Duties and Responsibilities of Permit-Required Confined Space Entry Team Members

Permit-required confined space entry is a team effort. Entry team members need to understand the duties and follow the rules.

• By Bob Henderson
• May 01, 2003

OSHA's 29 CFR 1910.146, "Permit Required Confined Spaces," contains the requirements for practices and procedures to protect employees in general industry from the hazards of entry into permit-required confined spaces. 1910.146 is a horizontal standard that applies to a wide variety of industries and employer activities. While it's important to note that certain industries such as telecommunications (29 CFR 1910.268), construction (29 CFR 1926.21), or shipyard employment (29 CFR 1915 Subparts A and B) have their own "vertical" standards, which take precedence over the general standard, it is 1910.146 that governs the most confined space activities and provides the most comprehensive requirements for how to structure confined space programs.

Confined Space Definition
A confined space is characterized by the simultaneous existence of three conditions:
(1) It must be large enough and so configured that it is possible for a person to bodily enter and perform work.
(2) It has limited or restricted means for entry and exit.
(3) It is not designed for continuous employee occupancy.

Confined spaces include everything from railroad tank cars to sewers, boilers, open topped pits, aircraft wing tanks, fuel storage tanks, vaults, manholes, elevator pits, and many other common workplace environments. Just because a space meets the basic confined space definition, however, doesn't automatically trigger any special workplace procedure beyond those for similar activities undertaken in any other non-confined space environments.

Non-permit confined spaces are by definition not associated with any additional serious safety hazards. On the other hand, many confined spaces are associated with serious safety hazards and require special procedures to ensure worker safety. In addition, it is important always to remain on the lookout for conditions or activities that may change the dangers associated with a non-permit space. Activities such as hot work, using degreasers, or painting may introduce additional potential hazards that change the classification of the space from a non-permit to a permit-required confined space (PRCS).

A permit-required confined space (or permit space) is a confined space that contains hazards capable of causing death or serious physical harm. Besides the basic three conditions common to all confined spaces, a permit-required confined space contains at least one additional serious or recognized danger such as:
(1) It has the potential to contain or generate a hazardous atmosphere, (such as oxygen deficiency from rusting metal, combustible methane from decomposing leaves or debris, or hydrogen sulfide from sewage).
(2) The space contains a material that has the potential for engulfing an entrant, (anything from water to mud, to wood chips, to molasses).
(3) Its internal configuration is such that an entrant could be trapped or asphyxiated by inwardly converging walls or by a floor that slopes downward and tapers to a smaller cross-section (such as many bins, chutes and dust collectors).
(4) Or any other recognized serious safety or health hazard exists (from rotating blades or vanes to poisonous snakes).

Once the environment has been identified as a permit space that contains at least one additional serious safety hazard, the next question is what to do about it. There is more than one option. In some cases, the employer may elect to permanently secure the space to prevent entries. Because the space is no longer subject to entry, there is no need to develop procedures governing entry into the space. In other cases, entry into the permit space can't be avoided.

Employers have three options for procedures for entering permit spaces:
1. Reclassification. In some cases, it may be possible to completely eliminate all hazards from the space without having to enter the space in order to do so. In this case, it may be possible to reclassify the PRCS as a non-permit space. Once again, non-permit spaces are confined spaces but do not require a permit for entry, because the hazards have been eliminated. The reclassification continues only as long as all hazards remain eliminated.

2. Alternate Entry Procedures. In cases where the only hazards are exclusively atmospheric in nature and where continuous forced air ventilation alone is sufficient to maintain the permit space safe for entry, entry may be by means of the "Alternate Entry Procedures" contained in paragraph (c) (5) (ii) of the standard. The alternate entry procedures require that before employees enter, the internal atmosphere must be tested for:
(1) Oxygen content,
(2) Flammable gases and vapors, and
(3) Potential toxic air contaminants.

Once testing has been completed, the atmosphere within the space must be periodically tested to ensure the atmosphere remains safe for the entrants. There must be no hazardous atmosphere within the space when an employee is inside the space. If a hazardous atmosphere is detected during entry, employees must exit immediately, the space must be evaluated, and corrective measures must be taken.

When entries are undertaken by means of the Alternate Entry Procedures, there are no requirements for a written program, permit system, attendant, supervisor, or rescue provisions. Solo entries are permitted. The emphasis is squarely on use of continuous ventilation and atmospheric monitoring to ensure atmospheric hazards are controlled and that the atmosphere remains safe for entry. Because of the reliance on atmospheric monitoring to verify that conditions remain safe, OSHA has established a guideline of 50 percent of the level of flammable or toxic substances that would normally constitute a "hazardous atmosphere" as a safe level for entry using the Alternate Entry Procedures. As an example, a concentration of 5 percent LFL combustible gas, or half the PEL concentration of a toxic gas, would represent a hazardous atmosphere per the Alternate Entry guidelines.

3. Permit Space Entry procedures. If the hazard cannot be eliminated or controlled, then the only remaining option for entry is the implementation of a comprehensive permit space program.

Paragraph (c) (4) of the standard requires employers whose employees enter permit spaces to establish a written permit space program (permit program). Employers must make this written program available to employees and their authorized representatives. The written program includes specific details regarding how the employer will comply with each of the requirements of 1910.146. Employer obligations include:
(1) To secure permit spaces to prevent unauthorized entry.
(2) To evaluate and identify hazards before entry.
(3) To implement operation procedures that ensure safe entry.
(4) To provide and maintain the necessary equipment.
(5) To evaluate PRCS conditions.
(6) To provide attendant(s).
(7) To develop and implement the specific methods to be used if attendants are responsible for monitoring more than one PRCS at the same time, or if an emergency occurs.
(8) To designate the roles and responsibilities of all active PRCS entry team personnel.
(9) To develop and implement effective rescue and emergency procedures.
(10) To develop and implement an entry permit system.
(11) To develop and implement procedures to coordinate entry operations when employees of more than one employer will enter a PRCS.
(12) To develop and implement procedures for concluding an entry.
(13) To periodically review entry operations.
(14) To periodically review the permit space system.

One of the most important goals of the confined space program is to clarify the responsibilities of the confined space entry team members. Employers must assign clear roles and duties to persons involved in PRCS entry and provide training to allow employees to carry out their duties.

It is mandatory that all of the employees who work with permit spaces are fully trained before performing assigned duties. Employees must be able to demonstrate proficiency in performing their assigned tasks and have the necessary understanding, knowledge, and skills to safely perform their duties. Paragraphs (h), (i), and (j) of the standard specify the duties of authorized entrants, attendants, and entry supervisors.

Duties of the Authorized Entrant
The duties of the authorized entrant are specified in paragraph (h). Authorized entrants are employees who are authorized by the employer to enter a permit space. Authorized entrants must:
(1) Know the hazards associated with confined space entry, and in particular, the hazards associated with the PRCS being entered.
(2) Know how to use all required equipment.
(3) Know the procedures for communication with the attendant.
(4) Know how to alert the attendant of hazardous or prohibited conditions.
(5) Know how to exit the space if necessary (that is, self rescue).

Duties of the Attendant
Paragraph (i) specifies the duties of the attendant. At least one attendant must be present outside the PRCS during the entry. The attendant role is frequently seen as a low-grade responsibility anyone can perform. In reality, the attendant has more duties listed than either the authorized entrant or the entry supervisor. The attendant must:
(1) Know the hazards.
(2) Know the behavioral effects of the hazards.
(3) Be able to identify the authorized entrants.
(4) Remain outside until relieved.
(5) Communicate with entrants.
(6) Monitor and evacuate entrants if necessary.
(7) Summon rescue.
(8) Warn away unauthorized persons.
(9) Be able to perform non-entry rescues.
In addition, the attendant may not undertake any additional duty that might interfere with these primary safety-related duties.

Duties of the Entry Supervisor
The duties of the entry supervisor are specified in paragraph (j). The entry supervisor is responsible for determining whether acceptable entry conditions exist, authorizing the entry, overseeing entry operations, terminating the entry, and canceling the entry permit. The entry supervisor represents the employer and is accountable for entry operation safety. If the entry supervisor is properly trained and equipped, he or she may also serve as an authorized entrant or attendant. The entry supervisor must:
(1) Know the hazards.
(2) Verify safe entry conditions.
(3) Terminate entry and cancel permit.
(4) Verify availability and effectiveness of rescue services.
(5) Remove unauthorized persons.
(6) Ensure acceptable entry conditions are maintained.

Duties of Persons Who Test or Monitor the Atmosphere
Paragraph (d)(8) also requires the designation and identification of other people who have an active role in the PRCS entry; for example, persons who test or monitor the atmosphere in a permit space. Although this important role is not specifically called out in the standard, OSHA has suggested guidelines for the responsibilities of these individuals, as well. They are responsible for:
(1) Correctly using the instruments used to monitor or verify the atmosphere of the PRCS is safe for entry.
(2) Verify the instrument(s) used are calibrated and maintained in accordance with manufacturers' and written PRCS program procedures.
(3) Verify the instruments used to monitor the PRCS are functioning properly.
(4) Taking appropriate measures in the event a hazardous or prohibited condition is detected.

Permit space entry team members can function effectively and safely only when they fully understand their responsibilities and duties. Thorough training is essential. Permit spaces are by definition inherently dangerous. Mistakes are "Not Permitted!"

This article originally appeared in the May 2003 issue of Occupational Health & Safety.