Personnel Safety

Q&A: Non-Permit Confined Space Marking

: Recently, one of our subscribers asked the following question:

Do non-permit confined spaces have to be marked with signage or listed in the confined space plan?

This was our answer:

There is no specific OSHA requirement to mark non-permit confined spaces with signs; however, non-permit confined spaces must be identified and a preentry certification completed for each non-permit space as part of your comprehensive confined space program. OSHA requires employers to document the evaluations for classifying spaces as non-permit required. Listing them in your written plan is a good practice to keep track of the evaluations, and marking them will avoid any confusion among workers or contractors about the status of a confined space.

The determination of whether an area is a non-permit or permit-required confined space must be made through an onsite evaluation using the criteria in your written plan and according to OSHA procedures. Time spent in the space is not a factor in the space evaluation.

OSHA’s definition of a confined space is: “An employee can bodily enter and perform assigned work, has limited or restricted means for entry or exit (for example, tanks, vessels, silos, storage bins, hoppers, vaults, and pits are spaces that may have limited means of entry), and is not designed for continuous employee occupancy.”

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