Page 35 - Confined Space Training - Student Manual 2021
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Non-Permit Required Confined Spaces

               Two options for entry into a permitted confined space

               Option 1 – Reclassification of the Confined Space
               The OSHA standard states:
                       “A space  classified by the employer as a permit-required  confined space  may be
                       reclassified as a non-permit confined space. If the permit space poses no actual or
                       potential atmospheric hazards and if all hazards within the space are eliminated without
                       entry into the space, the permit space may be reclassified as a non-permit confined space
                       for as long as the non-atmospheric hazards remain eliminated.”

               This is considered a C7 reclassification (C7 refers to the applicable paragraph in the OSHA
               standard.)

               Reclassification requires:
                   1.  No Actual or potential atmospheric hazards in the space
                   2.  Safety hazards can be eliminated without going into the space
                   3.  The employer must monitor/inspect the confined space and record data supporting use of
                       non-permit entry procedures

                        NOTE 1:  Control of atmospheric hazards  through forced-air ventilation does not
                        constitute elimination of the hazards.

                        NOTE 2: The employer must document the basis for determining that all hazards in a
                        permit-required  confined  space  have  been  eliminated  through  a  certification  that
                        contains the date, the location of the space and the signature of the person making the
                        determination. The certification must be made available to each employee entering the
                        space or to that employee’s representative.

                        NOTE 3: Reclassified of a permit-requires confined space does not automatically make
                        it  reclassified  for  the  next  entry operation.  Each  entry  operation  must  be assessed,
                        rendered safe and certified before it can be reclassified as a non-permit required space.

               Option 2 – Alternate Entry Procedures
               Employees needing to  enter a permit-required  confined space can utilize an alternate entry
               procedure if it can be demonstrated that the only risk associated with the confined space is an
               actual or potential hazardous atmosphere and the space can be made safe for entry.

               Alternate Entry Requires the Following:
                   1.  Any potential or actual hazardous atmosphere must be controlled  (made safe) by
                       continuous forced-air  ventilation and  the atmosphere assessed  to be  safe for entry.
                       Ventilation alone must ensure that the space can be made safe for entry.
                   2.  There must be no safety hazards associated with the entry process.
                   3.  The employer must monitor/inspect the confined space and record data supporting use of
                       the alternate entry procedures.
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