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POLICY

[COMPANY NAME]’s policy is to ensure that employees are protected from the potential hazards involved with confined spaces (or permit spaces) at a construction site with one or more confined spaces. The company will comply with the OSHA permit-required confined space (PRCS) standard (29 CFR 1926.1200 – subpart AA).

For this program’s purposes, the following definitions apply:

Attendant – An individual stationed outside one or more confined/permit space(s) who assesses status of authorized entrants and must perform duties specified in 1926.1209 and outlined in this program.

Authorized entrant – An employee authorized by [Company Name] and the entry supervisor to enter a permit space.

Competent person – One capable of identifying existing and predictable hazards in surroundings or working conditions related to entering and working in confined spaces, which are unsanitary, hazardous, or dangerous to employees, and has authorization to take prompt corrective measures to eliminate them.

Confined space – A space that:

  • Is large enough and so configured that an employee can bodily enter it
  • Has limited or restricted means for entry and exit
  • Is not designed for continuous employee occupancy

Control – Action taken to reduce hazard level inside a confined space using engineering methods (ventilation, etc.) and using these methods to maintain the reduced hazard level. Control also refers to the engineering methods used for this purpose. Personal protective equipment (PPE) is not a control.

Controlling contractor – Employer with overall responsibility for construction at the worksite.

Early-warning system – Any method used to alert authorized entrants and attendants that an engulfment hazard may be developing. (ex: alarms activated by remote sensors, lookouts with equipment for immediately communicating with the authorized entrants and attendants, etc.)

Emergency – Any occurrence (including any power, hazard control, or monitoring equipment failure) or event, internal or external, to the permit space that could endanger entrants.

Engulfment – The surrounding and effective capture of a person by a liquid or finely divided (flowable) solid substance that can be aspirated to cause death by filling or plugging the respiratory system or that can exert enough force on the body to cause death by strangulation, constriction, crushing, or suffocation.

Entry – When any part of a person passes through an opening into a PRCS. Entry includes ensuing work activities in that space and is considered to have occurred as soon as any part of the entrant’s body breaks the plane of an opening into the space, whether or not such action is intentional or any work activities are actually performed in the space.

Entry employer – Any employer who decides that their employee will enter a permit space.

  • Note: An employer cannot avoid the duties of the standard merely by refusing to decide whether employees will enter a permit space and OSHA will consider the failure to decide to be an implicit decision to allow employees to enter those spaces if they are working in the proximity of the space.

Entry permit – Written or printed document provided by employer who designated space a permit space to allow and control entry. Contains information specified in 1926.1206.

Entry supervisor – Qualified person (employer, foreman, or crew chief) responsible for determining if acceptable entry conditions are present at a permit space where entry is planned, authorizing entry and overseeing entry operations, and terminating entry as required by this standard.

  • Note: An entry supervisor may also serve as an attendant or authorized entrant if that person is trained and equipped as required by this standard for each role they fill. Also, the duties of entry supervisor may be passed from one individual to another during an entry operation.

Hazard – A physical hazard or hazardous atmosphere.

Hazardous atmosphere – Atmosphere that may expose employees to risk of death, incapacitation, impairment of ability to self-rescue (escape unaided from a permit space), injury, or acute illness from one or more of the following causes:

  • Flammable gas, vapor, or mist more than 10% of its lower flammable limit (LFL)
  • Airborne combustible dust at a concentration that meets or exceeds its LFL
  • Atmospheric oxygen concentration below 19.5 % or above 23.5 %
  • Atmospheric concentration of any substance for which a dose or a permissible exposure limit is published in subpart D or subpart Z of 29 CFR 1926, which could result in employee exposure more than its dose or permissible exposure limit (PEL)
  • Any other atmospheric condition that is immediately dangerous to life or health

Host employer – Employer that owns or manages property where construction work is taking place.

  • Note: In no case will there be more than one host employer. If a property owner has contracted with an entity for the general management of that property and has transferred the required information to that entity, OSHA will treat the contracted management entity as the host employer for as long as the entity manages the property. Otherwise, OSHA will treat the property owner as the host employer.

Immediately dangerous to life or health (IDLH) – Any condition that interferes with an individual’s ability to escape unaided from a permit space and poses a threat to life or would cause irreversible adverse health effects.

  • Note: Some materials—hydrogen fluoride gas and cadmium vapor, for example—may produce immediate transient effects that, even if severe, may pass without medical attention, but are followed by sudden, possibly fatal collapse 12-72 hours after exposure.  The victim may feel normal after recovery from transient effects until collapse. Such materials in hazardous quantities are immediately dangerous to life or health.

Limited/restricted means for entry or exit – Condition with potential to impede employee movement in or out of a confined space. Such conditions include trip hazards, poor illumination, slippery floors, inclining surfaces and ladders, etc.

Monitor/monitoring – Process used to identify and evaluate hazards after authorized entrant enters the space. Includes checking for changes performed in a periodic or continuous manner after the completion of the initial testing/evaluation of that space.

Non-entry rescue – Occurs when rescue service, usually the attendant, retrieves employees in a permit space without entering the permit space.

Non-permit confined space – Space that meets the definition of confined space but does not meet requirements for a PRCS as defined in this subpart.

Permit-required confined/permit space – Space that has one or more of the following characteristics:          

  • Contains or has potential to contain a hazardous atmosphere
  • Contains material that has potential for engulfing an entrant
  • Has an internal configuration where an entrant could be trapped or asphyxiated by inwardly converging walls or by a floor that slopes downward and tapers to a smaller cross-section
  • Contains any other recognized serious safety or health hazard
  • Important note: Work performed within the space, including hot work (welding, cutting, soldering, brazing, etc.), painting, applying sealants, solvent use, or running gasoline- or diesel-powered engines, can result in hazardous atmospheres in the space. Remind workers that welding fumes and chemical vapors (glue, seam sealer, etc.) can travel to other parts of a confined space. Consider these activities in the assessment of the confined space hazards.

Physical hazard – Existing or potential hazard that can cause death or serious physical damage. Examples include, but are not limited to: explosives (as defined by paragraph [n] of 29 CFR 1910.146, definition of “explosive”); mechanical, electrical, hydraulic and pneumatic energy; radiation; temperature extremes; engulfment; noise; and inwardly converging surfaces. Physical hazards also include chemicals that can cause death or serious physical damage through skin or eye contact (rather than through inhalation).

Prohibited condition – Any condition in a permit space that is not allowed when entry is authorized. A hazardous atmosphere is a prohibited condition unless the employer can demonstrate that PPE will provide effective protection for each employee in the permit space and provide the appropriate PPE to each employee.

Qualified person – One who, by possession of a recognized degree, certificate, or professional standing, or who by extensive knowledge, training, and experience, has successfully demonstrated their ability to solve or resolve problems relating to the subject matter, work, or project.

Rescue – The act of retrieving and providing medical assistance to one or more employees who are in a permit space.

Ventilate/ventilation – The means of controlling a hazardous atmosphere using continuous forced-air mechanical systems that meet the requirements of 1926.57 – ventilation.

29 CFR 1926.1202 defines terms that could be applicable to this standard and program.

Employers should consult with affected employees and their authorized representatives on the development and implementation of all aspects of the permit space program. All information about PRCSs should be available for each affected employee and their authorized representatives at [LOCATION].

CONFINED SPACES IDENTIFICATION AND EVALUATION

Location examples where confined spaces may occur, include: bins; boilers; pits (elevator, escalator, pump, valve, or other equipment); manholes (fuel, chemical, water, or other liquid, solid, or gas); incinerators; scrubbers; concrete pier columns; sewers; transformer vaults; heating, ventilation, and air-conditioning (HVAC) ducts; storm drains; water mains; precast concrete and other pre-formed manhole units; drilled shafts; enclosed beams; vessels; digesters; lift stations; cesspools; silos; air receivers; sludge gates; air preheaters; step-up transformers; turbines; chillers; bag houses; mixers/reactors; crawl spaces and attics.

An inspection of company premises/workplaces by a competent person has identified the following spaces as confined spaces and/or PRCSs:

Confined Spaces (List all spaces that meet the definition of a confined space. Include locations.)

 

 

 

 

 

 

 

Permit-Required Confined Spaces (List all spaces that also meet the definition of a PRCS. Include locations.)

 

 

 

 

 

 

 

All PRCSs have been marked with warning signs reading: "Danger - permit-required confined space - authorized entrants only" or something similar. In addition, the employer must inform affected employees/contractors of the existence, location, and danger of each permit space in a timely manner and in a manner other than posting signs.

RESPONSIBILITIES

Typically, while performing work on a construction site, the company may serve the entry employer role (versus a host employer or controlling contractor), as defined here. In some cases, where the company’s scope of work is much broader, it may serve as the controlling contractor. The following outlines the assignment of responsibilities as well as guidance and recommendations pertaining to each of these roles.

Company policy: When the project scale is such that the host employer does not possess confined space entry resources and the OSHA regulation requirements are beyond the company’s capability, the confined space work will be subcontracted to an entity qualified and capable of performing the work.

The program’s effectiveness depends on proactive engagement and communication of construction site management and employees. Before work begins at a construction site, each employer must ensure that a competent person identifies all confined spaces where one or more employees may work and identifies each permit space through considering and evaluating the space’s elements, including testing, as necessary.

If any employer conducting work on a construction site decides that employees will enter a permit space, the employer (entry employer) must have a written permit space program implemented at the construction site. A written program, as outlined here, must be made available prior to and during entry operations for inspection by employees and their authorized representatives.

Interaction and information sharing with client facility representatives, general contractors, and all related trade contractors is critical to the construction confined space process as hazards may be part of the jobs, tasks, and processes completed by these multi-employer work environments. Clients may have confined spaces in their facilities or on active construction sites and it is important the company works closely with these related organizations to identify these areas and take proper precautions.

This program (and the OSHA standard) is dependent on the controlling contractor, rather than the host/entry employer, as the primary point of contact for information about permit spaces at the worksite. The host employer must provide information about permit spaces at the worksite to the controlling contractor who then passes it on to employers whose employees will enter the spaces (deemed entry employers).

Likewise, entry employers must give the controlling contractor information about their entry program and hazards they encounter in the space and the controlling contractor passes the information along to other entry employers and back to the host employer.

The controlling contractor is also responsible for making sure employers outside a space know not to create hazards in the space and that entry employers working in a space at the same time do not create hazards for one another’s workers. 

  • Note: If there is no controlling contractor, the host employer or another employer will perform these duties. Or, if the controlling contractor owns or manages the property, then it is both a controlling contractor that also serves as the host employer.

Before beginning entry operations, the controlling contractor must:

  • Obtain the host employer’s information about the permit space hazards and previous entry operations
  • Provide the information below to each entity entering a permit space and any other entity at the worksite whose activities could foreseeably result in a hazard in the permit space:
    • The information received from the host employer
    • Any additional information the controlling contractor has about the subjects the host employer is responsible for listed above
    • The precautions that the host employer, controlling contractor, or other entry employers implemented for the protection of employees in the permit spaces

If workplace contains one or more permit spaces, host employer responsibilities include providing the information below to the controlling contractor before entry operations begin:

  • Note location of each known permit space.
  • Post signage to inform exposed employees and provide sufficient notification of the existence, location, and danger of each permit space (signage should read: DANGER – PERMIT-REQUIRED CONFINED SPACE, DO NOT ENTER).
  • Inform employee authorized representatives and controlling contractor about the existence, location, and danger of each permit space, in a timely manner and in a manner other than posting.
  • Note the hazards or potential hazards in each space or the reason it is a permit space
  • Note any precautions that host employer, or any previous controlling contractor/entry employer, implemented for the protection of employees in the permit space.

Specific Responsibilities

Safety Manager

  • Provides oversight and technical support
  • Secures the resources necessary to implement this program
  • Ensures routine safety checks of work operations are performed
  • Conducts annual review of program
  • Updates (as needed) to ensure program effectiveness
  • Ensures proper reporting and recordkeeping is executed

Entry Supervisor

  • Determines conditions for entry and terminates entry if conditions aren’t acceptable.
  • Authorizes entry and oversees entry operations.
  • Terminates entry procedures as required.
  • Serves as an attendant if trained and equipped appropriately for that additional role.
  • Verifies that appropriate entries have been made on the permit, all tests specified by the permit have been conducted, and all procedures and equipment specified by the permit are in place before endorsing the permit and allowing entry to begin.
  • Verifies a rescue team is available and instructed on rescue duties (an onsite team or a pre-arranged outside rescue service).
  • Ensures rescue team members have current certifications in first aid and CPR.
  • Removes any unauthorized individuals who may enter or attempt to enter the permit space during operation.
  • Ensures transfer of responsibility as required by entry permit is done in manner that maintains acceptable entry conditions.

Attendant

  • Knowledgeable of and able to recognize potential confined space hazards.
  • Remains outside permit space during entry operations until relieved by another attendant.
  • Maintains accurate count of all people in confined space and ensures all entrants are tracked in and out.
  • Monitors surrounding activities to ensure personnel safety.
  • Maintains effective and continuous communication with personnel during confined space entry, work, and exit.
  • Orders personnel to evacuate confined space if they:
    • Observe a condition that is not allowed on the entry permit
    • Notice entrants acting strangely, possibly because of exposure to hazardous substances
    • Notice a situation outside the confined space that could endanger personnel
    • Notice a hazard within the confined space that has not been previously recognized or considered
    • Must leave their workstation
    • Must focus attention on the rescue of personnel in another confined space they are monitoring
  • Immediately summons the rescue team/emergency service if rescue becomes necessary.
  • Keeps unauthorized people out of the confined space, orders them out, or notifies authorized personnel of unauthorized entry.
  • May act as attendant for more than one permit space if noted on the entry permit. 

Entrant

  • Reads and observes entry permit requirements.
  • Familiar with and understands potential hazards during entry, including information on the mode, signs or symptoms, and consequences of exposure.
  • Remains alert to potential hazards while in confined space.
  • Properly uses equipment required by the permit.
  • Stays in contact with attendant.
  • Immediately exits confined space when:
    • They are ordered to do so by an authorized/attendant person
    • They notice or recognize signs or symptoms of exposure
    • A prohibited condition exists
    • The evacuation alarm system sounds
    • The required task is completed.

Alert attendant(s) when:

  • There is any warning sign or symptom of exposure to a dangerous situation
  • The entrant detects a prohibited condition

GENERAL PROCEDURES 

Planning Confined Space Entries in Construction

In accordance with the provisions of this program, only properly trained and authorized employees may enter confined spaces in construction, while working for [Company Name].

NO EMPLOYEE SHOULD ENTER A CONFINED SPACE OR PERCEIVED CONFINED SPACE WITHOUT FIRST NOTIFYING A SUPERVISOR AND THE SUPERVISOR TAKES APPROPRIATE ACTIONS AS OUTLINED IN THIS PROGRAM.

No confined space entry should be performed unless at least one person trained and certified in basic first aid and cardiopulmonary resuscitation (CPR) is present onsite and immediately available for the duration of the entry.

Prior to executing any entry, entry supervisors must coordinate escape equipment and procedures, as well as rescue and emergency services, with the responsible person. No entry should be conducted until appropriate rescue and/or retrieval procedures have been coordinated with the responsible person.

Any confined space must be properly secured and protected from hazards outside of the space prior to any entry.

All entries, regardless of the type of space, must have a qualified attendant stationed at the opening of the space who can maintain constant communication with entrants for the duration of the entry.

The confined space entry permit should be completed for every confined space entry. The level of detail required on the permit depends on the size and configuration of the confined space, the work conducted inside, and the types of hazards present (or potentially present).

No space shall be entered while gasoline- or diesel-powered engines or equipment are operating within 50 feet of the entrance to the space.

Respiratory protection should not be used to execute any entry where levels of O2, LEL, CO or H2S levels are not within acceptable entry criteria.

ATMOSPHERIC TESTING IN CONSTRUCTION

Prior to any entry, atmospheric testing should be conducted at various levels within the space, including the lowest level within the space. Atmospheric testing should be conducted using a calibrated, multi-gas meter capable of measuring the following parameters: 

Atmospheric Test Parameter

Acceptable Entry Criteria/Alarm Level

Oxygen (O2)

19.5% to 23.5%

Lower explosive limit (LEL)

Less than (<) 10%

Carbon monoxide (CO)

Less than (<) 25 parts per million (ppm)

Hydrogen sulfide (H2S)

Less than (<) 10 parts per million (ppm)

The meter should be equipped with an audible alarm set to activate when measured levels are outside the range of acceptable atmospheric criteria shown above.

The atmosphere within the space must be continuously monitored unless the entry employer can demonstrate that equipment for continuous monitoring is not commercially available or periodic monitoring is sufficient. If continuous monitoring is used, the employer must ensure that the monitoring equipment has an alarm that will notify all entrants if a specified atmospheric threshold is achieved, or that an employee will check the monitor with sufficient frequency to ensure that entrants have adequate time to escape.

If continuous monitoring is not used, periodic monitoring is required. All monitoring must ensure that the continuous forced air ventilation is preventing the accumulation of a hazardous atmosphere. Any employee who enters the space, or that employee’s authorized representative, must be provided with an opportunity to observe the testing required by this paragraph.

If the confined space entry permit is used to document the entry, the intervals at which atmospheric tests are required must be determined prior to entry. The table below provides guidelines for determining the intervals of atmospheric testing. The entry supervisor and/or entrant(s) must make the determination based on space, worksite characterizations, and the work to be performed within the space.

Test Interval

Guideline

Initial

Required for all entries, regardless of the type of space. Must be conducted prior to entry.

Prior to Each Entry

Required if multiple entries into the same space are required during

a single shift, and no indication that more frequent testing is required. Testing must be conducted prior to each entry into the space.

Continuous

Required in all cases. Required if initial monitoring indicates any atmospheric testing parameter measured is outside the acceptable entry criteria and ventilation is required. Continuous monitoring can be conducted from outside the space or by equipping entrants with personal monitors capable of measuring all required parameters.   

If an extension hose or tubing is required to sample the lowest level of the space, the tester must allow sufficient time for the air sample to travel through the tubing to the instrument detector, as specified in the equipment manufacturer instructions manual. 

If the confined space entry permit is used to document the entry, test frequency, tester name, and the model, manufacturer, serial number, and date of last calibration should be entered on the permit.

SPACE VENTILATION IN CONSTRUCTION

If atmospheric testing measures levels outside the acceptable criteria range:

  • Provide space ventilation using a positive pressure ventilator or blower equipped with a duct long enough to reach the space’s lowest level.
  • Ventilate the space for at least 15 minutes prior to retesting the atmosphere. 
  • Do not enter the space until atmospheric testing results are within acceptable criteria limits.

Note: An alternate procedure for PRCS entry (essentially bypassing most program requirements) is allowed under the OSHA regulation at 1926.1203 (e)(2) if certain conditions are met, including atmospheric testing and continuous forced air ventilation. Only a company representative (competent person), in cooperation with company management and the controlling contractor, can make that determination.

PROCEDURES FOR ENTERING CONFINED SPACES IN CONSTRUCTION

A confined space entry permit should be completed for every confined space entry. No entry permit should extend beyond one work shift. If entries are required for multiple days, complete a separate permit for each day an entry will occur. Prior to any entry, the entry supervisor and entrant(s) determine if any of the following hazards are/could be present:

  1. Continuous or potentially hazardous atmosphere (consider type of work to be performed)
  2. Engulfment hazard
  3. Entrapment hazard
  4. Other hazardous/residual energy

Check the appropriate box on the confined space entry permit for all hazards that are or may be present.

PROCEDURES FOR SPACES WITH NO HAZARDS

  1. If no hazards are present, check the appropriate box on the confined space entry permit. You cannot check the “no hazards” box if any work activities that can create hazards, such as hot work, painting, solvent use, or running gasoline or diesel powered engines, will be performed in the space.
  2. Conduct initial atmospheric testing and record the results on the permit. 
    1. If initial atmospheric testing indicates unacceptable entry conditions, the entry becomes a “permit entry” and the controls referenced below must be implemented. Enter the test results on the permit.
    2. If initial atmospheric testing indicates acceptable entry conditions, enter the test results on the permit and all entrants, attendants, and the entry supervisor should sign the permit and proceed with the entry.
  3. An attendant is required for all entries into “no hazard” spaces. The attendant remains in constant communication with the entrant(s).
  4. At the completion of an entry or the end of a shift, whichever is first, close the permit by entering the date and time at the bottom of the form. Either an entrant or entry supervisor must sign the permit closure.

PROCEDURES FOR PERMIT ENTRY OF A SPACE WITH ANY IDENTIFIED HAZARD

Before entry operations begin, the host employer must provide the following information, if it has it, to the controlling contractor:​​​​​​​

  • The location of each known permit space
  • The hazards or potential hazards in each space or the reason it is a permit space
  • Any precautions that host employer or any previous controlling contractor/entry employer implemented for the protection of employees in the permit space

Before entry operations begin, the controlling contractor must:​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​

  • Obtain host employer information about the permit space hazards and previous entry operations
  • Provide the following information to each entity entering a permit space and any other entity at the worksite whose activities could foreseeably result in a hazard in the permit space:
    • Host employer information
    • Any additional information the controlling contractor has about the subjects listed in paragraph (h)(1) of this section
    • The precautions that host employer, controlling contractor, or other entry employers implemented for the protection of employees in the permit spaces

Before entry operations begin, each entry employer must:​​​​​​​

  • Obtain all the controlling contractor’s information regarding permit space hazards and entry operations
  • Inform controlling contractor about the permit space program that the entry employer will follow, including any hazards likely to be confronted or created in each permit space

The controlling contractor and entry employer(s) must coordinate entry operations:

  • If more than one entity performs permit space entry at the same time
  • If permit space entry is performed at the same time as any other activities that could foreseeably result in a hazard in the permit space are performed
  • If any hazards listed on the confined space entry permit are or may be present at any time during the entry (check the appropriate boxes on the permit)
  • If any activities that would change the characterization of the space (hot work, painting, solvent use) or running gasoline- or diesel-powered engines (check the appropriate boxes on the permit)
  • The controlling contractor and entry employer(s) should select and check the appropriate controls, PPE, and rescue/retrieval equipment required for the hazards identified on the permit. The entry supervisor/entrant verifies that all appropriate controls for ensuring a safe entry are available prior to entry.
  • Conduct initial atmospheric testing and record the documented results on the permit.
    • If initial atmospheric testing indicates unacceptable entry conditions, implement space ventilation (described above). Record test results on the permit.
    • If initial atmospheric testing indicates acceptable entry conditions, record the test results on the permit and all entrants, attendants, and the entry supervisor should sign the permit and proceed with the entry.
  • An attendant is required for all entries into permit-entry spaces.
    • The attendant should remain in constant communication with the entrant(s).
  • At the completion of the entry or at the end of the shift, whichever comes first, close the permit by entering the date and time at the bottom of the permit. Either an entrant or entry supervisor must sign the permit closure.

PROCEDURES FOR EVACUATING SPACES

Entrants must leave the space or be hoisted from the space immediately if at any time during the entry:

    1. Any of the parameters monitored are found to be outside of the acceptable criteria ranges
    2. The entrants or attendants determine that present conditions pose a risk to the entrants
    3. The attendant orders an evacuation of the space because an entrant shows signs of physiological effects of hazard exposure, an emergency outside the confined space exists, or the attendant cannot effectively and safely perform their required duties.

At no time should an attendant or other person enter a confined space to affect a rescue or assist with an evacuation by entering the space unless they are appropriately qualified and have the appropriate equipment, including an atmosphere supplying respirator suitable for rescue in an atmosphere considered immediately dangerous to life and health (IDLH).

If evacuation of a space is necessary, record the reason and time the evacuation occurred on the confined space entry permit.

DO NOT re-enter the space until the entry supervisor and/or the entrants verify that appropriate controls have been implemented and that all conditions are safe for re-entry. Re-establish all procedures for entry before re-entering the space, including repeating atmospheric monitoring. Record the re-entry time on the permit. 

After entry operations:

  • The controlling contractor must debrief each person who entered a permit space about the permit space program followed and any hazards confronted/created in the permit space during entry operations.
  • The entry employer must inform the controlling contractor in a timely manner about the permit space program followed and of any hazards confronted or created in the permit space during entry operations.
  • The controlling contractor must inform the host employer about the information exchanged with each person who entered the space.
  • If no controlling contractor is present, the requirements for, and role of, controlling contactor must be fulfilled by the host employer or other employer who arranges to have employees of another employer perform work that involves permit space entry.

TRAINING

The employer must provide training to each employee whose work is affected by this program, at no cost to the employee, and ensure that employees possess the understanding, proficiency, knowledge, and skills necessary to safely perform the assigned duties. Training should be provided upon assignment and when there’s a change in position assignment where an employee may serve as entry supervisor, entrant, or attendant on a jobsite.

Additional training should be provided when there’s a change in the procedures, in the permit spaces entry operations, and when there’s evidence of a deviation from the permit space entry procedures or inadequacies in the employee’s knowledge about the procedures.

All entry supervisors, entrants, and attendants should receive the same training that must address the following:

  • What constitutes a permit (confined) space
  • Understanding the permit space hazards and the methods used to isolate, control, and protect employees from these hazards
  • Countermeasures for controlling the identified hazards
  • Review the OSHA standards and other guidelines referenced in this program
  • Review the procedures for confined space entries established in this program
  • Dangers of attempting a rescue if not an authorized entrant
  • Procedures for evacuating spaces during entries
  • Procedures for rescue and retrieval

Each employee who receives training should receive a certificate after completion to document the training. The certificate should include the training date and trainer signature.

RECORDKEEPING

To comply with OSHA requirements for record retention and recordkeeping, the following records related to the confined space entry program should be maintained:

  • All confined space entry permits issued in an annual file
  • All employee training records in each employee’s file

PROGRAM REVIEW

Regularly evaluate the confined space entry program to maintain its effectiveness. It is also important that procedures and protocols accurately reflect changes in work activities and changes to current regulations and guidelines.

Review the program annually and remember to include the following:

  • Review all permits to determine program compliance.
  • Review any available documentation regarding space evacuations to identify lessons learned.
  • Review all confined space accidents/incidents and update procedures to minimize their risk.     
  • Evaluate the program procedures’ efficacy within the context of work activities and update, if needed.

PERMIT-REQUIRED CONFINED SPACE

If the scope of the company’s work requires workers to enter a PRCS, then the company’s role is the entry employer, and they must:

  • Implement necessary measures to prevent unauthorized entry
  • Identify and evaluate permit space hazards before employees enter
  • Develop and implement the necessary means, procedures, and practices for safe permit space entry operations, including but not limited to the items below:
    1. Specify acceptable entry conditions.
    2. Provide each authorized entrant or authorized representative with the opportunity to observe any permit space monitoring or testing.
    3. Isolate the permit space and any physical hazards within the space.
    4. Purge, inert, flush, or ventilate the permit space as necessary to eliminate/control atmospheric hazards

Note: When an employer is unable to reduce the atmosphere below 10% LFL, the employer may only enter if they can inert the space to render the entire atmosphere within the space noncombustible, employees use PPE to address any other atmospheric hazards (such as oxygen deficiency), and the employer eliminates/isolates all physical hazards in the space.

    1. Determine monitoring procedures to detect an increase in atmospheric hazard levels in sufficient time for the entrants to safely exit the permit space if the ventilation system stops working.
    2. Provide pedestrian, vehicle, or other barriers as necessary to protect entrants from external hazards.
    3. Verify that permit space conditions are acceptable for entry during an authorized entry and ensure employees are not allowed to enter or remain in a permit space with a hazardous atmosphere unless employer can demonstrate that PPE will provide effective protection for each employee in the permit space and is provided to each employee.
    4. Eliminate any conditions that could make it unsafe to remove an entrance cover.
    5. Provide the equipment specified in the OSHA standard at no cost to each employee, properly maintain that equipment, and ensure each employee uses equipment properly:
      1. Needed testing and monitoring equipment to comply with space ventilation requirements
      2. Needed ventilating equipment to obtain acceptable entry conditions
      3. Communications equipment, including any necessary electronic communication equipment for attendants assessing entrants’ status in multiple spaces
      4. Needed PPE (if engineering and work-practice controls do not adequately protect employees)

Note: These and other PPE requirements continue to apply to the use of PPE in a permit space. For example, if employees use respirators, then you must meet the respirator requirements in the OSHA standards for respiratory protection.

  1. Lighting equipment approved for ignitable/combustible properties of the specific gas, vapor, dust, or fiber present and sufficient to enable employees to see well enough to work safely and exit the space quickly in an emergency
  2. Barriers and shields
  3. Equipment, such as ladders, needed for safe ingress and egress by authorized entrants
  4. Rescue and emergency equipment that wouldn’t be provided by rescue services
  5. Any other equipment necessary for safe permit space entry, exit, and rescue

When entry operations are complete, evaluate permit space conditions according to the items below:

      1. Test conditions in the permit space to determine if acceptable entry conditions exist before changes to the space’s natural ventilation are made and before entry is authorized to begin. If an employer demonstrates that space isolation is infeasible because the space is large or is part of a continuous system (such as a sewer), the employer must:
        1. Perform pre-entry testing to the extent feasible before entry is authorized.
        2. If entry is authorized, continuously monitor entry conditions in the areas where authorized entrants are working. Employers may use periodic monitoring in accordance with the OSHA standard for monitoring an atmospheric hazard if they can demonstrate that equipment for continuously monitoring that hazard is not commercially available.
        3. Provide an early-warning system that continuously monitors for non-isolated engulfment hazards. The system must alert authorized entrants and attendants in sufficient time for the authorized entrants to safely exit the space.
      2. Continuously monitor atmospheric hazards unless the employer can demonstrate that the equipment for continuously monitoring a hazard is not commercially available or that periodic monitoring is of sufficient frequency to ensure that the atmospheric hazard is being controlled at safe levels. If continuous monitoring is not used, periodic monitoring is required with sufficient frequency to ensure that acceptable entry conditions are being maintained during entry operations.
      3. When testing for atmospheric hazards, test first for oxygen, then combustible gases and vapors, then toxic gases and vapors.
      4. Give each authorized entrant (or employee’s authorized representative) an opportunity to observe the pre-entry and any subsequent testing or monitoring of permit spaces.
      5. Reevaluate the permit space in the presence of any authorized entrant (or employee’s authorized representative) who requests that the employer conduct such reevaluation because there is some indication that the evaluation may not have been adequate.
      6. Immediately provide each authorized entrant (or employee’s authorized representative) with the results of any testing conducted in accordance with this program.
    2. Provide at least one attendant outside the permit space for the duration of entry operations where entry is authorized.
      1. Attendants may be assigned to more than one permit space if the duties described in the OSHA standard can be effectively performed for each permit space.
      2. Attendants may be stationed at any location outside the permit space if the duties described in the OSHA standard can be effectively performed for each permit space where the attendant is assigned.
      3. If multiple spaces are assigned to a single attendant, include in the program the means and procedures to enable the attendant to respond to an emergency affecting one or more permit spaces without distraction from the attendant’s responsibilities under the OSHA standard.
      1. Designate each person who will have an active role (ex: authorized entrants, attendants, entry supervisors, or people who test/monitor the atmosphere) in entry operations, identify the duties of each employee and provide them with training required by the OSHA standard.
      2. Develop and implement procedures to summon rescue/emergency services (including procedures to summon emergency assistance in the event of a failed non-entry rescue) for rescuing entrants from permit spaces, providing necessary emergency services to rescued employees, and preventing unauthorized personnel from attempting a rescue.

Note: Emergency services used for rescue must be able to notify the company immediately if rescue service becomes unavailable.

      1. Develop and implement a system to prepare, issue, use, and cancel entry permits as required by this standard, including safely terminating entry operations under both planned and emergency conditions.
      2. Develop and implement procedures to coordinate entry operations, in consultation with the controlling contractor, when employees from more than one employer are working simultaneously in a permit space or elsewhere on the worksite where their activities could, either alone or in conjunction with the activities within a permit space, foreseeably result in a hazard within the confined space, so that employees of one employer do not endanger the employees of another employer.
      3. Develop and implement necessary procedures (ex: closing off permit space, canceling permit) for concluding entry after entry operations have been completed.
      4. Review entry operations when the measures taken under the permit space program may not protect employees and revise the program to correct deficiencies found to exist before subsequent entries are authorized.

Note: Examples of circumstances requiring the review of the permit space program include: any unauthorized entry of a permit space, the detection of a permit space hazard not covered by the permit, the detection of a condition prohibited by the permit, the occurrence of an injury or near-miss during entry, a change in the use or configuration of a permit space, and employee complaints about the effectiveness of the program.

      1. Review the permit space program using the canceled permits retained under this program within one year after each entry and revise the program as necessary to ensure that employees participating in entry operations are protected from permit space hazards.

Note: Employer may perform one annual review covering all entries performed during a 12-month period. If no entry is performed during a 12-month period, no review is necessary.

RESCUE AND EMERGENCY SERVICES

If proper protective measures are taken to eliminate and control any possible hazards in the confined space (ventilation, purging, monitoring, lockout/tagout, etc.), rescue operations should not be necessary. Regardless, the company must be prepared for the worst-case scenario. If the company uses outside services for rescues/emergencies, make sure to:

  • Evaluate prospective rescuer’s ability to respond in timely manner, considering the identified hazards.
  • Evaluate prospective rescuer’s proficiency with rescue-related tasks and equipment to function appropriately while rescuing entrants from permit spaces.
  • Select an evaluated rescue team/service that:
    • Has capability to reach a victim within an appropriate timeframe for the identified permit space hazards.
    • Is equipped for, and proficient in, performing needed rescue services.
    • Agrees to immediately notify employer if rescue services become unavailable.

Once evaluated, the company should inform the selected rescue/emergency services team about the hazards they may confront when called on to perform rescue at the site and provide access to all permit spaces where rescue may be necessary so the rescue service can develop appropriate plans and practice operations. Once chosen, the company should put rescue service contact information in writing: [RESCUE/EMERGENCY SERVICES] will be used for rescues and emergencies when the above situations occur. Contact [CONTACT NAME] at [PHONE #].

In some instances, the company may use a designated employee rescue team to provide rescue services. If the company designates employees to provide permit space rescue, the company should:

  • Provide affected employees with PPE needed to safely conduct permit space rescues and PPE training.
  • Train affected employees to perform assigned rescue duties. Employer must ensure that such employees successfully complete required training to establish proficiency as authorized entrants.
  • Train affected employees in basic first aid and CPR. Employer should ensure at least one member of the rescue team/service who holds a current certification in first aid and CPR is available.
  • Ensure that affected employees practice making permit space rescues at least once every 12 months using simulated rescue operations (dummy, mannequin, or actual person removal from actual/representative permit spaces). Representative permit spaces should simulate the types of permit spaces where a rescue would be performed in opening size, configuration, and accessibility.

To facilitate non-entry rescue, retrieval systems or methods should be used whenever an authorized entrant enters a permit space, unless the retrieval equipment would increase the overall risk of entry or would not contribute to the rescue of the entrant. Retrieval systems should meet the following requirements:

  1. Each authorized entrant should use a chest or full-body harness with a retrieval line attached at the center of the entrant's back near shoulder level, above the head, or at another point. Wristlets may be used in lieu of a chest/full-body harness if an employer can demonstrate that use is not feasible or creates a greater hazard and that using wristlets is the safest and most effective alternative.
  2. The other end of the retrieval line should be attached to a mechanical device or fixed point outside the permit space so rescue can begin as soon as it becomes necessary. A mechanical device should be available to retrieve personnel from vertical-type permit spaces more than five feet (1.52 meters) deep.
  3. Unsuitable retrieval equipment should not be used, including retrieval lines that have a reasonable probability of becoming entangled with the retrieval lines used by other authorized entrants, retrieval lines that will not work due to the internal configuration of the permit space, etc.

If an injured entrant is exposed to a substance for which an SDS or other similar written information is required to be kept at the worksite, the SDS/written information should be made available to the medical facility treating the exposed entrant.

ADDITIONAL DEFINITIONS APPLICABLE TO CONSTRUCTION

Acceptable entry conditions – the conditions that must exist in a permit space before an employee may enter, to ensure that employees can safely enter and safely work in the space

Barrier – a physical obstruction that blocks or limits access

Blanking or blinding – the absolute closure of a pipe, line, or duct by the fastening of a solid plate (such as a spectacle blind or a skillet blind) that completely covers the bore and is capable of withstanding the maximum pressure of the pipe, line, or duct with no leakage beyond the plate

Double block and bleed – the closure of a line, duct, or pipe by closing and locking or tagging two in-line valves and by opening and locking or tagging a drain or vent valve in the line between the two closed valves

Entry rescue – occurs when rescue service enters a permit space to rescue one or more employees

Hot work – operations capable of providing a source of ignition (ex: riveting, welding, cutting, burning, heating)

Inerting – displacing the atmosphere in a permit space by a noncombustible gas (such as nitrogen) to such an extent that the resulting atmosphere is noncombustible

Isolate/isolation – the process by which employees in a confined space are completely protected against the release of energy and material into the space and contact with a physical hazard (by blanking or blinding; misaligning or removing sections of lines, pipes, or ducts; a double block and bleed system; lockout/tagout of all sources of energy; blocking or disconnecting all mechanical linkages; or placing barriers to eliminate potential for employee contact with a physical hazard)

Line breaking – the intentional opening of a pipe, line, or duct that is or has been carrying flammable, corrosive, or toxic material, or an inert gas, any fluid at a volume, pressure, or temperature capable of causing injury

Lockout – the placement of a lockout device on an energy-isolating device in accordance with an established procedure, ensuring that device and equipment being controlled cannot be operated until lockout device is removed

Lower flammable limit/lower explosive limit – the minimum concentration of a substance in air needed for an ignition source to cause a flame or explosion

Oxygen deficient atmosphere – atmosphere containing less than 19.5% oxygen by volume

Oxygen enriched atmosphere – atmosphere containing more than 23.5% oxygen by volume

PRCS (permit-required confined spaces) program – employer’s overall program for controlling permit space hazards, protecting employees from them, and regulating employee entry into permit spaces

Representative permit space – confined space mockup that has entrance openings of similar size, configuration, and accessibility to the permit space that authorized entrants enter

Rescue service – personnel designated to rescue employees from permit spaces

Retrieval system – equipment (retrieval line, chest/full-body harness, wristlets/anklets, lifting device/anchor, etc.) used for non-entry rescue of people from permit spaces

Serious physical damage – an impairment/illness in which a body part is made functionally useless or is substantially reduced in efficiency (Such impairment or illness may be permanent or temporary and includes loss of consciousness, disorientation, or other immediate and substantial reduction in mental efficiency. Injuries involving such impairment would usually require treatment by a physician or other licensed healthcare professional.)

Tagout – (1) placement of a tagout device on a circuit or equipment that has been de-energized in accordance with an established procedure to indicate circuit/equipment may not operate until tagout device is removed; and (2) employer ensures that tagout provides equivalent protection to lockout or lockout is infeasible and employer has relieved, disconnected, restrained, and otherwise rendered safe stored (residual) energy.

CONFINED SPACE ENTRY PERMIT

This permit must remain at jobsite until the entry is completed.                                                                                        

Project address: ______________________________________          Project #: ________

Space description: ____________________________________          Date: ___________

Entry purpose: _______________________________________           Entry time: _______

Entry supervisor: _____________________________________           Expiration: _______

               Hazards and Controls                                       Check here if NO HAZARDS are present: c

Atmospheric Hazards (check if present)

Controls Required (check if required)

Oxygen levels below 19.5%

 

Initial testing (O2, LEL, CO, H2S)

 

Oxygen levels above 23.5%

 

Continuous monitoring (O2, LEL, CO, H2S)

 

Flammable/combustible gases, vapors, or dust (specify):

 

 

Other testing* (specify type and duration): 

 

Toxic gases, vapors, or dust (specify):

 

 

Ventilation – blower w/sufficient duct length

 

Pressurized atmosphere

 

Air purifying respirator (circle)

 

Other (specify):

 

 

Mask type:  half-face     full-face

Cartridge:  P100   Combo P100/organic vapor

    Other (specify):

Configuration hazard (specify):

 

 

Lines broken – capped or blanked

 

Engulfment hazard (specify):

 

 

Purge – flush and vent

 

Shock hazard/electrocution

 

Lockout de-energize – tested and verified

 

Slips, trips, falls (specify):

 

 

If early warning system is required, is it installed and operational?

 

Moving parts (specify):

 

 

Lighting (explosion proof)

 

Connecting pipes, drains, ducts (specify):

 

 

Form of communication (circle):

voice      radio      other:

 

Biological hazard (specify):

 

Visual contact with attendant

 

Other (specify):

 

Ground fault circuit interrupter

 

PPE (check if required)

Rescue/Retrieval (check if required)

Safety glasses/goggles (circle one)

 

Full body harness

 

Hearing protection

 

Retrieval tripod with winch

 

Hard hat

 

Lanyard and lifeline

 

Steel-toed/steel shank shoes

 

Coordination with responsible person

 

Disposable coveralls (Tyvek)

 

Coordination with local EMS and verify they’re available the duration of entry operation. If EMS become unavailable, require immediate notification and suspend entry operations until EMS becomes available.

 

Shoe covers

 

SCBA available for rescue

 

Gloves (circle):

Disposable   Chemical Protective   Leather

 

Other (specify):

 

Face shield

 

Fire extinguisher

 

Other (specify):

 

 

 

Atmospheric Testing

Test Interval (circle):  Initial                Prior to each entry               Continuous

               Tester Name: _________________________________________________________________

 

 

Time of Test

 

 

 

 

 

 

 

 

Initials of Tester

 

 

 

 

 

 

 

Parameter

Acceptable Entry Criteria

Initial Test

Test 2

Test 3

Test 4

Test 5

Test 6

Test 7

% Oxygen

19.5% to 23.5%

 

 

 

 

 

 

 

% LEL*

Less than 5%

 

 

 

 

 

 

 

Carbon Monoxide

Less than 25 ppm

 

 

 

 

 

 

 

Hydrogen sulfide

Less than 10 ppm

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

List other gases or parameters to be tested in blank fields.

Was evacuation of space required at any time?            __ YES                 __ NO

If so, why? ___________________________________________________________________________

Time of evacuation: __________                                    Time of re-entry: __________________

Controls or actions taken to correct reason for evacuation: ___________________________________

Testing Instrument Used

Manufacturer

Serial No.

Date of Last Calibration

 

 

          

 

 

 

 

 

Permit Authorization

I certify that I have reviewed the permit, understand the hazards that are or may be present, and have verified that the appropriate controls have been implemented.  I understand the procedures necessary to ensure safe entry.  No entry can be initiated until this permit is completed and signed by all entrants, attendants, and the entry supervisor.

Authorized Entrants

Name: ________________________________             Signature: ______________________ Date: ________

Name: ________________________________             Signature: ______________________ Date: _________                         

Name: ________________________________             Signature: ______________________ Date: ________                           

Authorized Attendants

Name: ________________________________             Signature: ______________________ Date: _________                         

Name: ________________________________             Signature: ______________________ Date: _________                         

Entry Supervisor

Name: ________________________________             Signature: ______________________ Date: _________             

PERMIT CLOSED Date: ______________ Time: __________ By: ___________________________ 

General Employee Training Acknowledgment

Training topics covered:

  • (Standard parts covered)
  • (Procedures)
  • See section 6 (General Training) for details

I have received information on the above topics as presented to me in the training sessions I attended on (date) at (location).

Employee signature

Job title

Date

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

The above-named employees have been informed and instructed by qualified people about general confined space work practices and the 29 CFR 1910.146 standard or appropriate state standard and the location applicable to the employee.

  Manager signature:

Date:

 

 

 

  Responsible person signature:

Date:

 

 

Specific Employee Training Acknowledgment

Training topics covered:

  • (Standard parts covered)
  • (Procedures)
  • See section 7 (Specific Training) for details

I have received information on the above topics as presented to me in the training sessions I attended on (date) at (location).

Employee signature

Job title

Date

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

The above-named employees have been informed and instructed by qualified people about special confined space work practices and the 29 CFR 1910.146 standard or appropriate state standard and the location applicable to the employee.

  Manager signature:

Date:

 

 

 

  Responsible person signature:

Date: