The Permit Nobody Wrote
CFR reference: 29 CFR 1910.146
Permit-required confined space program. Atmospheric testing, entry permits, rescue procedures.
A permit-required confined space has limited entry, is large enough for a worker to enter, is not designed for continuous occupancy, and contains a recognized hazard. Tanks, vats, pits, silos, storage bins, and some mechanical enclosures all qualify. OSHA 29 CFR 1910.146 requires a written program, atmospheric testing, entry permits, trained attendants, and rescue procedures. Most small operations either don't know they have confined spaces or haven't built the program.
I find pits and tanks that workers enter routinely without a permit, without testing the atmosphere, and without an attendant. The space was never formally identified as a confined space because "it's just a pit." Nobody has a gas monitor. Nobody is watching the opening. The rescue plan is "call 911" — which means a 15-minute response for a space where an atmospheric hazard can incapacitate someone in seconds.
A permit-required confined space has limited or restricted means of entry or exit, is large enough for an employee to enter and perform work, is not designed for continuous occupancy, and has one or more recognized hazards — such as atmospheric hazards, engulfment potential, or configuration that could trap an entrant. Examples include tanks, vats, pits, silos, and some ductwork.
Yes. If your facility has any space that meets the OSHA definition of a permit-required confined space — even if employees rarely enter it — you must have a written program under 29 CFR 1910.146. This includes identifying all such spaces, posting danger signs, and establishing entry procedures.
The most common citation is failure to have a written permit-required confined space program. Many small operations have spaces that qualify but have never been formally identified or assessed.
Field Note by Vince Lawrence — GigLine Safety & Compliance — Kernersville, NC — (336) 329-8899