HiTool – Permit-Required Confined Space

The key to whether a human can occupy the space under normal operating conditions places the focus on the design of the space.

If, when the space was originally designed or subsequently redesigned, the designer took into consideration that humans would be entering the space and provided for the human occupancy (such as: provided ventilation, lighting, sufficient room to accomplish the anticipated task, etc.), then the space would be designed for employee occupancy.

Based on your input, the space is a CONFINED SPACE. 

Proceed to next question. 

Hazardous atmosphere means an atmosphere that may expose employees to the risk of death, incapacitation, impairment of ability to self-rescue (that is, escape unaided from a permit space), injury, or acute illness from one or more of the following causes:

1. Flammable gas, vapor, or mist in excess of 10 percent of its lower flammable limit (LFL);
2. Airborne combustible dust at a concentration that meets or exceeds its LFL;
   Note: This concentration may be approximated as a condition in which the dust obscures vision at a distance of 5 feet (1.52 m) or less.
3. Atmospheric oxygen concentration below 19.5 % or above 23.5 %;
4. Atmospheric concentration of any substance for which a dose or a permissible exposure limit is published in subpart G, Occupational Health and Environmental Control, or in subpart Z, Toxic and Hazardous Substances (refer to §12-60-50(d)(3), HAR Exhibit A, and Exhibit B), of this part and which could result in employee exposure in excess of its dose or permissible exposure limit;
   Note: An atmospheric concentration of any substance that is not capable of causing death, incapacitation, impairment of ability to self-rescue, injury, or acute illness due to its health effects is not covered by this provision.
5. Any other atmospheric condition that is immediately dangerous to life or health.
   An atmosphere that contains a substance at a concentration exceeding the permissible exposure limit (PEL) intended solely to prevent long-term adverse health effects is not considered to be a hazardous atmosphere on that basis alone. 

If the atmosphere is above the PEL, then it would it is not classified as a “hazardous atmosphere.”

Important Note: §12-60-50(d)(1)(A), HAR requires all employers to measure, monitor, and record employee exposure to toxic materials or harmful physical agents. 

Engulfment means the surrounding and effective capture of a person by a liquid or finely divided (flowable) solid substance that can be aspirated to cause death by filling or plugging the respiratory system or that can exert enough force on the body to cause death by strangulation, constriction, or crushing.

Stop. Consult other applicable HIOSH standards.

Based on your input, this is not considered CONFINED SPACES. 

Stop. Consult other applicable HIOSH standards.

Based on your input, this is not considered PERMIT-REQUIRED CONFINED SPACES (PRCS). 

Based on your input, this is considered PERMIT-REQUIRED CONFINED SPACES (PRCS). 

You need to warn exposed employees of their location and hazards using danger signs or equally effective methods.

Note: An example of a sign reading “DANGER – PERMIT-REQUIRED CONFINED SPACE, DO NOT ENTER” or other similar language. 

Proceed to next question. 

Stop. Prevent unauthorized entry (as required by §1910.146(c)(3)). Employees do their task from outside of PRCS.

To prevent employees from entering the PRCS, Host Employer must:

• (c)(1) – evaluating and following the flowchart in Appendix A
• (c)(2) – warn exposed employees of their location and hazards using danger signs or equally effective methods. An example of a sign reading “DANGER – PERMIT-REQUIRED CONFINED SPACE, DO NOT ENTER” or other similar language. 
• (c)(6) – when changes in the use or configuration of a non-permit confined space that might increase hazards to entrants, then you must reevaluate the space and, if necessary, reclassify it as PRCS; and
• (c)(8) – when host employer has other employees perform work in the PRCS, then host must:
  • inform contractor it is PRCS and permit space entry is allowed only through compliance with Permit Space Program meeting the requirements of the standard;
  • apprise the contractor of the elements, including the hazards identified and the host employer’s experience with the space, that makes the space in question a PRCS;
  • Apprise the contractor of any precautions or procedures that the host employer has implemented for the protection of employees in or near permit spaces where contractor personnel will be working;
  • near permit spaces, as required by paragraph (d)(11) of this section; and
  • Debrief the contractor at the conclusion of the entry operations regarding the permit space program followed and regarding any hazards confronted or created in permit spaces during entry operations.

Based on your input, the task/activity in PRCS will be done by contractors’ employees. 

You, as the Host Employer, must inform contractor as required by §1910.146(c)(8):

• Inform contractor it is PRCS and permit space entry is allowed only through compliance with Permit Space Program meeting the requirements of the standard;
• Apprise the contractor of the elements, including the hazards identified and the host employer’s experience with the space, that makes the space in question a PRCS;
• Apprise the contractor of any precautions or procedures that the host employer has implemented for the protection of employees in or near permit spaces where contractor personnel will be working;
• Near permit spaces, as required by paragraph (d)(11) of this section; and
• Debrief the contractor at the conclusion of the entry operations regarding the permit space program followed and regarding any hazards confronted or created in permit spaces during entry operations.

The Contractor must obtain information from Host Employer as required by §1910.146(c)(9):

• Any available information regarding permit space hazards and entry operations from the host employer;
• Coordinate entry operations with the host employer, when both host employer personnel and contractor personnel will be working in or near permit spaces, as required by paragraph (d)(11) of this section; and
• Inform the host employer of the permit space program that the contractor will follow and of any hazards confronted or created in permit spaces, either through a debriefing or during the entry operation.

Proceed to next question. 

Based on your input, both Contractors and Host’s own employees will enter the PRCS. 

Therefore, coordinate entry operations as required by:

• §1910.146(c)(8)(iv) – Coordinate entry operations with the contractor, when both host employer personnel and contractor personnel will be working in or near permit spaces, as required by paragraph (d)(11) of this section; and
• §1910.146(d)(11) – Develop and implement procedures to coordinate entry operations when employees of more than one employer are working simultaneously as authorized entrants in a permit space, so that employees of one employer do not endanger the employees of any other employer;

Note: A PRCS Program must be developed and implemented if employer decides its own employees will enter PRCS. The program must meet §1910.146(d) requirements. 

Resources:

• OSHA Publication Protecting Construction Workers in Confined Spaces: Small Entity Compliance Guide (PDF)

Proceed to next question. 

Based on your input, the hazards in the PRCS can be eliminated. When this happens, the employer may choose to reclassify the space to non-PRCS using §1910.146(c)(7):

• If the permit space poses no actual or potential atmospheric hazards and if all hazards within the space are eliminated without entry into the space, the permit space may be reclassified as a non-permit confined space for as long as the non-atmospheric hazards remain eliminated.
• If it is necessary to enter the permit space to eliminate hazards, such entry shall be performed under paragraphs (d) through (k) of this section. If testing and inspection during that entry demonstrate that the hazards within the permit space have been eliminated, the permit space may be reclassified as a non-permit confined space for as long as the hazards remain eliminated.
  Note: Control of atmospheric hazards through forced air ventilation does not constitute elimination of the hazards. Paragraph (c)(5) covers permit space entry where the employer can demonstrate that forced air ventilation alone will control all hazards in the space.
• The employer shall document the basis for determining that all hazards in a permit space have been eliminated, through a certification that contains the date, the location of the space, and the signature of the person making the determination. The certification shall be made available to each employee entering the space or to that employee’s authorized representative.
• If hazards arise within a permit space that has been declassified to a non-permit space under paragraph (c)(7) of this section, each employee in the space shall exit the space. The employer shall then reevaluate the space and determine whether it must be reclassified as a permit space, in accordance with other applicable provisions of this section.

Note: The space may have to be evacuated and re-evaluated if hazards arise during entry.

Based on your input, the space can be maintained in a condition safe to enter by continuous forced air ventilation only.

For this to apply, §1910.146(c)(5) must be followed: 

• An employer may use the alternate procedures specified in paragraph (c)(5)(ii) of this section for entering a permit space under the conditions set forth in paragraph (c)(5)(i) of this section.

Note: The space may have to be evacuated and re-evaluated if hazards arise during entry.

1910.146(c)(5)(i)

Prepare for entry via Permit Procedures

Stop. Based on your input, acceptable entry conditions have not been verified. 

Permit not valid until conditions meet permit specifications. 

Stop. Based on your input, permit has not been issued with an authorizing signature and acceptable entry conditions were not maintained throughout entry.

• Emergency exists (prohibited condition). Entrants evacuated entry aborts. (Call rescuers if needed). Permit is void.
• Must reevaluate program to correct/prevent prohibited condition. Occurrence of emergency (usually ) is proof of deficient program.

Therefore, no re-entry until program (and permit) is amended. (may require new program). 

After above is met, then revisit #3 question. 

Based on your input, permits have been issued by authorizing signature and acceptable entry conditions are maintained throughout entry. 

• Entry tasks completed. Permit returned and canceled. 
• Audit permit program and permit based on evaluation of entry by entrants, attendants, testers and preparers, etc.