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What rescue provisions must be in place for entry into a simple confined space that isn’t a permit space?
Responding is Judie Smithers, editor – workplace safety, J.J. Keller & Associates Inc.
The first step is to properly evaluate the space.
OSHA defines a confined space as meeting all of the following criteria:
- Is large enough for an employee to bodily enter and work
- Has limited or restricted means of entry and exit
- Is not designed for continuous occupancy
If you determine that a space meets the definition of “confined space,” then you need to further evaluate the space.
A permit-required confined space is a confined space that has one or more of the following characteristics:
- Contains or has the potential to contain a hazardous atmosphere
- Contains a material that has the potential for engulfing an entrant
- Has an internal configuration that could trap or asphyxiate an entrant by inwardly converging walls or a floor that slopes downward and tapers to a small cross-section
- Contains any other recognized serious safety or health hazard
If a confined space does not meet the definition of a permit-required confined space (permit space), then 1910.146 requirements for entry into a permit space do not apply. OSHA has no rescue requirements for entry into a non-permit confined space. A confined space does not have any of the hazards that would make it a permit space; the standard’s rescue provisions at 1910.146(k) only apply to entries into permit spaces.
If, while assessing the work employees will perform in a non-permit confined space, you determine that the work itself could cause a hazardous atmosphere or other recognized serious safety or health hazards to develop, then you need to re-classify the confined space as a permit space. OSHA’s 1910.146(c)(6) requires employers to reevaluate non-permit spaces when changes in their use or configuration could cause the space to be reclassified as a permit space.
Under 1910.146(c)(7), a permit space may be reclassified as a non-permit confined space if it poses no actual or potential atmospheric hazards and if all hazards within the space are eliminated without entry into the space. For example, if you lock out hazardous equipment prior to entry, the space can be reclassified as a non-permit confined space if it poses no actual or potential atmospheric hazards.
A reclassified space is exempt from the requirements in 1910.146 (d) through (k). You do not need a permit or rescue provisions during entry into the reclassified space; however, you do need to document the basis for the reclassification and make the certification available to the entrants.
The standard also has provisions for alternate entry procedures at 1910.146(c)(5). These can be followed when the only hazard in a permit space is an atmospheric hazard that can be controlled through the use of continuous forced air ventilation during the entry. When following alternate entry procedures, you do not need to meet 1910.146(d) through (f) and (h) through (k).
OSHA’s most thorough explanation of these requirements is in the January 1993 preamble to the final rule.
Editor's note: This article represents the independent views of the author and should not be construed as a National Safety Council endorsement.