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OSHA section 1926.1204, Permit-required confined space program, outlines requirements for protecting individuals from the hazards of entering permit-required confined spaces. If workers or contract workers are not allowed to enter or work in a permit-required confined space, use adequate measures to prevent entry into those spaces. If workers are allowed to enter permit spaces, develop a written permit space program, ensuring its available, communicated, and effectively implemented.
OSHA requires that employers protect workers who must enter confined spaces. But what exactly is a confined space? And is it permit-required? Identifying a confined space may not be as easy as you think.
The definition of a confined space is relatively straightforward. According to OSHA, it’s a space that is:
Applying this definition to spaces on your jobsite may not be so simple, however. Take a large duct, for instance. It’s large enough for entry and not designed for continuous occupancy, but it’s not a confined space by OSHA’s definition when it does not limit the way of entry or exit. Some large powerplant ducts are large enough to walk into without any restrictions.
The key is that the space must meet all three criteria. Once you determine that a confined space exists on your jobsite, the next step is to evaluate whether it’s a permit-required confined space. This requires examining the confined space’s actual or potential hazards and the dangers it presents to entrants.
The OSHA regulation says that confined spaces with one or more of the following characteristics qualify as permit-required:
Again, the key here is that only one of these criteria must be satisfied. Also, note that “entry” to a permit space occurs when any part of a worker’s body breaks the plane of the space. For example, just reaching one arm into a permit space to retrieve an item or tighten a bolt would be considered “entry” to that space.
When a jobsite contains a permit-required confined space, OSHA requires necessary steps to protect workers, including:
Reclassify a permit-required confined space as a non-permit space for the length of entry by eliminating the hazard for the entry time. This depends on the hazards it presents (such as atmospheric hazards, physical hazards, or mechanical/energy hazards).
Determine if your enclosed space is a confined space, permit-required confined space, or neither on a case-by-case basis. Taking a proactive approach to identify and evaluate enclosed spaces on your jobsite carefully is critical. It could mean the difference between life and death.