Safety Pre-Checks and Entry Permits in Confined Space Entry

Confined space environments hide many hazards and are one of the leading causes for occupational fatalities in the US. Some 2.1 million workers enter confined spaces annually and expose themselves to physical and not-so-obvious respiratory hazards that typically plague confined spaces. Since oxygen deficiency, flammable gases and toxic gases are silent killers, knowing exactly what dangers lie ahead is vital for workers’ safety.

Why are pre-entry checks important?

Pre-entry checks and follow-up procedures have become a crucial part of any confined space entry procedure. Before entering a confined space, a trained safety professional (entry supervisor or duty manager) must test the internal atmosphere for oxygen, flammable gases, vapors and potential air contaminants.

Samples of the atmosphere are taken remotely from a safe distance. If the space is deemed safe for work, a permit is filled and the worker enters the space to complete the job. While inside the confined space, the worker needs to wear a personal gas detector to notify him of any changes in the environment. Oftentimes, the portable gas monitor used for the pre-entry check is also worn for personal monitoring.

OSHA’s standard for confined spaces (29 CFR 1910.146) regulates the order of analyzing air borne hazards, but multi-gas meters help test for more gases simultaneously. In most countries, this is a legislated requirement.

A complete typical entry pre-check list includes:

1. General information about the confined space, its type, how often it is used, and the work to be performed inside.
2. Names of the people involved in the work
3. If the area is free and will remain free from hazards for the duration of the work. If potential hazards are identified (atmospheric, mechanical, electrical, thermal, fire and explosion, entrapment etc.) the space will be classified as a permit-required confined space.
4. Evaluation of worker competency and training.
5. Are workers fit to perform the job? Is proper protective equipment worn properly? Have workers been trained in the operation of the gas monitoring devices? Has the worker been instructed on rescue/emergency procedures?
6. Safety recommendations. This set of guidelines needs to be followed through to ensure continued safe occupancy of the area. (i.e. the area must be sampled daily and show no gas readings before it can be occupied).

Permit requirements

2018 marked the 25th anniversary of the implementation of permit required confined space entry regulations in the United States.

OSHA defines a permit as “the written or printed document that is provided by the employer to allow and control entry into a permit space and that contains the necessary information as required in paragraph (f) of this standard’s section.”

The document must include these 14 pieces of information:

1.       The name of the space

2.       The purpose of the entry

3.       The date and authorized duration of the permit – the duration takes into consideration the time required to complete the task.

4.       The name of the entrants

5.       The name of the attendants (attendants may become entrants)

6.       The name of the entry supervisor (no necessarily work supervisor)

7.       The hazards of the space (all the environmental conditions). OSHA’s standard for confined spaces (29 CFR 1910.146) regulates the order of analyzing for these hazards, but multi-gas meters can test for more gases simultaneously. In most countries, this is a legislated requirement.

8.       Measures taken to eliminate the hazards

9.       Acceptable entry procedures – what needs to happen before the next entry, what PPE should be used?

10.   Documentation of initial and period test results

11.   Rescue and emergency services – who to call and how

12.   Communication procedures used by entrants and attendants to maintain communication

13.   List all the equipment to be used, from alarms systems to emergency systems

14.   Any additional information, including other permits

Before entering a permit-required confined space, all workers, regardless of their role, need to get trained in the proper use of equipment to be used, know confined space entry procedures and agree to sign the permit. The permit must be publicly available to all workers, anytime.

The role of permit checking

Most work sites have confined spaces that need to be reviewed in a single day or shift. For example, shipyards could have some 200 confined space areas that need to be analyzed by various staff members throughout a working day. With that many different areas, it may prove extremely difficult for one worker to do a pre-entry check each time they plan to enter the space.

Instead, a trained and dedicated person, sometimes known as a “Competent Worker”” is in charge with completing a confined space entry pre-check (in accordance to the permit guidelines) in each of the identified areas. This single worker could do 50-100 confined space pre-entry checks per day. Once they complete the pre-entry check, they will update the permit which shows workers that certain areas are safe to enter, or that additional actions need to be taken before the area can be occupied.

In some cases, the Competent Worker will act as a hole watch for the team entering the confined space. This person is entrusted with the safety of the whole crew. Their job is to verify the space is safe for the team to enter, but also to remain outside of the confined space while the team is working. This person needs to continually monitor the confined space and be vigilant to hazards like oxygen deficient atmospheres, toxic fumes, combustible gases and other potential risks. Should a risky situation arise, he/she is responsible with communicating the evacuation of an area and can request additional emergency response, if needed.