A great question came up in last week's 40 hour HAZWOPER class:
“We've been working in this same confined space for years. Originally it was a non-permit confined space, now safety tells us we need a confined space permit to enter and do the same work we've been doing. Why?”
First let’s examine the definitions of a confined space.
What is a confined space?
- Large enough to enter and perform work
- Restricted means for entry or exit
- Is not designed for continuous occupancy
What has to be present for a confined space to require confined space permit?
- Contains or has the potential to contain a hazardous atmosphere
- Contains material that has the potential to engulf an entrant
- Has walls that converge inward or floors that slope downward and taper into a smaller area which could trap or asphyxiate the entrant
- Contains any other recognized safety or health hazard, such as unguarded machinery, exposed live wires, or an environment conducive to heat stress
After some conversation we eliminated the possibility that any changes had been made to the confined space. The nature of the work inside the space and the substance present within the space had not changed. What could have happened? Safety could have reassessed the space and erred on the side of safety, or if a proper hazard assessment had not taken place before, it's possible an assessment of the confined space took place.
Depending on what truly occurred this may paint the safety department or culture in a negative light. This might not be the case, what should be emphasized is that an assessment has taken place, documented, and now the work site has another layer of protection because of the requirements of a confined space permit.
If there are any doubts about your confined spaces OSHA has an interactive assessment tool to aid your assessment process – OSHA Confined Spaces Advisor. Additionally, always ensure that your entrants and rescuers are properly trained as well as anyone else assessing the hazards or the nature of the work inside.