Confined Spaces: You Have Questions, We Have Answers

Here are some questions and answers about OSHA’s confined space safety requirements, courtesy of our sister website Safety.BLR.com.

We have several confined spaces at our plant, but only two of them would be considered permit-required. For our other confined spaces, which aren’t permit-required, what requirements do we have? Is training still required? These spaces are entered very infrequently (once a year or less).

OSHA does not specifically regulate non-permit confined spaces, but there are related requirements for ensuring that employees are protected from other hazards in the work area. For example:

• Employees must acquire the understanding, knowledge, and skills necessary for the safe performance of duties when entering a confined space—the rule does not distinguish between a permit space and non-permit space.
• Non-permit confined spaces must be evaluated when changes occur in their use or configuration and, where appropriate, must be reclassified as permit spaces.

Also, since you have permit-required spaces, you should list your non-permit spaces in your written confined space plan, and post signs to ensure employees and contractors know the difference between the permit spaces and non-permit spaces.

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Does breaking the plane of entry on a manhole mean leaning over to look down the manhole or actually putting any part of your body below the plane of the manhole cover?

“Entry” means the action by which a person passes through an opening into a permit-required confined space. Entry includes ensuing work activities in that space and is considered to have occurred as soon as any part of the entrant’s body breaks the plane of an opening into the space. In order “break the plane,” the person’s face or other body part would have to be below the plane of the manhole.

We have a pit in the ground, and only one way in. There are no hazards in the space other than potential atmospheric hazards. However, to get into the pit we have to open a door that leaves a floor opening that someone could fall into (about 8′). So you could use forced air ventilation as the alternative procedure, but since you create the fall hazard for other people walking around the pit, would that mean you need to reclassify it instead?

You can classify the pit as a non-permit space if it has been determined that the forced air ventilation alone is sufficient to maintain safe entry.

If you still have a recognized serious safety or health hazard, however, such as a fall hazard, then it must be classified as permit-required.

The federal confined space rule says a space (including a pit) must be classified as a permit-required space if it:

• Contains or has a potential to contain a hazardous atmosphere; and
• Contains any other recognized serious safety or health hazard.

Does OSHA give any direction on a minimum safe size for a manhole or vault space?

OSHA does not give any direction on a minimum safe size for a manhole or vault space other than “Is large enough and so configured that an employee can bodily enter and perform assigned work.”

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We have a space—actually a tank that is 15’x15’x4′ beneath a parts washing operation—that must be entered for cleaning with a water hose and vacuum hose. Is it possible to reclassify this space as non-permit required once the tank is drained and all associated operations (fill inlet and any other associated operation) are locked out? If so, do we have to perform atmospheric testing prior to reclassification?

Carefully evaluate the following regulatory conditions for classifying a space as non-permit required. A confined space classified as a permit space may be reclassified as a non-permit space if:

• The permit space poses no actual or potential atmospheric hazards and if all hazards are eliminated without entering the space.
• Testing and inspection demonstrate that the hazards have been eliminated.
• It has been documented that the basis for determining that all hazards have been eliminated is through a certification that contains the date, location of the space, and the signature of the person making the determination.
• It is necessary to enter the permit space to eliminate hazards, such entry must be performed under the requirements of the permit space program.

When hazards arise within a permit-required space that has been declassified to a non-permit space, anyone in the space must exit; under such conditions, the employer must reevaluate the space and determine if it will be reclassified as a permit space.

When there are changes in the use or configuration of a non-permit confined space that might increase the hazards to entrants, the employer must reevaluate that space and, if necessary, reclassify it as a permit space.

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