Do I Have to Use a Permit for this Confined Space?
Permit required confined space entries become complicated, time consuming, and expensive very quickly. Often times, setting up to complete a permit required confined space entry can take longer than completing the actual task within the confined space. Having a rescue team onsite will cost thousands of dollars and they will typically do nothing more than supervise. For these reasons, any time a confined space entry is required, it will inevitably be asked if doing the entry under a permit is actually required.
The most common recommendations to avoid doing a permit entry will be to eliminate the confined space completely. If it is possible to eliminate the confined space, this would certainly be the best method to avoid needing to use a permit. While considering this method, it is important to understand the definition of a confined space. Confined spaces have 3 components. They are large enough for human entry, have limited routes of ingress and egress, and are not designed for continuous human occupancy. If one of the three components can be eliminated, it is no longer a confined space. Typically the only component that can be addressed is the matter of limited ingress and egress. To simplify the process, if the space does not have a standard size door and a completely unobstructed path to the worksite, the the ingress and egress path is considered limited. If there is a change of elevation, there would need to be a set of permanent steps that fully comply with the OSHA standards. According to the OSHA compliance officers enforcement guide, temporary or mobile stairs, spiral stairs, or a ladder will still be considered limited means of ingress or egress.
A common question is, “If we remove all the guards to allow free air flow, is it still a confined space”? To answer this question, you must go back to the three components that are required for a confined space. Limited ingress and egress, large enough for entry, and not designed for human occupancy. Air flow is not a consideration at all. The only way that removing all of the guards would eliminate a confined space is if it completely removed all obstruction to enter the space. Then ingress and egress would not be limited.
So when is a permit required? Permits are required when there is a potential for atmospheric hazards, has the potential to engulf an entrant with material, has an internal configuration that could entrap an entrant, or has any other recognized hazard. Any other hazard can include fall hazards, contact with machinery, severe temperatures, etc. These “Other” hazards are easily overlooked but are critical when planning for a confined space entry. However, OSHA does have a process which would allow entry into a Permit Required confined space without a permit. If a space does not have ANY potential for an atmospheric hazard, and the only hazards present are ELIMINATED, then a Permit Required confined space may be declassified to a non-permit required confined space. It is important to understand the word “Eliminated”. This is not equivalent to implementing engineering controls. Locking out the equipment does not allow you to declassify a space. Putting an anchorage point for fall protection does not allow for the declassification of a space. The hazard itself needs to be removed entirely and made to be physically impossible to interact with at all while in the space. If a space is permit required because there is machinery inside the space, once the machinery is removed, then the space can be declassified. If there is a fall hazard, once a working surface is set in place that entirely covers the fall hazard, then the space can declassified. Unless the hazards have been completely eliminated, confined space entries must be done under permit conditions if the space contains a hazard.
