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Is your disaster-recovery plan up-to-date? (cover page)
Navigating the confusing reclassification of OSHA's permit-required spaces
Winter driving dangers will soon be present
OSHA to inspect 4,400 high-hazard work sites
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Navigating the confusing reclassification of OSHA’s permit-required spaces
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| Frequently reviewing and updating your company's disaster-recovery plan is vital. |
"That which we call a rose, by any other name, would smell as sweet.”
— Juliet, from “Romeo and Juliet,” by William Shakespeare
To Shakespeare, names don’t mean much. But to the Occupational Safety and Health Administration (OSHA), names definitely mean something. OSHA does agree with Shakespeare, however, when it comes to its definition of a confined space: A confined space, by any other name, is just as dangerous.
We want to explore the reclassification of permit-required confined spaces. Let’s start with the basics.
OSHA defines a confined space as 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.
A “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 that slopes downward and tapers to a smaller cross-section; or
(4) Contains any other recognized serious safety or health hazard.
If you have permit-required confined spaces, a great deal of resources must be committed to training, recordkeeping, equipment purchases and coordination with local rescue agencies.
To avoid these requirements, many companies hire qualified contractors to essentially seal off their confined spaces, label them as such and train employees that the spaces are never to be entered.
Another means of minimizing required confined-space management resources is to reclassify permit-required confined spaces.
If the permit-required space poses no actual or potential atmospheric hazards, and if all hazards within the space are eliminated without entry into the space, the permit space may be reclassified as a non-permit confined space for as long as the non-atmospheric hazards remain eliminated.
What does this really mean? Let’s say that a tank has no atmospheric hazard, and that the only other hazard involved in the empty tank is a mixing blade that rotates within the tank. The mixing blade can be locked without entering the tank.
Many companies hire qualified contractors to essentially seal off their confined spaces, label them as such and train employees that the spaces are never to be entered. |
Because the only hazards in the space can be eliminated via lockout without entering the space, the space can be reclassified from a permit-required confined space to a non-permit space.
Personnel can then enter the space without all the training, rescue equipment and documentation requirements of a permit-required space. If it is necessary to enter the space to alleviate the hazards, the entry must be accomplished under all the requirements of a permit-required space.
To take advantage of reclassifying a permit-required space, the company must document the basis for determining that all hazards in the permit-required space have been eliminated.
The documentation is accomplished through a certification that contains the date, location of the space and signature of the person making the determination.
This certification must then be made available to each person who enters the space. NATLSCO Risk and Safety Services recommends that prior to entry, each person entering a reclassified space signs a dated acknowledgment that he or she has reviewed the certification and understands the requirements for eliminating the hazards. These acknowledgments should then be kept on file.
The company must reassess the now-reclassified space anytime new hazards are introduced. For example: A NATLSCO client had a space that could be reclassified as non-permit-required. However, the client had welders entering the space and performing work, which created a new hazard in the space.
Because the hazard was an atmospheric hazard that was being controlled through ventilation, the space no longer qualified as one that could be reclassified — you can’t reclassify a permit-required space if there is an atmospheric hazard.
The client had to either implement a full, permit-required confined space program, subcontract the work or implement the alternate procedures described in 1910.146(c)(5).
For assistance or more information on this topic, please contact:
Larry I. Perkinson, CSP, ARM
NATLSCO Risk and Safety Services
Phone: 972-394-2700
Fax: 267-295-2634
E-mail: larry.perkinson@us.bureauveritas.com
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