Confined Spaces in Construction

Confined space or permit space?

A confined space has all three

• It is large enough and shaped so that you can bodily enter it.
• It has limited or restricted means for entry and exit.
• It is not designed for continuous employee occupancy.

Examples on construction sites include bins, boilers, pits, manholes, tanks, sewers, transformer vaults, HVAC ducts, storm drains, water mains and drilled shafts.

A permit-required confined space has one or more of these

• Contains or could contain a hazardous atmosphere
• Contains a material that could engulf you
• Has an inside shape that could trap or asphyxiate you, such as walls that converge inward or a floor that slopes down and tapers
• Contains any other recognized serious safety or health hazard

Before work begins at a site, each employer must have a competent person identify all confined spaces its employees may work in, and identify which ones are permit spaces.

Reference: 29 CFR 1926.1202 "Confined space" · 29 CFR 1926.1202 "Permit-required confined space (permit space)" · 29 CFR 1926.1201(a) Note · 29 CFR 1926.1203(a)

Danger signs and staying out

Your employer must tell you where each permit space is and the danger it poses, by posting danger signs or another equally effective means. A sign reading "DANGER—PERMIT-REQUIRED CONFINED SPACE, DO NOT ENTER" or similar language meets the rule.

If your employer has not authorized you to work in a permit space, it must take effective measures to keep you out.

Reference: 29 CFR 1926.1203(b)(1) · 29 CFR 1926.1203(b)(1) Note · 29 CFR 1926.1203(c) · 29 CFR 1926.1202 "Entry"

The entry permit

Before entry is authorized, the entry employer prepares an entry permit documenting the safety measures. The entry supervisor named on the permit must sign it before entry begins. The completed permit must be available to you at the time of entry, usually posted at the entry portal, so you can confirm the preparations are done.

Things to look for on the permit

The permit must identify these items, among others:

• The space to be entered, and the date and authorized duration
• The hazards of the space
• The acceptable entry conditions
• The test results, with the testers' names or initials and when the tests were done
• The rescue and emergency services and how to summon them
• The communication procedures between entrants and attendants

Reference: 29 CFR 1926.1205(a) · 29 CFR 1926.1205(b) · 29 CFR 1926.1205(c) · 29 CFR 1926.1206(a) · 29 CFR 1926.1206(c) · 29 CFR 1926.1206(h) · 29 CFR 1926.1206(j) · 29 CFR 1926.1206(k) · 29 CFR 1926.1206(l) · 29 CFR 1926.1206(m)

Atmospheric testing: you can watch it

The testing order

Some hazardous atmosphere limits

• Oxygen below 19.5 percent or above 23.5 percent
• Flammable gas, vapor or mist in excess of 10 percent of its lower flammable limit (LFL)

Your rights as an entrant

• You (or your authorized representative) get the opportunity to observe the pre-entry testing and any later testing or monitoring.
• You get the results immediately.
• If there is some indication the evaluation of the space may not have been adequate, you can request a reevaluation, and it is done in your presence.

Reference: 29 CFR 1926.1204(e)(3) · 29 CFR 1926.1204(e)(4) · 29 CFR 1926.1204(e)(6) · 29 CFR 1926.1204(e)(5) · 29 CFR 1926.1202 "Hazardous atmosphere" · 29 CFR 1926.1202 "Oxygen deficient atmosphere"

When you are the authorized entrant

An authorized entrant is an employee authorized by the entry supervisor to enter a permit space. The entry employer must ensure that you:

• Know the hazards you may face, including how exposure happens, its signs or symptoms, and its consequences
• Use the equipment properly that the entry employer must provide at no cost: testing and monitoring, ventilating, communications, personal protective and lighting equipment; barriers and shields; equipment such as ladders for getting in and out; rescue and emergency equipment (except what rescue services provide); and any other equipment needed for safe entry, exit and rescue
• Communicate with the attendant so they can check on you and tell you to get out

Alert the attendant whenever

• You notice any warning sign or symptom of exposure to a dangerous situation, or
• You detect a prohibited condition

Get out as quickly as possible whenever

• The attendant or entry supervisor orders you to evacuate
• There is any warning sign or symptom of exposure to a dangerous situation
• You detect a prohibited condition
• An evacuation alarm goes off

Reference: 29 CFR 1926.1208(a) · 29 CFR 1926.1208(b) · 29 CFR 1926.1208(c) · 29 CFR 1926.1208(d)(1) · 29 CFR 1926.1208(d)(2) · 29 CFR 1926.1208(e)(1) · 29 CFR 1926.1208(e)(2) · 29 CFR 1926.1208(e)(3) · 29 CFR 1926.1208(e)(4) · 29 CFR 1926.1202 "Authorized entrant" · 29 CFR 1926.1204(d) · 29 CFR 1926.1204(d)(1) · 29 CFR 1926.1204(d)(2) · 29 CFR 1926.1204(d)(3) · 29 CFR 1926.1204(d)(4) · 29 CFR 1926.1204(d)(5) · 29 CFR 1926.1204(d)(6) · 29 CFR 1926.1204(d)(7) · 29 CFR 1926.1204(d)(8) · 29 CFR 1926.1204(d)(9)

When you are the attendant

The attendant is stationed outside the permit space and watches over the entrants. The entry employer must ensure that you:

• Know the hazards, and are aware of possible behavioral effects of exposure in entrants (a good practice is to watch for changes such as confusion or slurred speech)
• Continuously keep an accurate count of who is inside
• Stay outside the space during entry operations until another attendant relieves you
• Communicate with entrants to check on them and alert them to evacuate
• Summon rescue as soon as you determine entrants may need help to escape
• Do no other duties that might interfere with your primary job of assessing and protecting the entrants

Order the entrants out immediately if

• There is a prohibited condition
• An entrant shows behavioral effects of hazard exposure
• Something outside the space could endanger them
• You cannot effectively and safely do all your duties

If unauthorized people approach

Warn them to stay away. If they have entered, tell them to exit immediately, and inform the entrants and the entry supervisor.

Reference: 29 CFR 1926.1209(b) · 29 CFR 1926.1209(c) · 29 CFR 1926.1209(d) · 29 CFR 1926.1209(f) · 29 CFR 1926.1209(f)(1) · 29 CFR 1926.1209(f)(2) · 29 CFR 1926.1209(f)(3) · 29 CFR 1926.1209(f)(4) · 29 CFR 1926.1209(g) · 29 CFR 1926.1209(h)(1) · 29 CFR 1926.1209(h)(2) · 29 CFR 1926.1209(h)(3) · 29 CFR 1926.1209(j) · 29 CFR 1926.1209(a) · 29 CFR 1926.1209(e)

Retrieval lines, and why you do not go in after them

Non-entry rescue comes first

Non-entry rescue (pulling someone out without going in) is required unless the retrieval equipment would increase the overall risk or would not help. When it is used, retrieval systems are used whenever an entrant goes in:

• Each entrant wears a chest or full body harness with the retrieval line attached at the center of the back near shoulder level, above the head, or at another point the employer shows gives a small enough profile for removal. Wristlets or anklets may be used instead only if the employer can show that a harness is infeasible or creates a greater hazard and that wristlets or anklets are the safest and most effective alternative.
• For vertical permit spaces more than 5 feet deep, a mechanical device must be available to retrieve people.
• The attendant performs non-entry rescues as the employer's rescue procedure specifies.

Do not go in after them

The employer's program must include procedures for preventing unauthorized personnel from attempting a rescue. If you are not authorized to perform entry rescues, your training must cover the dangers of attempting them. The rule lets a relieved attendant enter to attempt a rescue when the program allows attendant entry for rescue and the attendant has been trained and equipped for rescue.

Reference: 29 CFR 1926.1211(c) · 29 CFR 1926.1211(c)(1) · 29 CFR 1926.1211(c)(2) · 29 CFR 1926.1209(d) Note · 29 CFR 1926.1209(i) · 29 CFR 1926.1207(a) · 29 CFR 1926.1204(i)