Alternate Entry Procedures

OSHA allows employers to use an alternate entry procedure for permit spaces where the only hazard is atmospheric and continuous forced air ventilation alone can control the hazard. By using the alternate procedure, employers are able to simplify confined space entries by eliminating OSHA’s requirements for:

§  An attendant during the entry,

§  A written permit program, and

§  Emergency rescue provisions.

Alternate procedures are covered in the standard at §1910.146(c)(5). The steps involved in verifying that a space qualifies for the alternate entry provision include:

1.  Ensure that it is safe to remove the entrance cover;

2.  Determine that ventilation alone is sufficient to maintain the permit space safe for entry and that work to be performed within the permit-required space must introduce no additional hazards;

3.  Gather monitoring and inspection data to support (1) and (2);

4.  If entry is necessary to conduct initial data gathering, perform such entry under the full permit program; and

5.  Document the determinations and supporting data and make them available to employees.

Entry can take place after:

§  It has been determined safe to remove the entrance cover;

§  Any openings are guarded to protect against falling and falling objects;

§  Internal atmospheric testing;

§  Air remains without hazard whenever any employee is inside the space; and

§  Continuous forced air ventilation has eliminated any hazardous atmosphere.

The space has to be tested periodically. Employees must exit immediately if a hazardous atmosphere is detected during entry, and the space must be evaluated to determine how the hazardous atmosphere developed. When a permit space is entered using alternate procedures, the employer must verify that the space is safe for entry and that the required pre-entry measures have been taken. The certification has to include:

§  Date,

§  Location of the space, and

§  Signature of the person providing the certification.

This document has to be available for review by all entrants prior to entry.