Permit-required confined spaces pose increased risk of exposure to serious physical injury or death from hazards including entrapment, engulfment, and hazardous atmospheric conditions to employees. Without the proper equipment, procedures, or knowledge, a worker exposed to hazardous atmospheric conditions in a confined space could experience brain damage or death in four minutes. The OSHA standard 29 CFR 1910.146 provides regulations to protect employees entering permit-required confined spaces. Is your workplace fully compliant with the OSHA standard?

1. Complying with OSHA’s
Regulations for Permit-Required
Confined Space Entry
Alex Rutledge, Environmental Health and Safety Consultant
Triumvirate Environmental

2. Meet Your Moderator
2
Nita Vaidya

3. 3
During This Webinar
✓ All lines will be muted.
✓ Communicate via the questions tab in your webinar panel.
✓ Unanswered questions will be responded to personally after the
webinar.
✓ Webinar recording and slides will be emailed to you tomorrow.

4. Alex Rutledge
Environmental Health and Safety Consultant
Triumvirate Environmental
4
Meet Your Presenter

5. Agenda
5
Overview of Confined Space Standard
Evaluate Your Spaces
Entry Options
PRCS Program
Q&A

6. The Standard
• Promulgated in 1993 – OSHA
▪ Non-existent/non-mandatory previously
• 29 CFR 1910.146
• Comprehensive framework to protect employees
who enter PRCS though…
▪ Written programs
▪ Permit systems
▪ Measures necessary for safe operations
▪ Emergency response
6
Permit Required Confined Spaces, DOL; 11/28/1991; https://www.osha.gov/laws-regs/federalregister/1994-11-28
29 CFR 1910.146(b)

7. The Statistics
• 2.1 million workers enter permit-required confined spaces
(PRCS) annually
▪ Routine maintenance, repairs, and inspections
• 166 fatalities in 2017
▪ 144 in 2016 (15% increase)
• Common themes include:
▪ No written program
▪ Atmospheric hazards (H2S and CO)
▪ Lack of, or improper, training for employees
7
National Census of Fatal Occupational Injuries in 2017; Bureau of Labor Statistics, 12/18/2018; https://www.bls.gov/news.release/pdf/cfoi.pdf
We Must Change the Statistics of Confines Space Injuries and Fatalities; OHS Online, 08/01/2018; https://ohsonline.com/Articles/2018/08/01/

8. Agenda
8
Overview of Confined Space Standard
Evaluate Your Spaces
Entry Options
PRCS Program
Q&A

9. What is a Confined Space?
OSHA defines confined space as a space that is:
1. Large enough for bodily entry
2. Restricted or limited entry / egress
3. Not designed for continuous occupancy
9 29 CFR 1910.146(b)

10. What is a Confined Space?
Examples:
• Tanks
• Silos
• Pits/Manholes
• Underground storage
• Vaults
• Ditches
• Crawl spaces
10 29 CFR 1910.146(b)

11. Types of Confined Spaces
Confined spaces can be classified into three main types:
1. Non-Permit Required
2. Temporary Permit-Required
3. Permit-Required
Employers are required to evaluate all spaces to determine if
they are permit-required confined spaces
11 29 CFR 1910.146(b)
29 CFR 1910.146(c)(1)

12. Poll Question
Do you understand the
OSHA definition of a permit-
required confined space?
12

13. Non-Permit Required Confined Spaces
Non-PRCS are confined spaces that
• Contain no potential or actual hazards
capable of causing death or serious
harm
• Signs, permits, or special precautions
are not required to enter non-PRCS
• However, conditions may arise that
causes a non-PRCS to temporarily
become a permit-space
13 29 CFR 1910.146(b)

14. Temporary Re-Classification
• If conditions change within a non-PRCS, employers must
re-classify the space as permit-required as long as the
hazard(s) is present
• Example:
▪ A non-PRCS is entered by an employee
▪ Employee cleans inside with a alcohol
▪ Creates a hazardous atmosphere
▪ Temporarily becomes a PRCS
14 29 CFR 1910.146(c)(6)

15. Permit-Required Confined Space
(PRCS)
Confined spaces that have one or more of the following characteristics:
• Actual or potential hazardous atmosphere
• Engulfment or entrapment
• Internal configuration that can trap or asphyxiate
• Other serious hazards (no specific definition)
▪ Electrical
▪ Mechanical
▪ Temperature
▪ Noise
▪ Falling objects
15
IT ONLY TAKES ONE TO TRIGGER THE PRCS DEFINITION!
29 CFR 1910.146(b)

16. PRCS Characteristics - Atmosphere
1. Flammable gasses, vapor, or mist >10% LEL
▪ Lower Explosive limit
- Concentration required to ignite
2. Combustible dust ≥ its LEL
▪ 5-foot rule of thumb
3. Oxygen deficient
▪ >23.5% or <19.5%
4. Toxic substances >PEL
▪ Permissible exposure limits
5. Immediately dangerous to life or health (IDLH)
16 29 CFR 1910.146(b)

17. PRCS Characteristics - Engulfment
Engulfment is defined as:
• When an employee becomes
surrounded or captured by solids or
liquids that can cause death by…
▪ Filling or plugging lungs
▪ Strangulation
▪ Constriction or
▪ Crushing
▪ Examples include flour, cement, pellets, or
water/sludge
17 29 CFR 1910.146(b)
Grain Bridge Collapse and Entrapment, NASD; http://nasdonline.org/4100/i000005/grain-bridge-collapse-and-entrapment-gif.html

18. PRCS Characteristics - Configuration
A confined space that contains
• “an internal configuration such that an
entrant can be trapped or asphyxiated
by inwardly converging walls or by a
floor that slopes downward and tapers to
smaller cross-section”
• Examples
▪ Hoppers
▪ Cyclones
18 29 CFR 1910.146(b)

19. Falling Objects
Electrical
PRCS Characteristics – Other Hazards
Mechanical
Noise
• Permit-required confined space standard applies when a safety
or health hazard is serious enough to inhibit an entrant’s ability
to rescue themselves
• Examples:
19
Falls
Temperature
Biological

20. Inform Your Employees
After all spaces have been evaluated as permit or non-permit,
you must effectively inform your employees of the:
1. Existence
2. Location; and
3. Dangers of all permit-required confined spaces
20 29 CFR 1910.146(c)(2)

21. Inform Your Employees
This can be accomplished through…
• Posting signs, such as
• Securing/restricting entry with a barricade
• Or training employees who are
reasonably anticipated to enter the space
21 29 CFR 1910.146(c)(2)
THE GOAL IS TO INFORM YOUR EMPLOYEES

22. Entering a PRCS
After evaluating your spaces, you must decide if employees will
enter the space
22
No Entry Prevent EntryPost Signs
Inform
Contractors
Entry
Evaluate
Spaces
Options
Maintain
Safety
Emergency
Preparedness

23. Agenda
23
Overview of Confined Space Standard
Evaluate Your Spaces
Entry Options
PRCS Program
Q&A

24. No Entry Requirements
If you decide your employees are not going to enter PRCS
• Effectively communicate this policy through training
• Inform employees of their existence, location, and hazards
• Ensure they do not enter
If you decide contractors will enter PRCS
• Inform them of existence, location, and hazards of permit-
spaces
• Ensure entry is compliant with a permit-space program
• Debrief upon completion of work
24 29 CFR 1910.146(c)(3)
29 CFR 1910.146(c)(8)

25. Options for Entry
If you decide your employees are going to enter PRCS:
1. Enter using alternate procedures – 1910.146(c)(5)
2. Enter by reclassifying as a NPRCS – 1910.146(c)(7)
3. Enter under an entry program – 1910.146(c)(4)
25

26. Entering Under Alternate Procedures
Alternate procedures can be used:
• Only for PRCS with atmospheric hazards that can be
maintained “safe-for-entry” with continuous forced-air ventilation
▪ ½ the hazardous level (5% LEL, PEL/2, etc.)
▪ Requirements for ventilation discussed later
• No physical hazards to eliminate
• Permit, attendants, supervisor or rescue are not required if
conditions are met
26 29 CFR 1910.146(c)(5)

27. Alternate Procedure Requirements
To enter under 1910.146(c)(5), employers must
• Test internal atmosphere
▪ 02 ,LEL, and toxics
▪ Calibrated direct-reading instrument (discussed later)
• Certify the space is safe in writing
▪ Including the location, date, and signature
27 29 CFR 1910.146(c)(5)
COMPLETED PRIOR TO ENTRY AND MAINTAINED

28. Options for Entry
If you decide your employees are going to enter PRCS:
1. Enter using alternate procedures – 1910.146(c)(5)
2. Enter by reclassifying as a NPRCS – 1910.146(c)(7)
3. Enter under an entry program – 1910.146(c)(4)
28

29. Entering Under Reclassification
Another option is to reclassify the space as non-permit
• Only for PRCS that pose no potential/actual
atmospheric hazards
• All other hazards must be “isolated” or completely
protected against release of energy and materials
29 29 CFR 1910.146(c)(7)

30. Reclassification Requirements
To enter under 1910.146(c)(7), employers must
• Isolate hazards by
▪ Blanking or Blinding
▪ Removing sections of ducts, lines, or pipes
▪ Double block and bleeding; or by
▪ Locking-out/tagging-out all energy sources
• Certify the space is safe in writing
▪ Including the location, date, procedure(s) used, signature
30 29 CFR 1910.146(c)(7)

31. Options for Entry
If you decide your employees are going to enter PRCS:
1. Enter using alternate procedures – 1910.146(c)(5)
2. Enter by reclassifying as a NPRCS – 1910.146(c)(7)
3. Enter under an entry program – 1910.146(c)(4)
31

32. Agenda
32
Overview of Confined Space Standard
Evaluate Your Spaces
Entry Options
PRCS Program
Q&A

33. Permit Required Confined Space Entry
Program
If alternative entry and re-classification are not feasible, employers
must develop a written permit space program that contains:
• Means for preventing unauthorized access (previously discussed)
• Identification of hazards
• Required procedures
• Equipment required
• Responsibilities
• A permit system; and
• Training
33

34. Inventory of permit-required spaces that
includes:
• An initial evaluation of hazard(s)
• Pre-entry requirements for that space; and
• Subsequent evaluation(s)
▪ Changes to the space during work
Identification of Hazards
34
Electrical
Mechanical
Noise
Falls
Falling Objects
Temperature
Biological
29 CFR 1910.146(d)(2)
REMEMBER TO INCLUDE ALL ACTUAL AND
POTENTIAL HAZARDS

35. Procedures
Programs must include the means,
procedures, and practices necessary for
safe-entry, including but not limited to:
• Acceptable entry conditions
• Testing/monitoring data
• Isolation/LOTO procedures
• Control of hazardous atmosphere; and
• How hazards will remain controlled
throughout the duration of entry
35 29 CFR 1910.146(d)(3)

36. Equipment
General requirements for equipment include:
• Provision at no cost to employees
• Maintained sufficient for use
• Ensure proper training for employees
36 29 CFR 1910.146(d)(4)

37. Equipment
Atmospheric testing monitors
• Direct reading instruments
• Alarm/emergency instruments
• Gas Detectors (multi, single, etc.)
37 29 CFR 1910.146(d)(4)

38. Equipment
Ventilation
• Forced air blowers
▪ Fresh air blown into space
• Exhaust (extraction) fans
▪ Contaminated air is removed
38 29 CFR 1910.146(d)(4)

39. Communication devices/systems
• Walkie-talkie, signaling devices,
verbal, etc.
Personal Protective Equipment
• Gloves, eye/face, body,
respiratory (1910.134)
39
Equipment
29 CFR 1910.146(d)(4)

40. Equipment
Adequate lighting to work safely
• In dimly lit spaces
Barriers or shields
• Internal or external hazards
Ingress and Egress
• Ladders
40 29 CFR 1910.146(d)(4)

41. Equipment
Rescue and emergency equipment
• Lifelines
• Harnesses
• Tripods
41 29 CFR 1910.146(d)(4)

42. Responsibilities / Duties
Employers with PRCS Programs
must designate responsibilities for
each of the following
• Authorized Entrants
• Attendants
• Entry Supervisors
• Rescue and Emergency
42 29 CFR 1910.146(h-k)

43. Authorized Entrants
• Understand the hazards
• Properly use equipment
• Communicate
• Evacuate when necessary
• Attend training
43
Responsibilities and Duties
29 CFR 1910.146(h)

44. Responsibilities and Duties
Attendants
• Understand hazards including
over-exposure symptoms
• Conduct headcount
• Communicate
• Monitor activities (in and out)
• Order evacuations
• Summon emergency response
44 29 CFR 1910.146(i)

45. Responsibilities and Duties
Attendants
• Prevent unauthorized access
• Perform non-entry rescue
• Attend training
• Does not
- Leave space unattended
- Enter the space
- Engage in other tasks/distractions
45 29 CFR 1910.146(i)

46. Responsibilities and Duties
Entry Supervisors
• Understand hazards and over-
exposure symptoms
• Verify permit
• Ensure rescue/emergency
services available
• Prevent unauthorized access
• Ensure adequate conditions
46 29 CFR 1910.146(j)

47. Responsibilities and Duties
Entry Supervisors
• Terminate/cancel permits when
work is finished
• Attend training
• May act as attendant or entrant
▪ Cross-trained
▪ Capable of performing functions
47 29 CFR 1910.146(j)

48. Responsibilities and Duties
Onsite Rescue/Emergency Team
• Equipped, trained and proficient
in use of rescue PPE and
equipment
• Must be trained to entrant
responsibilities/duties
• Basic CPR and first aid
▪ 1 member must be certified
• Annual mock rescues
48 29 CFR 1910.146(j)

49. Responsibilities and Duties
Outside Rescue/Emergency
Crew
• Evaluate your need for an
outside service - onsite rescue
teams require advanced training
and equipment
49 29 CFR 1910.146(j)

50. Permit Requirements
Employers must develop a system for
issuing permits that describes all
information about the space
• Permits must be written, signed, and
posted prior to entry into PRCS
• Detail the time and task(s); and
▪ Cancelled when complete (kept for 1
year)
50 29 CFR 1910.146(e-f)

51. Permit Requirements
Permits must include
• The space to be entered
• Names of employees entering
▪ Authorized entrants, attendants, supervisor
• Hazards (actual and potential)
• Isolation procedures
• Acceptable conditions to enter the space
▪ Including monitoring data (initial and continuous)
• Means for summoning emergency rescue
• Means of communication (entrants and attendants)
51 29 CFR 1910.146(f)

52. Permit Requirements
• Equipment
▪ PPE, ventilation, rescue, etc.
• Description of additional permits
▪ hot work, special permits, etc.
• Must be revised or re-issued if
changes occur
• Example permit found in 1910.146
Appendix D
52 29 CFR 1910.146(f)

53. Training Requirements
• Understanding, knowledge, skills necessary to perform duties
safely
▪ Authorized entrants, attendants,
supervisors
• Prior to conducting duties
• Changes in duties
• New/changes in hazards
• Must establish proficiency
• Employer must certify
53 29 CFR 1910.146(g)

54. Poll Question
Is your facility fully compliant
with OSHA’s regulations
regarding permit-required
confined spaces?
54

55. Agenda
55
Overview of Confined Space Standard
Evaluate Your Spaces
Entry Options
PRCS Program
Q&A

56. Questions?

57. THANK YOU!
CONTACT US!
1-888-834-9697
Alex Rutledge: arutledge@triumvirate.com