Safety at work is a crucial issue for employers and employees, especially for those working in specific environments. When working in confined spaces, various risks need to be taken into account so they can be managed for a safe working environment. Some confined spaces require permits before work can be conducted. Other confined spaces may not need a permit for work to be carried out. Knowing when a permit is required for confined spaces and how this relates to worker safety is vital.
What Is a Confined Space, As Defined By OSHA?
Before understanding the difference between permit-required and non-permit required spaces, it’s necessary to know how OSHA defines a confined space. The specific definition given by OSHA includes a set of conditions that a space must meet to be a confined space.
Before a space can be classified as either permit-required or non-permit required, it must meet OSHA’s definition of a confined space. OSHA has specific requirements through several standards. Their statndard include: General Industry (29 CFR 1910.146), Construction (29 CFR 1926 Subpart AA), and Shipyard Employment (29 CFR 1915 Subpart B). While each standard is tailored for the unique hazards in those industries, the core definition remains consistent.
All three of these conditions from 29 Code of Federal Regulations (CFR) 1910.146(b) must be met:
- The space is large enough and configured in a way that allows an employee to bodily enter and complete work
- There are limited means of entry or exit
- The space is not designed for continuous employee occupancy
These foundational criteria help employers and workers determine if a workspace is subject to confined space regulations, regardless of whether the job site is a factory, construction project, or shipyard.
Some examples of spaces that might meet this definition include manholes, silos, underground vaults, and pits. Spaces that meet these conditions can be permit-required or non-permit required spaces.
Permit-Required Confined Space
A permit-required confined space must meet all three of the conditions above, as well as at least one more of the following conditions:
- A hazardous or potentially hazardous atmosphere
- Material that could engulf or asphyxiate the entrant
- Inwardly converging walls or a downward-sloping floor that tapers to a small cross-section
- Any other serious hazards to safety or health
Identifying a Permit-Required Confined Space
A space that meets any of the conditions above must be identified with clear signage to ensure permit oversight. Safety signs labeling the space as a permit-required confined space and warning people to keep out can be used. If the space is not to be entered, the employer must take steps to keep people out.
Can a Permit-Required Confined Space Be Reclassified as Non-Permit?
It is possible for a permit-required confined space to be reclassified as a non-permit confined space, but strict criteria must be met. This process centers on the elimination of all hazards within the space—not merely controlling them.
Here are the key steps for reclassification:
- All existing or potential hazards must be completely eliminated from the space, not just temporarily controlled. Importantly, atmospheric hazards must be removed from the source—not just managed by forced air ventilation.
- Thorough inspections and tests should be conducted to verify that no hazards remain. This might include atmospheric testing, review of engulfment risks, and structural hazard assessments.
- The employer must document the findings and the rationale for reclassification in a signed statement. This documentation must be easily accessible to any employee who will enter the space.
Only when these requirements are met can the space be temporarily treated as a non-permit confined space. However, if conditions change or new hazards are introduced, the space would immediately revert to permit-required status, and all related controls and procedures would need to be reinstated.
Employers should always err on the side of caution and maintain documentation to keep employees informed and protected.
Implementing a Written Permit Space Entry Program
When the permit-required confined space needs to be entered, a written permit space entry program must be in place. The program should contain safety procedures for workers to follow when working in and around the confined space. This includes drafting the permit (entry permit), which is written and printed to allow and control entry into the space.
An entry permit needs to contain certain information. It must include the spaces to be entered, when they will be entered, who will be entering, and more. OSHA defines which information needs to be included. They also provide examples of procedures and practices that might be detailed to control or eliminate hazards. OSHA also defines some circumstances when a full entry permit may not be required, and alternative procedures may be used instead. This includes, for example, if the only hazard is an atmosphere that can only be made safe using continuous forced air ventilation.
Reclassifying a Permit-Required Confined Space as Non-Permit
Sometimes, it’s possible to reclassify a permit-required confined space as a non-permit space, but certain conditions must be fully met. The key is to eliminate all hazards. Simply controlling them with ventilation isn’t enough for OSHA’s purposes.
To properly reclassify a space, employers should:
- Evaluate the space thoroughly and confirm that no atmospheric or other hazards are present (this involves careful testing and inspection).
- Remove hazardous conditions without anyone entering the space during the elimination process.
- Create detailed documentation explaining how hazards were eliminated. The designated entry supervisor or responsible party must sign this.
- Ensure this documentation is easily accessible to all employees entering the space.
Keep in mind, hazards controlled solely by forced air ventilation do not qualify as being eliminated. If all hazards are truly removed and remain absent, the space can be treated as non-permit required for as long as those conditions persist. If hazards return, permit requirements are reinstated.
When Should Confined Space Hazard Re-Assessment Occur?
Keeping workers safe in and around confined spaces isn’t just a one-time effort—it requires ongoing attention to changing conditions. Hazard re-assessment should take place:
- On a regular schedule: Routine checks should align with your workplace’s established safety procedures and any applicable regulatory guidelines.
- When conditions change: Any modification to equipment, processes, or the space itself – like construction changes, new chemicals, or altered ventilation – should prompt a fresh assessment to identify new or hidden dangers.
- After incidents or near misses: If an accident, close call, or unusual event takes place, it’s important to immediately re-evaluate hazards to prevent recurrence.
- Before each entry into permit-required spaces: Atmospheric testing and hazard evaluation must be conducted every time workers are to enter, ensuring the environment is safe for entry.
By making hazard re-assessment a consistent part of your safety routine, you help protect everyone involved and maintain compliance with safety standards.
How Often Should Confined Spaces Be Re-Assessed for Hazards?
Confined spaces aren’t a “set it and forget it” safety concern. Hazards can change over time, so it’s critical to regularly review and reassess these spaces to keep workers safe and maintain compliance.
Employers should re-evaluate confined spaces under several circumstances:
- At routine intervals: Assessments should take place periodically, according to your organization’s safety policies and any applicable regulations (such as OSHA standards).
- After workplace changes: Any modification—whether to the physical space, the equipment used, or the work being done—can introduce new risks. Always re-assess the space if anything significant changes.
- Following incidents: If there’s been an accident, a near-miss, or even a suspected exposure to danger, conduct a thorough hazard evaluation before allowing anyone to re-enter.
- Before each entry: For permit-required confined spaces, it’s essential to test the atmosphere and check for hazards every single time before someone enters, even if the space was just certified earlier in the day.
By making these assessments part of your standard operating procedure, you’ll help prevent surprises, and keep your team out of harm’s way. Regular checks ensure that your permit programs and safety controls remain effective, supporting a culture of vigilance and care on every job site.
Types of Confined Space Entry Training Available
To ensure that employers and employees are adequately prepared for working in confined spaces, a range of confined space entry training options are available, each designed to suit different industries and regulatory requirements.
- Construction-Focused Training: Confined space entry training tailored for the construction industry addresses the unique hazards commonly encountered on job sites. These courses cover OSHA standards specific to construction and emphasize best practices for entry, work procedures, hazard recognition, and emergency response.
- General Industry Training: For those working outside construction, general industry confined space entry training provides instruction on OSHA 29 CFR 1910.146 standards.
Both training types generally offer classroom sessions, hands-on exercises, and demonstrations. These methods ensure participants can recognize hazards, understand regulatory obligations, and properly implement safety protocols. Leading organizations such as the National Safety Council (NSC), American Society of Safety Professionals (ASSP), and various accredited training providers offer flexible options that can be tailored to your workplace’s specific needs.
Investing in the proper training ensures that employees are compliant. It also genuinely prepares them to work safely in these challenging environments.
Training Requirements for Confined Space Entry
Proper training is essential for anyone who may enter, work in, or even supervise confined spaces. OSHA’s standards require employers to provide comprehensive training to all affected employees before they are assigned duties related to permit-required confined spaces. This initial training covers recognizing hazards, safe entry procedures, emergency protocols, and the use of any safety equipment required for the task.
In addition to this initial instruction, refresher training should be provided whenever there is a change in operations that introduces new hazards. Also, if there are indications that an employee does not fully understand the procedures. OSHA does not specify an exact schedule for refresher training. However, many organizations recommend periodic retraining to ensure knowledge remains current and to reinforce a culture of safety.
Key aspects of confined space training include:
- Identifying permit-required confined spaces and their hazards
- Understanding the written permit program and entry permits
- Proper use of air monitors, ventilators, harnesses, and other safety equipment
- Emergency response steps, including communication and evacuation procedures
- Recognizing the roles of authorized entrants, attendants, and entry supervisors
By making sure all workers are adequately trained and knowledgeable, employers can reduce risk and improve safety outcomes for every confined space entry.
Employer Responsibilities in Confined Spaces
Confined space safety is a shared responsibility, and OSHA outlines distinct roles for different types of employers involved. Understanding who is responsible for what helps ensure safe entry and coordination, especially when contractors are part of the work.
Here’s how these roles break down:
- Host Employer: This is typically the owner or manager of the property where the confined space is located. The host employer must share any known hazards or previous entry experiences with all parties involved. They must also provide information about the permit program and space conditions.
- Controlling Employer: Often, this is the general contractor or the party arranging for work to be done. The controlling employer is responsible for coordinating activities among all employers onsite, ensuring that everyone is aware of hazards, and overseeing how entry operations are carried out.
- Entry Employer: This is the employer whose workers are actually entering and working in the confined space. The entry employer is tasked with implementing the entry permit system, providing training and protective equipment, and ensuring all safety procedures are followed.
Clearly identifying each employer’s responsibilities helps prevent miscommunication and, ultimately, keeps everyone safer on the job.
Confined Space Training Requirements
Confined space training is not just a one-time requirement. It must be provided before an employee is assigned any duties involving permit-required spaces. In addition to initial training, further instruction may be required. For example, whenever there’s a modification in operations that impacts exposure to hazards. Also, another example is if there’s any reason to believe someone’s understanding or performance isn’t up to standard.
While OSHA doesn’t set a specific timeline for refresher courses, it’s a best practice for employers to schedule regular training updates. This helps ensure everyone remains confident and competent in permit space procedures.
Confined Space Rescue Teams
Working in confined spaces is hazardous and is one of the leading causes of occupational fatalities. Working with a confined space rescue team helps employers cover all necessary permit requirements and ensures assistance is available during emergency situations. Even with the correct procedures in place and following all OSHA guidelines, things can go wrong. A confined space rescue may still be required. Employers can benefit from looking at the non-mandatory “Rescue Team or Rescue Service Evaluation Criteria” to help them determine the capabilities of rescue teams.
Knowing the difference between a permit-required confined space and a non-permit required confined space is a must for employers. First, understand what a confined space is, as defined by OSHA, before assessing whether a permit is required. With the correct understanding, the right procedures can be put in place. Hazards can then be managed whenever work needs to be carried out in the space.
DCS Rescue can help employers with a range of services, providing technical and confined space rescue. Contact us to find out more about the services that we provide.