Confined Space Entry Requirements You Need to Know for Safe Operations

Key Takeaways

• A confined space entry permit documents hazards, safety measures, and roles, ensuring safe operations in high-risk spaces.

• A confined space permit identifies hazardous spaces, while an entry permit is specific to a single operation with detailed safety steps.

• The entry supervisor reviews safety measures, verifies readiness, and signs the permit to authorize entrants to enter the particular confined space.

• An alternate entry confined space allows safe entry without a full permit if hazards are controlled or eliminated, with continuous monitoring required.

Understanding Confined Space Entry

Any area large enough for a worker to enter, with limited or restricted means of entry or exit, and not meant for continuous employee occupancy is considered a confined space. Think tanks, storage bins with inwardly converging walls, ducts, or sewers. These spaces can quickly turn dangerous; hazardous atmospheres like toxic gases, lack of oxygen, or the risk of engulfment make them serious business.

This is why confined space entry is so heavily regulated. The Occupational Safety and Health Administration (OSHA) Confined Space Standard 1910.146 has detailed requirements to minimize risks, and it’s essential to understand what’s expected before anyone enters these spaces. 

In the following sections, I’ll discuss these requirements in detail to help guide you through the key elements of confined space entry safety.

1. Confined Space Entry Permit

A confined space permit is a general document used to identify any confined space that requires specific safety measures but does not include detailed instructions for a particular entry. In contrast, a confined space entry permit is a highly specific and detailed document required for each individual entry operation. It serves as both a checklist and a record, outlining identified hazards, required safety equipment, the names of authorized entrants, supervisors, and attendants, as well as the duration of the entry. In short, it provides all the critical information needed for a single, safe entry into a confined space.

Now, not all confined spaces need a permit. Non-IDLH (Immediately Dangerous to Life or Health) spaces may not require one, but any permit-required confined space does. Understanding whether a space is considered IDLH or non-IDLH significantly impacts the permitting process:

• • IDLH Spaces: These environments pose immediate threats, like toxic atmospheres, low oxygen levels, or explosive gases. A confined entry permit space is mandatory for IDLH spaces.

  • Non-IDLH Spaces: While still confined spaces, non-IDLH environments do not present immediate life-threatening hazards. Though these spaces may not require as intensive a confined space entry permit, they still demand safety measures like restricted access and monitoring.

For spaces requiring a confined space entry permit, the document must cover:

1. Hazard Identification: Clearly outlines what dangers exist within the confined space, such as toxic fumes, electrical hazards, or mechanical risks.

2. Safety Measures: Details the controls in place, like ventilation, lockout/tagout procedures, and personal protective equipment (PPE).

3. Authorized Personnel: Lists the names of entrants, attendants, and the entry supervisor, ensuring only trained individuals participate.

4. Duration of Entry: Specifies how long the confined permit space is valid, ensuring time limits are adhered to for safety.

5. Emergency Procedures: Includes contact information for rescue services, retrieval methods, and first aid measures.

6. Ventilation Plan: if required, determines the placement and air change requirements for the space depending on the work. For example, welding requires 2000cfm for each welder.

Who Is Required to Provide an Entry Permit for a Permit Required Confined Space?

According to OSHA 1910.146(c)(1), the employer is responsible for providing a confined space entry permit for a confined space. Employers must first identify and evaluate spaces to determine if they qualify as permit-required confined spaces. Once these spaces are identified, the employer is required to develop a written permit space program and issue the permit document to allow and control entry into the confined space. 

However, before issuing the permit, the confined space supervisor must verify that all required safety measures are in place. Once confirmed, the supervisor must sign the permit to officially authorize the operation. This process helps prevent unauthorized or unsafe entry into hazardous spaces and maintains accountability throughout the operation.

Who Must Sign a Confined Space Entry Permit?

Before any work begins, a confined space entry permit requires the following signatures:

• • The Entry Supervisor: The entry supervisor is responsible for reviewing the permit, ensuring all safety measures are in place, and verifying that the confined space is safe for entry. They sign the permit to authorize the operation. This signature signifies that they were able to eliminate or control permit space hazards.

  • Authorized Entrants and Attendants: In many cases, entrants and attendants also sign the permit. By doing so, they acknowledge their roles and confirm that they understand the hazards, the safety measures, and the procedures outlined in the permit.

These signatures not only confirm compliance with safety regulations but also create accountability for all employees involved in the operation. Without these approvals, the entry cannot proceed.

2. Confined Space Entry Training

Confined space entry training is an essential part of preparing employees to safely perform tasks in a confined space. A comprehensive confined space entry training program typically includes the following:

1. Hazard Recognition: Workers are trained to identify potential confined space hazards such as toxic gases, low oxygen levels, or physical hazards like structural instability. They learn how to differentiate between permit-required and non-permit confined spaces.

2. Equipment Use: Training covers the proper use of confined space entry equipment.

3. Confined Space Entry Procedure: Employees are taught how to follow the step-by-step entry process, including pre-entry preparation, conducting initial and periodic tests, permit documentation, and communication protocols during entry.

4. Emergency and Rescue Procedures: Training includes instruction on how to respond to emergencies, use retrieval systems, and communicate with rescue and emergency services. Since confined space rescues are high-risk, workers must know how to act quickly and effectively during emergencies.

5. Regulatory Requirements: Employees are familiarized with OSHA standards and guidelines specific to confined space entry. This includes understanding the confined space requirements for permits, atmospheric testing, and ongoing monitoring.

After completing confined space entry training, workers often receive a confined space certification to validate their competency. Certification is not a one-time process; periodic refresher confined space training is necessary to stay current with regulations, update skills, and address any changes in workplace conditions or equipment. For example, if new hazards are identified in a confined space or updated equipment is introduced, retraining is required to keep workers prepared.

3. Confined Space Entry Supervisor

Any confined space classified as "permit-required" must have an entry supervisor assigned to oversee the operation. The confined space entry supervisor ensures that all aspects of a confined space operation are conducted safely and in compliance with regulations. Their responsibilities extend beyond simply authorizing and signing entry through the permit process—they cover everything from pre-entry preparations to monitoring ongoing operations.

I recently came across an OSHA interpretation letter that provided clarity on several aspects of confined space entry operations, particularly concerning the roles of entry supervisors and their potential overlap with other positions. Here's a summary of the insights I gathered:

Can an Entry Supervisor Also Serve as an Entrant?

According to OSHA, yes, an entry supervisor can indeed take on the role of an authorized entrant or an attendant, provided they are adequately trained and equipped for each role they assume. However, it's essential that performing multiple roles does not compromise the individual's ability to fulfill their primary responsibilities. 

For instance, if an entry supervisor is also acting as an attendant, they must remain focused on monitoring and protecting the entrants without any distractions. This means that while dual roles are permissible, they should not interfere with the safety and effectiveness of the confined space operation.

Can the Duties of the Entry Supervisor Be Passed From One Individual to Another During Permit Entry Operations?

OSHA acknowledges that there are situations where the responsibilities of an entry supervisor may need to be handed over to another qualified individual during an ongoing operation. This is acceptable as long as the transition is seamless, ensuring continuous oversight of the entry process. The incoming supervisor must be adequately trained and fully aware of the current conditions within the confined space. 

Such transfers are often necessary in operations that extend beyond a single work shift or when unforeseen circumstances arise. The primary concern is to maintain uninterrupted supervision to uphold safety standards throughout the operation.

4. Confined Space Entry Equipment

When preparing for a confined space entry, it’s critical to have a comprehensive set of tools and devices as seen above to address both the anticipated and unforeseen permit space hazards. Proper equipment helps monitor the environment, protect workers, and provide a means for safe entry and exit. Below is a detailed look at the essential equipment needed for permit space operations, but not limited to:

• • Air Monitoring Equipment: Confined spaces often pose hazardous atmospheres that are invisible and odorless. Air monitors are used to continuously test for air contaminants and oxygen levels.

  • Communication Equipment: Radios, intercom systems, or hand signals (when communication devices fail) are used to keep everyone connected, especially in emergencies.

  • Barriers and Shields: Barriers like confined space guardrails prevent unauthorized access to manholes, pits, or shafts that present fall hazards. A confined space cover including Danger signs can also lock out various openings such as manways, crawl spaces, or vessels.

  • Ingress and Egress Equipment: Depending on the confined space, this might include ladders, tripods with winches for vertical spaces, and rescue and emergency equipment to assist with emergency evacuation.

  • PPE: These are PPE tailored to the specific hazards of the confined space, such as respirators or supplied air systems for toxic atmospheres, gloves and coveralls, hard hats, and steel-toe boots.

  • Lighting Equipment: Portable lighting is necessary for visibility. Explosion-proof or intrinsically safe lighting is recommended to prevent ignition in flammable atmospheres.

  • First Aid Kit: Allows immediate treatment of minor injuries or stabilization of more serious physical harm until professional medical help arrives.

5. Confined Space Rescue and Emergency Response Plans

OSHA regulations require that employers develop a site-specific rescue plan to address potential confined space hazards and outline how an emergency should be handled. Confined space rescues are categorized into three types, depending on the nature of the emergency and the feasibility of extracting the worker safely:

6. Confined Space Ventilation

Confined spaces, by nature, often have poor natural ventilation, allowing toxic gases, low oxygen levels, and flammable vapors to accumulate. Ventilation and purging are often the first steps after isolating the space. It ensures hazardous gases are removed and oxygen levels are safe before entry.

OSHA limits for air contaminants and oxygen levels:

To ventilate or purge a confined space, use forced-air ventilation by positioning a blower or fan to introduce fresh air and displace hazardous gases, ensuring airflow reaches all areas, especially low-lying pockets where heavier gases may accumulate. For spaces with toxic or flammable vapors, use exhaust ventilation in combination with a fresh air supply to effectively remove contaminants.

Always monitor atmospheric conditions before, during, and after ventilation to confirm that oxygen levels, toxic gas concentrations, and flammable vapors are within OSHA’s safe limits before entry. Furthermore, ensure ventilation equipment is grounded to an approved grounding point to prevent buildup of static electricity which can produce a spark.

What Is the Confined Space Entry Procedure?

Confined space entry follows a structured process to minimize risks and ensure worker safety. Below is a detailed breakdown of each step:

1. Identify and Assess the Confined Space: Conduct a hazard assessment to determine if the space qualifies as a permit-required confined space by identifying risks such as toxic gases, oxygen deficiency, or engulfment hazards.

2. Pre-Entry Planning: Develop a written confined space entry plan and pre-entry checklist, assign roles (entrant, attendant, and entry supervisor), and confirm that all required permits, equipment, and rescue procedures are in place.

3. Isolate Utilities: Shut down and lockout/tagout (LOTO) any mechanical, electrical, hydraulic, or chemical energy sources that could create health hazards during entry.

4. Ventilation and Purging: Use forced-air ventilation or exhaust systems to remove toxic gases, reduce flammable vapor concentrations, and stabilize oxygen levels before and during entry.

5. Atmospheric Monitoring: Test air quality using multi-gas detectors to confirm that oxygen levels remain between 19.5% and 23.5%, flammable gases stay below 10% of the LEL, and toxic gases are within OSHA’s permissible limits.

6. Confined Space Entry Permit: Complete and sign the confined entry permit space, documenting hazards, safety measures, authorized personnel, emergency procedures, and the duration of entry before work begins.

What Is an Alternate Entry Confined Space?

An alternate entry confined space is a type of confined space that allows for entry without following the full permit-required confined space procedures, provided certain conditions are met. These spaces are typically lower-risk environments where hazards can be effectively controlled or eliminated. OSHA specifies that the following conditions must be met for alternate entry:

• • All hazards in the space are eliminated or controlled before entry.

  • Continuous ventilation is used to maintain safe conditions.

  • Hazardous atmosphere monitoring confirms that the space remains safe throughout the work.

  • Workers must exit immediately if atmospheric conditions change or new hazards are introduced.

I remember one of my colleagues once worked on an underground utility vault that had been classified as an alternate entry confined space because it was well-ventilated with natural airflow. Before entry, they conducted atmospheric testing, which showed no flammable gases or toxic substances, and since there was no risk of engulfment or entrapment, a full permit wasn't required. Throughout the job, they used continuous monitoring to confirm that conditions remained safe, allowing them to perform assigned work efficiently without additional confined space restrictions.

Confined Space Entry FAQs

What is the most important part of a confined space entry?

The most important part of a confined space entry is conducting a thorough hazard assessment and implementing safety controls, such as ventilation and atmospheric monitoring, to ensure the space is safe for workers. Without this step, workers are at significant risk of exposure to toxic atmospheres, low oxygen levels, or other hazards.

How many people are required to evaluate the  confined space entry?

At least three trained individuals are typically required for confined space entry: an entrant, an attendant stationed outside the space, and an entry supervisor to oversee the operation and safety procedures.

Which member of the confined space entry team is responsible for overseeing entry operations?

The entry supervisor is responsible for overseeing confined space entry operations, verifying safety measures, signing the entry permit, and ensuring compliance with all procedures.

What is the first step before entering a confined space?

The first step before entering a confined space is to identify and assess the hazards, which includes classifying the space, conducting atmospheric testing, and determining if it is a permit-required confined space.

What PPE is required for confined space?

The PPE required for confined space depends on the hazards present but often includes respirators, gloves, protective clothing, hard hats, steel-toe boots, and in some cases, harnesses for retrieval.

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