit-required confined space program and make the program available for employee inspection.  This written program should include written entry procedures for the permit-required confined spaces along with the hazards present, and how to eliminate or control the hazards. 

  The written permit-required confined space program should include an entry permit.  The entry permit is a document to be used for all permit-required confined space entries.  The entry permit should include the date of entry and authorized duration of the entry, the location of the entry, the names of all entrants, and the work that is being conducted in the confined space.  Additionally, the permit must include the names of attendants, the name of the entry supervisor, the hazards present in the space to be entered, how the hazards will be eliminated or controlled before entry, acceptable entry conditions, results of initial and periodic tests performed along with the names of the testers and when tests were performed, rescue and emergency services to contact in the event of an emergency, communication procedures between the entrant and the attendant, equipment necessary including personal protective equipment, testing equipment, communication equipment, alarm systems, and rescue equipment, other information deemed necessary for safe entry, and any additional permits such as hot work permits.  Lastly, the permit should have a signature line for the entry supervisor to authorize the entry, including the date and time of the entry.  The entry supervisor should communicate the contents of the entry permit to the authorized entry personnel and may wish to post the entry permit in a designated location.

  OSHA requires that employers provide training for all employees who must work in permit-required confined spaces.  The training should occur before the initial work assignment, when job duties change, employee performance deficiencies occur, or when the permit-required confined space program changes or operations change.  Although it is not required to train all employees to the extent of the authorized entrants training, it is a best practice to inform all employees of the confined spaces present in the workplace and the hazards that accompany the confined spaces.  

  If entry is required in a permit-required confined space, the employer must provide an authorized entrant (the person who enters the space and conducts maintenance or cleaning operations), an attendant (a person who remains outside of the confined space), and an entry supervisor (the person who oversees the entry operations and ensures the entrants follow the permit and are safe).  These personnel have specific duties that must occur to ensure safe entry into permit spaces.  Their duties must be followed in order to comply with the OSHA Permit-Required Confined Spaces standard.

  When the entry into the permit space is complete, the entry supervisor terminates the confined space entry.  The entry supervisor can also cancel the entry of the confined space if the conditions within the space are no longer safe for the entrant.  As a best practice, when the entry is complete, a debrief should be conducted with the entry personnel to determine if any changes are needed for future entry procedures.  Employers are required to keep canceled entry permits for one year.  Any deviations or problems with the entry should be noted on the canceled permits.

  Even with a permit-required confined space program in place, emergencies can happen.  It is important that local emergency responders are aware of the specific hazards associated with confined spaces in the workplace.  Invite local emergency agencies to the workplace and evaluate their knowledge of confined space rescue, their rescue equipment, and their capabilities. 

  Having a permit-required confined space program in place will help vineyards and wineries avoid catastrophic incidents and costly OSHA citations.  To learn more about Permit-Required Confined Spaces, go to osha.gov or ansi.org.

  Steven R. Sawyer, ARM, MS, CSP, is the owner/operator of LSW & Associates Safety Consulting Services, LLC.  Sawyer has been active in the safety industry since 1999, much of that time working with multi-faceted, high-hazard agribusinesses, developing a special expertise in grain bin engulfment and prevention; OSHA grain handling standards; lockout/tagout (LOTO); machine guarding; confined spaces; heavy equipment and specialized equipment operations; and safety program development and training.

Website:  sawyersafetysolutions.com

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