December 21, 2011

When you have a confined space that is clearly permit-required, determining your responsibilities under the regulations is fairly easy. But often circumstances take you into "what if" territory where it can be more difficult to figure out what you need to do. Here are some points to remember:

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1. A permit-required confined space requires entry: If you're not going to enter a space, you don't need a permit. Remember, though, that entry occurs when any part of the body crosses the plane of the opening to the space. So if you have a confined space, and you intend to avoid a permit requirement by doing all work from outside the space, remember that sticking your hand, arm, or head in will constitute an entry.
2. Just because it's permit-required doesn't mean you need a written entry plan: You don't necessarily need a written confined-space entry plan just because you have a confined space on your facility, even if a permit is required for entry. A written confined-space entry plan is required if the space is a permit-required confined space and your employees will be entering that space. If employees won't be entering the space, no written plan is required.
3. You must keep employees out: If you have a permit-required confined space and you are not going to enter it, you don't need a written plan, but you do need to ensure that employees are aware of the space and take effective measures to ensure they don't enter the space. This includes informing employees of the presence of the space and the hazards of the space as well as installing physical barriers or permanently closing the space by bolting and locking it.
4. Once a permit-required confined space is not always a permit-required confined space: If the permit-required space poses no actual or potential atmospheric hazard and if all hazards within the space are eliminated without entering the space, the space can be reclassified as a nonpermit-required confined space as long as the nonatmospheric hazard is not present. For example, let's say a space is a permit-required confined space because of an engulfment hazard. If the materials can be emptied without entering the space, removing the engulfment hazard, it can be reclassified as nonpermit-required confined space for as long as the materials are out of the space.
5. And once a nonpermit-required confined space is not always a nonpermit-required confined space: If your facility undergoes changes that include changes to a nonpermit-required confined space, you need to re-evaluate that space to confirm that those changes have not created a situation requiring a confined-space entry permit. Changes in how and where materials are stored are an example of changes that could affect how a confined space is classified.