Permit vs. Non Permit Required Confined Spaces
What is the difference between a Non Permit and Permit Required Confined Spaces?
Finding the answer to this question would seem simple and straight forward. However if you have ever read through the letter of interpretations provided by OSHA relating to Confined Spaces, you would see that there all kinds of questions regarding when you can reclassify a space to Non Permit Required.
First lets look at OSHA’s definition of a Confined Space, and then what makes a Confined Space a Permit Required Confined Space.
A confined space is a space that:
(1) Is large enough and so configured that an employee can bodily enter and perform assigned work; and
(2) Has limited or restricted means for entry or exit (for example, tanks, vessels, silos, storage bins, hoppers, vaults, and pits are spaces that may have limited means of entry); and
(3) Is not designed for continuous employee occupancy.
In addition to the criteria listed above, a permit-required confined space (permit space) means a confined space that has one or more of the following characteristics:
(1) Contains or has a potential to contain a hazardous atmosphere;
(2) Contains a material that has the potential for engulfing an entrant;
(3) Has an internal configuration such that an entrant could be trapped or asphyxiated by inwardly converging walls or by a floor which slopes downward to a smaller cross-section; or
(4) Contains any other recognized serious safety and health hazard.
It is important to note that all 3 items must be present to define an area as a Confined Space. However, any 1 of 4 items make a Confined Space into a Permit Required Space.
With this information in mind, why are the questions about the difference? Most people are confused about the definition of potential. This particular word is the subject of great debate. Many people think that if the only thing that exists is the “Potential” for hazardous air, then we can just add ventilation. OSHA letters of interpretation tell us that ventilation can control the hazard but does not eliminate the hazard. This is very important when determining to re-classifying a space. You must take into account that the ventilation alone will not insure beyond a reasonable doubt that no Hazardous Atmosphere could occur within the space.
With all of this information at hand, I would recommend that when in doubt, leave the space classified as a Permit Required Confined Space. It is better to be SAFE rather than SORRY!
AEST Inc. can provide your on-site, trained, equipped, competent, rescue team. We additionally provide all levels of Confined Space Training, and consulting. If you have any questions regarding these types of services, please do not hesitate to contact us. You may email David Laviner at firstname.lastname@example.org.
Feel free to comment below! Also, check us out on Facebook!