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As many employers have found out the hard way, "confined space" is a fairly misleading term. "Confined" immediately makes you think of a small, cramped location-a pipe or a manhole, perhaps-where a worker has to squeeze in and run the risk of getting stuck. Many OSHA-defined confined spaces fit this description, but unfortunately, many others don't.
Is a million-gallon storage tank a confined space? How about a pipeline 10 feet in diameter? How about an open trench excavation? The truth is, all of these could be considered confined spaces. Unless you enjoy being on the receiving end of an OSHA fine, you need to know whether they are.
So what makes them a confined space? According to the OSHA definition in 29 CFR 1910.146, a confined space is characterized by the following: 1) it is large enough for an employee to physically enter the space and perform assigned work, 2) it has limited means of entry and exit, and 3) it is not intended for continuous employee occupancy.
As an employer, once you have determined that your employees are working in or near confined spaces, you must decide whether or not they fit the criteria for an OSHA permitrequired confined space. This is where it gets even trickier.
According to the OSHA standard: "The...