Confined Space Program
By: William (Billy) Kinch
Does your facility have a confined space? You may have one or more and not be aware of it and not have the appropriate safety precautions in place. Most organizations don’t know if they have a confined space because they are not aware of what one is. Here is what OSHA defines as a confined space: A confined space means a space that is:
- Large enough and so configured that an employee can bodily enter and perform assigned work; and
- Has limited or restricted means for entry or exit (for example, tanks, vessels, silos, storage bins, hoppers, vaults, and pits are spaces that may have limited means of entry); and
- Is not designed for continuous employee occupancy.
Additionally, OSHA goes on to talk about a permit required confined space which is a confined space that has one or more of the following characteristics:
- Contains or has a potential to contain a hazardous atmosphere;
- Contains a material that has the potential for engulfing an entrant;
- Has an internal configuration such that an entrant could be trapped or asphyxiated by inwardly converging walls or by a floor which slopes downward and tapers to a smaller cross-section; or
- Contains any other recognized serious safety or health hazard.
An organization is required to evaluate the workplace to determine if they have any spaces that would meet the definition of a permit-required confined space. If they do, then they are required to meet the OSHA requirements found in 1910.146.
Let’s say that because of the evaluation, it was determined that the organization had a location that would meet the requirements of a permit-required confined space. What should you do next? The first thing that is required is that the organization must inform the employees that would be exposed to the location. This can be done by posting danger signs or by any other equally effective means to notify the staff of the existence and location of and the danger that is posed by the space. An example of verbiage is: DANGER – PERMIT-REQUIRED CONFINED SPACE, DO NOT ENTER.
Because of the risks that come with entering a confined space, an organization may determine that they will not permit their employees from entering these locations. If that is the case, then the organization must take effective measures to prevent the employees from entering the spaces. If the organization hires a contractor to come and do work in the space instead of using their own employees, the organization must inform the contractor of the permit-required confined space. The organization is required to maintain a written confined space program. This should include information related to the following:
- Program responsibilities
- Identification of confined spaces
- Identification of personnel involved in the confined space entry
- Standard operating procedures, such as atmospheric monitoring and ventilation
- Entry permits
- Other facility safety permits and procedures
- Emergency communications and rescue procedures
- Program auditing
- Medical qualifications
- Regulatory and best practices
- A written confined space policy where only qualified contractors will enter the confined space that explains the following:
- How the organization determines contractors are qualified
- How confined space hazards are communicated to contractors
- How relevant facility safety information is communicated to contractors
- How contractors are debriefed after entry is completed
Take the time to evaluate your organization to determine if you have a confined space. Then, put in a proper confined space program that works for your facility and keeps your employees safe.
Occupational Safety and Health Standards (OSHA) 1910.146
NFPA 350 – Guide for Safe Confined Space Entry and Work – 2016 edition
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