DOE OSH Standards Interpretations Response Line

Section 5 - Confined Space Entry

Frequently Asked Questions (FAQs)

PERMIT REQUIRED CONFINED SPACE ENTRY, 29 CFR 1910.146 - SCOPE AND APPLICATION

• Is compliance with 1910.146 mandated by DOE?

• The caller wanted to know if mechanical equipment rooms could be considered to be permit required confined spaces?

• Under the new confined space standard, is the space within an external tank with a floating top a confined space? At what depth of floating roof does this space become a confined space? The height of the roof varies with the depth of the product in the tank. Workers climb a ladder to the top of the tank and down an internal ladder to the roof. The "Oil and Gas Journal" advises that when the roof is more than 5 feet down from the lip of the tank, that it should be considered a confined space.

• Is there an exemption from the confined space standard for utility workers. He recalls hearing, perhaps in the BNA Reporter, that there was a recently issued OSHA exemption for utility workers and would like to know which kinds of utilities are exempted: telecommunications, water/sewer, electric?

• The caller asked for help in interpreting the definition of a confined space. Although the spaces in question are large enough for entry and are not designed for continuous employee occupancy, there is a question as to whether the single "submarine style" door constitutes a limited or restricted means for entry or exit under the definition of a confined space in 1910.146(b).

  Each space is a filter plenum that measures approximately 40 x 40 x 20 feet. The only means of entry or exit is the submarine style door that is an airlock. It allows upright entry, but requires 15-20 pounds of pressure to open because of the negative pressure in the space. There is a 6 inch high door ledge that one must step over, which helps make the seal. When closed, it is air-tight and virtually sound proof. Workers enter the space to change out filters or take readings. Workers are required to wear PPE, including respirators, inside this space because the filters contain alpha emitters.

DEFINITIONS

• Is a harness required in the following situation, there is a 12-15' well in which a pump must be replaced on rare occasions. An employee must enter to undo the bolts. Air monitoring is performed and no air quality problems have been detected. A permit program is in place and the response team is notified prior to each entry.

• What is the meaning of "limited egress" in the definition of confined space? Is a pit or trench that is 3 1/2 feet deep considered to have limited egress?

• Must a space be large enough for a whole body to fit into it in order to be considered a confined space under 1910.146?

GENERAL REQUIREMENTS

• The caller asked if DOE had issued any guidance on the confined space standard.

• Do all permit required confined spaces have to be marked or do they have to be marked just before entry?

• If an entry is made into a confined space with the worker wearing a harness and attached to a retrieval winch, must procedures be established to summon rescue and emergency services?

• Does OSHA provide guidance on proper sampling for confined space entry? If not in the standard, where can one find this guidance?

• Is a harness required for confined space entry?

• What are the procedures, concerning safety and health, for entry into non permit required confined spaces?

• Are permits required for firefighters who enter confined spaces for emergency response? Would standard operating procedures be sufficient/required?

• The Permit Required Confined Space Entry Standard (1910.146) in paragraph (c)(5) allows an employer the option of developing alternate entry procedures. If an employer is to do this:
  1. What documentation and testing is required?
  2. If you have a number of spaces that are virtually identical, can a typical space be monitored and the results applied to other spaces?
  3. Are calculations of volumes and flow rates acceptable in place of monitoring?
  4. How many air changes per hour are required? What would be considered an acceptable rate?

• What are the differences between the OSHA general industry and construction standards on confined space. Has OSHA published a compliance directive (CPL) on the confined space standard yet?

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Last modified: 04/18/96 08:50:32