by Darryl Castillo
Environmental Health & Safety Specialist

The Occupational Health and Safety Administration (OSHA) has implemented stringent regulations when identifying confined spaces in the workplace.  Such standards are due to the number of fatalities associated with occupying these spaces.  According to the U.S. Bureau of Labor Statistics, “From 2011 to 2018, 1,030 workers died from occupational injuries involving a confined space.” The annual figures ranged from a low of 88 deaths in 2012 to a high of 166 in 2017. The Bureau’s Census of Fatal Occupational Injuries (CFOI) cites ”sixty percent of those fatalities were untrained people trying to rescue someone from a confined space and becoming victims themselves.”

Almost every manufacturing facility in America includes some type of confined space.  If the two OSHA standards (29 CFR 1910.146 for general industries and 29 CFR 1926.1201 for the construction industry) regarding these dangerous spaces were more consistently followed, there is little doubt that countless lives would be saved.

What qualifies as a confined space?

Three conditions that have to be met for an area to be classified as a confined space:

·  Is the space large enough and so configured that an employee can bodily enter the space and perform assigned work?

·  Does the space have 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)?

·  Is the space not intended for continuous employee occupancy?

What qualifies as a permit required confined space (PRCS)?
Next, you must determine if a space qualifies as a “permitted confine space.”  If the space contains or has the potential to contain a hazardous atmosphere or converging inward walls or floors, or if the space has material that can engulf the entrant, such a space needs to be a permitted confined space.  Basically, any potential hazard in addition to the the three qualifying confined space conditions makes a confined space require a permit.  Even the presence of hazardous energy is sufficient to require a permit to ensure that lockout/tagout is appropriately performed prior to entering a confined space.

OSHA states that if an employer permits its employee to enter a permit space, that employer shall implement a written program for those spaces.

First, the employer shall have a process to identify and evaluate hazards in the confined space before allowing an employee to enter. Next, there must be measures to prevent unauthorized entry into a confined space. The confined space must have its atmosphere measured for hazardous conditions before employees enter into the space and during the occupancy.  Finally, there must be a trained entry attendant at the access of the confined space for the duration of the occupancy. This is in order to prevent unauthorized entry. The entry attendant must be alert at all times and ready to call emergency services should the occupant(s) require rescue. Additional requirements that must be included in a confined space written program can be found on the OSHA website.

OSHA also requires employers to train all employees that will enter a confined space.  Entrants and attendants should be able to recognize hazards as well as the warning signs of hazard exposure. A competent person must identify all mechanical, atmospheric, temperature, electrical and any other potential hazards that may exist in the confined space and have those hazards controlled before anyone enters the space.  All identified hazards must be included on a confined space permit and communicated to each member of the entry team.

Confined spaces require serious safety considerations at every facility with areas that qualify.  EI is proud to offer confined space specialists that can provide confined assessments as well as assist with space identification, training, permitting and reclassification procedures.   

If you have questions regarding confined spaces or wish to discuss what EI safety professionals can do to address specific concerns at your facility, please contact us at (800) 717-3472 or [email protected].