Confined Spaces Series – Part 2: OSHA Standards & Key Terminology

In the first part of this three-part series on confined spaces we introduced you to some of the grim statistics for confined spaces, talked about the numerous standards and provided two tools to help make understanding the standards a bit easier.

This is part two of a three-part series on confined spaces.
Part one covered key statistics, applicable standards, and tools to simplify understanding. Part two focuses on OSHA terminology, space classification, the reclassification process, and new templates and tools from EHS Insight to support the entire process.

To Be or Not To Be….A Confined Space

A common confusion point in confined space standards is understanding what constitutes a confined space and the different types — largely because many people overlook that classification is a two-step process.

The first step is simply determining whether a space meets the criteria for being a confined space at all — hazards and permits are evaluated in the next step.

To make this determination, there are three criteria that all must be present within a space for that space to be considered a confined space:

The space must:

• Be large enough and so configured that an employee can bodily enter and perform assigned work; and
• Have limited or restricted means for entry or exit (for example, tanks, vessels, silos, storage bins, hoppers, vaults, and pits are spaces that may have limited means of entry.); and
• Not be designed for continuous employee occupancy

If a particular space doesn’t meet all three criteria, it’s not a confined space and doesn’t need further evaluation. However, if it does meet all three criteria, the space should be classified as a confined space and will require an additional classification step (which we’ll get to later).

EHS Insight's Confined Spaces Identification and Documentation tool helps users evaluate and document all potential confined spaces in one place.

By answering three simple questions per space, users receive an immediate determination of whether a space qualifies as a confined space — and a complete record of the assessment for future reference.

Now, let’s talk about terminology for a minute and look at an example of how a misinterpretation can change the way a space is classified.

It’s Just Semantics…Or Is It?

The three criteria for confined spaces may seem straightforward, but misinterpreting OSHA's terminology can directly affect how a space is classified.

For example, the first criterion requires that a space be "large enough and so configured that an employee can bodily enter and perform assigned work" — but what does it mean to "bodily enter" a space?

It’s easy to get confused because when looking at the other two criteria of having limited or restricted means for entry and exit and also not being designed for continuous human occupancy, this can lend itself to the idea that to “bodily enter” a space is referring to an employee’s whole body—but that’s incorrect. OSHA defines “bodily enter” as:

“The action by which a person passes through an opening into a permit-required confined space. Entry includes ensuing work activities in that space and is considered to have occurred as soon as any part of the entrant's body breaks the plane of an opening into the space.”

Here are two examples of how important this understanding is to the classification process and what can happen if it’s not interpreted as OSHA intended.

Scenario: a bin vent on top of a silo has a small access door used to change filters, allowing only an employee's hands, head, and upper body to enter.
How the employer interprets "bodily enter" will directly determine whether this space is classified as a confined space.

Example 1: If the employer considers “bodily entering” to mean an employee’s whole body, then based on the space’s configuration, the employer will not consider it a confined space—which is incorrect.

Example 2: If the employer considers “bodily entering” to mean when any part of an employee’s body breaks the plane of the space, the space will have met all three criteria and will therefore be properly classified as a confined space.

Misclassifying spaces due to misunderstood terminology is one of the primary reasons confined space incidents turn fatal.

OSHA may leave some things open to interpretation — but the terminology used to classify confined spaces is not one of them.

What Kind of Confined Space Is It?

Once the first part in the classification process has been completed and all the true confined spaces have been identified and documented, the next step is to individually evaluate each of those confined space to determine whether the space is going to require an entry permit or not.

For a confined space to require an entry permit, the space must include one or more of the following characteristics:

1. Contain or have a potential to contain a hazardous atmosphere;
2. Contain a material that has the potential to engulf an entrant;
3. Have an internal configuration such that an entrant could be trapped or asphyxiated by inwardly converging walls or by a floor which slopes downward and tapers to a smaller cross-section; or
4. Contain any other recognized serious safety or health hazard

Here again understanding the key terminology used in this part of the process is important to ensuring the space is properly classified. Without a good understanding of what OSHA means by “potential” and “configuration” (among other things), spaces will end up being misclassified which has the potential to put lives at risk.

Because we know this part of the process can get a little tricky, we’ve created a Confined Spaces Hazard Evaluation tool to help users easily and quickly evaluate those spaces which they’ve already identified as “confined spaces” to determine which spaces will require a permit to enter. When the questions are answered properly, users will be left with a list of their confined spaces and a classification of each one as either a “permit-required” space or a “non-permit required” space.

Once this process has been completed, a facility will usually have a much better idea of how complex their confined spaces program will be. This is typically a good time to look at things from a 30,000 feet view and decide the feasibility of having the workforce performing permitted entries or not.

Many companies, especially smaller ones, hire contractors to enter permit spaces rather than sending their own workers — but no matter who enters, there will be a cost either way.

Complying with permit space entry requirements adds up quickly, including initial and annual training for entrants, entry supervisors, attendants, and rescuers, as well as specialized equipment for atmospheric testing and rescue.

Every permit entry also requires multiple people for the duration of the entry, making routine permit space access both time-consuming and costly.

Performing a simple cost benefit analysis that compares the costs of using a contractor for permit entries to the costs of using a company’s own workforce can be a good exercise for a safety professional to do. Once again OSHA has devoted a segment of their website to understanding how to make the business case for safety which includes information on determining costs, benefits and provides resources for how to account for safety within the business, among other useful information.

Space Reclassification

Facility changes can add or eliminate hazards in confined spaces — either way, any change affecting a confined space requires re-evaluation and possible reclassification before the next entry.

When a non-permit required space undergoes changes that increase hazards, it must be re-evaluated and, if necessary, reclassified as a permit-required space — triggering new signage, updated records, and full permit entry protocols.

However, the process for reclassifying a permit-required space which has undergone changes to eliminate certain hazards is a bit more regulated.

For starters, a permit space may only be reclassified as a non-permit space when the space no longer poses either an actual or potential atmospheric hazard and when all the other hazards within the space have been eliminated—with a few caveats.

1. If all of the hazards are eliminated without entering the space to do so, the space can be reclassified as a non-permit space for as long as the non-atmospheric hazards remain eliminated.
   
   
2. But, if it’s necessary to enter the space to eliminate those hazards, the space must still be treated like a permit required space and will still require a permit, testing, etc. to enter. If the space can be tested and inspected during entry and if those results demonstrate that hazards have been eliminated, that space can be reclassified as a non-permit space—for as long as the hazards remain eliminated.

(It’s important to note that forced air ventilation does NOT constitute an elimination of atmospheric hazards.)

3. To reclassify a permit-space as a non-permit space requires some paperwork. Employers must document the basis for their determination that all hazards have been eliminated by certifying the space. The certification must include the date, location of the space and the signature of the person who made the determination—and this certification must be made available to each employee who enters the space.
   
   
4. If while in the process of entering a space that’s been reclassified as non-permit space, the conditions happen to change or entrants discover that not all of the hazards have been eliminated, they must exit the space immediately and the employer must go through the entire re-evaluation and recertification process.

To make this process a bit easier, we’ve created a simple and editable Temporary Confined Space Reclassification template that guides users through the reclassification process and when completed, provides the necessary documentation to justify and certify that determination.

What’s Next?

Part three of this series will cover permits and post-entry activities, along with a final set of EHS Insight templates to simplify the entry process, recommended follow-up activities, and record-keeping for every permit space entry.

Interested in seeing what other resources EHS Insight has to offer, please check out our website’s resource center and for those interested in hearing more about what our industry leading EHS software modules can do for you, please contact us!