Reclassifying Confined Spaces
At Virginia Tech, confined spaces are considered to be permit-required unless otherwise classified or reclassified/declassified. Spaces may be classified (as non-permit spaces) by the department in conjunction with Environmental Health and Safety based upon preliminary evaluation, or reclassified by the confined space supervisor at the time of entry/assessment based upon the absence of existing or potential hazards, or the effective elimination/isolation of identified hazards. Where an existing or potential atmospheric hazard has been identified, the space may be entered under an alternate procedure - see requirements for forced air ventilation.
Note: The use of personal protective equipment does not constitute elimination or isolation of the hazard and therefore is not sufficient to reclassify a space.
The table below provides guidance regarding the reclassification of permit-required confined spaces.
| Hazard | Elimination (may reclassify the space) | Control (may not reclassify the space) |
|---|---|---|
Inwardly converging walls or an internal configuration that could trap entrants
|
Use of temporary floor that is secured and designed to carry the anticipated load of entrants and would-be rescuers. | Use of a harness and lifeline. |
Atmospheric hazard
|
See alternate method (forced air ventilation). | Use of respiratory protection. |
Heat stress
|
Allow sufficient cool-down time before entering space (ex. boilers, ovens). | Use of ventilation, frequent breaks outside of space, and/or personal protective equipment. |
Electrical hazards, exposed or live work (> 50 volts)
|
Effective lockout/tagout of energy source(s). Entrants must be "electrical qualified persons," 1910.269 (e) and (t) must be followed, and any remaining hazards must not be capable of endangering the life of the entrant or interfere with escape in the event of an emergency. |
1910.269 (e) and (t) is followed, and the remaining hazards are capable of endangering the life of the entrant or may interfere with escape in the event of an emergency. |
Hydraulic hazards
|
Effective lockout/tagout - provided that hydraulic energy is the source of power to drive/activate a device within the space. | Single in-line valve locked out on an elevated tank (i.e. must be "isolated" instead of locked out). |
Flowable materials (steam, natural gas, other substances) that can cause hazardous atmospheres or engulfment hazards
|
Line must be "isolated" (i.e. blanked, blinded, misaligned, a section removed, double blocked, and bled with inline venting). | Lockout/tagout (ex. control switches) |
Elevator pits (> 4 feet deep)
|
Lockout/tagout of electrical and mechanical hazards without entering the space. Note: At Virginia Tech, elevator pit entry must be made in conjunction with the elevator service company. | Electrical and mechanical hazards must be locked/tagged out by entering the space. |
Water in space
|
Depth of water is only 2-3 inches and there is no possibility of concealed hazards (ex. there is a solid concrete bottom). | Depth of water is 2-3 inches or more where there may be concealed hazards, such as unknown flooring, sub pits, etc.). |
Open-topped container or pit (> 4 feet deep), ex. dump truck beds, roll-off dumpsters, etc.
|
Temporary stairs meeting specifications for fixed industrial stairs, securely installed. | Use of portable ladder. |
Fall hazard (> 4 feet) is the only hazard
|
Use of a secured, temporary floor. Use of a harness and lifeline if the fall hazard is not inherent to the design of the space; ie. use of a scaffold or ladder within the space. |
Use of a harness and lifeline where the fall hazard is inherent to the design of the space. |
Welding and cutting
|
All other welding hazards have been eliminated by following 1910.252 and mechanical ventilation is used - see alternate method (forced air ventilation). | Use of respiratory protection. |
Mechanical hazards (ex. blades, belt drives, chains, rotating equipment, etc.)
|
Effective lockout/tagout of energy source(s). Hazards are effectively guarded per 1910 Subpart O. |
Mechanical hazards must be locked/tagged out by entering the space. |
Utility service lines (water, natural gas, fuel oil, sewage, steam electrical) within the space
|
If utility services do not terminate at end-use equipment within the space (i.e. only pass through), and there is no reasonable probability of a rupture or leak where the contents of the piping would cause serious safety or health hazards, they do not have to be considered as hazardous. Line must be "isolated" (i.e. blanked, blinded, misaligned, a section removed, double blocked, and bled with inline venting). |
There is a reasonable probability of a rupture or leak where the contents of the piping would cause serious safety or health hazards. |
Contact Information
Robin McCall-Miller, Occupational Safety Program Manager
Phone: 540-231-2341
Email: rmmiller@vt.edu