OSHA Confined Spaces Advisor

Your answers indicate that some of your workers, at least some of the time, engage in general industry work, i.e. work that is not construction, agriculture, marine terminal or ship yard employment. With respect to your general industry workers, your business is subject to OSHA's Permit-Required Confined Spaces rule for general industry.

You must inspect your workplace to determine if any confined spaces exist, and if such spaces are permit-required confined spaces. Use the option of this Confined Spaces Advisor, "determine if a specific space is a permit required confined space," to help you identify permit-required spaces and to determine your obligations under the OSHA rule.

Even if you do not intend for your workers to enter permit spaces you have specific obligations to post signs and control entry to such spaces.

If you hire contractors to work in permit spaces, you also have specific obligations under the permit-required spaces rule.

If your workers work as contractors in workplaces of others, you have responsibility to identify permit-required spaces that they may enter and to take measures to protect them.

Asphyxiation is the leading cause of death in confined spaces. The asphyxiation that have occurred in permit spaces have generally resulted from oxygen deficiency or from exposure to toxic atmospheres. In addition, there have been cases where employees who were working in water towers and bulk material hoppers slipped or fell into narrow, tapering, discharge pipes and died of asphyxiation due to compression of the torso. Also, employees working in silos have been asphyxiated as the result of engulfment in finely divided particulate matter (such as sawdust) that blocks the breathing passages.

OSHA has, in addition, documented confined space incidents in which victims were burned, ground-up by auger type conveyors, or crushed or battered by rotating or moving parts inside mixers. Failure to deenergize equipment inside the space prior to employee entry was a factor in many of those accidents.

Many employers have not appreciated the degree to which the conditions of permit space work can compound the risks of exposure to atmospheric or other serious hazards. Further, the elements of confinement, limited access, and restricted air flow, can result in hazardous conditions which would not arise in an open workplace. For example, vapors which might otherwise be released into the open air can generate a highly toxic or otherwise harmful atmosphere within a confined space. Unfortunately, in many cases, employees have died because employers improvised or followed "traditional methods" rather than following existing OSHA standards, recognized safe industry practice, or common sense.

The failure to take proper precautions for permit space entry operations has resulted in fatalities, as opposed to injuries, more frequently than would be predicted using the applicable Bureau of Labor Statistics models. OSHA notes that, by their very nature and configuration, many permit spaces contain atmospheres which, unless adequate precautions are taken, are immediately dangerous to life and health (IDLH). For example, many confined spaces are poorly ventilated - a condition that is favorable to the creation of an oxygen deficient atmosphere and to the accumulation of toxic gases.

Furthermore, by definition, a confined space is not designed for continuous employee occupancy; hence little consideration has been given to the preservation of human life within the confined space when employees need to enter it.

In general, the Permit-Required Confined Spaces Standard requires that you, the employer, evaluate the workplace to determine if any spaces are permit-required confined spaces. If permit spaces are present, and your workers are ever authorized to enter such spaces, you must develop and implement a comprehensive permit spaces program, which is a an overall plan/policy for protecting employees form permit space hazards and for regulating employee entry into permit spaces. The OSHA standard includes detailed specification of the elements of an acceptable permit spaces program (29 CFR 1910.146(d)). Permit spaces must be identified by signs, and entry must be controlled and limited to authorized persons. An important element of the requirements is that entry be regulated by a written entry permit system, and that entry permits be recorded and issued for each entry in to a permit space. The standard specifies strict procedures for evaluation and atmospheric testing of a space before and during an entry by workers. The standard requires that entry be monitored by an attendant outside the space and that provisions be made for rescue in the event of an emergency. The standard specifies training requirements and specific duties for authorized entrants, attendants, and supervisors. Rescue service provisions are required, and where feasible rescue must be facilitated by a non-entry retrieval system, such as a harness and cable attached to a mechanical hoist.

The OSHA Permit-Required Spaces Standard provides for alternative (less stringent than full permit procedures) entry procedures in cases where the only hazard in a space is atmospheric and the hazard can be controlled by forced air. The alternative procedure is allowed only in cases where specified requirements for substantiation and notification are met.

Special requirements apply to contractors whose employees work in spaces controlled by others. Employers who engage contractors to work in their permit-required confined spaces also have special obligations pertaining to that arrangement