Questions About Confined Space Compliance? Find Answers Here

Today and tomorrow, we offer a brief selection of questions about OSHA’s confined space requirements (29 CFR 1910. 146). These are questions that safety managers from around the country have asked BLR^® over the past couple of years. You’ll find a lot more information about confined spaces, including regulatory analysis, 24/7, on Safety.BLR. com^®.

How can we determine if a space is considered a confined space under OSHA’s confined space standard?

To make a determination based on your specific conditions, see OSHA’s Permit-Required Confined Space Decision Flow Chart (29 CFR 1910.146, Appendix A).

Can I identify a confined space with a specific symbol if it is referenced in my plan? We are having trouble labeling our manhole covers with all of the wording and it still being legible.

You may modify the warning sign wording as long as it still conveys the basic information to all affected employees. You can use whatever language you want—even omit the warning signs—as long as you educate all affected employees through a training program about the existence, location, and dangers of the confined spaces.

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Following is the language of the confined space sign rule (29 CFR 1910.146(c)(2)):

If the workplace contains permit spaces, the employer shall inform exposed employees, by posting danger signs or by any other equally effective means, of the existence and location of and the danger posed by the permit spaces.

Note: A sign reading DANGER—PERMIT-REQUIRED CONFINED SPACE, DO NOT ENTER or using other similar language would satisfy the requirement for a sign.

What is the definition of a “hazardous atmosphere”?

OSHA defines a hazardous atmosphere in its confined space standard 1910.146(b) as follows:

“Hazardous atmosphere” means an atmosphere that may expose employees to the risk of death, incapacitation, impairment of ability to self-rescue (that is, escape unaided from a permit space), injury, or acute illness from one or more of the following causes:

(1) Flammable gas, vapor, or mist in excess of 10 percent of its lower flammable limit (LFL).
(2) Airborne combustible dust at a concentration that meets or exceeds its LFL.
Note: This concentration may be approximated as a condition in which the dust obscures vision at a distance of 5 feet (1.52 m) or less.
(3) Atmospheric oxygen concentration below 19.5 percent or above 23.5 percent.

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(4) Atmospheric concentration of any substance for which a dose or a permissible exposure limit is published in Subpart G, Occupational Health and Environmental Control, or in Subpart Z, Toxic and Hazardous Substances, of this Part and which could result in employee exposure in excess of its dose or permissible exposure limit.
Note: An atmospheric concentration of any substance that is not capable of causing death, incapacitation, impairment of ability to self-rescue, injury, or acute illness due to its health effects is not covered by this provision.
(5) Any other atmospheric condition that is immediately dangerous to life or health.
Note: For air contaminants for which OSHA has not determined a dose or permissible exposure limit, other sources of information, such as material safety data sheets that comply with the Hazard Communication Standard, Section 1910.1200 of this Part, published information, and internal documents, can provide guidance in establishing acceptable atmospheric conditions.

Tomorrow, we continue with more questions from your colleagues and more answers from the safety experts at Safety.BLR.com.