A space with confined entry is “any place which has a limited means of egress, which is subject to the accumulation of toxic or flammable contaminants or has an oxygen-deficient atmosphere” [29CFR1926.21]. That definition encompasses storage tanks, process tanks, bins, boilers, and utility vaults among other kinds of spaces.
OSHA provides the regulations for “permit-required confined spaces” in 29CFR1910.146, but those regulations do not apply to construction, shipyard employment, or agriculture. However, a site owner with a confined entry program may require construction contractors to follow it.
“Confined Entry” addresses the atmosphere within a confined space; therefore, it’s only part of the total safety situation. You still must address issues you’d have in a “normal” space, for example lockout/tagout. You also must know the hazards of the confined space as you would any other space. The confined entry permit does not address these other dangers.
The Permit
You must sign the confined entry permit before entering a confined space. Don’t just sign the permit as if it’s a guest registry. Your signature on the permit certifies you are satisfied that its requirements have been met. Every item on that permit is there for a reason, so go through every item personally.
If there’s a checkbox for ventilation, verify the ventilation is adequate for the space. If the permit states a given flow rate, have the person in charge of ventilation show you how that is achieved and measured. Follow a similar procedure for each item.
Each confined entry permit belongs to a specific crew, for a specific purpose, for a specific time. Like lockout/tagout, it automatically expires at the end of each shift. It may expire after a shorter, specified time. Furthermore, the permit may pertain to specific locations within the confined space.
Never accept excuses for ignoring a permit requirement. If an operator says the requirement no longer applies, fine. Get an updated permit issued in place of the existing one. Verbal doesn’t cut it, and neither do “field changes.” The changes must be reflected on an updated permit in “as issued” condition (not marked up).
The permit (now bearing the signature of everyone entering) must be posted at or near the entrance to the space. If someone else signed for you (or another coworker), remove the permit and report that violation. Then get a new permit. Regardless of any pressure from peers or managers, never abdicate your responsibility to personally verify each permit item.
Don’t assume a job planner thought of everything. To the extent possible, conduct a “dry run” in which you walk through the steps of the job. Try to determine how those would be accomplished, given the conditions in the confined space. Can you safely bring tools, materials, and equipment into the work area and out again? Evaluate ingress, egress, and emergency extraction. How will you get out or get someone out if there’s an incident?
Also:
• Get clarification on anything that’s unclear.
• Examine the job safety survey. Does it match what’s needed to complete the job?
• Verify the permit requirements have been met. This is different from “they will be met.” Promises don’t mean anything — actual correction of a deficiency does.
• Test communications gear/lights.
• Inspect PPE.
• If extraction equipment is needed, test it, and ensure the people using it are qualified.
If in doubt, stay out. Don’t sign the permit if, for example:
• You’re unable to review all pertinent documentation.
• The activity description does not match your job planning.
• Even one required item cannot be verified.
• The permit is for a different crew, job, or time.
• The permit doesn’t address all your work locations in that space.
Before entering:
• Know where the emergency equipment is located.
• Know which gases may be present, what the concentration limits are, and how gas concentrations will be monitored.
• Verify the entry supervisor has signed the confined entry permit. If not, don’t enter.
• Consult with the entry supervisor if conditions differ from what the permit says or anything seems wrong or unclear.
• Follow the entry supervisor’s instructions.
To re-enter the confined space, for example when your crew comes back from lunch, each of you must repeat the above steps. Anything could have changed in your absence.
During a repair job at a plastics plant, some operators shut off the ventilation fans for the lunch break. When the crew returned, their foreman noticed the silence, and requested another atmospheric survey. The operators said the permit was still valid; no testing was needed.
The foreman notified the entry supervisor, who then ordered another survey; it showed insufficient oxygen to sustain life. The entry supervisor ordered ventilation to be run for 15 min., after which a second test showed oxygen was sufficient. The entry supervisor then used duct tape to “lock down” the fan switches.
After entering:
• Follow the attendant’s instructions.
• Keep the attendant apprised of your status.
• Be alert to the condition of your coworkers.
• Periodically check gas meters or other safety equipment.
In addition, you may discover:
• A condition prohibited by the permit.
• An atmospheric hazard the permit did not identify
• A condition change.
• If any of the above occur, exit the confined space, and consult with the entry supervisor.
The Attendant
Unless mechanical ventilation can, on its own, maintain a safe atmosphere, OSHA requires an attendant. Many companies take this further, requiring that every confined space must have at least one attendant. If you’re going in, learn the following about your attendant(s):
• Qualifications to attend this entry.
• How to communicate with them.
• How they will communicate with you.
• How they will communicate with other resources (e.g., the control room).
• Whether there are enough attendants with the equipment and physical strength to extract every crew member.
Ensure the attendant knows to order you out if anything isn’t right. Your own judgment could be impaired because of low oxygen or other factors.
If you are the attendant:
• Review the confined entry permit. If something’s not right, don’t let work proceed.
• Understand you may be the only means of obtaining help. If there’s an emergency, don’t enter the vessel. Putting any part of your body in it is considered entering. If you stick your head in to see what’s going on, you’ll breathe what’s in that vessel, and your choice may prove fatal. For everyone.
• Test your communication gear before entering; you must be able to communicate both with the crew and with outside help.
• If extraction equipment is necessary, test it. Ensure you are capable of extracting everyone, including that 260-lb former linebacker.
• Always pay attention to what’s going on in the vessel. Yes, it can be boring, but don’t be distracted by conversation or text messaging.
• Periodically contact the crew. Not only does this fight boredom, but it helps you assess their status. An occasional question like, “What does your O2 meter read” is good. Bantering is not. Also, just listen for activity; silence is a bad sign.
• If extraction is necessary, call for help before starting the extraction so they can be on the way while you’re extracting.
• That morning coffee! You radioed for a relief attendant, but nobody is available. The only solution is to order the crew to exit so you can make that trip to the head. The crew can’t give you permission to leave your station; they need your permission to be in that confined space.
• If you are a relief attendant, ensure you can communicate with the crew and you understand the permit before letting the other person leave.
Clearing the Air
A primary cause of confined entry confusion is the misconception that it’s all about getting permission to enter. The reality is you also give permission. Without your approval, the permit is not valid. You’re not signing some permit to get inside that space. You’re evaluating the safety of the air in that space so you can confidently sign that permit.
You also have veto power after you enter. An OSHA-compliant employer expects you to withdraw your approval and exit that space if you find a problem related to the air inside it. Don’t “soldier on” if something’s wrong — you exit. You can always re-enter after the problem is solved.
Lamendola is an electrical consultant located in Merriam, Kan. He can be reached at [email protected].
About the Author
Mark Lamendola
Mark is an expert in maintenance management, having racked up an impressive track record during his time working in the field. He also has extensive knowledge of, and practical expertise with, the National Electrical Code (NEC). Through his consulting business, he provides articles and training materials on electrical topics, specializing in making difficult subjects easy to understand and focusing on the practical aspects of electrical work.
Prior to starting his own business, Mark served as the Technical Editor on EC&M for six years, worked three years in nuclear maintenance, six years as a contract project engineer/project manager, three years as a systems engineer, and three years in plant maintenance management.
Mark earned an AAS degree from Rock Valley College, a BSEET from Columbia Pacific University, and an MBA from Lake Erie College. He’s also completed several related certifications over the years and even was formerly licensed as a Master Electrician. He is a Senior Member of the IEEE and past Chairman of the Kansas City Chapters of both the IEEE and the IEEE Computer Society. Mark also served as the program director for, a board member of, and webmaster of, the Midwest Chapter of the 7x24 Exchange. He has also held memberships with the following organizations: NETA, NFPA, International Association of Webmasters, and Institute of Certified Professional Managers.