Non-permit confined space

Atmospheric testing, entry supervisor duties, attendants and entrants, retrieval systems, hazard identification, and entry procedures for non-permit confined spaces. 

Non-permit confined space—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. 

During the evaluation survey process, if confined spaces are identified, then the determination must be made whether or not they are "permit-required confined spaces" or "non-permit confined spaces." To do this, you must be familiar with (TSHA s definitions for both. Recall from the definitions list that... 

In accordance with 1910.146(c)(7), the space may be reclassified as a non-permit confined space if the space poses no actual or potential atmospheric hazards and if all hazards within the space are eliminated without entry into the space. 

An employer who eliminates the hazards from a permit space, as provided by paragraph (c)(7) of the standard, can reclassify that space as a non-permit confined space. That reclassification, which would remain in effect as long as the hazards remain eliminated, would allow employers to have employees enter the curing ovens without implementing a permit space program. 

Question 1 Please provide an interpretation of potential as it is used in 29 CFR 1910.146(c)(7)(i) as it relates to hazardous atmospheres in the definitions for Non-permit confined space and Permit-required confined space in 1910.146(b). Specifically, does a background or ambient reading of flammable gas, below the specified 10 percent LFL, constitute potential even when there is no source or when all sources have been isolated ... 

Non-Permit Confined Space A confined space that does not contain an actual or potential hazardous atmosphere. Any hazard that can cause death or physical harm. 

Confined spaces should be identified with signs indicating Danger, Confined Space Permit Required or Confined Space if a non-permit confined space. 

A permit-required space may be reclassified to a non-permit confined space by a trained supervisor after ... 

CFR1910.119(f)(4) 29CFR1910.120(d) and (g)(1) 40CFR68.69(d) 4.2.1.3 Safe work practices shall be implemented such as lockout/tagout permitted confined space entry removal of non-essential persoimel from hazardous material areas and site and building access control. 

Permit-to-work systems See under Maintenance Entry into confined spaces (e.g. vat, vessel, flue, sewer, boiler or similar) Use of non-flameproof electrical equipment where flammable liquids/ vapours/dusts may arise... 

For permit-required confined space entry operations, respiratory protection is a key piece of safety equipment, one always required for entry into an immediately dangerous to life or health (IDLFi) space and one that must be readily available for emergency use and rescue if conditions change in a non-IDLH space. Remember, however, that only air-supplying respirators should be used in confined spaces where there is not enough oxygen. 

Other Equipment If tools are to be used during a confined space entry or rescue, it may be necessary to use non-sparking tools if flammable vapors or combustible residues are present. These non-sparking, nonmagnetic, and corrosion resistant tools are usually fashioned from copper or aluminum. A fire extinguisher, additional radios for commimication, spare oxygen bottles (for SCBA and cascade systems as needed), a first-aid kit, and any other equipment required for safe entry into and rescue from permit spaces may also be necessary. 

Do non-permit required confined spaces require a sign to be posted at the entrance ... 

OSHA does not specifically require employers to post signs at the entrance of a nonpermit required confined space. Generally speaking, a perm it-required confined space is a confined space with an actual or potential serious safety and health hazard. If a confined space is not a permit space, then that confined space has been determined to have no serious hazards. Therefore, there would be little need to identify the space. However, there could be less than serious hazards in an ordinary nonpermit required confined space. Posting a sign on a non-permit space would simply be going beyond requirements. 

OSHA does not require an employer to document that the facility has been evaluated for the presence of permit spaces. If they are present at an employer s facility, post signs and warn employees. If an employer has confined spaces that are not permit spaces, they need to be reevaluated if there are changes in how they are used or configured. These changes could make a non-permit space become a permit space. 

Clarification of potential atmospheric hazard when reclassifying a PROS as a non-permit required confined space... 

T or F—All confined spaces start off as non-permit required confined... 

Non routine work which is conducted in process areas needs to be controlled by the employer in a consistent manner. The hazards identified involving the work that is to be accomplished must be communicated to those doing the work, but also to those operating personnel whose work could affect the safety of the process. A work authorization notice or permit must have a procedure that describes the steps the maintenance supervisor, contractor representative, or other person needs to follow to obtain the necessary clearance to get the job started. The work authorization procedures need to reference and coordinate, as applicable, lockout/tagout procedures, line breaking procedures, confined-space entry procedures, and hot work authorizations. This procedure also needs to provide clear steps to follow once the job is completed in order to provide closure for those that need to know the job is now completed and equipment can be returned to normal. 

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