Thursday, August 1, 2013

Misunderstandings About the Applicability of OSHA's Permit-required Confined Spaces Standard

When OSHA published their Permit-required Confined Space standard (1910.146), it was inevitable that some people would misunderstand one or more parts of that complex standard. Surprisingly, though, the employers I find who are not in compliance with the requirements of this OSHA regulation are often not the ones who have implemented a permit-required confined space entry program at their site, but rather the ones who have not!  That is because many employers mistakenly believe they do not have confined spaces on their premises, or, they do have permit spaces on their site but think the standard does not apply to them because their employees do not enter those spaces.
So in this month’s blog post, I am going to address the three most common myths, mistakes and misinterpretations I have seen made by employers regarding the applicability of OSHA’s permit-required confined space entry standard to their operations.
Mistake #1 – “This standard does not apply to me because I do not have any confined spaces at my facility.”
When many employers think of OSHA’s definition of a confined space, they envision only tanks and silos. And if none of these are present at their work site, then they surmise that the OSHA permit-required confined space standard does not apply to them. But what many employers often overlook are other potential confined spaces that are present at their site, such as but certainly not limited to many crawl spaces, air handlers, duct-work, bag houses, utility . . . 


  1. Valid points, indeed! I support a cadre of engineers around the nation who collectively make thousands of confined space entries every year - and none are on our properties or facilities. The broad spectrum of understanding and compliance by the Host Employers is mindboggling - from a total lack of recognizing the (potential) hazards to declarations that every confined space entry is considered a Permit-Required Entry.

  2. Thanks. Excellent points, well presented. Bob W.

  3. A plumber or electrician [many of which work alone] enters the crawl space under a residence which is egressed through a small 2' x 2' access door.

    Is this a confined space?

    What precautions must they take?


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