One of the challenges in administering a confined space safety program is deciding which spaces to include in your inventory. The simple answer is to just include those spaces that meet the definition of a permit space*, but is this a confined space safety best practice?

My sense is that it may not be. In fact, I believe that when you’re deciding which spaces to place under the confined space program, you should consider putting aside OSHA’s legal definition of a permit space and instead use a broader measuring stick.

(For more information on this and other confined space safety best practices, consider attending our July 19-20 Confined Space Train the Trainer class being held in Medford, Oregon).

Why should we put aside the OSHA rules? The simple answer is the rules don’t take us as far as we’d like to go if we are truly going to follow confined space safety best practices and protect our employees. In other words, instead of relying on a compliance-based safety system (following rules) we should use a risk-based safety system (identifying and managing/eliminating hazards). 

Each confined space entry has unique hazards, each of which require a thorough risk assessment.

To understand this approach, let’s examine some of the deficiencies in the current permit space rules.