Good Communication is Critical to Confined Space Safety
By: Bob Henderson, Contributor
Confined space entry is a team effort, and good communication is central to confined space safety. Since 1993, OSHA 1910.146, “Permit-Required Confined Spaces,” has made this clear. Entry supervisors, attendants, entrants, rescue team members, employers, contractors and management all need to understand their duties and follow the rules.
What is the OSHA standard that explains “Permit-Required Confined Spaces” for general industry?
OSHA 29 CFR 1910.146, “Permit-Required Confined Spaces,” contains the requirements for practices and procedures to protect employees in general industry from the hazards of entry into permit-required confined spaces. OSHA 1910.146 is a horizontal standard that applies to a wide variety of industries and employer activities. While certain industries have their own “vertical” standards, it is 1910.146 which governs the most confined space activities and provides the most comprehensive requirements for how to structure confined space programs. If an employee is working in an industry where a vertical or industry-specific standard applies, then the entry is subject to the vertical standard. If a vertical standard not applicable, the general industry standard prevails.
What is OSHA 29 CFR 1926 Subpart AA, “Confined Spaces in Construction?”
OSHA enacted 29 CFR 1910.146, “Permit-Required Confined Spaces,” in 1993. The provisions did not apply to activities that were already regulated by 29 CFR 1926, “Safety and Health Regulations for Construction.” According to OSHA, the original intent was to extend 1910.146 to include construction. However, it was quickly recognized that 1910.146 did not fully address issues unique to the construction industry, such as higher employee turnover rates; worksites that change frequently; and the multi-employer business model that is common in construction. In August 2015, 29 CFR 1926 Subpart AA, “Confined Spaces in Construction,” went into effect. The new standard specifies the practices and procedures to protect employees from confined space hazards during construction activities.
The “Confined Spaces in Construction” rule is similar in content and organization to the general industry confined spaces standard but incorporates additional provisions that address construction-specific hazards. The construction rule puts even greater emphasis on communication.
What is a Confined Space?
Under both rules, a confined space is characterized by the simultaneous existence of three conditions:
- It must be large enough and so configured that it is possible for a person to bodily enter and perform work.
- It has limited or restricted means for entry and exit.
- It is not designed for continuous employee occupancy.
Just because a space meets the basic confined space definition, however, doesn’t automatically trigger any special workplace procedures beyond those for similar activities undertaken in any other non-confined space environments. By definition, non-permit confined spaces are not associated with additional serious safety hazards.
What is a Permit-Required Confined Space (PRCS)?
A permit-required confined space (or permit space) is a confined space that contains hazards capable of causing death or serious physical harm. Besides the basic three conditions common to all confined spaces, a permit-required confined space (PRCS) contains at least one additional serious or recognized danger such as:
- The potential to contain or generate a hazardous atmosphere
- The space contains a material that has the potential for engulfing an entrant
- An internal configuration such that an entrant could be trapped or asphyxiated by inwardly converging walls or by a floor which slopes downward and tapers to a smaller cross-section
- Any other recognized serious safety or health hazard
It is important to remain vigilant for conditions or activities that may change the dangers associated with a confined space. Activities such as hot-work, using degreasers or painting may introduce additional potential hazards that change the classification of the space from a non-permit to a permit-required confined space (PRCS).
What are the Procedural Options for Permit Confined Spaces?
Once the space has been classified as a PRCS, the next question is what to do about it. When entry into the permit space can’t be avoided, employers have three options. The numbering of the sections is different, but the options and requirements are the same in 1910.146 and 1926 AA.
If the hazards can be completely eliminated without having to enter the space, it may be possible to temporarily reclassify the PRCS as a non-permit space. Non-permit spaces are confined spaces but do not require a permit for entry, because the hazards have been eliminated. The reclassification continues only as long as the hazards remain eliminated.
2. Alternate Entry Procedures
When the only hazards are exclusively atmospheric in nature, and continuous forced air ventilation alone is sufficient to maintain the permit space safe for entry, entry may be by means of “Alternate Entry Procedures.”
The alternate entry procedures require that, before employees enter, the internal atmosphere must be tested for:
- Oxygen content,
- Flammable gases and vapors, and
- Potential toxic air contaminants.
Once testing has been completed, the atmosphere within the space must be periodically tested or continuously monitored, to ensure that the atmosphere remains safe for the entrants. If a hazardous atmosphere is detected during entry, employees must exit immediately; the space must be re-evaluated; and corrective measures must be taken.
When entries are undertaken by means of the Alternate Entry Procedures, there are no formal requirements for the presence of an attendant, entry supervisor or standby rescue team. Solo entries are permitted. The emphasis is squarely on use of continuous ventilation and atmospheric monitoring to ensure that atmospheric hazards are controlled—and that the atmosphere remains safe for entry.
3. Permit-Required Confined Space Entry Procedures
If the hazard cannot be eliminated or controlled, the only remaining option for entry is the implementation of a comprehensive permit space program. The written program includes specific details regarding how the employer will comply with each of the requirements. Employer obligations include (but are not limited to):
- To secure permit spaces to prevent unauthorized entry
- To evaluate and identify PRCS hazards before entry
- To implement operation procedures that ensure safe entry
- To provide and maintain the necessary equipment
- To provide attendant(s)
- To designate the roles and responsibilities of all active PRCS entry team personnel
- To develop and implement effective rescue and emergency procedures
- To develop and implement an entry permit system
- To develop and implement procedures to coordinate entry operations when employees of more than one employer will enter a PRCS
- To develop and implement procedures for concluding an entry
- To periodically review entry operations
- To periodically review the permit space system
Construction Confined Space Employer Responsibilities
Employers engaged in construction work must (1) identify any confined spaces in which their workers will be working; and (2) determine whether any such spaces are permit spaces.
When workers work in permit spaces, they must be protected against the hazards in those spaces. The construction standard imposes specific duties on “entry employers,” “host employers” and “controlling contractors.” Employers must inform workers of the location and dangers posed by all known confined spaces at the worksite. Confined spaces should be posted and secured against entry by unauthorized persons. Where an employer’s workers have no work to do in the space, the employer must ensure that its workers stay out.
1. Entry Employer
An entry employer is an employer who decides that an employee it directs will enter a permit space. There may be more than one entry employer if the employees of multiple employers must enter the space. Each entry employer is responsible for complying with all provisions in the standard—except those specifically imposed on the controlling contractor and host employer.
2. Controlling Contractor
A controlling contractor is the employer with overall responsibility for construction at the worksite. The controlling contractor is responsible for coordinating entry operations when there is more than one entry employer and when other activities on the site could foreseeably result in a hazard. Once again, the standard here is emphasizing communication! In addition, controlling contractors must provide any information they have about any permit space hazards and precautions previously used in the space.
3. Host Employer
A host employer is the employer that owns or manages the property where the construction work is taking place. The host employer must share information about confined space hazards on the site with the controlling contractor, who is then responsible for sharing it with the other employers on the site.
Canceling Entry Permits
A special condition of construction site confined spaces is that the status, contractors and entry team members can change from one day to the next, as construction activities move from one phase to the next. It is critically important that workers understand who has responsibility for authorizing entry into the confined space. Responsibility for on-going permit space entry must be clearly designated.
The employer must make sure that the entry supervisor cancels entry permits when an assignment is completed or when new conditions exist. Once a permit is cancelled, entry under it is no longer permitted. New conditions must be noted on the canceled permit and used in revising the permit space program. The employer must keep all canceled entry permits for at least one year.
Suspending Entry Permits
An entry supervisor may suspend an entry permit, instead of cancelling it, if a temporary condition has occurred in or near the space that, once corrected, is not expected to reoccur. The permit may be reinstated, and entry may occur under the permit if the entry supervisor has determined that the conditions in the space match the allowable conditions listed on the permit.
Duties of the Entry Team Members
One of the most important goals of the confined space program is to clarify the responsibilities of the confined space entry team members. Employers must assign clear roles and duties to persons involved in PRCS entry and provide training to allow employees to carry out their duties, and how to communicate vital information.
Duties of the Authorized Entrant
Authorized entrants are employees who are authorized by the employer to enter a permit space. The authorized entrant must stay in communication with attendants as necessary to enable the attendants to monitor the entrant’s status and alert the entrant to evacuate when necessary. The authorized entrant must:
- Know the hazards associated with confined space entry, and in particular, the hazards associated with the PRCS being entered
- Know how to use all required equipment
- Know the procedures for communication with the attendant
- Know how to alert the attendant of hazardous or prohibited conditions
- Know how to exit the space if necessary, (that is, self-rescue)
Duties of the Attendant
At least one attendant must be present outside the PRCS during the entry. It is especially important for the attendant to keep an accurate account of workers entering or leaving the permit space and to maintain communication with the entrants. The attendant must:
- Know the hazards
- Identify if a prohibited condition exists in the space
- Identify if a condition outside the confined space could endanger entrants
- Know the behavioral effects of the hazards
- Be able to identify the authorized entrants
- Remain outside until relieved
- Communicate with entrants
- Monitor and evacuate entrants if necessary
- Summon rescue
- Warn away unauthorized persons
- Be able to perform non-entry rescues
The attendant may not undertake any additional duties that might interfere with these primary safety-related duties.
Duties of the Entry Supervisor
The entry supervisor is responsible for determining whether acceptable entry conditions exist; authorizing the entry; overseeing entry operations; terminating the entry; and canceling the entry permit. The entry supervisor represents the employer and is accountable for entry operation safety. If the entry supervisor is properly trained and equipped, he or she may also serve as an authorized entrant or attendant. Also, the role of entry supervisor can be passed from one individual to another during an entry operation. The entry supervisor must:
- Know the hazards
- Verify safe entry conditions
- Terminate entry and cancel permit
- Verify availability and effectiveness of rescue services
- Remove unauthorized persons
- Ensure that acceptable entry conditions are maintained
Duties of Persons Who Test or Monitor the Atmosphere
Although this important role is not specifically called out in the standard, OSHA has suggested guidelines for the responsibilities of this individual as well. They are responsible for:
- Correctly using the instruments used to monitor or verify that the atmosphere of the PRCS is safe for entry
- Verifying that the instrument(s) used are calibrated and maintained in accordance with manufacturer and written PRCS program procedures
- Verify that the instruments used to monitor the PRCS are functioning properly
- Taking appropriate measures if a hazardous or prohibited condition is detected
Duties of the Rescue Team
Communication becomes particularly urgent during an emergency. Communication requirements need to be planned and practiced well in advance of any emergency.
The safest outcome, if conditions begin to become hazardous, is for entrants to “self-rescue” and leave the space in a deliberate, but normal manner. Emergency procedures should focus on methods such as use of harness and retrieval systems that make it possible to perform a rescue without having to enter the space. Deliberate entry into the confined space to perform a rescue may be necessary, but it requires the most planning, training, equipment and personnel and is the least desirable and hardest to successfully execute response. It is also highly dependent on communication between all affected parties.
Employers are required to develop and implement procedures for summoning rescue or emergency services in permit-required confined spaces. An employer who relies on local emergency services for assistance is still required to have a plan for meeting the requirements for performing a successful rescue. The emergency responder must agree to it, as well as to be capable of responding in the event of an emergency. It is not adequate to simply dial 911 once an emergency has occurred!
Training and Communication Are Keys to Success
Confined space entry teams can only function effectively and safely when they fully understand their duties, responsibilities and communication requirements. Thorough training is essential. Permit spaces are inherently dangerous, and mistakes are “not permitted!”