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In July 2015, OSHA issued a new standard for construction work in confined spaces; the standard became effective August 3, 2015. The rule was similar in many respects to the general industry confined spaces standard while also incorporating construction-specific hazards. One issue employers regularly confront under the construction standard is the difference between a confined space and a permit space. Employers must evaluate all confined spaces to determine whether they are permit spaces but must take steps to protect workers only if a space is classified as a permit space.

Here are several aids to understanding the differences between confined spaces and permit spaces, which OSHA provides in Protecting Construction Workers in Confined Spaces: Small Entity Compliance Guide.

 

Definitions

First, the two definitions:

  1. confined space is a space that is large enough and so arranged that an employee can bodily enter it; has limited or restricted means for entry and exit; and is not designed for continuous employee occupancy.
  2. permit-required confined space (permit space) is a confined space that 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; or contains any other recognized serious safety or health hazard.

Four Questions

Under the construction standard, a competent person (defined by OSHA as a person capable of identifying existing and predictable hazardous conditions and who has the authority to address them promptly) must answer the following four questions to determine whether a confined space is a permit space. If the answer to one or more of the questions is “yes,” the space is a permit space.

  1. Does the space contain or have the potential to contain a hazardous atmosphere? Most deaths and injuries in confined spaces result from atmospheric hazards. Such hazards include insufficient oxygen and toxic or flammable chemicals.
  2. Does the space contain a material with the potential to engulf an entrant? Engulfment means the surrounding and effective capture of a person by a liquid or finely divided (flowable) solid substance that can be aspirated to cause death by filling or plugging the respiratory system or that can exert enough force on the body to cause death by strangulation, constriction, or crushing; or the substance suffocates the individual.
  3. Does the space have an internal configuration such that an entrant could be trapped by inwardly converging walls or by a floor that slopes downward and tapers to a smaller cross section? An area of a confined space with a small cross section can develop a hazardous atmosphere if ventilation is inadequate. In addition, a space of this configuration could prevent an injured worker from escaping the space and add to the difficulty of rescuing the worker.
  4. Does the space contain any other recognized serious safety or health hazard(s) that pose an immediate danger to a worker’s life or health or would impair the worker’s ability to escape from the space in the event of an injury? Hazards the competent person should consider include fire and explosion hazards; the presence of mechanical, electrical, hydraulic, and pneumatic energy; temperature extremes; radiation; noise; corrosive chemicals; and biological hazards, such as venomous animals or insects.

Required Written Program

If an employer’s workers will enter a permit space, the employer must develop a written permit space program, and entry is only permitted under the terms of the program. Also, the employer must inform employees in the vicinity of the permit space of the dangers it poses. This can be done by posting signs that prohibit entry or by providing effective training on and enforcement of a work rule against entry.

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IMEC Technologies provides Safety Management Software to increase worker safety and aid compliance. IMEC’s Safety Management Software will manage inspections and audits, provides hazard identificationincident reporting, management of corrective and preventative actions from generation to closure. IMEC provides lock out tag out software solutions that will allow users to create lockout tagout procedures using an intuitive Mobile App and Manage Lockout Tagout Procedures, also the Review and Execution of those Lockout Tagout Procedures using the Mobile App. Annual Lockout Tagout Procedures audits are conducted using a Mobile App. The Mobile Inspection App allow users to perform inspections and audits, for example the system can be used as a Fire Extinguisher Barcode Inspection Software system to manage monthly fire extinguisher inspections and general fire safety inspections and also to record safety observations and manage corrective actions, anywhere and anytime. The solution can be used as a fire extinguisher barcode inspection software system or life safety inspection system to aid compliance in Higher Education, Healthcare, Industrial and Commercial Organizations. Benefits from a Fire Extinguisher Barcode System include the elimination of paperwork and reducing the burden of compliance with regulations such as NFPA, The Joint Commission. The Incident Reporting App allows users to easily and quickly report incidents, hazards and near-misses, these are then sent to the appropriate people for action and are managed to closure.  Web Apps provide features such as, setup, management, scheduling tools, analysis, reporting and dashboards etc with the ability to report incidents to government bodies such as OSHA and RIDDORHazMat T&T is a hazardous waste management software solution designed for Environmental Service Companies and companies who generate a large quantity of hazardous waste. The solution tracks hazardous waste from cradle to grave aiding compliance, providing accurate waste inventory, increasing waste handling efficiency, reducing risk and also helps manage waste costs. HazMat T&T Hazardous Waste Management Software can be deployed in a number of deployment scenarios, from Large Hazardous Waste Generators, tracking their hazardous waste at their site to Environmental Service and Waste Management Companies using it track and manage hazardous waste at transfer and disposal sites. For more information visit our website www.imectechnologies.com