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OSHA 1926.1203

Confined spaces general requirements

Subpart AA

23 Questions & Answers
10 Interpretations

Questions & Answers

Under 1926.1203(a), who must identify confined spaces and permit spaces at a construction worksite?

Under 1926.1203(a), a competent person designated by the employer must identify all confined spaces and determine which are permit-required before work begins.

  • The employer must ensure the identification is done by a competent person and include evaluation of the space elements and testing as necessary. See 1926.1203(a).

Under 1926.1203(b)(1), how must employers inform employees about the existence and danger of permit spaces?

Under 1926.1203(b)(1), employers must inform exposed employees of the existence, location, and danger of each permit space by posting danger signs or by any other equally effective means.

  • A sign reading “DANGER—PERMIT-REQUIRED CONFINED SPACE, DO NOT ENTER” is an example that would satisfy the posting requirement. See 1926.1203(b)(1).

Under 1926.1203(b)(2), what must an employer notify the controlling contractor and employees' authorized representatives about a permit space?

Under 1926.1203(b)(2), the employer must inform employees' authorized representatives and the controlling contractor, in a timely manner and by means other than posting, of the existence, location, and dangers posed by each permit space.

  • This communication must go beyond signs and be timely so the controlling contractor and representatives can take appropriate actions. See 1926.1203(b)(2).

Under 1926.1203(c), what must an employer do if it identifies a permit space but does not authorize its employees to enter it?

Under 1926.1203(c), the employer must take effective measures to prevent its employees from entering that permit space.

  • These measures are in addition to other applicable requirements of the standard and can include physical barriers, lockouts, or other methods to keep unauthorized employees out. See 1926.1203(c).

Under 1926.1203(d), when must an employer have a written permit space program available at the construction site?

Under 1926.1203(d), an employer who decides its employees will enter a permit space must have a written permit space program that complies with 1926.1204 implemented at the construction site before entry operations begin.

  • The written program must be made available prior to and during entry operations for inspection by employees and their authorized representatives. See 1926.1203(d).

Under 1926.1203(e)(1), when can an employer use the alternate procedures in paragraph (e)(2) instead of complying with 1926.1204–1211?

Under 1926.1203(e)(1), an employer may use the alternate procedures only if it demonstrates that all specified conditions (e)(1)(i)–(vi) are met, including elimination or isolation of non-atmospheric hazards, forced-air ventilation controlling the only remaining hazard (a hazardous atmosphere), supporting monitoring/inspection data, documentation, and compliance with the paragraph (e)(2) requirements.

Under 1926.1203(e)(2)(iii), what pre-entry atmospheric testing must be done before an employee enters a permit space under the alternate procedures?

Under 1926.1203(e)(2)(iii), the employer must test the internal atmosphere before entry, in this order, using a calibrated direct-reading instrument: oxygen content, flammable gases and vapors, and potential toxic air contaminants.

  • The employer must also give any entrant or that entrant's authorized representative an opportunity to observe the pre-entry testing. See 1926.1203(e)(2)(iii).

Under 1926.1203(e)(2)(v), what are the requirements for using continuous forced air ventilation in a permit space entry?

Under 1926.1203(e)(2)(v), continuous forced air ventilation must be used so that an employee does not enter until the ventilation has eliminated any hazardous atmosphere, it ventilates the immediate areas where employees will be present and continues until all employees leave, and the air supply must come from a clean source that does not increase hazards.

Under 1926.1203(e)(2)(vi), when is continuous atmospheric monitoring required and what must monitoring provide?

Under 1926.1203(e)(2)(vi), the atmosphere must be continuously monitored unless the employer demonstrates continuous monitoring is not commercially available or periodic monitoring is sufficient; continuous monitoring must have an alarm that notifies entrants if a threshold is met, or an employee must check the monitor frequently enough to allow safe escape.

  • If continuous monitoring is not used, the employer must perform periodic monitoring. All monitoring must ensure the forced air ventilation is preventing hazardous atmosphere accumulation. See 1926.1203(e)(2)(vi).

Under 1926.1203(e)(2)(vii), what actions must employers take if a hazard is detected during entry under the alternate procedures?

Under 1926.1203(e)(2)(vii), if a hazard is detected during entry, each employee must leave the space immediately, the employer must evaluate how the hazard developed, and the employer must implement measures to protect employees before any subsequent entry.

Under 1926.1203(e)(2)(viii), what are the requirements if a hoisting system is used for entering or exiting a permit space under alternate procedures?

Under 1926.1203(e)(2)(viii), the employer must ensure a safe method of entering and exiting the space; if a hoisting system is used it must be designed and manufactured for personnel hoisting, or a job-made hoisting system may be used only if approved in writing for personnel hoisting by a registered professional engineer before use.

  • This means commercially manufactured personnel hoists are acceptable; custom hoists must have a written engineering approval. See 1926.1203(e)(2)(viii).

Under 1926.1203(e)(2)(ix) and related paragraphs, what written verification must an employer provide before entry using alternate procedures?

Under 1926.1203(e)(2)(ix), the employer must verify that the space is safe for entry and that required pre-entry measures have been taken by preparing a written certification containing the date, location of the space, and the signature of the person providing the certification; this certification must be made before entry and made available to each entrant or their authorized representative.

  • See 1926.1203(e)(2)(ix) and the general availability requirement in the subsequent paragraph. Also note that if configuration changes increase hazards, a competent person must reevaluate the space under 1926.1203(f).

Under 1926.1203(f) and (g), when must a permit space be re-evaluated or reclassified, and is forced-air ventilation alone considered elimination of hazards?

Under 1926.1203(f) and (g), a competent person must reevaluate a non-permit confined space when changes might increase hazards or if initial evaluation may have been inadequate, and a permit space may be reclassified as non-permit only when a competent person determines all hazards have been eliminated or isolated without entry (unless infeasible), and documents that determination; control of atmospheric hazards by forced air ventilation alone does not constitute elimination or isolation.

Under 1926.1203(g)(3), what documentation must an employer prepare when reclassifying a permit space to a non-permit confined space?

Under 1926.1203(g)(3), the employer must document the basis for determining that all hazards have been eliminated or isolated through a certification containing the date, the location of the space, and the signature of the person making the determination, and must make that certification available to each employee entering the space or their authorized representative.

  • This certification supports reclassification and must be retained and available as required in 1926.1203(g)(3).

Under 1926.1203(h), what must the host employer, controlling contractor, and entry employers exchange and coordinate before, during, and after permit space entry operations?

Under 1926.1203(h), the host employer must give the controlling contractor (if available) information about known permit spaces, hazards, and precautions; the controlling contractor must obtain that information and pass it to entry entities plus any additional information and precautions; each entry employer must obtain the controlling contractor’s information and tell the controlling contractor which permit program they will follow; and the controlling contractor and entry employers must coordinate operations when multiple entities work or when other activities could create hazards, with debriefings required after entry.

Under 1926.1203(i), who fulfills the role of the controlling contractor if there is no controlling contractor at the worksite?

Under 1926.1203(i), if there is no controlling contractor present, the host employer or the employer who arranged to have another employer’s employees perform the permit space entry must fulfill the responsibilities and role of the controlling contractor.

  • This ensures the duties in paragraph (h) are covered even when a formal controlling contractor is absent. See 1926.1203(i).

Under 1926.1203(e)(2)(i)–(ii), what must employers do with an entrance cover before removing it to enter a confined space?

Under 1926.1203(e)(2)(i)–(ii), employers must eliminate any conditions that make it unsafe to remove an entrance cover before removing it, and when covers are removed they must immediately guard the opening with a railing, temporary cover, or other barrier to prevent accidental falls and protect employees from foreign objects entering the space.

Practical question referencing the Asbestos remediation LOI: If a property remediation company working on residential homes encounters asbestos-containing building materials (ACBM), which asbestos standard applies?

If remediation work involves asbestos-containing building materials, the work is covered by OSHA’s construction asbestos standard, 29 CFR 1926.1101, not the general industry standard.

  • OSHA explained this distinction in its November 14, 2024 letter of interpretation about asbestos remediation protocols: see Asbestos remediation protocols (Nov. 14, 2024). Employers conducting remediation that may disturb ACBM should follow 1926.1101 and associated requirements for asbestos in construction. See the Asbestos LOI for details.

Practical question referencing the PPE hazard assessment LOI: Do employers need to assess hazards (and keep a written certification) before selecting PPE for confined space entry?

Yes. Employers must assess the workplace for hazards that require PPE and must prepare a written certification of that hazard assessment when PPE will be required.

  • OSHA’s March 28, 2024 letter of interpretation explains that employers must perform a hazard assessment and provide written certification when PPE is required (PPE hazard assessment requirements, Mar. 28, 2024). For confined spaces, the confined-space provisions also require monitoring and documentation of atmospheric testing and demonstrations when using alternate procedures; see 1926.1203(e)(1)(iii).

Practical question referencing the respirator selection LOI: If asbestos is present during a confined space job, can an employer pick respirators based solely on periodic sampling and switch down from supplied-air respirators if initial samples are lower?

No. For Class I asbestos work, employers must follow the respirator requirements in 29 CFR 1926.1101; when exposures exceed 1 f/cc as an 8-hour TWA, full facepiece supplied-air respirators operated in pressure-demand mode with an auxiliary positive-pressure SCBA are required, and employers cannot downgrade simply based on initial sampling unless the requirements for a negative exposure assessment (NEA) or other provisions are met.

Under 1926.1203(e)(2)(iii) and (e)(2)(vi), can an entrant or their representative observe atmospheric testing and monitoring?

Under 1926.1203(e)(2)(iii) and (e)(2)(vi), an entrant or that entrant's authorized representative must be provided an opportunity to observe the pre-entry testing and the testing required under continuous or periodic monitoring.

Under 1926.1203(e)(1)(iv), what must an employer do if an initial entry is necessary to obtain data showing alternate procedures are acceptable?

Under 1926.1203(e)(1)(iv), if an initial entry into the permit space is necessary to obtain the data required to support the alternate procedures, that initial entry must be performed in compliance with 1926.1204 through 1926.1211 (the full permit-required confined space entry procedures).

  • In other words, you cannot rely on the alternate (e)(2) procedures to justify an initial data-collection entry; the full permit program applies for that entry. See 1926.1203(e)(1)(iv).

Under 1926.1203(e)(2)(vi) and (e)(2)(vii), if continuous monitoring equipment alarms, what are the employer's and entrants' immediate obligations?

Under 1926.1203(e)(2)(vi) and (vii), if continuous monitoring alarms or a hazard is otherwise detected, entrants must leave the space immediately and the employer must evaluate how the hazard developed and implement corrective measures before any subsequent entry.

  • Continuous monitoring must provide an alarm that notifies all entrants when a threshold is reached (1926.1203(e)(2)(vi)); upon alarm the actions in 1926.1203(e)(2)(vii) apply. See both paragraphs for details.