Confined Spaces

You may be asking yourself "What is a confined space?" The official definition contained in the Code of Federal Regulations (29 CFR 1910.146(a)) is:

"Confined space" means a space that: (1) Is large enough and so configured that an employee can bodily enter and perform assigned work; and (2) Has 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 (3) Is not designed for continuous employee occupancy.

Confined spaces are divided into two types: Permit confined spaces and Non-Permit confined spaces. The definitions of these are also given in 29 CFD 1910.146(a):

"Non-permit confined space" means a confined space that does not contain or, with respect to atmospheric hazards, have the potential to contain any hazard capable of causing death or serious physical harm. 

"Permit-required confined space (permit space)" means a confined space that has one or more of the following characteristics: 

(1) Contains or has a potential to contain a hazardous atmosphere; 

(2) Contains a material that has the potential for engulfing an entrant; 

(3) Has 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) Contains any other recognized serious safety or health hazard. 

Basically, if there are hazards or potential hazards within a room or area that meets the definition of "Confined Space" then it is a Permit Required Space. It is an employers duty to examine their workplace and determine if confined spaces exist and, if they do exist, evaluate each them and determine if they are "Permit" or "Non-Permit" spaces.

If permit spaces exist and the employer decides the employees WILL NOT enter the Permit space, then it is the employers responsibility to:
1. Warn employees of the danger with signs or "equally effective" means. (The employer must tell the employees that the dangers exist.)

2. Take effective measures to prevent employees from entering the permit spaces. (It is not enough to say "Don't go in there".)
3. Reevaluate any confined space if the use or configuration changes. (This is to make sure that a space isn't mistakenly classified as a "Non-Permit" space.)
4. Inform the contractor of the danger and ensure that any contractor employees that enter a space follow a permit program that is in accordance with 29 CFR 1910.

If permit spaces exist and the employer decides that employees will enter the permit spaces, then it is the employer's responsibility to develop AND implement a written Permit Space Plan in accordance to 29 CFR 1910. This plan must be made available for inspection by employees. Without going into any details about a written plan, it basically is a plan that describes;

1. How the hazards will be removed from the space.
2. How the workers will be protected from the hazards that exist within the space.
3, How injured or incapacitated workers will be removed from the space without exposing other workers to risk.
4. What emergency and/or medical equipment will be supplied.
5. Identifies the number of people that must be involved in any entry into a permit space and outlines the responsibilities of each team member.

The specifics of each plan are left to individual employer to develop since each work site is different and has different hazards.

There are a few places around the home that would qualify as confined spaces such as crawl spaces or attics. These two areas are large enough to enter and "do work", they are not designed for continuous occupancy and they typically have limited or restricted means of entry. Generally speaking, most crawl spaces and attics would qualify as "Non-permit confined spaces". I used to live in a house whose furnace was located in the crawl space that had so many Black Widow and Brown Recluse spiders that I think it met condition (4) above and actually should have been a Permit Space! In all seriousness, since the furnace was located in the crawl space, there was potential for a buildup of carbon monoxide (CO) within the space and so it would meet characteristic (1) listed above. If a furnace technician were to enter the crawl space to work on the furnace, it could qualify as a Permit Space and the technician would need to follow a procedure to ensure that the atmosphere was not hazardous and the other elements contained within a Permit Space Entry plan.