Non-Permit Confined Space Requirements
If you are unfamiliar with the term confined space, you are not alone. Confined spaces often go by different names, depending on the industry and location, such as storage tank, dumpster, silo, floor pit, and more.
Non-permit confined spaces are areas that fall under the requirements of the OSHA Standard Hazard Communication (29 CFR 1910.1200) even though they do not meet the OSHA definition of permit spaces. These types of spaces are often overlooked, and if you have employees working in them, you need to know the non-permit confined space requirements that OSHA outlines to ensure your employees are safe while working in them.
This article will detail four of the most important non-permit confined space requirements that apply in many industries, so read on to make sure you stay safe and healthy at all times.
What Is A Non-Permit Confined Space?
A “Non-permit confined space” means a confined space that does not contain or, with respect to atmospheric hazards, have the potential to contain any hazard capable of causing death or serious physical harm.
READ: 6 Major confined space hazards
It is important to note that there are different types of confined spaces and OSHA defines three types: permit required confined spaces (29 CFR 1910.146), non-permit confined spaces (29 CFR 1910.146) and voluntarily entered confined spaces (29 CFR 1910.146). The difference between these three types is defined by whether an entry permit is required for entry into each type of confined space, as well as what type of entry procedures must be followed when entering them.
According to OSHA’s definition, there are a few requirements for non-permit confined spaces. First, there must be no or negligible potential for atmospheric hazards inside. Second, if there is a potential for atmospheric hazards inside of a non-permit confined space (such as with fire or toxic fumes), then all employees entering must be properly trained in how to recognize and control those hazards. Third, both initial and refresher training of non-permit confined space entry procedures must be provided.
In addition, OSHA also requires a written entry permit program for non-permit confined spaces. There are four requirements of an entry permit program:
(1) The employer must provide each employee with a copy of the confined space entry procedures;
(2) The employer must ensure that all employees understand and follow those procedures;
(3) The employer must ensure that all employees are properly trained in recognizing and controlling atmospheric hazards; and
(4) The employer must maintain records verifying that these requirements have been met.
If a non-permit confined space does not meet these four requirements, then it is considered a permit required confined space and all entry procedures required by 29 CFR 1910.146 must be followed when entering.
READ: Major forms of confined space classification
4 Important Non-Permit Confined Space Requirements You Need to Know
Entry And Exit
When confined space entry is required, you have to make sure that workers have a safe way of entering and exiting. A trench less than five feet deep does not require a permit but does need ladders or stairs. A pit without guardrails requires a safe means of entry and exit—whether it’s an attached ladder or scaffolding, etc. Also, if someone has worked in a confined space recently, you must ventilate it before anyone else enters.
The second consideration is how workers are going to get in and out of your confined space. If they can do so safely and without putting themselves at risk, that’s ideal. That way, you are not taking any extra time from other operations or risking injuries during entry or exit.
The third consideration is whether workers will need to enter or exit through a trench, pit, etc. This means that you will need some sort of safe and sturdy ladder or stairs. Otherwise, if they have to climb out over an edge or just jump up into a space, they could hurt themselves in an accident.
Monitoring And Rescue Equipment
The confined space entry permit requirements are designed to keep workers safe during non permit confined space entry. This entails having proper monitoring and rescue equipment available as well as properly trained personnel on hand in case of emergency.
A non permit confined space is one that does not require an entry permit because there are no reasonable foreseeable hazards. However, you should still provide protection for workers with monitoring and rescue equipment and training. An example of a non permit confined space would be a utility closet or storage room. In most cases, these spaces have been assessed by personnel and deemed safe for occupation.
READ: Confine Space Entry Hoist
Although all employees are required to complete entry permit training, not all employees need a permit to enter non-permit required confined spaces. For example, if you have an employee who will be entering a space with zero hazards or limited hazards and there is no chance of oxygen deficiency, that person does not need an entry permit. They only need training in order to comply with OSHA regulations.
Even though non-permit required confined spaces do not need entry permits, OSHA regulations still require employers to have a written plan in place for these spaces. This includes entry permit procedures, training requirements and an escape plan in case of an emergency.
In some situations, employees need both an entry permit and non-permit required confined space training. Other examples of non-permit required confined spaces include waste bins, process tanks and reactors where there is a possibility of oxygen deficiency but no other hazards. In order for these spaces to be entered by employees without permits, they must be vented so that oxygen levels do not dip below 19.5 percent or higher than 23.5 percent.
Personal Protective Equipment (PPE)
When working in a confined space, an employee is required to follow all applicable government regulations. When an employee enters a non permit required confined space, he or she must also wear protective clothing and equipment that is appropriate for specific work conditions.
A non permit required confined space is any work space that does not require an entry permit, and contains one or more of any of these hazards: combustible dust; an oxygen deficient atmosphere; a high concentration of airborne contaminants (such as solvents); or a significant amount of an atmospheric pollutant. Without protective clothing and equipment, workers who enter these spaces face increased risk for immediate harm. Personal Protective Equipment can be your best defense in hazardous conditions.
Different levels of protection are required depending on if your confined space is permit required or non permit required. If you are not sure which type of confined space you have, refer to OSHA publication 3165 (PDF).