Confined space work is certainly not a new part of construction and general industry life - yet the finer details of said work is often filled with conjecture, myth and misunderstanding. Let’s clear some of that up by understanding our options when dealing with confined spaces.
OSHA defines two classes of confined spaces: Permit required and Non-permit required. Understanding which category your confined space fits into is quite simple. OSHA lists three criteria for designating an area a confined space:
- The area is not intended for continuous employee occupancy
- The area has limited means of entry or egress
- The area is large enough for an employee to enter to perform work
It is important to note that “entry” is defined as any part of the body breaking the plane of a confined space entryway. For example, handing someone inside a confined space a tool by reaching into a hatch is considered an entry while inserting an air sampling device that is attached to a stick or a rope is not.
To better conceptualize confined spaces think of an empty, in-ground, swimming pool with a 12 foot deep end. It certainly meets the criteria of a confined space, but does it require a Confined Space Permit?
A Permit Required Confined Space is a confined space that, in addition to the three requirements above, meets any ONE of the following conditions:
- The area contains or has the potential to contain a hazardous atmosphere (CO, H2S, smoke…)
- The area contains a material that has the potential for engulfment (sand, grain…)
- The area is configured in a way that could cause an employee to become trapped or asphyxiated
- The area contains or has the potential to contain any other serious safety hazard
The requirements for working inside a Permit Required Confined Space are laid out in 29 CFR 1910.146 for general industry and 29 CFR 1926 Subpart AA for construction. Consider the swimming pool example. As described, the empty pool meets the criteria for a Non-Permit Required Confined Space but it does not meet the threshold to be considered a Permit Required Confined Space. While OSHA spells out four conditions that would elevate a confined space to require a permit, the important one to remember is the last: “Does this space contain or does it have the potential to contain any other serious safety hazard?” If we added “any other serious safety hazard” to the empty swimming pool by, for example, introducing a rabid raccoon, we would have a Permit Required Confined Space. Inversely by removing all serious safety hazards inside a Permit Required Confined Space, the area can be downgraded to a Non-Permit Required Confined Space.
If you are working in confined spaces and have questions on compliance, training, rescue, air quality monitoring or planning, you can reach out to the Marsh & McLennan Agency Loss Control Team for customized support to help your operation run smoothly.