Written by Charles Jackson

OSHA Standard 1910.146, Permit Required Confined Spaces, requires an assessment be made to determine if a confined space can be entered with or without a permit.

Written by Charles Jackson, CIH

Assessing the potential hazards of the work environment can take on numerous connotations. Think of assessments as being on a continuum with Hazard Operability Studies (HAZOPS) being at the upper end and at the lower end a Work Task Review. A HAZOP is a step by step formal structured and well documented process primarily used to assess complex processes. A Work Task Review could simply be a visual and/or verbal review of the work task with or without documentation. Regardless of the situation or the type assessment being performed, it is a critical proactive process that must be accomplished to ensure that all of the “what-if” questions are asked and addressed to ensure the safety of all affected persons prior to start-ups/work performance of the process/work task.

OSHA Standard 1910.146, Permit Required Confined Spaces, requires an assessment be made to determine if a confined space can be entered with or without a permit. This assessment should be thorough and well documented to show that a specific assessment process was used to make the determination. This standard also requires that all confined spaces that are entered using a permit must have an atmospheric evaluation conducted prior to allowing safe entry and/or continuous evaluation depending upon the nature of the space and the work to be performed.

Consider the confined space atmospheric evaluation/assessment as being in the upper to middle range on the assessment continuum. Confined space atmospheric assessments are too often referred to as a “sniff test”. In most cases, the atmospheric “sniff-tester” simply turns on a meter which has been calibrated by someone (no bump test performed), sticks the probe or meter into the space, records the readings on the permit, and moves on to the next space to be checked. (All of this may take 2 minutes.) Confined space atmospheric assessment is so critical that unless the tester has the formal training and has acquired competency to accurately perform assessment and testing, the organization should not allow “sniff-tests” to be conducted.

A confined space atmospheric tester should receive formal training in the art and science of performing assessments and should be able to anticipate, recognize, evaluate, and control potential hazards associated with each confined space prior to allowing safe entry. This type training will allow the tester to take all things pertaining to the confined space, the work to be performed, and any known or anticipated conditions which are inside or outside of the space into consideration along with the monitoring results to make informed decisions about the safe entry of the space.

The confined space entry standard is a very thorough standard and requires specific attention be given to each aspect in complying with the standard. Entry into confined spaces in industry is common in the on-going maintenance programs. It is critical that each confined space be accurately assessed by trained qualified persons because the lives of the entrants depend on it. Confined space emergencies, unfortunately, are too often retrieval events rather than rescue.

If you would like more information or assistance with your confined space – related issues, please contact SET Solutions today.