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CONFINED SPACES
1. Scope
1.1 This guideline covers practices and procedures
to protect employees in the galvanizing industry from
the hazards of entry into confined spaces.
1.2 This guideline covers the Occupational Health
and Safety Administration (OSHA) final rule and
amendment in 29 CFR 1910.146 concerning
requirements for Confined Space Entry (CSE).
1.3 This guideline for confined spaces follows the
CSE standard and applies to all of general industry,
including galvanizers. The CSE standard requires
employers to prepare a written program and
implement a confined space entry permit system.
J.J. Keller Associates, Confined Space Final
Rule Your New Requirements Under OSHA Section
1910.146. March 1993, Volume 3, Number 3
J.J. Keller Associates, Industrial Safety Report
Special Report Permit-Required Confined Spaces.
October 1996, Volume 6, Number 10
Roughton, James. Hazardous Materials Control.
Confined Space Entry: The Standard. May/June
1993, p.16-17
3. Terminology

2. Referenced Documents 3.1 Definitions

BNA Communications Inc. Confined Spaces,
Deadly Places Employees Manual. Edited by: Judy
Knight, 1992
BNA Communications Inc. Survival by Permit
Employees Manual. 1992
J.J. Keller Associates, OSHA Compliance Manual
29 CFR 1910 Plant Safety. Updated October 1998.
3.1.1 The following terms and definitions are
specific to the guideline for confined spaces.
3.2 Definitions of Terms Specific to the Guideline
3.2.1 acceptable entry conditions conditions that
must exist in a permit space to allow entry and to
ensure that employees involved with a permit-
required confined space entry can safely enter into
and work within the space.
3.2.2 attendant an individual stationed outside
one or more permit-required confined spaces who
monitors the authorized entrants and who performs
all attendants duties assigned in the employers
confined space program.

Disclaimer

The material contained herein has been developed to provide accurate and authoritative information about the practices and
procedures to protect employees in the galvanizing industry from the hazards of entry into confined spaces. This material
provides general information only and is not intended as a substitute for competent professional examination and verification
as to suitability and applicability. The publication of the material herein is not intended as a representation or warranty on the
part of the American Galvanizers Association, Inc. Anyone making use of this information assumes all liability arising from
such use.

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 3.2.3 authorized entrant individual who is
authorized by the employer to enter a permit-required
confined space
3.2.4 authorized entry an entry that is has been
authorized by the entrant supervisor and is restricted
to authorized personnel, such as, authorized entrant,
and attendant
3.2.5 confined space a space that is:
(1) large enough and configured so that an employee
can bodily enter and perform assigned work; and
(2) has limited or restricted means for entry or exit
(ex. Tanks, vessels, silos, storage bins, hoppers,
vaults, and pits are spaces that may have limited
means of entry); and
(3) not designed for continuous employee
occupancy.
3.2.6 entry action by which a person passes
through an opening into a confined space. Entry
includes performing work activities in that space and
is considered to have occurred as soon as any part of
the entrants body breaks the plane of an opening into
the space.
3.2.7 entry permit written or printed document
that is provided by the employer to allow and control
entry into a permit-required confined space and that
contains the information specified in section 6.2.1
and 6.2.2 of this guideline.
3.2.8 entrant supervisor individual (such as an
employer, foreman, or plant manager) responsible
for:
(1) determining if acceptable entry conditions are
present at a permit-required confined space
where entry is planned,
(2) authorizing entry and overseeing entry
operations,
(3) terminating entry as required.
3.2.9 program administrator individual
responsible for issuing and administrating the
confined space program and making sure that the
program satisfies all applicable Federal, State, and
local confined space requirements
4. Definition of a Confined and Permit-Required
Confined Space
4.1 The OSHA standard defines a Confined
Space as an enclosed area that is large enough that an
employee can completely enter the space to perform
an assigned task, has limited or restricted means for
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entrance and exit, and is not designed for continuous
employee occupancy.
4.2 A Permit-Required Confined Space is
defined as a confined space that exhibits one or more
of the following characteristics:
Contains or has the potential to contain a
hazardous atmosphere (toxic, flammable,
asphyxiating).
Contains a material which may engulf the
entrant.
Is configured such that an entrant could be
trapped or asphyxiated by inwardly
converging walls; or has a downward
sloping floor that tapers to a smaller cross-
sectional area.
Contains any other recognized serious
safety or health hazards.
4.2.1 If one or more permit-required confined
spaces are present at a facility, the employer must
develop a confined space entry permit system to
restrict and regulate entry into those spaces.
4.2.2 Employees are allowed to participate in
developing a confined space entry permit system and
to have access to permit-required confined space
program information.
4.2.2.1 Employee participation ensures
employee involvement in developing and
implementing the confined space entry permit
system.
4.3 A sample of a permit-required confined space
decision flow chart and an example of a typical
permit are included as appendices.
4.4 A space classified by an employer as a permit-
required confined space may be reclassified as a non-
permit confined space under the following process:
i.) If the space poses no actual or potential
atmospheric hazards and if all hazards within
the space are eliminated without entry into the
space, the permit-required confined space may
be reclassified as a non-permit confined space
for as long as the non-atmospheric hazards
remain eliminated.
ii.) The employer shall document the basis
for determining that all hazards in a permit-
required confined space have been eliminated
through a certification that contains the date,
location of the space, and signature of the
person making the determination.
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 iii.) The certification shall be made available
to each employee entering the space and be
retained by the employer for one year.
5. Types of Confined Spaces
5.1 Confined spaces can be categorized as areas
with open tops that restrict the natural movement of
air or enclosed spaces with a limited number of
openings for entry or exit. In both cases, the space
may contain mechanical equipment with moving
parts, that compound the hazards present within the
confined space.
5.1.1 Galvanizing kettles, pickling and caustic
tanks, and the access pits around these vessels may
be classified as open topped confined spaces that
usually contain no moving parts.
5.2 Open topped water tanks that appear harmless
may develop toxic atmospheres such as hydrogen
sulfide from the vaporization of contaminated water.
When an entry into a confined space is being
planned, gases heavier than air are a primary concern.
5.3 Confined spaces such as sewers, manholes,
storage tanks, baghouses, and furnaces usually have
limited access. The potential problems arising in
these areas are similar to the hazards that occur in
open topped confined spaces; however, the limited
access increases the risk of injury.
5.4 Under certain conditions, excavations,
trenches or natural depressions may be considered
confined spaces because they trap potentially
hazardous vapor and restrict the flow of oxygen.
5.5 Activities associated with storage tanks that
may involve confined space entry include tank lining,
trench digging for access to piping associated with
tanks, excavating or repairing beneath tanks, and
entering manways to access instrumentation.
5.6 Examples of areas common to the galvanizing
industry that can be considered confined spaces
include:
access pits
baghouses (dust collectors)
caustic tanks
chemical storage tanks
containment pits
galvanizing kettles
hazardous and non-hazardous waste tanks
kettle pits
manholes
pickling tanks
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quench tanks
rinse tanks
spent acid tanks
sumps
6. Hazards of a Confined Space
6.1 Hazards may also develop due to the work
being performed in a confined space. For example,
welding can generate toxic gases or use up the
available oxygen and change the status of a confined
space from safe to hazardous.
6.2 Gases that are heavier than air may lie in a
confined space for hours or even days after the area
has been opened. The hazard may be overlooked
with fatal results because some gases are odorless.
Gases that are lighter than air may also be trapped
within an enclosed type of confined space, especially
those with access from the bottom or side.
7. Entry Permit
7.1 Before entering any permit-required confined
space, acceptable entry conditions must be verified
through testing and an entry permit must be
completed and signed by an entry supervisor to
authorize entry.
7.2 An entry permit, in addition to an authorized
entry, serves as a source of critical safety and hazard
information for entrants, attendants, and emergency
responders.
7.2 An entry permit acts as a check that all
hazards have been controlled, and equipment and
safety procedures are in place prior to authorization
by an entry supervisor.
7.2.1 The permit must identify all conditions to be
evaluated to ensure safe entry into a permit-required
confined space, and should include the following
information in the checklist portion of the permit:
Hazards (potential and actual) of the confined
space
Measures for isolation (i.e. lockout/tagout) of
the confined space
Equipment and procedures used for purging,
inerting, ventilating and flushing the
confined space in order to remove or control
potential hazards
Acceptable environmental conditions which
must be maintained during entry (i.e.
temperature, atmosphere, etc.)
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 Testing procedures and monitoring equipment
used by the employer to verify that
acceptable environmental conditions are
being maintained during entry
Rescue and other emergency services to be
summoned in case of an emergency,
including the appropriate means of
communicating with those services
On-site rescue equipment which will be
provided; if necessary
Communication procedures and equipment
used by authorized entrants and attendants in
order to maintain contact during the entry
Personal protective equipment, such as
respirators, clothing and retrieval lines,
necessary to ensure employee safety
Any other pertinent information dependent
upon the circumstances and conditions of the
confined space
Specific measures taken to remove or control
permit confined space hazards
Initial and/or periodic test results
corresponding to entry conditions with
name(s) or initial(s) of tester(s) and when
tests were performed
A list of all equipment used to comply with
entry requirements
Any additional permits issued to authorize
work in the permit space
7.2.2 In addition to the checklist items required
above, the standardized permit form must also
include the following information:
Identity of the confined space
Purpose of the entry
Date and authorized duration of the entry
A list of authorized entrants
A list of eligible attendants
A list of individuals eligible to supervise the
entry
Signature and printed name of the person
authorizing the entry, verifying that all
actions and conditions necessary for safe
entry have been performed
8. Duties of Permit-Required Confined Space
Entry Personnel
8.1 Authorized entrants Authorized entrants must
know the hazards they may face, be able to recognize
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signs or symptoms of exposure, and understand the
consequences of exposure to the hazards.
8.1.1 Authorized entrants must know how to use
necessary equipment and communicate with the
attendants.
8.1.2 Authorized entrants must be aware of the
emergency plan, how to warn other entrants of the
existence of a hazardous condition, and summon help
if someone is in distress.
8.1.3 Authorized entrants must be familiar with the
tasks they are expected to perform in the permit-
required confined space. The authorized entrants
should complete additional training in procedures that
are not routine, as well as any potential hazards and
how to control them.
8.1.4 Authorized entrants or their authorized
representative have an opportunity to observe any
testing or monitoring of permit-required confined
spaces conducted prior to entry and subsequent to
entry.
8.1.4.1 By observing the testing or monitoring
of a permit-required confined space, the authorized
entrants or their authorized representative help to
ensure that the testing has been done properly,
respirators and other personal protective equipment
being worn are appropriate.
8.2 Attendant - An attendant must be assigned to
every permit-required confined space entry.
8.2.1 An attendant can monitor multiple spaces if
the permit program incorporates procedures to enable
the attendant to respond to an emergency in one or
more of the spaces without compromising the
attendants overall responsibilities.
8.2.2 An attendant cannot perform other duties
that interfere with the primary duties of monitoring
and protecting the safety of authorized entrants.
8.2.3 The attendant must know the hazards of the
confined space and be aware of the warning signs and
physical symptoms of toxic gases.
8.2.4 Some of the other responsibilities for
attendants include:
maintain a continuous count and identification
of authorized entrants
prevent unauthorized entry by remaining
stationed outside until the space is relieved
communicate with the entrants to monitor
status and activities inside and outside the
space and order an emergency exit if required
summon rescuers if necessary and begin to
perform a non-entry rescue if it can be done
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 safely
8.2.5 An attendant may also be responsible for
continuously monitoring the air, recognizing
hazardous atmospheric changes, and ordering
evacuation of the space as warranted. An attendant
must also be aware of any special work practices that
need to be done in the space before an entry begins.
If auxiliary ventilation is used, the attendant should
be sure that the source of air intake does not draw
carbon monoxide or other contaminants into the
space.
8.3 Entrant supervisors An entrant supervisor
must know the hazards that may be faced during
entry, including information on the mode, signs or
symptoms, and consequences of exposure.
8.3.1 An entrant supervisor needs to verify that all
tests specified by the permit have been conducted and
that all procedures and equipment specified by the
permit are in place before endorsing the permit and
allowing entry to begin.
8.3.2 Other responsibilities of an entrant
supervisor include:
terminating the entry and canceling the permit
verifying that rescue services are available and
that the means for summoning them are
operable
removing unauthorized individuals who enter
or who attempt to enter the permit-required
confined space during entry operations
determining that entry operations remain
consistent with the terms of the entry permit
and that acceptable entry conditions are
maintained
9. Preparation of Permit-Required Confined
Space
9.1 All material (for example, liquid) will be
transferred into a holding container(s).
9.2 Once this procedure is completed, all transfer
piping will be properly locked-out/tagged-out
according to the lockout/tagout procedure.
9.3 All heat and energy sources will be properly
locked-out/tagged-out according to the lockout/tagout
procedure.
9.4 The necessary supervisors will then be
notified that the permit-required confined space is
free of material and the material and heat sources are
locked-out/tagged- out.
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10. Hazard Testing before Entry into Permit-
Required Confined Space
10.1 Prior to entry, the permit-required confined
space shall be tested for lingering hazards.
10.1.1 The atmospheric testing of the permit-
required confined space should include oxygen,
flammability (LEL Lower Explosive Limit) and
toxics (i.e. carbon monoxide, hydrogen sulfide).
Testing should be conducted in the following order:
First test for oxygen content, secondly test for
flammability (LEL), then test for toxic hazards. If
oxygen, flammability and toxic atmospheric testing
are acceptable, proceed with preparing the equipment
for the permit-required confined space entry. The
acceptable levels of oxygen are between 19.5% and
23.5% by volume. Flammable gases shall not
contain flammable gas, vapor, or mist in excess of 10
% the LEL. The acceptable toxic levels will depend
on the permissible exposure levels (PELs) of the type
of gas.
10.1.2 If the testing indicates unacceptable levels,
the next step is to utilize forced air ventilation to
provide oxygen to the space and/or remove toxic or
flammable atmospheres. The permit-required
confined space should be monitored while the space
is being ventilated. When the permit-required
confined space atmosphere is acceptable, proceed
with preparing equipment for the permit-required
confined space entry.
10.1.3 The permit-required confined space area
will be continuously monitored while the repairs or
work is being done on the permit-required confined
space.
10.1.4 The permit-required confined space entry
evaluation log will be maintained at all times from
the initial testing until all personnel and equipment
are out of the area.
10.2 Authorized entrants have an opportunity to
observe the testing or monitoring of the permit-
required confined space to ensure that testing has
been done properly prior to entry or subsequent to
entry.
11. Preparing the Equipment
11.1 All necessary equipment will be gathered and
inspected prior to entry into the permit-required
confined space.
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 11.1.2 The equipment should include items
necessary to perform the activity in the permit-
required confined space.
11.1.3 The equipment should also include any
personal protective devices that are needed. The
equipment should be checked to make sure that it is
working correctly and fitted properly to the
authorized entrant.
12. Topics to Discuss Before Entering the Permit-
Required Confined Space
12.1 Before entering the permit-required confined
space, a meeting should take place to discuss issues
that may occur during the procedure.
12.2 These issues would involve potential
situations that may occur while attending to tasks
while in the permit-required confined space and
information on various personal assignments.
12.2.1 Topics for Discussion
1. Potential slippery floor surface
2. Overhead crane activity
3. Proper use of personal protective
equipment
4. Individuals who will be in permit-required
confined space
5. Safety observer assignment
6. Ensure safety observers understand their
duty and responsibility
7. Use of safety harnesses, and rescue
procedure
8. Length of time expected to be in permit-
required confined space
9. Individuals going into permit-required
confined space personally check
lockout/tagout locations
10. Procedure for evacuation if atmosphere
turns hazardous while in permit-required
confined space
13. Rescue Procedures
13.1 A procedure is set up in case of an
emergency situation and a rescue is necessary.
13.2 The following is a list of procedures when an
authorized entrant is in a confined space.
1. Entrant supervisor will be monitoring
atmospheric conditions for a change in
oxygen level at all times.
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2. If there is a change in the condition of the
atmosphere in the permit-required confined
space, the authorized entrant shall
immediately leave the space.
3. If the authorized entrant is overcome by
vapors, the entrant supervisor will
immediately radio for emergency backup, and
then retrieve the authorized entrant with the
retrieval system.
4. When radioing for backup, the entrant
supervisor will instruct the main office to dial
911 and have an emergency response.
5. When the authorized entrant is rescued from
the permit-required confined space, the entry
supervisor or the attendant should
immediately provide first aid as needed, until
the emergency response department arrive.
14. Rescue and Emergency Services
14.1 OSHA permits employers to rely on outside
rescue and emergency services.
14.1.1 If an employer chooses this strategy, the
company must provide outside responders with
information about their permit-required confined
spaces and make their facilities available for permit-
required confined space rescue practice.
14.1.2 An employer must select a rescue service
that is trained, equipped and available to respond to
emergencies that occur during permit-required
confined space entries.
14.1.2.1 OSHA has added a non-mandatory
Appendix F to the 29 CFR 1910.146 that provides
guidance to employers in choosing appropriate rescue
services for permit-required confined spaces.
14.2 Employers may elect to have their own
employees enter permit-required confined spaces to
perform rescue services.
14.2.1 Employers must ensure that each member of
the rescue team is:
Provided with and trained to properly use the
personal protective equipment and rescue
equipment necessary for making rescues from
permit-required confined spaces
Trained to perform the assigned rescue duties
Practice making permit-required confined
space rescues at least once every twelve
months by means of simulated rescue
operations in which they remove dummies,
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 mannequins, or persons from the actual
permit-required confined spaces or from
representative permit-required confined
spaces. Representative permit-required
confined spaces shall with respect to opening
size, configuration, and accessibility,
simulate the types of permit-required
confined spaces that rescue is to be
performed
Trained in basic first aid and in CPR
15. Nonpermit-Required Confined Spaces
15.1 Confined spaces can also be nonpermit
required confined spaces. Nonpermit-required
confined spaces do not have the same stringent
procedures as a permit-required confined space.
15.1.1 Nonpermit-required confined spaces do
not require an entry permitting system with
authorized personnel.
15.2 A nonpermit-required confined space is a
confined space that does not contain any
characteristics of a permit-required confined space.
15.3 Procedures for a nonpermit-required
confined space
The first step is to set up rescue procedures in
case an emergency occurs in the nonpermit-
required confined space. The procedures
should include:
1. The location of the emergency equipment
that is easily accessible to the location of
a nonpermit-required confined space.
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2. Emergency equipment should be checked
to make sure it is working properly and is
not damaged.
3. Employees should be trained in the
proper use and care of the emergency
equipment.
4. Emergency contacts should be readily
available and posted
5. General training in confined space
hazards should be done for any employee
that will be working in or around the
nonpermit-required confined space.
Before entering any type of confined space,
testing of the atmosphere in the confined
space may be necessary.
1. Testing should involve making sure that
the nonpermit-required confined space is
safe for entry.
2. Under certain circumstances, the
atmosphere in the nonpermit-required
confined space may change. Working in
a nonpermit-required confined space may
decrease the level of oxygen and
ventilation may be needed.
3. If the atmosphere changes in a
nonpermit-required confined space,
necessary precautions should take place.
The precautions should entail the proper
procedures in ventilating the nonpermit-
required confined space.
General safety precautions and common sense
should be used while working in or around a
nonpermit-required confined space.
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