My employees will not be entering permit-spaces, so what are my responsibilities?

In our last article (read it here), we defined confined spaces and permit-required confined spaces. We also learned that if your employees are required to enter permit-spaces in your facility to perform work, you have to develop and use a written permit-required confined space program. But what if your employees do NOT have to enter the permit-spaces? Good question!

Employers with permit-spaces in the workplace, but who's employees will not be entering them, do not technically need to utilize a written permit-required confined space program. However, there are still several other requirements they have to comply with, so having a basic confined space safety policy is strongly encouraged.

First and foremost, host employers must post danger signs at the permit-spaces informing employees that they must not enter. Additionally, it is strongly recommended that all employees in a workplace with confined spaces receive at least awareness level confined space training. That way, when they see the danger sign they actually understand what it is talking about and understand the risks associated with ignoring the danger message. Take a look at the danger sign at the top of this article. Do you think it is acceptable?

Non-permit spaces must also be re-evaluated if there are changes in its use or configuration that could change its classification to a permit-required confined space. Additionally, whenever contractors will be entering the permit-spaces, the host employer has the following responsibilities:

1. Inform the contractors of the locations of the permit-spaces and that they must utilize an acceptable written permit-required confined space program.
2. Inform the contractors of the type of hazards inside of the permit-space(s), and any previous experiences with mitigating those hazards.
3. Coordinate entry operations between contractor's employees entering the space, and any other employees that may be working in the space or in close proximity to the space. The Confined Spaces in Construction Standard (OSHA 1926 Subpart AA) provides specific communication and coordination requirements. Specifically, it defines the responsibilities of the host employer, entry employer, and controlling contractor.

Lastly, a debrief must occur when the permit-required confined space work is completed. The debrief is intended to ensure the host employer and the contractors that performed work in the space are all aware of any old or new hazards that are present in the space.

As you can see, even if your employees are not going to enter a permit-required confined space, you still have quite a few responsibilities. Plus, you want to make sure your employees work in any non-permit spaces safely as well. I highly recommend at least having a basic confined space safety policy and training your employees to the awareness level if there are ANY confined spaces in your workplace.

Contact us if you need any assistance. Stay safe!