cetd memo adm 09 2

							MIOSHA                                                          DIVISION
Consultation Education and Training Division                    MEMORANDUM
Michigan Occupational Safety and Health Administration
Department of Energy, & Labor and Economic Growth
DOCUMENT IDENTIFIER:                                   DATE:
CETD-MEMO-ADM-09-2                                     March 19, 2009
SUBJECT: Permit-Required Confined Spaces (PRCS) – Consultation Education and
             Training (CET) Responsibility

I.     Purpose:           This memorandum provides guidance to CET staff in assisting
                          employers with PRCS determinations.

II.    Scope:             CET consultation and training activities.

III.   References:        A.     Agency Instruction MIOSHA-STD-05-1 Application of the
                                 Permit-Required Confined Spaces Standard (PRCS).
                          B.     General Industry Safety Standard, Part 90./R408.19001 et. seq.,
                                 Confined Space Entry.
                          C.     Occupational Health Standard, Part 490./R325.63001 et. seq.,
                                 Permit-Required Confined Spaces.

IV.    Distribution:      CET Staff, CET and Public S Drive folders; Internet accessible.

V.     Cancellations:     None

VI.    Contact:           Connie O’Neill, Division Director

VII.   Originator:
                                               ___________
                          Connie O’Neill, Division Director
                          Consultation Education and Training Division

This memorandum provides guidance to CET staff in providing assistance to employers with
PRCS determinations. It is the role of CET safety and health field staff to consult with and train
employers on the process of evaluating confined spaces and PRCSs. CET staff will inform
employers of their options for entering a PRCS and the associated requirements. In the course of
any consultation and training, CET staff shall not enter any confined space.

During any survey, training, intervention, assistance visit, or phone call, when CET staff is asked
to provide assistance with determining PRCS status, they will do one of the following:

       1. Give a clear answer on whether a space is a confined space or a PRCS.
       2. Call a supervisor for assistance if uncertain of the determination, or
       3. Inform the employer that further clarification is needed and provide a response back
          to the employer as soon as possible.
CETD-MEMO-ADM-09-2
March 19, 2009
Permit-Required Confined Spaces (PRCS) – CET Responsibility



If necessary, collect or obtain photos and review them with a supervisor before providing a
determination.

The decision logic for a determination should come from:

        A.       Part 90/490 Permit-Required Confined Spaces, Appendix A: Permit-Required
                 Confined Space Decision Flow Chart.
        B.       MIOSHA-STD-05-1 Application of the Permit-Required Confined Spaces
                 Standard (PRCS).
        C.       MIOSHA/OSHA Interpretations.

Definitions and explanation:

    A confined space means a space where all three of the following conditions are met:

            The space is large enough and so configured that an employee can bodily enter and
             perform assigned work; and
            The space has limited or restricted means for entry or exit (for example, tanks, vessels,
             silos, storage bins, ovens, hoppers, vaults, and pits are spaces that may have limited
             means of entry). This definition will be met if employees have to 1) bend over to keep
             from hitting their head, 2) step up over a threshold or barrier more than two inches
             (i.e., serious trip hazard); 3) use their hands to assist in entry.
            The space is not designed for continuous employee occupancy (e.g., no lighting, no
             ventilation).

    A permit-required space is a confined space which has one or more of the following
    characteristics:

            Contains or has a potential to contain a hazardous atmosphere (i.e., IDLH that could
             prevent self-rescue).
            Contains a material that has the potential for engulfing an entrant (e.g. enough liquid
             to drown, enough material to sink and suffocate).
            Has an internal configuration such that an entrant could be trapped or asphyxiated by
             inwardly converging walls or by a floor which slopes downward and tapers to a
             smaller cross-section.
            Contains any other recognized serious safety or health hazard (i.e., electrical,
             mechanical, laser light, etc.).

Resources:

There are PRCS resources on the MIOSHA website (ex. sample written programs, checklists)
that should be referred or provided to employers as part of the consultation.



                                                   2
             APPENDICES TO SECTION 1910.146 – PERMIT-REQUIRED CONFINED SPACES
    NOTE: Appendices A through F serve to provide information and non-mandatory guidelines to assist employer s and employees in
    complying with the appropriate requirements of this section.
                                                                  Appendix A

                                         (1)       Permit-required Confined Space Decision Flow ChartConsult other
                                                                                                     applicable OSHA
                                                                                                                   standards STOP

    Does the workplace contain confined spaces as defined by §1910.146 (b)?               NO
       YES

    Does the workplace contain Permit-required Confined Spaces as defined by 1910.146 (b)?                             NO

       YES

    Inform employees as required by §1910.146 (c)(2).

                                                                                    Prevent employee entry as required by
                                                                                    §1910.146 (c)(3). Do task from outside of space.
    Will permit spaces be entered:         NO

       YES

    Will contractors enter?     YES              Task will be done by contractors’ employees. Inform contractor as required by
                                                 §1910.146(c)(8)(i), (ii) and (iii). Contractor obtains information required by
        NO                                       §1910.146(c)(9)(i), (ii) and (iii) from host.

    Will host employees enter to         NO                                                       YES
    perform entry tasks?
                                          Prevent                    Both contractors and host employees will enter the space?
     YES                                  unauthorized entry.
                                                                                                  YES
                                          STOP
                                                                     NO
                                                                                  Coordinate entry operations as required by
    Does space have known or potential hazards?                                   §1910.146(c)(8)(iv) and (d)(11)

       YES                         NO                                     Not a permit required confined space. 1910.146 does
                                                                          not apply. Consult OSHA standards.
    Can the hazards be eliminated?             YES
                                                                          Employer may choose to reclassify space to non-permit
       NO                                                                 required confined space using §1910.146(c)(7). STOP
                                                                                                                              1


    Can the space be maintained in a condition safe to
                                                                                                                               1
    enter by continuous forced air ventilation only?           YES        Space may be entered under §1910.146(c)(5). STOP

      NO
    Prepare for entry via permit procedures.

                                                                                                        Permit not valid until
                                                                                                        conditions meet permit
    Verify acceptable entry conditions (Test results recorded, space isolated if                        specifications.
    needed, rescuers/means to summon available, entrants properly equipped, etc.)            NO

       YES
    Permit issued by authorizing signature. Acceptable                                Emergency exists (prohibited condition).
    entry conditions maintained throughout entry.                    NO               Entrants evacuated entry aborts. (Call
                                                                                      rescuers if needed.) Permit is void.
       YES
                                                                                      Reevaluate program to correct/prevent
                                                                                      prohibited condition. Occurrence of
    Entry tasks completed. Permit returned and canceled.                              emergency (usually) is proof of deficient
                                                                                      program. No re-entry until program (and
     YES                                                                              permit) is amended. (May require new
                                                                                      program.)
    Audit permit program and permit based on evaluation                                               CONTINUE
    of entry by entrants, attendants, testers and
    preparers, etc.


1
Spaces may have to be evacuated and re-evaluated if hazards arise during entry