Permit-Required Confined Spaces – Do You Know What They Are?
Confined spaces in the workplace are common, and they may even be more common than you think. For example, sewers, storage bins and tanks can all be confined spaces, but in many cases so are silos and open pits. Some confined spaces may not pose great harm, but others can be very dangerous to anyone entering them.
One example of a tragic accident involving a confined space occurred at Precision Industrial Maintenance Inc. of Albany, New York, in 2009. An employee working inside a tanker truck was overcome by vapors and could not be revived.
OSHA’s investigation of the incident found that the company had failed to test conditions in the space before entry, did not complete the required permit, did not provide confined space training to employees, did not post warning signs and did not evaluate rescue services for this type of incident, according to a press release from OSHA.
So we know a number of things went wrong in this example, but what could the employer have done to prevent this accident? We’ll take a look at the OSHA standard for confined spaces and then consider employer and employee best practices for handling confined space hazards.
People easily get confused about confined spaces and which of those spaces require permits for entering and performing work. According to OSHA, a confined space has three components: 1) it is large enough for employees to bodily enter it and perform work, 2) it has limited or restricted means for entry and exit, and 3) it is not designed for continuous occupancy.
Many spaces fall under that definition, but things get complicated when those spaces also include hazards. For example, a sewer entry is a confined space where toxic gases could be present and the air could become oxygen deficient, so that confined space becomes a permit-required confined space (PRCS).
Basically, OSHA’s three criteria for a confined space plus a hazard equals a PRCS. OSHA lists a number of hazards that could make a confined space a PRCS:
- May contain a hazardous or potentially hazardous atmosphere
- May contain a material which can engulf an entrant
- May contain walls that converge inward or floors that slope downward and taper into a smaller area which could trap or asphyxiate an entrant
- May contain other serious physical hazards such as unguarded machines or exposed live wires
Once a person enters a confined space, it may be difficult to exit quickly in an emergency, so it’s important that any hazards are properly mitigated before work begins.
What Employers Should Do
First, you need to know what locations in your workplace are considered PRCSs. Walk around and do an assessment. Be sure not to overlook small spaces; if a small employee could fit inside, a space needs to be noted.
Next, you must make sure your employees will be aware of these PRCSs. Provide training in what is and isn’t considered a PRCS and give examples of these spaces in your facility. If employees will be asked to enter these spaces to perform work, they need to be trained in the appropriate procedures. Other employees should be trained to at least recognize these spaces.
In addition to training, businesses are advised to label these spaces so workers are alerted to the dangers present. Signs and labels that say “Danger” and note that a permit is required for entry in the space should be placed outside all PRCSs. Make sure to use “danger” as the signal word so employees are aware of the severity of the hazard(s) present.
When work does need to be performed in a dangerous confined space, you’ll need to use a permit. The word permit sounds official, like something you might need to obtain from a government body, but permits for confined spaces are actually issued by your company. These permits are written or printed documents that allow and control entry into the space. The permit must include 14 specific pieces of information including the date, personnel involved and hazards present. The list of requirements can be found in OSHA standard 29 CFR 1910.146(f).
Employers are also responsible for providing gear such as gas monitors and relevant personal protective equipment (PPE). Depending on the situation, this PPE could include personal fall arrest systems, respirators, gloves, boots and other protective clothing.
Finally, workplaces should also make sure to consider rescue procedures for confined spaces. Rescuing someone from a confined space during an emergency can be challenging. You’ll either need to have an in-house team trained for such situations or consult with your local fire department about this type of response.
Like many safety programs in the workplace, if you have confined space hazards, you’ll need a written PRCS plan that details your procedures for issuing permits and working around these hazards, so make sure your company has appropriate documentation.
What Workers Should Do
In general, employees need to make sure they follow the guidelines developed by their employers for entering and working in permit-required confined spaces. They should keep the following best practices in mind:
- Make sure you have received training
- Make sure you have the required permit
- Identify the physical hazards that could cause problems (like structural barriers, materials that could fall and trap you, etc.)
- Test and monitor the atmosphere (low oxygen levels are common in PRCSs; hazardous gases such as carbon monoxide can also accumulate)
- Wear PPE (if applicable)
- Make sure the area is ventilated
- Use communication equipment to stay in contact with an attendant outside the space
In too many cases, what seems like routine work takes a dangerous turn in a confined space. Many of the hazards present in these spaces can incapacitate a person quickly, so make sure you have plans in place to avoid accidents and to respond to them when they occur.
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