Confined Space Labeling
When does a confined need to be labeled?
If it meets the criteria of a standard entry permit required confined space but we don't enter it, does it need to be labeled? Or is it that once we decide to enter it, then we need to label it and add it to the inventory? Something that's come up at my plant, appreciate any input.
Comments (6)
It would still need to be labeled, even if you don't enter it. You will still need to ensure the space is secured to prevent people from entering it. See below. 1910.146(c)(3) says that even if you don't enter the permit space, you still need to comply with (c)(2), which is where labeling is required.
1910.146(c)(2)
If the workplace contains permit spaces, the employer shall inform exposed employees, by posting danger signs or by any other equally effective means, of the existence and location of and the danger posed by the permit spaces.
1910.146(c)(3)
If the employer decides that its employees will not enter permit spaces, the employer shall take effective measures to prevent its employees from entering the permit spaces and shall comply with paragraphs (c)(1), (c)(2), (c)(6), and (c)(8) of this section.
I think I know the answer, but what if you have Confined Spaces, but they do not rise to the level of Permit Required Confined Spaces?
Anyone else label everything? We pretty much treat all confined spaces (permit vs non-permit) the same in terms of execution and labeling.
Hello Larry, non-permit confined spaces and permit confined spaces can be re-classified, depending on the atmospheric conditions in the space. If you have evaluated the space after one complete work shift, using air monitoring systems, and concluded that no atmospheric conditions exist, then you may proceed to reclassify the space as a non-permit required confined space. This reclassification status can change if a new atmospheric condition is present that may become hazardous to the employees that have entered the space, which in turn, then you would have to reevaluate the space and consider it a permit-required confined space. Currently, you can go without labeling if you provide a locking mechanism to the entry of the space; if a locking mechanism is not possible, then you would have to label the space regardless of whether it is a non-permit-required confined space or a permit-required confined space. I hope this helps.