Confined Spaces: A Manager’s View

Protect yourself and your employees from confined spaces hazards

• By Randy DeVaul
• May 01, 2025

The topic of confined spaces never goes away. The fact that people continue to die from entering confined spaces shows the need for ongoing reminders on how to identify and conduct entries into those spaces. In simple terms, we will discuss confined spaces, the role of the authorizing supervisor and manager, and the impact that role has on front-line employees who are expected to work within those spaces. 

Defining Confined Spaces 

As an experienced safety professional of 40+ years, I am still struck by how much confusion there is around confined spaces. So, let’s start with the basics so we are all understanding the topic the same way. 

Let’s review the definition of a confined space. A basic confined space is defined by meeting three criteria: 

• The space has limited ingress/egress; 

• The space is large enough for a person to perform work inside it; 

• The space is not designed for continuous human occupancy. 

All three of these criteria must exist for it to be a confined space. Briefly, this means that there is generally only one way in and out of the space—whether a ladder, restricted doorway, etc. 

The space must be large enough for a person to physically fit inside it to perform work. The space is not ventilated climate-controlled, likely has no or limited lighting, no plumbing fixtures, etc. 

Examples of what a confined space is NOT: 

• A portable office or cubicle inside a maintenance shop or warehouse, though it has one door in/out, is not a confined space as it will normally have heating/air conditioning, lights and light switches, electrical receptacles, etc. 

• A tank with a 4-inch hinged panel to visually inspect or read a gauge or to turn a valve handle is not a confined space since a person cannot fit through a 4” hole. 

• An attic, basement, or storage shed/barn accessed by a single ladder or stairway or single door is not a confined space because of its design. 

Permit-Required Confined Space (PRCS).  

First, a space cannot be a permit-required space unless it meets the initial definition of a ‘confined space.’ Entering a storage unit after some type of chemical spill may suggest a hazard. It does not change the space to a PRCS if it was never ‘confined’ in the first place. Entering it would be no different than addressing any other workplace hazard when working around machinery, pressurized lines, etc. Precautions are taken but a permit is not required to be there. 

So, a Permit-Required Confined Space is: 

• A ‘confined space’ by definition, and contains or has the potential to contain one or more of: 

• Atmospheric hazards (flammable vapors, toxic vapors, too little/too much oxygen), or 

• Physical hazards (unguarded machinery, excessive noise/heat/cold), or 

• Engulfment or entrapment hazards, or 

• Other hazards not otherwise listed that can cause death or serious injury (exposed energized wires, high-pressure fluids) 

In other words, the space is confined (meeting all three criteria in the definition) and has at least one life-threatening or life-ending hazard that requires attention prior to entry. 

Training Requirements 

All employees engaged in entry, attending, working in, and supervising work in a confined space must be trained in the hazards, potential hazards, the task being performed, emergencies, duties and responsibilities of entrants, attendants, and authorizing supervisors, and the use of monitoring and communication equipment. 

It’s key to understand potential hazards. When performing tasks in a confined space, it’s important to know what potential hazards could enter the space. It may not readily contain toxic vapors, but welding above the entry point may lead to toxins sinking into the space. Employees and authorizing supervisors need to look for such potential hazards every time and entry is being made. Knowing how to properly conduct risk assessments before each entry will help reveal those hazards. 

Authorizing Supervisors 

One of the requirements of entering a permit-required confined space (PRCS) is completing a space permit application. This is to be performed by those entering the space. Once completed, the application is reviewed and signed by an entry-authorizing supervisor. 

A designated authorizing supervisor doesn’t have to be a supervisor by position, but he or she is accountable and responsible for the lives of confined space entrants. That may sound a bit dramatic, but it’s accurate. For that reason, many companies expect the “authorizing supervisor” to be a supervisor by position. 

When reviewing a permit application, the authorizing supervisor must do more than just read through it. He or she is responsible for physically walking through the application, visually ensuring all controls and protective measures have been done and that the air monitoring readings are safe for entry.  

In a nutshell, it is the authorizing supervisor who is the final check, the one who ensures all measures were taken and that nothing was overlooked that could endanger the entrants. Signing off on the permit application means he or she is convinced that entry is safe, that an assigned attendant is ready, that emergency procedures and/or responders are in place, and that the permit is posted. 

The authorizing supervisor must be prepared to hold the team accountable with following permit-entry protocols. There is no room for condoning or ignoring shortcuts, pencil-whipping the application, or allowing variations in protective measures.  

The authorizing supervisor’s manager has a role, as well, ensuring the supervisor is properly trained and fulfills his or her responsibilities. 

Evaluating Confined Spaces 

Confined space standards require that each space be identified, listed, and evaluated annually for changes in potential hazards or classifications. Know the definitions and classify spaces, based on the definitions. This is a critical step to ensure the confined space program is successful. Failure to classify spaces properly leads to shortcuts and preventable deaths! 

Employers who choose to classify all “confined spaces” as permit-required spaces do so at great risk. Whether it’s thinking this decision provides greater safety or there is confusion on what a real confined space is, the results create confusion, apathy, and complacency in hazard recognition. 

When all confined spaces are classified as permit-required, employees soon recognize the “stupidity” of it all—the extra work of completing an application and all the required actions of air monitoring to taking an extra person to post as an attendant when there is no life-threatening hazard, to mis-classifying work areas as confined spaces because of normal work-related hazards (lockout/tagout, need for respirators or dust masks, etc.). 

This one decision alone sets your team up for failure. It encourages shortcuts and generates apathy toward all confined spaces, including the dangerous ones. 

Conclusion 

Confined spaces can be deadly. Knowing how to identify and properly classify a confined space is critical to ensuring the right protocols and practices are followed. Authorizing supervisors and managers are responsible for ensuring the team is properly trained and follows safe practices while serving as the final link between an entrant staying safe and healthy or being exposed to life-threatening hazards. 

Confined space deaths are preventable. Do not under-value your role and responsibilities regarding the safety and health of your team. Don’t be the person with life-long regret or guilt because of being the weakest link in the program. 

This article originally appeared in the April/May 2025 issue of Occupational Health & Safety.