Confined
Spaces
Introduction/Background
OSHA Standard(s)
Hazard
Prevention & Control
FAQs
Links Each
year, a significant number of deaths and “close calls”
occur on farms as a result of incorrect and unsafe entry into
confined spaces. Confined spaces on farms can be found in
bins, manure pits, silos, and other areas. A “confined
space” is defined as a space that:
• Is large enough for one body to enter
in order to perform a task,
• Has limited restricted means for entry or exit, and
• Contains or has the potential to contain a hazardous
atmosphere or other physical danger, including toxic gases,
blades or fans.
OSHA Standards
As a result of the risks associated with confined
space entry and the need to protect workers, several protocols
exist for helping employers and workers to reduce the risk
of entry. The most widely used protocol that pork producers
must be aware of is OSHA’s 1910.146 standard on entry
into “Permit-required Confined Spaces.” This standard
took effect in the early 1990’s and has saved lives!
Compliance with the OSHA 1910.146 can be complicated
and takes knowledge of a range of different procedures and
personal protective equipment such as specialized respirators,
rescue and retrieval devices, air monitoring equipment, and
high capacity ventilation fans that can be used to provide
fresh air to a potentially contaminated space.
As is the case with any significant workplace
hazard, it’s always better to “avoid” the
hazard altogether rather than trying to work within or around
the hazard. With on-farm confined spaces, this includes either:
1) Prohibiting workers from entering confined spaces and providing
signs, barriers and other means to prevent entry. 2) When
entry must be done (for example, going into a manure pit to
repair a fan), hiring an external contractor/service personnel
with the correct equipment and knowledge to do the job safely.
A pork producer who wishes to develop a full
confined space entry program needs to spend time on this issue,
or work with an expert who has helped other producers with
this task.
The Pork Production Safety System includes
a number of checklists and other parts of a confined space
entry protocol that will be helpful in designing a confined
space entry program that will help to reduce the risks to
employees.
General Safety Procedures for Confined Spaces:
The following general guidelines will help
you understand some of the basic steps to be followed for
entering a confined space. Additional measures may be needed
to fully comply with OSHA’s 1910.146 standard.
• Allow only properly trained employees
or approved service personnel to enter the space to perform
needed work or repairs.
• Post warning signs such as “No Entry”
near confined spaces, especially near pits and grain bins.
• Be sure to enforce this policy with your employees
to prevent unnecessary tragedies.
• When trained employees arrive on the scene:
o First, verify they have the proper permits, certifications,
and documented training to work in a confined space.
o Test the air quality of a pit or grain bin to be sure there
is sufficient oxygen that any noxious gases are at a level
safe enough for work to be performed. Air testing is a good
example of an issue requiring specialized training. Specific
testing procedures are beyond the scope of this document,
but should only be done by a trained individual who understands
the testing device and its limitations.
• You must inform anyone entering a confined space of
ANY type of hazard they may encounter.
• Utilize lockout/tagout to control any type of stored
energy hazard in addition to taking specific steps to control
hazardous environments or atmospheres.
• Make sure that anyone entering a confined space:
o Has appropriate personal protective equipment, and
o Knows how to properly use it. For example, respirators aid
in the prevention of asphyxiation and suffocation, but only
if worn properly. SCBA or other supplied air respirators must
be worn when entering confined spaces with potentially hazardous
atmospheres. Make sure you are adhering to the requirements
of a “respiratory protection program” that requires
proper respirator selection; fit testing; medical evaluation
of employees; and other steps.
o Does not work in the confined space without external “attendants”
and others who can help if an emergency occurs.
• Ask any contractor who you contact to visit your facility
about the confined space procedures they use and make sure
they are aware of the specific hazards they may be encountering.
Never hire a contractor that does not have specific plans
and procedures in place to protect their workers.
Other Information from OSHA’s Small
Business Handbook
ENTERING CONFINED SPACES
? Are confined spaces thoroughly emptied of any corrosive
or hazardous substances, such as acids or caustics, before
entry?
? Are all lines to a confined space that contain inert, toxic,
flammable, or corrosive materials valved off and blanked or
disconnected and separated before entry?
? Are all impellers, agitators, or other moving parts and
equipment inside confined spaces locked out if they present
a hazard?
? Is either natural or mechanical ventilation provided prior
to confined space entry?
? Are appropriate atmospheric tests performed to check for
oxygen deficiency, toxic substances and explosive concentrations
in the confined space before entry?
? Is adequate illumination provided for the work to be performed
in the confined space?
? Is the atmosphere inside the confined space frequently tested
or continuously monitored during work?
? Is there a trained and equipped standby employee positioned
outside the confined space, whose sole responsibility is to
watch the work in progress, sound an alarm if necessary and
render assistance?
? Is the standby employee appropriately trained and equipped
to handle an emergency?
? Are employees prohibited from entering the confined space
without lifelines and respiratory equipment if there is any
question as to the cause of an emergency?
? Is approved respiratory equipment required if the atmosphere
inside the confined space cannot be made acceptable?
? Is all portable electrical equipment used inside confined
spaces either grounded and insulated or equipped with ground
fault protection?
? Are compressed gas bottles forbidden inside the confined
space?
? Before gas welding or burning is started in a confined space,
are hoses checked for leaks, torches lighted only outside
the confined area and the confined area tested for an explosive
atmosphere each time before a lighted torch is taken into
the confined space?
? If employees will be using oxygen-consuming equipment such
as salamanders, torches, furnaces, etc., in a confined space,
is sufficient air provided to assure combustion without reducing
the oxygen concentration of the atmosphere below 19.5 percent
by volume?
? Whenever combustion-type equipment is used in a confined
space, are provisions made to ensure the exhaust gases are
vented outside of the enclosure?
? Is each confined space checked for decaying vegetation or
animal matter which may produce methane?
? Is the confined space checked for possible industrial waste
which could contain toxic properties?
? If the confined space is below ground and near areas where
motor vehicles will be operating, is it possible for vehicle
exhaust or carbon monoxide to enter the space?
A Sample “Program,” Forms, and
Other Information from the PPSS
Below are several tools that can you can modify
to use as you begin to think about a confined space entry
program for your facility. However, again, these hazards can
be deadly, and it is important to consult with or have your
program reviewed by a qualified expert.
[Company Name Here]
Confined Space Program
The following Confined Space Program is provided
only as a guide to assist employers and employees in complying
with the requirements, as well as to provide other helpful
information. It is not intended to supersede the requirements
of the OHSA standard. An employer should review the standard
for particular requirements which are applicable to their
individual company. A feedyard shall add information relevant
to their particular facility in order to develop an effective,
comprehensive program.
The plan shall be signed by the operator or
other signatory authority and shall be made available to all
company and contract employees.
Name (printed): ___________________________
Signature: ___________________________
Date: ___________________________
Company Name: ___________________________
Address: ___________________________
___________________________
Phone Number: ___________________________
1.0 Purpose
The purpose of this Confine Space Program is to establish
a safe working procedure for the employees of this facility
and to ensure the protection of all employees from the hazards
associated with confined space entry. This program will describe
reasonable and necessary policies and procedures for management
and employees to follow during confined space entry.
1.1 Responsibilities
A. Management: It is the responsibility of
management to reduce the need for confined entry and/or to
eliminate whenever possible all confined space hazards in
order to reclassify permit-required spaces to a non-permit
confined space. Whenever confined space entry is necessary,
management shall make sure all provisions of this document
are to be followed. Management shall provide the proper protective
equipment when such equipment is necessary to protect the
safety of all employees. They are responsible for the establishment
and review of a confined space entry program.
B. Management/Supervisor: Supervisor shall
be responsible for the following:
1. Identify and report job areas and locations that are or
may be confined spaces.
2. Classify confined spaces as permit required or non-permit
required.
3. Identify personnel who will enter confined spaces.
4. Identify the personnel under their supervision to wear
respirators.
5. Provide detailed instructions and training on confined
hazards and entry procedures.
6. Provide instructions on proper use of equipment required
for confined space entry.
7. Maintain equipment that is used to enter confined spaces.
8. Conduct work site inspections.
9. Maintain records of equipment maintenance and employee
training.
10. Inform employees who may enter permit-confined space by
posting danger signs and by training.
11. Issuance and cancellation of entry permit.
12. Identify and evaluate the hazards of permit space before
employees enter them.
C. Employees: It is the responsibility of
the employee to follow all given policies and procedures.
He shall also report any deficiencies or malfunction of equipment,
understand emergence procedures, and under no circumstance
enter a confined space, even to rescue an employee.
D. Contractor: If an outside contractor is
hired to perform work within a permit-required confined space,
management and contractor shall work closely together to insure
proper entry procedures. Management shall:
1. Inform the contractor that the area in
question is a permit-required confined space.
2. Review the permit-required confined space program followed
by the contractor.
3. Inform the contractor of the hazards identified within
the space and any past experience with the space.
4. Inform the contractor of any precautions or procedures
that have been implemented for the protection of employees
in the permit-confined space where contractors personnel will
be working.
5. Debrief the contractor at the end of the work to identify
hazards discovered or created in the permit-required confined
space during the operations.
2.0 General Requirements
2.1 Identifying Confined Spaces
A. Recognition is an important aspect of making
a safe entry into a confined space. Not all confined spaces
will be considered permit-required confined spaces and being
able to identify the difference between the two is important.
A site evaluation shall be conducted in order to determine
if any spaces are considered to be a confined space or a permit-required
confined space. A confined space is any space that has the
following:
1. It is large enough or so configured that an employee can
not easily enter to perform his or her job duties.
2. It has limited or restricted means for entry or exit. Confined
space openings are limited primarily by size and location.
Some confined spaces may have large openings such as a pit.
Entrance and exit may be required from top, bottom, or side
having to access the work area by ladder.
3. It is not designed for continuous employee occupancy. Most
confined spaces are not designed for employees to enter and
work on a routine basis. They may be designed to store a product,
enclose materials and process, or transport product or substance.
The danger associated with entry may come from chemicals or
physical hazards within the space.
B. A non-permit confined space is space that
poses no actual or potential atmospheric hazards and if all
the hazards within the space are eliminated without entry
into the space. Examples of some non-permit required confined
spaces might include attics, walk-in freezers or refrigerators,
and some building crawl spaces.
2.2 Permit Required Confined Space
A. A permit-required confined space is a confined
space that is potentially hazardous. A permit-required space
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 that slopes downward and tapers to a smaller cross
section.
4. Contains any other recognized serious safety or healthy
hazard such as but not limited to:
• fall hazards
• unguarded machinery
• extreme heat or cold
• steam pipes or chemical lines
• hazardous noise levels
• electrical hazard
• potentially hazardous levels of dust
B. Management/supervisors are directly responsible
for ensuring the safety of their employees. It is their responsibility
to evaluate potentially hazardous spaces within their facility
and areas to ensure that the proper precautions are taken
for safety. This includes clearly marking permit-required
confined space, training the employee, and ensuring proper
entry procedures are followed. No employee shall be sent on
a job that could potentially involve work in a confined space
unless they have been properly trained.
2.3 Reclassification to a Non-Permit Confined
Space
If it is necessary to enter the permit space,
management should try to eliminate hazards. If testing and
inspection during the entry demonstrates that the hazard within
the permit space has been eliminated, the permit space may
be reclassified as a non-permit confined space for as long
as the hazard remains eliminated.
2.4 Identifying Permit Space Hazards
Once a space has been classified as confined,
the hazards that may be present within the confined space
must be identified. Confined space hazards can be grouped
into the following categories:
1. Oxygen-deficient atmospheres
2. Flammable atmospheres
3. Toxic atmospheres
4. Mechanical and physical hazards
Every confined space must be evaluated for
these four types of hazards. The three types of atmospheric
hazards are often the most difficult to identify since they
might not be detected without the assistance of a gas monitor.
A. Oxygen-Deficient Atmosphere: the normal
atmosphere is composed of approximately 21% oxygen and 79%
nitrogen. An atmosphere containing less than 19.5% oxygen
shall be considered oxygen deficient. The oxygen level inside
a confined space may be decreased as the result of either
consumption or displacement. There are a number of processes
that consume oxygen in a confined space. Oxygen is consumed
during combustion of flammable materials, as in welding, cutting,
or brazing. A more subtle consumption of oxygen occurs during
bacterial action, as in the fermentation process. Oxygen can
also be consumed during chemical reactions such as in the
formation of rust on the exposed surfaces of a confined space.
The number of people working in a confined space and the amount
of physical activity can also influence oxygen consumption.
B. Flammable Atmosphere: Flammable atmosphere
are generally the result of flammable gases, vapor, dust mixed
in certain concentrations with air, or an oxygen-enriched
atmosphere are those atmosphere that contain an oxygen concentration
greater than 22%. An oxygen-enriched atmosphere will cause
flammable materials such as clothing and hair to burn violently
when ignited.
Combustible gases or vapors can accumulate
within a confined space when there is inadequate ventilation.
Gases that are heavier than air will accumulate in the lower
levels of a confined space. The work being conducted in a
confined space can generate a flammable atmosphere. Work such
as spray painting, coating, or the use of flammable solvents
for cleaning can result in the formation of an explosive atmosphere.
Welding or cutting with oxyacetylene equipment can also be
the cause of an explosion in a confined space and shall not
be allowed without a hot work permit. Oxygen and acetylene
hoses may have small leaks in them that could generate an
explosive atmosphere. The atmosphere shall be tested continuously
while any hot work is being conducted within the confined
space.
C. Toxic Atmosphere: Toxic atmosphere may
be present within a confined space as the result of one or
more of the following:
1. A product stored in a confined space can be absorbed by
walls, giving off a toxic vapor when removed or when cleaning
the residual materials. The product can also produce toxic
vapors that will remain in the atmosphere due to poor ventilation.
2. Toxic atmosphere can be generated as the result of work
being conducted inside the confined space. Example of such
work includes things like welding or brazing, painting or
scraping, sanding, etc. Many of the solvents used for cleaning
and/or degreasing produce highly toxic vapors.
3. Toxic fumes produced by processes near the confined space
may enter and accumulate in the confined space. For example,
if a confined space is lower than the adjacent area and the
toxic fume is heavier than air, the toxic fume may settle
into the confined space.
D. Mechanical and Physical Hazards: Rotating
and/or moving mechanical parts or energy sources can create
hazards within a confined space. All rotating or moving equipment
such as pumps, process lines, electrical sources, etc., within
a confined space must be identified. Physical factors such
as heat, cold, noise, vibration, and fatigue can contribute
to accidents.
3.0 Safe Entry Practices
All confined spaces shall be classified as either a Permit-Required
confined space, or a Non-Permit confined space. Non-permit
confined space is a space that does not present a real potential
hazard. All employees shall be made aware of these spaces
through training.
3.1 Written Permit
A. The permit system procedures for all personnel
entering permit-required confined spaces are the responsibility
of the management/supervisor in charge.
1. The permit system will document the following:
i. The signature of the authorized entry personnel
ii. Time duration for the permit.
iii. Termination procedures.
B. The entry permit must identify the following:
1. The identity of the space to be entered
2. Purpose of entry
3. Date and duration of the permit
4. Authorized entrant(s)
5. The name of the attendant(s)
6. The name of the entry supervisor
7. Identification of Hazards (must be specific)
8. Isolation measures
9. Acceptable entry conditions
10. The results of initial and periodic testing
11. Rescue and Emergency procedures
12. Communications procedures
13. Equipment used
14. Additional permits requirements (hot work-welding)
15. Any other information that may be relevant to the safety
of employees.
3.2 Atmospheric Monitoring
Atmospheric monitoring is used to determine
if the space contains or has the potential to contain a hazardous
atmosphere. Atmospheric testing evaluates the hazard of the
permit space and then verifies acceptable entry conditions
for entry into that confined space exit.
A. The atmosphere of a confined space should
be analyzed using equipment of sufficient sensitivity and
specificity to identify and evaluate any hazardous atmospheres
that may exist or arise, so that appropriate entry procedures
can be developed and acceptable entry conditions can be made
for that space. A minimum of three tests should be performed
to identify atmospheric hazards in confined space. These tests
must be performed in the following sequence:
1. oxygen content
2. flammability
3. toxicity
B. Verification testing of the atmosphere
of a permit space which may contain a hazardous atmosphere
should be tested for residue at entry and make sure they are
within the range of acceptable entry conditions. Measurement
of values for each atmospheric parameter should be made for
at least the minimum response time of the test instrument
specified by the manufacturer.
C. To ensure that the atmospheric testing
equipment is functioning properly, the user shall perform
the following three operations:
1. Inspection
2. Calibration
3. Function Test
D. If any of the alarms sound, exit the space immediately.
3.3 Ventilation of Confined Space
i. Ventilation is one of the most effective
means of controlling hazardous atmospheres in confined space.
In this procedure, clean air replaces contaminated air by
natural or forced ventilation. When ventilating a confined
space, the following factors must be taken into consideration:
a. Volume of air: This determines the capacity
of the blower or ejector.
b. Type of atmosphere: This will determine the type of blower
used and the length of time needed to ventilate until it is
safe for people to enter the space
c. Access to space: This determines how to get the ventilating
air into and out of the space
d. Power requirements and availability: This will influence
the power source and fan motor size
e. Source of clean air: This is necessary to ensure adequate
ventilation
f. Length of time ventilation is needed: This is determined
by the type of contaminant and the work that is to be done
in the space
g. Type of work to be done: This determines whether local
exhaust ventilation or general ventilation is required
ii. Ventilation Guide:
a. Select fan with a capacity to quickly replace
the air in the space. Limitations are typically posted on
the fans housing.
b. Use reliable, grounded electrical power.
c. Eliminate any hazardous atmosphere. Exhaust toxic and flammable
air, supply fresh air when oxygen-deficient.
d. Provide constant circulation of fresh air while space is
occupied:
i. Natural ventilation is allowable only on
non-permit entry.
ii. Direct high-velocity supply ventilation to mix the air
throughout the space.
iii. Capture contaminants during hot work or cleaning with
solvents by using additional local exhaust.
iv. Pure oxygen is not fresh air. Never use bottle oxygen
for ventilation.
v. Arrange ductwork to ensure safety.
vi. Monitor the air to ensure ventilation is keeping the air
safe to breathe.
3.4 Employee Duties
A. Duties of Authorized Entrants:
1. Know the hazards that may be faced during
entry.
2. Recognize the signs and symptoms of hazard exposure
3. Understand the consequences of hazardous exposure.
4. Use equipment properly.
5. Communicate with the attendant.
6. Alert the attendant of hazards.
7. Exit the permit space quickly when required.
B. Duties of Attendant:
1. Know entry hazards.
2. Know behavioral effects of exposure.
3. Maintain accurate entrant identification.
4. Remain outside the permit space.
5. Communicate with entrants.
6. Monitor entry activities.
7. Summon rescue and emergency services.
8. Prevent unauthorized entry.
9. Perform non-entry rescue.
C. Duties of Entry Supervisor:
1. Know the potential hazards during entry
and work.
2. Determine if acceptable entry conditions are present at
a permit space where entry is planted.
3. Terminate entry.
4. Verify that rescue services are readily available or the
means for summoning them are operable.
5. Remove unauthorized individuals who enter or try to enter
the permit space during entry and work.
6. Determine that entry and work operations remain consistent
with entry permit terms and that acceptable entry conditions
are maintained.
3.5 Conclusion of Entry
The lead worker will determine when the entry
operations have been completed. The permit space will be closed
and the permit canceled. The lead worker will write “Permit
Closed” with the date, time and signature. Reentry into
the permit space will only be allowed after following all
aspects of this program.
3.6 Measures to Prevent Unauthorized Entry
If a permit-required confined space is located
within this facility, management shall inform employees of
the existence of such a space by posting a warning sign which
reads:
DANGER
PERMIT-REQUIRED CONFINED SPACE
DO NOT ENTER
When posting of warning signs is not feasible,
permit-required confined spaces shall be identified by other
equally effective means such as by training.
4.0 Emergency Response
A. To facilitate pre-entry rescue, retrieval
system or other methods shall be used whenever an authorized
entrant enters a permit space, unless the retrieval equipment
would increase the overall risk of entry or would not contribute
to the rescue of the entrant.
B. Retrieval system shall meet the following
requirements:
1. Each authorized entrant shall use a chest
or full body harness with a retrieval line attached at the
center of the entrant’s back near shoulder level or
above the entrant’s head.
2. The other end of the retrieval line shall be attached to
a mechanical device or fixed point outside the permit space
in such a manner that rescue can begin as soon as the rescuer
becomes aware that rescue is necessary.
C. If an injured entrant is exposed to a substance
for which a MSDS or other similar written information is required
to be kept at the worksite, the MSDS or written information
shall be made available to the medical facility treating the
exposed entrant.
D. The facility shall contact its local Fire
Department/Emergency Rescue to inform them that they will
be designated as the outside rescue team. They shall be made
aware of the hazards they may confront when called on to perform
rescues. Facilities shall provide the Fire Department/Emergency
Rescue with access to all permit spaces from which rescue
may be necessary so that they can develop appropriate rescue
plans and practice rescue operations.
5.0 Training
Employees involved with permit-confined space
work will be trained to assure the knowledge, understanding,
and skills necessary for the safe performance of their duties.
Management and supervisors will be trained in the identification
and evaluation of confined space hazards and the proper precautions
to be taken to assure safe entry and work in confined spaces.
Employees entering confined spaces will be trained in the
hazards and potential hazards involved and how to protect
themselves from the hazards. They will be trained to never
enter a confined space until a permit has been authorized
to enter. Attendants will be trained in their duties and responsibilities
and the action to be taken in the event of an emergency.
A. Initial and annual training refresher courses
must be completed.
1. Initial training must be provided to each
affected employee:
o Before the employee is assigned confined
space duties.
o Before there is a change in assigned duties.
o When there is a change in permit space operations.
o Whenever management feels that there are inadequacies in
the program or training.
2. Annual Training:
Annual training must be accomplished for all
affected employees on a refresher and review basis.
3. Training documents must contain each trained
employees name, signature and date of training.
B. Management/supervisor shall be responsible
for the following:
1. Identifying confined spaces.
2. Identifying hazards within a confined space.
3. Document that all training requirements for a specific
confined space entry have been met by signing the pre-entry
authorization space on the entry permit
4. Obtaining and maintaining all equipment necessary to complete
the confined space entry.
5. Terminating the entry and canceling the permit.
C. The person(s) authorized to enter a confined
space shall be responsible for and receive training in the
following:
1. The knowledge of hazards that may be faced
during entry, including symptoms and consequences of the exposure.
2. Proper use of equipment:
• Atmospheric testing and monitoring
equipment.
• Ventilating equipment needed to obtain acceptable
entry condition.
• Communication equipment necessary to maintain contact
with the attendant.
• Personal protective equipment as needed.
• Rescue and emergency equipment as needed.
• Any other equipment necessary for safe entry into
and rescue.
3. How and when to communicate with attendant
as necessary.
4. Alert the attendant whenever:
• The entrant recognizes any warning
sign or symptom of exposure.
• The entrant detects a prohibited condition.
5. Exiting the permit space as quickly as
possible whenever:
• An order to evacuate has been given by the attendant
or supervisor.
• The entrant recognizes any warning sign or symptom
of exposure.
• The entrant detects a prohibited condition.
• An evacuation alarm is activated.
D. Person authorized to perform duties as
attendant shall be responsible for and receive training in
the following:
1. Knowing the hazards that may be faced during
entry.
2. Continuously maintaining an accurate count of authorized
entrants in the permit space.
3. Remain outside the permit space during entry operation.
4. Attempting non-entry rescue if proper equipment is in place
and the rescue attempt will not present further hazards to
the entrant or attendant.
5. Communicating with authorized entrants as necessary to
monitor entrant’s status and to alert entrants of the
need to evacuate the space when conditions warrant.
6. Monitoring activities inside and outside the space to determine
if it is safe for entrants to remain in the space and ordering
the authorized entrants to evacuate the permit space immediately
under any of the following conditions:
• If the attendant detects a prohibited condition.
• If the attendant detects the behavioral effects of
a hazardous exposure.
• If the attendant detects a situation outside the space
that could endanger the authorized entrant.
• If the attendant cannot effectively and safely perform
all the duties required by this program.
7. Summoning rescue and other emergency services when necessary.
8. Perform no duties that might interfere with the attendant’s
primary duty to monitor and protect the authorized entrants.
Confined Space Summary Inventory Sample
CONFINED SPACE AREA DESCRIPTIONS AND HAZARDOUS
ANALYSIS
Each facility shall perform a workplace analysis to determine
if any space fits the criteria for a permit required confined
space. Based on a walk through analysis of the work place,
both permit and non-permit confined spaces have been identified
and their hazards evaluated.
Confined Space Descriptions: Hazard Analysis
Permit for Entry Required?
1. Manure Pit – Barn 1 Oxygen deficient, presence of
CO2, methane, and H2S Permit-Confined Space
Non-Confined Space
2. Grain Bin 2 Auger located in bottom
Grain being received from top of bin, possible O2 deficiency
Permit-Confined Space
Non-Confined Space
3. Feed Truck Auger rotation Permit-Confined Space
Non-Confined Space
4. Walk-in Freezer Cold Temp, asphyxiation potential Permit-Confined
Space
Non-Confined Space
5. Permit-Confined Space
Non-Confined Space
6. Permit-Confined Space
Non-Confined Space
7. Permit-Confined Space
Non-Confined Space
8. Permit-Confined Space
Non-Confined Space
9. Permit-Confined Space
Non-Confined Space
10. Permit-Confined Space
Non-Confined Space
11. Permit-Confined Space
Non-Confined Space
12. Permit-Confined Space
Non-Confined Space
13. Permit-Confined Space
Non-Confined Space
14. Permit-Confined Space
Non-Confined Space
[Company Name Here]
CONFINED SPACE AREA DESCRIPTIONS AND HAZARDOUS
ANALYSIS
Each facility shall perform a workplace analysis to determine
if any space fits the criteria for a permit required confined
space. Based on a walk through analysis of the work place,
both permit and non-permit confined spaces have been identified
and their hazards evaluated.
Confined Space Descriptions: Hazard Analysis
Permit for Entry Required?
1. Permit-Confined Space
Non-Confined Space
2. Permit-Confined Space
Non-Confined Space
3. Permit-Confined Space
Non-Confined Space
4. Permit-Confined Space
Non-Confined Space
5. Permit-Confined Space
Non-Confined Space
6. Permit-Confined Space
Non-Confined Space
7. Permit-Confined Space
Non-Confined Space
8. Permit-Confined Space
Non-Confined Space
9. Permit-Confined Space
Non-Confined Space
10. Permit-Confined Space
Non-Confined Space
11. Permit-Confined Space
Non-Confined Space
12. Permit-Confined Space
Non-Confined Space
13. Permit-Confined Space
Non-Confined Space
14. Permit-Confined Space
Non-Confined Space
[Company Name Here]
CONFINED SPACE ENTRY PROCEDURE CHECKLIST/PERMIT
DATE: _____________
REASON FOR ENTRY: ______________________________________________________
SPACE TO ENTER: ________________________________________________________
EMPLOYEES: ____________________________________________________________
Supervisor present at entry ________________________________________________
Note: If there is a crew change or shift change,
this checklist must be completed again before entry.
Air Quality:
% oxygen prior to entry, at least 19.5%
Oxygen to be monitored continuously
No pesticides, flammables, sewer gas, or other potentially
hazardous odors known/suspected
Note: Work cannot proceed until confirmed safe for entry
Mechanical ventilation needed
Ventilation
a. Natural: doors, vents, inspection ports, etc. opened
b. Mechanical: fan if needed to maintain air quality
Safety Equipment Inspected and Free of Defects:
Safety Harness
Hoist Mechanism
Lifeline
Other, specify
Personal Protective Equipment to be Used:
Respirator, specify type ___________________________________________
Gloves
Eye/face protection
Other, specify __________________________________________________
General Practices:
Employees trained in procedure(s).
Communication methods, signals, etc. understood
Emergency procedures understood
Symptoms of oxygen deficiency explained
Appropriate equipment locked out, tagged, blocked, bled or
otherwise secured against unwanted movement
Duties of safety observer(s) explained
Appropriate lighting and tools provided
Work Site Conditions
Bin Entry:
If entry and exit is made with rope or chain ladder, additional
personnel are on hand to pull employee out of bin if necessary
The distributor(s) feeding the bin has been blocked so that
material is not accidentally run into the bin
Inspect bin to ensure that there is no suspended or lodged
material above the work area. Employees are not permitted
to work in bins under these conditions
Everyone understands that the safety harness and lifeline
must be used, and that they must be put on before entry and
may not be taken off until the employee is out of the bin.
Lifeline will be kept tight at all times
At least two observers will be present at all times (More
if more than one person is entering the bin)
Tank, Vessel, Equipment Entry:
Equipment secured against unwanted movement, blocked, bled
Material/liquid level low enough not to constitute a hazard
Safety line needed. If no, why? ________________________________________
Possible entrapment hazard. If so, list ___________________________________
[Company Name Here]
CONFINED SPACE TRAINING
Date of Employee Training __________
Employees involved with permit-confined space
work will be trained to assure the knowledge, understanding,
and skills necessary for the safe performance of their duties.
Management and supervisors will be trained in the identification
and evaluation of confined space hazards and the proper precautions
to be taken to assure safe entry and work in confined spaces.
Employees entering confined spaces will be trained in the
hazards and potential hazards involved and how to protect
themselves from the hazards. They will be trained to never
enter a confined space until a permit has been authorized
to enter. Attendants will be trained in their duties and responsibilities
and the action to be taken in the event of an emergency.
Topics Discussed:
Initial and annual training refresher courses
must be completed.
Initial training must be provided to each affected employee:
o Before the employee is assigned confined space duties
o Before there is a change in assigned duties
o When there is a change in permit space operations
o Whenever management feels that there is inadequacies in
the program or training
Annual Training:
o Annual training must be accomplished for all affected employees
on a refresher and review basis
Training documents must contain each trained employee's name,
signature and date of training
Management/supervisor shall be responsible for the following:
Identifying confined spaces
Identifying hazards within a confined space
Document that all training requirements for a specific confined
space entry have been met by signing the pre-entry authorization
space on the entry permit
Obtaining and maintaining all equipment necessary to complete
the confined space entry
Terminating the entry and canceling the permit
Other Topics Discussed:
Signature of Employees Attending Training:
(Print and Sign Name)
1. 2. 3.
4. 5. 6.
7. 8. 9.
Trainer Signature:
[Company Name Here]
CONFINED SPACE TRAINING FOR THE ENTRANTS
Date of Employee Training __________
Topics Discussed:
The person(s) authorized to enter a confined
space shall be responsible for and receive training in the
following:
The knowledge of hazards that may be faced during entry, including
symptoms and consequences of the exposure
Proper use of equipment:
Atmospheric testing and monitoring equipment
Ventilating equipment needed to obtain acceptable entry condition
Communication equipment necessary to maintain contact with
the attendant
Personal protective equipment as needed
o Rescue and emergency equipment as needed
o Any other equipment necessary for safe entry and rescue
How and when to communicate with attendant as necessary
Alert the attendant whenever:
o The entrant recognizes any warning sign or symptom of exposure
o The entrant detects a prohibited condition
Exiting the permit space as quickly as possible whenever:
o An order to evacuate has been given by the attendant or
supervisor
o The entrant recognizes any warning sign or symptom of exposure
o The entrant detects a prohibited condition
o An evacuation alarm is activated
Other Topics Discussed:
Signature of Employees Attending Training:
(Print and Sign Name)
1. 2. 3.
4. 5. 6.
7. 8. 9.
10. 11. 12.
13. 14. 15.
16. 17. 18.
19. 20. 21.
Trainer Signature:
[Company Name Here]
CONFINED SPACE TRAINING FOR THE ATTENDANTS
Date of Employee Training __________
Topics Discussed:
The person(s) authorized to perform duties
as attendant shall be responsible for and receive training
in the following:
Knowing the hazards that may be faced during entry
Continuously maintaining an accurate count of authorized entrants
in the permit space
Remain outside the permit space during entry operation
Attempting non-entry rescue if proper equipment is in place
and the rescue attempt will not present further hazards to
the entrant or attendant
Communicating with authorized entrants as necessary to monitor
entrants status and to alert entrants of the need to evacuate
the space when conditions warrant
Monitoring activities inside and outside the space to determine
if it is safe for entrants to remain in the space and ordering
the authorized entrants to evacuate the permit space immediately
under any of the following conditions:
o If the attendant detects a prohibited condition
o If the attendant detects the behavioral effects of a hazardous
exposure
o If the attendant detects a situation outside the space that
could endanger the authorized entrant
o If the attendant cannot effectively and safely perform all
the duties required by this program
Summoning rescue and other emergency services when necessary
Perform no duties that might interfere with the attendant's
primary duty to monitor and protect the authorized entrants
Other Topics Discussed:
Signature of Employees Attending Training:
(Print and Sign Name)
1. 2. 3.
4. 5. 6.
7. 8. 9.
10. 11. 12.
13. 14. 15.
16. 17. 18.
19. 20. 21.
Trainer Signature:
FAQ’s on this Issue and Answers:
http://www.osha.gov/html/faq-confinedspaces.html
Q: What are the most common confined spaces
I might find on a pork production operation?
A: As an employer, it’s up to you to do an inventory
of your confined spaces, as all farms are very different (forms
for completing that inventory are provided here). Likely,
you will encounter confined spaces in manure pits (and other
manure storage areas); grain and feed bins/silos; manure tankers
(“honey wagons”); feed mixers/grinders.
Q: The OSHA 1910.146 standard indicates that
it does not apply to agriculture. Is that true?
A: On a federal level, OSHA regulatory inspectors cannot inspect
your farm for compliance on 1910.146. However, confined spaces
are deadly hazards, and you can be cited for the hazards associated
with confined spaces under OSHA’s general duty clause.
The best protocol therefore to follow is 1910.146. Also, in
the past, some states have had their own confined space entry
regulations which farms DID need to comply with.
Q: I’ve tested air around my pit before,
and have NEVER detected any level of toxic gas. Do I need
to worry about this stuff?
A: The air around/in stored animal waste is often unpredictable
and can change in a matter of seconds, especially when manure
is agitated. It releases gases such as hydrogen sulfide and
other gases just like when you shake a can of soda. Many cases
where deaths have occurred happen in warmer weather when the
waste is very biologically active. You should ALWAYS monitor
the air in any pit or other farm confined space before and
during entry. This includes testing for oxygen (need 19.5%
or more oxygen); toxic gases; and flammable/explosive gases.
Additional Notes and Information
National Ag Safety Database information on
manure pits (numerous documents, fact sheets, etc): http://www.cdc.gov/nasd/menu/topic/manure.html
National Ag Safety Database information on
grain (and feed) storage (numerous documents, fact sheets,
etc): http://www.cdc.gov/nasd/menu/topic/grain.html
NIOSH document on Preventing Deaths of Farm
Workers in Manure Pits http://www.cdc.gov/niosh/90-103.html
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