Under article 29 CFR 1910,146 (c)(7), you have an option to reclassify a permit-required confined space to a non-permit confined space. If the confined space does not contain a hazardous atmosphere or hazards dangerous to entrants, it can be reclassified to a non-permit confined area. Before we delve into the confined space reclassification process, let's understand what the two terms entail. Read on!
What is a Permit-Required Confined Space?
For a workplace to be termed as a permit-required confined space, it has to meet a set of criteria. First, a confined space must have limited points of entry and exit. It may also be difficult for employees to enter and perform general maintenance or repair activities. In the case of an emergency, while a person is inside the confined area, escape may be difficult.
Also, if the space was built to host anything else but human beings, it can be defined as a confined space. Usually, these spaces are not intended for human occupancy, and typical examples include utility holes and tanks.
If the space is large enough for someone to enter and do work but can engulf or trap an entrant, it equally qualifies as a confined space. However, the Occupational Safety and Health Administration (OSHA) states that if a space doesn't meet any of these criteria, it's not considered a permit-required confined space but a non-permit confined space.
The NFPA 350 (section 3.3.56) defines a Permit-required confined space as a confined space that has one or more of the following characteristics:
- Contains or has the potential to contain a hazardous atmosphere
- Contains a material that has the potential for engulfing an entrant
- 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
- Contains any other recognized serious safety or health hazard
What is a Non-Permit Confined Space?
Non-permit confined spaces do not contain hazards or risks that could cause serious injuries or death. Therefore, when employees or rescue personnel enter a non-permit required confined space, they don't need to create a permit or have an attendant before conducting the work. Common non-permit confined spaces include ventilated tunnels, drop ceilings, equipment closets, and machinery cabinets.
Non-permit required confined spaces may be hard to get into, but aren’t going to have dangerous conditions such as compromised air so you can’t breathe or trap you inside, such as a grain elevator.
Confined Space Reclassification
To reclassify a confined space, you must eliminate all potential hazards, inherent or introduced.
Alternatively, you can reduce or eliminate the risk during entry of the confined space. You can avoid the placement of piping containing hazardous chemicals, gases, or other materials and prevent moisture that could cause oxygen deficiency. You can also control the infiltration of organic debris that could lead to the production of toxic gases upon decomposition.
This non-permit required confined space pre-entry hazard evaluation checklist is a good way to evaluate the status of your confined space and work towards reclassification to non-permit required.
There can be no obstruction to exit including ducking under pipes or stepping over a knee high threshold. If a worker's mental status is altered by a medical condition or sudden change in atmosphere by a toxic gas, a clear path of egress must be maintained to exit the space.
In this video, the rescuer on the right is overcome during the rescue attempt by the toxic atmosphere that incapacitated the workers. Pay attention to his feet when he attempts to get back in the basket. He has lost the ability to control his faculties to the point he can't step up to get back in the basket. In a confined space, something as simple as stepping over a threshold or ducking under a pipe could keep a worker from being able to self-rescue.
We have found that the Job Hazard Assessment (JHA) or Pre Job Risk Assessment (PJRA) is a good place to start. When this form, that is completed by the worker, has hazards identified for the work inside the space, either they have to find a way to eliminate that hazard or the space can not be reclassified.
Once you eliminate all the hazards inherent and your work doesn't introduce new hazards, your confined space can be reclassified as a non-permit required confined space. However, you must document the details of the hazard elimination process and ascertain how the risks were eliminated to be considered for reclassification.
At Hux Safety Solutions, we can assist you with your permit required confined space or reclassification to a non-permit required confined space. Contact us today with any questions you have.