Simone Lawson
Permit-required confined spaces are areas that require a permit due to the presence of hazards that have not been eliminated. These hazards may include a hazardous atmosphere, the potential for engulfment or entrapment, or other serious safety or health risks. Employers must evaluate the workplace to identify any permit-required confined spaces and implement necessary control measures to protect employees. This includes providing training, ensuring acceptable entry conditions, and developing rescue plans. An entry permit is a written document provided by the employer to control entry into these spaces, and it is crucial to determine if conditions are acceptable for entry and to prevent unauthorized access. Understanding and managing permit-required confined spaces are essential for maintaining a safe working environment.
| Characteristics | Values |
|---|---|
| Hazardous atmosphere | Flammable gas, vapour or mist in excess of 10% of its lower flammable limit (LFL), Airborne combustible dust at a concentration that meets or exceeds its LFL |
| Contains material with the potential to engulf or entrap | Liquids or finely-divided "flowable solids" (like grain or dirt) that can cause death or injury by aspiration, strangulation, constriction, or crushing |
| Contains other recognised serious safety or health hazards | Any condition that exposes employees to the risk of death, incapacitation, impairment to self-rescue, injury, or acute illness |
| Lack of training | Workers are not properly trained on the potential hazards |
| Lack of signage | Lack of a sign reading "DANGER—PERMIT-REQUIRED CONFINED SPACE, DO NOT ENTER" |
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What You'll Learn
- Flammable gas, vapour, or mist exceeding 10% of the lower flammable limit (LFL)
- Airborne combustible dust at LFL concentration or higher
- Inwardly converging walls or a downward-sloping floor
- Lack of worker training on hazards and safety measures
- Insufficient atmospheric testing and evaluation prior to entry
Flammable gas, vapour, or mist exceeding 10% of the lower flammable limit (LFL)
LFL refers to the lowest concentration of a flammable gas, vapour, or mist that can ignite and burn when exposed to a spark, flame, or other ignition source. This is typically measured as a percentage of the total atmosphere. For example, methane gas, which is often found in confined spaces, has an LFL of 4.4%-5%. This means that if the level of methane gas exceeds 0.44-0.5% of the total atmosphere, the confined space must be classified as permit-required.
The presence of flammable gas, vapour, or mist exceeding 10% of the LFL poses a serious risk of fire or explosion, and therefore, any confined space with this level of flammability must be designated as a permit-required confined space. This classification is important as it dictates the safety measures and protocols that must be followed.
OSHA regulations require employers to determine the permit applicability of a confined space by evaluating the presence of hazards. In the case of flammable gas, vapour, or mist, the employer must ensure that the level does not exceed 10% of the LFL. If it does, the space must be reclassified, and employees must be warned about the existence, location, and dangers of the permit-required confined space.
To ensure safety, employers must implement procedures to eliminate or control atmospheric hazards, such as purging, inerting, flushing, or ventilating the space. Additionally, atmospheric monitoring must be conducted prior to entry and continuously throughout the work within the confined space. These measures are crucial to protect employees from the dangers associated with flammable gases, vapours, or mists in permit-required confined spaces.
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Airborne combustible dust at LFL concentration or higher
A permit-required confined space is a space that has one or more of the following characteristics: it contains or has the potential to contain a hazardous atmosphere; it contains a material that has the potential to engulf an entrant; it has an internal configuration that could trap an entrant; or it contains other recognised serious safety or health hazards.
OSHA defines a hazardous atmosphere with respect to airborne combustible dust as "at a concentration that meets or exceeds its LFL". This concentration may be approximated as a condition in which the dust obscures vision at a distance of 5 feet (1.52 meters) or less. However, this definition has been criticised as vague and not providing clear guidance on determining whether a hazardous concentration of combustible dust is present.
To address this, the 2019 edition of NFPA 652 requires the completion of a Dust Hazard Analysis, which includes defining the actual concentration of combustible dust that may cause an explosion. This information can then be used to more clearly define the level of hazard from airborne combustible dust in a confined space.
In any case, employers must be vigilant in maintaining equipment and controlling dust accumulation levels to reduce the hazard level in a facility. Additionally, employers must inform workers of the hazards associated with combustible dust and provide the necessary training to ensure safe working conditions.
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Inwardly converging walls or a downward-sloping floor
A permit-required confined space is a space that has one or more characteristics that make it dangerous. One such characteristic is the presence of inwardly converging walls or a downward-sloping floor, which can lead to a person becoming trapped or asphyxiated.
Inwardly converging walls are walls that slope inwards, towards each other, often forming a smaller cross-section at the bottom. This can create a hazard where a person could become trapped or wedged in the space, especially if they slip or fall. Similarly, a downward-sloping floor can cause a person to slide and become stuck in a small cross-section of the confined space. The presence of these inwardly converging walls or a downward-sloping floor alone may not always require a permit, but if combined with other factors, such as a hazardous atmosphere or the potential for engulfment, it would render the space permit-required.
In the case of inwardly converging walls, a temporary floor can be installed above the smaller cross-section to eliminate the risk of falling and becoming trapped. However, this does not address the potential hazards of a confined space with a hazardous atmosphere or the presence of engulfing materials.
To ensure the safety of employees entering these spaces, employers must evaluate the specific hazards, the work being performed, and the industry standards. This includes providing worker training and implementing safety controls, such as erecting barriers and ensuring proper ventilation to control atmospheric hazards.
It is important to note that even if a confined space does not require a permit, hazards may still be present. Therefore, employers must continuously evaluate the space and take measures to protect their employees from potential dangers.
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Lack of worker training on hazards and safety measures
Confined spaces present unique hazards that require special safety measures and training to navigate safely. A lack of worker training on hazards and safety measures can lead to dangerous and even fatal outcomes.
Workers must be trained to identify and understand the risks associated with confined spaces. These spaces may contain hazardous atmospheres, materials with the potential for engulfment or entrapment, configurations that could trap or asphyxiate, and other serious safety or health hazards. Workers need to be able to recognise these risks and take appropriate precautions. For example, if a worker is unaware of the dangers of a hazardous atmosphere, they may not take the necessary precautions, such as air monitoring and the use of breathing apparatus.
Comprehensive and ongoing training is crucial for ensuring employee safety. Employers are mandated by OSHA standard 1910.146(g) to provide thorough training to all employees who may encounter confined spaces in their work. This training should cover various topics, including risk assessment, safety procedures, emergency response plans, and the use of safety equipment.
In addition to initial training, employers should also provide regular refresher courses and updates on any changes in procedures or hazards. Continuous learning is essential as hazards and conditions in confined spaces can change over time. By investing in ongoing training, employers can ensure that their workers remain vigilant and prepared for any challenges they may encounter in confined spaces.
The consequences of inadequate training can be severe. Case studies have shown that a lack of proper safety training has led to tragic incidents, including asphyxiation from hazardous gases and loss of consciousness due to oxygen deprivation. These incidents highlight the critical importance of comprehensive worker training and the implementation of effective safety protocols. Employers must prioritise worker training to ensure the safety and well-being of their employees in confined spaces.
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Insufficient atmospheric testing and evaluation prior to entry
Insufficient atmospheric testing and evaluation before entering a permit-required confined space can have severe consequences. Atmospheric testing is a critical component of ensuring worker safety in confined spaces. The employer must ensure that a qualified person performs a hazard assessment and atmospheric testing before workers enter a confined space. This testing must be accurate and thorough, following a specific sequence: oxygen, combustible gases, and toxic gases and vapours. Testing must also be conducted at multiple levels within the space—top, middle, and bottom—to account for gas layering.
The evaluation testing phase aims to identify any hazardous atmospheric conditions, such as toxic gases or oxygen-deficiency, that may be present or could develop over time. This process requires the use of gas detection equipment that can measure hazardous substances at levels below exposure limits. The results of these tests are crucial for establishing safe entry procedures and implementing necessary safety measures to protect workers.
A technically qualified professional, such as an industrial hygienist or registered safety engineer, must review the evaluation test results. They determine if the space is safe for entry and if any additional precautions are necessary. It is essential to remember that atmospheric testing is not a one-time procedure. Continuous or periodic monitoring is required, especially if conditions within the confined space could change due to activities like welding, chemical cleaning, or material movement.
In addition to pre-entry testing, workers entering the confined space must be equipped with personal gas monitors to detect hazards inside. Employers must also provide respiratory protection and ensure that safety procedures are followed. By following these comprehensive testing and evaluation protocols, employers can help ensure a safe working environment for their employees and mitigate the risks associated with permit-required confined space entry.
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Frequently asked questions
A permit-required confined space is a space that meets the following criteria: being large enough for an employee to enter and perform work, has limited or restricted means for entry or exit, and is not designed for continuous occupancy. In addition, it must contain one or more of the following: a hazardous atmosphere, a substance with the potential for engulfment or entrapment, or any other serious safety or health hazard.
Unacceptable entry conditions include any atmospheric hazards that expose employees to the risk of death, incapacitation, impairment to self-rescue, injury, or acute illness. This includes flammable gas, vapour, or mist in excess of 10% of its lower flammable limit (LFL) and airborne combustible dust concentrations that meet or exceed the LFL. Other unacceptable entry conditions include engulfment hazards such as liquids or finely-divided solids that can cause death or injury by aspiration, strangulation, constriction, or crushing.
Employers are responsible for evaluating the workplace to determine if any spaces are permit-required confined spaces. They must inform employees about the existence, location, and dangers of permit-required confined spaces through warning signs or other effective means. Employers must also develop and implement procedures for safe entry operations, including providing necessary equipment and ensuring acceptable entry conditions throughout the duration of authorized entry.
