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Permit Space Entry Procedures

Before workers enter a permit space, you must ensure that the hazards associated with the space have been eliminated or controlled.

A completed entry permit verifies that hazards have been eliminated or controlled and the permit space is safe. The entry supervisor must certify that the space is safe to enter, sign the entry permit, and post it on the space so that authorized entrants can see it.

Permit Space Pre-Entry Communication and Coordination

Host Employer Communications: The host employer owns or manages the property where the construction work is taking place. Before permit space entry operations begin, the host employer must provide the following three items of information, if it has it, to the controlling contractor:

1. The location of each known permit space;
2. The hazards or potential hazards in each space or the reason it is a permit space; and
3. Any precautions that the host employer or any previous controlling contractor or entry employer implemented for the protection of employees in the permit space.

Controlling Contractor Communications: The controlling contractor has overall responsibility for construction at the worksite. If the controlling contractor owns or manages the property, then it is both a controlling employer and a host employer. Before entry operations begin, the controlling contractor must:

• Obtain the host employer's information about the permit space hazards and previous entry operations; and
• Provide the following information to each entity entering a permit space and any other entity at the worksite whose activities could foreseeably result in a hazard in the permit space:
• Information received from the host employer;
• Additional information the controlling contractor has including information about the permit space, hazards, precautions and previous operations; and
• Precautions that the host employer, controlling contractor, or other entry employers implemented to protect employees in the permit spaces.

If there is no controlling contractor present at the worksite, the controlling contractor's role and responsibilities must be fulfilled by the host employer or other employer who arranges to have employees of another employer perform work that involves permit space entry.

Entry Employer Communications: The entry employer is usually a subcontractor who decides that an employee it directs will enter a permit space. Before entry operations begin, each entry employer must:

• Obtain all of the controlling contractor's information regarding permit space hazards and entry operations; and
• Inform the controlling contractor of the permit space program that the entry employer will follow, including any hazards likely to be confronted or created in each permit space.

Coordination between the Controlling Contractor and Entry Employer: The controlling contractor and entry employer(s) must coordinate entry operations when:

• More than one employee performs permit space entry at the same time; or
• Permit space entry is performed at the same time that any activities that could foreseeably result in a hazard in the permit space are performed.

Safe Entry Conditions

Essential requirements to establish safe entry conditions into a permit space including:

Guarding the space: Use warning signs or barriers at entry locations to keep out unauthorized people and to protect entrants from falling objects.

Isolating the space: Disconnect, lock out, or tag out hazardous equipment in the space. If you lock out equipment, remember that “lock out” includes testing to ensure the lockout method works.

Testing the space for hazardous atmospheres: Test the atmosphere from outside the space for all potential atmospheric hazards, which may include oxygen; flammable gasses, dusts, or vapors; toxic gasses or vapors; and corrosive atmospheres. Provide entrants with test results. Re-test the space if an entrant believes that initial testing was inadequate.

Eliminating or controlling hazardous atmospheres: Eliminate or control the hazards in the space then document the method and the steps necessary to eliminate or control the hazards. Allow entrants to observe testing, monitoring, and any other activity necessary to eliminate or control hazards.

For permit spaces that are deep or have areas leading away from the entry point, the atmosphere may be layered or may be different in remote areas. For these spaces, testing must be done in the area surrounding the worker, which is considered four (4) feet in the direction of travel and to each side. If a sample probe is used to do the testing, then the worker must move slowly enough so that testing is completed, keeping the equipment "response time" in mind, before he/she moves into the new area.

Providing necessary equipment: Ensure the entrants have the equipment they need to do their jobs (including rescue equipment) and they know how to use the equipment.

Planning for emergencies: Attendants must know how to respond to emergencies, including who to contact and how to remove entrants.

Equipment for Entry

You must have all necessary equipment to ensure safe entry into permit spaces. This equipment can include:

• Testing and monitoring equipment
• Ventilating equipment to maintain acceptable entry conditions
• Communication equipment, such as a two-way radio, for communication between the attendant and entrants, and to initiate a rescue
• Appropriate lighting, so they can see and can exit the space quickly in an emergency
• Barriers or shields to protect them from hazards outside the space such as pedestrians and vehicles
• Ladders or similar equipment so they can enter and exit the space
• Rescue equipment, if they are unable to evacuate in an emergency
• Appropriate personal protective equipment

The equipment must be available to the employees at no cost, must be used in accordance with the instructions from the manufacturer, and the employees must be trained to use it properly.

Alternative Entry Preconditions

Before the employer can use alternate permit space entry procedures, the employer must prove with supporting monitoring and inspection data that:

• All physical hazards in the space are eliminated or isolated through engineering controls so that the only hazard posed by the permit space is an actual or potential hazardous atmosphere;
• Continuous forced air ventilation alone is sufficient to maintain that permit space safe for entry;
• If, in the event the ventilation system stops working, entrants can exit the space safely;
• If, in the event initial entry to a permit space is necessary to obtain supporting data, required entry will be performed in compliance with OSHA Standard 1926.1204 through 1211;
• All determinations and supporting data are properly documented and made available to each permit space authorized entrant and the authorized representative; and
• Permit space entry will comply with the requirements set forth in OSHA Standard 1926.1203(e)(1).

Alternative Initial Entry Procedures

If the employer can meet the above conditions, entry into permit spaces is allowed using the following procedure:

• Ensure all of the conditions making a permit space unsafe to enter are eliminated before the entrance cover is removed,
• After the entrance cover is removed, immediately guard it with a railing, cover or other temporary barrier to prevent falls into the permit space and to protect entrants from falling objects.

Prior to entry, test for each of these conditions in the following order:

1. oxygen content
2. combustible/flammable gases and vapors
3. potential for toxic air contaminants

Allow all permit space entrants to observe the pre-entry testing and results prior to entry.

Continuous Forced Air Ventilation

Be sure to comply with the following requirements for using continuous forced air ventilation:

• Continuous forced air ventilation must be used whenever employees are inside a permit space.
• Make sure force air ventilation has eliminated all hazardous atmosphere conditions within a permit space prior to and whenever any employee is inside the space.
• Direct forced air ventilation in the permit space where employees are or will be present, and continue ventilating until all employees have completed work and left the space.
• Ensure the air supply for the forced air ventilation is from a clean source. Never place the intake for forced air ventilation near equipment or vehicles creating hazardous fumes.

Monitoring the Permit Space

It's critically important to monitor the atmosphere within a permit space to make sure it's safe for employees. Monitoring must ensure forced air ventilation is preventing the development of a hazardous atmosphere.

Be sure to always continuously monitor the atmosphere within the space unless one of the following two conditions are met:

• the employer can prove that equipment for continuous monitoring is not commercially available, or
• the employer can prove periodic monitoring is sufficient.

Make sure the monitoring equipment has an alarm to notify all entrants if a specified atmospheric threshold is achieved, or that an employee will frequently check the monitor to make sure employees have time to escape. Periodic monitoring is always required if continuous monitoring is not used.

Ensure employees or their authorized representatives are able to observe monitoring and testing as desired.

If a Hazard is Detected

It's important to quickly evacuate the space if any kind of hazard is detected. If a hazard is detected during entry or work be sure to do the following:

• Make sure all employees leave the space immediately (no exceptions).
• Evaluate the space to see how the hazard developed.
• Take measures to protect employees and eliminate the hazard.
• Do not allow reentry until the hazard is completely eliminated.

It's important to understand that control of atmospheric hazards through forced air ventilation does not constitute elimination or isolation of the hazards unless the employer can prove that forced air ventilation alone will control all hazards in the space.

Safe Entry Methods

Make sure a safe method of entering and exiting the space is used. If a hoisting system is used, it must be designed and manufactured for personnel hoisting; however, a job-made hoisting system is permissible if it is approved for personnel hoisting by a registered professional engineer, in writing, prior to use.

Verifying the Space is Safe to Enter

Prior to entry, certify in writing that the space is safe for entry and that required pre- entry measures have been taken.

• Verification should include the following three items:
1. date,
2. the location of the space, and
3. the signature of the person providing the certification.

• Make the certification available to each employee or authorized representative entering the space.

Reclassifying a Non-Permit Space

Make sure a competent person reevaluates the non-permit space and, if necessary, reclassify it as a permit space when any of the following two conditions exist:

1. there are changes in the use or configuration of a non-permit confined space that might increase the hazards to entrants, or
2. some indication that the initial evaluation of the space may not have been adequate.

Reclassifying a Permit Space

A permit space may only be reclassified as a non-permit confined space when a competent person determines that each of the following requirements are met:

• The entry employer must eliminate or isolate the hazards without entering the space, unless the employer can prove this is not feasible.
• The permit space poses no actual or potential atmospheric hazards and all other hazards within the space are eliminated or isolated without entry into the space, unless the employer can prove this is not feasible.
• The entry employer must certify in writing the basis for determining that all hazards in a permit space have been eliminated or isolated. Include the date, the location of the space, and the signature of the person making the determination.
• The certification is available to each employee entering the space or the employee's authorized representative.

If hazards arise within a permit space that has been reclassified as a non-permit space, each employee in the space must exit the space. The entry employer must then reevaluate the space and reclassify it as a permit space as appropriate.

The permit space may be reclassified as a non-permit confined space for as long as testing and inspection demonstrates that the hazards within the permit space have been eliminated or isolated.

Permit Space Post-Entry Communication and Coordination

Controlling Contractor Communications: The controlling contractor must debrief each entity that entered a permit space regarding the permit space program followed and any hazards confronted or created in the permit space(s) during entry operations.

The controlling contractor must also apprise the host employer of the information exchanged with the entrants.

Entry Employer Communications: The entry employer must inform the controlling contractor in a timely manner of the permit space program followed and of any hazards confronted or created in the permit space(s) during entry operations.

Instructions

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