From labeling to atmospheric hazards to training, compliance with OSHA's confined space standard has proven to be a breeding ground for misunderstanding. Here is the real story on what OSHA requires.
Much of the "popular" information circulating about confined spaces is simply wrong. Confined spaces don't have to be labeled. Oxygen levels of 19.5 percent aren't necessarily "safe" for entry. The mere possibility that an atmospheric hazard may exist doesn't necessarily mean that a confined space is a permit space. Showing employees a 20-minute video or sending them to a one-day, state-sponsored fire rescue institute seminar doesn't mean they have been trained.
Much of the truth underlying these myths can be found by carefully reading the OSHA standard, its preamble, the related compliance directive and the more than 80 formal letters of interpretation concerning confined spaces that the agency has issued over the last decade (see "Supporting Documents: the Rest of the Story").
Myth: The OSHA standard requires you to prepare a written inventory of permit-required confined spaces.
Fact: Read 29 CFR 1910.146(c)(1). It only requires you to "... evaluate the workplace to determine if any spaces are permit-required confined spaces." While conducting an inventory is one way of doing this, it's not the only way. If you know your facility well enough, you might be able to make an evaluation without leaving your office. Don't believe me, look at the answer to the third question in Appendix E, section (c) of CPL 2.100.
Once you've identified your permit spaces, you must inform your employees about the existence of these spaces and of the hazards they pose. This leads to another confined space myth -- that permit spaces must be labeled.
Myth: The standard requires that permit-required confined spaces be labeled or posted.
Fact: If you read 29 CFR 1910.146(c)(2), you will see that the standard requires that employees be informed of the existence, location and danger posed by permit spaces" ... by posting danger signs or other equally effective means" [emphasis added]. In other words, you can explain to people what a permit confined space is, tell them where they are in a facility and verbally warn them as to the hazards they present. If you're still a doubter, take a look at Federal Register, Vol. 58, No. 9, pages 4481-4484, and the answer to the fourth question in Appendix E, section (c) of CPL 2.100.
In some cases, posting may actually create another hazard. How can this be? I've seen lots of cases where someone has done a survey and determined at a particular point in time which spaces were permit spaces and which were not. Those that were, they posted, and those that weren't, they didn't.
When I'd ask what work was done in the space, they'd say something like inspection, removing materials or making mechanical adjustments. When I pressed further, they'd often point out that they might also use solvents in the space to clean or degrease parts.
What these folks failed to realize was that many confined spaces are not static environments. Things can change. In fact, they can change year to year, month to month, day to day and, in some cases, hour to hour or minute to minute.
Unfortunately, they failed to consider that job-related hazards, such as solvent vapors, could turn a nonpermit space into a permit space. If a space isn't posted as a permit space, workers who enter might not think that any special precautions or permits are necessary.
The whole purpose for posting permit spaces is to notify people who might not otherwise recognize them as permit spaces and enter them inadvertently. Moreover, in the standard's preamble, OSHA specifically points out that it does not" ... require the posting of any permit space whose only means of access necessitates the use of tools or keys, provided that the employees who are expected to gain entry into these spaces are trained to recognize the hazards involved. …