Confined Space- Site Safety

The Occupational Safety and Health

Administration or OSHA requires

employers to evaluate the workplace to

determine if any spaces or permit

required confined spaces this is

essentially a two-step process step one

identify all of your confined spaces and

step two determine which of those

confined spaces are permit required and

conversely which ones are not the focus

of this tutorial is on OSHA's definition

of a confined space employers must

evaluate all confined spaces in the

workplace even if they do not have

employees who will be entering those

phases also the permit required confined

space standard does not require

documentation of this evaluation however

it may be a good idea so what is OSHA's

definition of a confined space the OSHA

definition of a confined space can be

found at 1910 146 paragraph B

definitions there you will see the

confined spaces are characterized by

three criteria it is important to note

that all three criteria must be in place

for of space to be considered a confined

space also keep in mind that whether or

not a hazard is present inside the space

is not relevant at this point you are

only trying to identify confined spaces

the first criteria listed in OSHA's

definition of a confined space is the

space is large enough and so configured

that an employee can bodily enter and

perform assigned work the operative term

is bodily enter this means that the

employee can fit entirely inside the

space if the space is not large enough

for the employee to fit entirely inside

then the space does not meet the

definition of a confined space this

standard is only intended to apply to

spaces large enough

and configured so the entire body of an

employee can enter this is clarified in

the preamble to the final rule the

second criteria and OSHA's definition of

a confined space is the space has

limited or restricted means for entry or

exit contrary to popular belief this

does not mean that the space has only

one way in or out

it means the entrance ability to escape

in an emergency would be hindered

further explanation of this term is

provided by OSHA in the preamble to the

final rule and in the OSHA confined

space advisor they further explained

that a space would have a limited means

of entry or exit where the occupant must

crawl climb twist be constrained in a

narrow opening follow a lengthy path or

otherwise exert unusual effort to enter

or leave or where the entrance may

become sealed or secured against opening

from inside examples of a limited or

restricted means of entry or exit could

include portholes where the entrant must

squeeze through to enter or exit hatches

of a size or location that required the

entrance to climb or squeeze through

manhole openings that the entrant must

pass through to get into or out of the

space and entry ways where the worker

must climb a ladder to enter or exit the

space spiral stairways which are

difficult to climb or descend steep

stairways such as ships ladders and

other non-standard stairways tight crawl

spaces such as beneath equipment under

floors between walls and above some

seedlings and enclosed spaces where the

worker must travel a long distance to

get to the means of exit

the question often arises as to whether

or not OSHA considers a standard sized

doorway to be a limited or restricted

means of entry or exit in the preamble

to the permit require confined space

standard OSHA states that doorways and

other portals through which a person can

walk are not to be considered a limited

means of entry or exit however a space

containing such a door or portal may

still be deemed a confined space if an

entrance ability to escape in an

emergency would be hindered OSHA further

clarifies their position and a later

amendment published in the Federal

Register where they state that even if

the door or portal of a space is of

sufficient size obstructions inside the

space could make entry into or exit from

the space difficult the agency intended

that spaces which otherwise meet the

definition of a confined space and which

have obstructed entry or exits even

though the portal is a standard sized

doorway be classified as confined spaces

the third and final criteria listed in

OSHA's definition of a confined space is

the space is not designed for continuous

employee occupancy for example this

particular utility vault has not been

designed with any safeguards for

entrance so at a minimum workers would

have to utilize a portable blower

auxilary lighting and a portable gas

detector before entering this space on

the other hand this fully functioning

submarine is designed for continuous

employee occupancy so it would not be

considered a confined space so in review

here is a recap of the three criteria

listed in OSHA's definition of a

confined space number one the space is

large enough and so configured that an

employee can bodily enter and perform

assigned work and number two the space

has limited or restricted means for

entry

or exit and number three the space is

not designed for continuous employee

occupancy as a reminder all three

criteria must be present for the space

to be considered a confined space we

will now look at some examples of

confined spaces however you must keep in

mind that while these are confined

spaces they may not be permit required

confined spaces that will be determined

at a later time using additional

criteria tanks of many configurations

are considered confined spaces as our

most silos and similarly constructed

storage bins air handler units and

associated equipment are often

constructed of a size and configuration

that make them a confined space as would

be any ductwork large enough to be

bodily entered many smokestacks are

confined spaces as would be many

chimneys and escalator pits of a size

large enough for the employee to bodily

enter would also be considered confined

spaces some mixers such as this mobile

concrete mixing drum are confined spaces

as are many types of boilers large

furnaces and associated equipment often

qualify as confined spaces as do tanks

affixed to trailers or to rail cars and

many trash compactors are configured to

be confined spaces as are some material

Baylor's and as previously mentioned

many crawl spaces beneath floors and

equipment between walls and above some

ceilings are considered confined spaces

as well most sanitary sewer systems are

confined spaces as our sewer lift

stations and digesters some storm drains

and culverts are confined spaces as our

many septic tanks utility vaults and

pipelines of various sizes

one commonly overlooked type of confined

space is dock levelers of the variety

that have a front cover that lifts to

where a worker could crawl inside and is

previously mentioned some utility

tunnels could be considered confined

spaces as would be some attic spaces and

open top pits and many conveyor tunnels

are confined spaces as are some elevator

pits these are but a few examples of

confined spaces that are present in some

workplaces and there are many that we

have not identified in this short

tutorial so you are encouraged to use

your knowledge of the OSHA definition of

a confined space to identify all of the

confined spaces present in your

workplace as this is the first step you

will need to take so you can determine

which or permit required confined spaces

and conversely which ones are not