Last month, we discussed common misconceptions about the Lockout/Tagout program. Many similar misconceptions exist about Permit-required Confined Space Programs and affect their implementation. The most common misconceptions are:
My employees do not enter permit-required confined spaces; we use contractors, so I do not need a program.
For permit-required confined spaces, the host employer performs the following items:
- Inform the contractor that the workplace contains permit spaces and that permit space entry is allowed only through compliance with a permit space program meeting the requirements of 1910.146.
- Apprise the contractor of the elements, identified hazards and any experience which makes the space a permit space.
- Apprise the contractor of any precautions or procedures that have been implemented for the protection of employees in or near permit spaces where contractor personnel will be working.
- Coordinate entry operations with the contractor.
- Debrief the contractor at the conclusion of the entry operations regarding the permit space program followed and regarding any hazards confronted or created in permit spaces during entry operations.
In order to effectively perform the requirements above, the host employer must have those elements of a written permit confined space program in place.
Our employees only enter non-permit required spaces.
Sometimes there is some confusion on when a space is considered permit-required. I performed some confined space assessments for a facility where staff indicated they did not enter permit-required confined spaces. When I performed the assessment, I noticed the facility had air handling units that were marked as non-permit confined spaces; however, portions of these units had unguarded equipment such as fans, belts and shafts that would make the space permit required. When I spoke to facility personnel, they informed me they lockout the equipment before entering, so it was not a permit-required confined space. While they were correct that locking out the equipment before entry allowed them to reclassify the space as a non-permit space, it still should have been labeled as permit-required. The correct procedure would have been to include an element in the confined space program for reclassifying a permit-required confined space to a non-permit required space after eliminating the hazards of the space.
For more information, please contact Conan Reed.