Log the air test, ventilation, energy isolation and permit retention for each confined space entry. The guide below covers eight suggested checklist topics and the rule behind each one.
Key Takeaways
- Space evaluation: Your employer must identify all permit-required confined spaces at the worksite, as stated by the Washington State Department of Labor & Industries.
- Air testing: Record oxygen levels, noting that an atmosphere with more than 23.5 percent oxygen by volume is considered enriched, according to the California Department of Industrial Relations.
- Energy isolation: De-energize or isolate all hazardous energy sources, then lock them out, before entry, according to CCOHS.
- Permit retention: Retain each canceled entry permit for at least 1 year to facilitate program review, as required by the California Department of Industrial Relations.
Record permit details for the daily log
These eight topics make a practical checklist for your permit and daily log:
- Space evaluation
- Air testing
- Ventilation
- Energy isolation
- Entry opening
- Permit retention
- Alternate entry
- Employer duty
Record these items in your daily site log. For a wider daily log, see the Construction Daily Log Checklist for Supervisors. Keep each record tied to the specific publisher's rule. Do not treat one jurisdiction's rule as the rule everywhere.
Review your current confined space entry permits to ensure the oxygen percentage, ventilation method, and energy isolation steps are explicitly recorded.
Permit requirements by publisher side by side
The table below compares specific regulatory requirements from three publishers. Each row lists the publisher, the rule subject, and the exact requirement stated in the source.
| Publisher | Rule Subject | Specific Requirement or Limit |
|---|---|---|
| California Department of Industrial Relations | Energy isolation lines | Lines conveying flammable, injurious, or incapacitating substances must be disconnected, blinded, or blocked off to prevent dangerous air contamination, oxygen enrichment, or oxygen deficiency California Department of Industrial Relations. |
| California Department of Industrial Relations | Testing device approval | Electronic or thermal devices used to test spaces with flammable or explosive substances must be approved for use in such conditions as required by section 2540.2 California Department of Industrial Relations. |
| California Department of Industrial Relations | Ventilation verification | Entry may proceed only when additional ventilation has removed dangerous conditions, as demonstrated by additional testing conducted and recorded in accordance with subsection (d)(3) California Department of Industrial Relations. |
| California Department of Industrial Relations | Oxygen enrichment limit | An atmosphere containing more than 23.5 percent oxygen by volume is defined as enriched California Department of Industrial Relations. |
| Oregon Secretary of State | Alternate entry exemptions | When employees enter permit spaces under alternate entry, compliance with paragraphs (5), (6), (8), (9), (12), and (13) of the rule is not required for those entries Oregon Secretary of State. |
| CCOHS | Oxygen content check | The oxygen content in the confined space must be checked to ensure it is not enriched CCOHS. |
Use this table to verify that your permit documentation addresses each specific requirement listed by the relevant publisher.
Identify and evaluate the space before entry
Before any crew member enters a confined space, the employer must evaluate the workplace to determine if any spaces are permit-required confined spaces, according to California Department of Industrial Relations. Use this initial assessment as the baseline hazard profile for your site.
Washington State Department of Labor & Industries states that the employer has a responsibility to identify all permit-required confined spaces at the worksite, according to Washington State Department of Labor & Industries. Keeping a current list of these spaces is a practical step for your records.
California Department of Industrial Relations mandates that when there are changes in the use or configuration of a non-permit confined space that might increase the hazards to entrants, the employer shall reevaluate that space and, if necessary, reclassify it as a permit-required confined space, according to California Department of Industrial Relations. This reevaluation requirement covers spaces that were previously classified as non-permit. Writing down any reclassification decision in the site log is a sensible step.
- Initial evaluation: Conduct a full workplace assessment to identify all permit-required confined spaces.
- Hazard identification: List every space that meets the permit-required criteria for the current project phase.
- Reevaluation trigger: Monitor for changes in space use or configuration that might increase hazards.
- Reclassification check: If hazards increase, reevaluate the space and update its classification status.
- Record keeping: Log the evaluation results and any reclassification actions in the daily site record.
Test the atmosphere and verify ventilation
Before entry, test the air. CCOHS instructs workers to make sure that the oxygen content in the confined space is not enriched. California Department of Industrial Relations defines an enriched atmosphere as one containing more than 23.5 percent oxygen by volume. Compare the oxygen reading with that 23.5 percent threshold, then note both on your permit.
If the initial test reveals a flammable hazard, the air should be corrected before anyone enters. CCOHS states that if potential flammable atmosphere hazards are identified during the initial testing, the air in the confined space should be cleaned or purged, ventilated and then tested again before entry to the confined space is allowed. That sequence is the one CCOHS describes for this situation.
Select testing equipment carefully based on the environment. California Department of Industrial Relations requires that if an electronic or thermal device is used to test a confined space that contains or is likely to develop a dangerous air contamination due to flammable and/or explosive substances, then the device must be approved for use in such explosive or flammable conditions as required by section 2540.2. Using unapproved devices in these conditions violates the regulation.
Ventilation alone does not clear a space for entry. California Department of Industrial Relations specifies that when additional ventilation provided in accordance with subsection (d)(6) has removed dangerous air contamination, oxygen enrichment and/or oxygen deficiency as demonstrated by additional testing conducted (and recorded) in accordance with subsection (d)(3), entry into and work within the space may proceed subject to the provisions of subsection (d)(5). The key requirement here is that the removal of hazards must be demonstrated by additional testing that is also recorded.
To manage this process on your site:
- Check the oxygen level against the 23.5 percent threshold.
- Purge and ventilate if flammable hazards are found.
- Retest the atmosphere after ventilation.
- Confirm your testing device is approved for explosive conditions.
- Record the additional testing results before allowing entry.
Isolate energy sources and prepare the opening
Before any worker enters the space, you must secure the energy sources that could start equipment or release harmful substances. California Department of Industrial Relations requires that lines which may convey flammable, injurious, or incapacitating substances into the space be disconnected, blinded, or blocked off by other positive means. This action prevents the development of dangerous air contamination, oxygen enrichment, and/or oxygen deficiency within the space.
CCOHS specifies that all potentially hazardous energy sources must be de-energized or isolated and locked out prior to entry. The sources listed include electrical, mechanical, hydraulic, pneumatic, chemical, or thermal energy. Locking out these sources ensures that equipment cannot be turned on unintentionally while workers are inside.
The physical access point also requires specific preparation. CCOHS states that the opening for entry into and exit from the confined space must be large enough to allow the passage of a person using protective equipment. Check that the opening size fits a worker wearing the protective equipment the task requires.
To document this step on your permit, record the following:
- Line isolation: Note which specific lines were disconnected, blinded, or blocked off.
- Energy lockout: List every electrical, mechanical, hydraulic, pneumatic, chemical, or thermal source that was de-energized and locked out.
- Opening size: Confirm the entry and exit opening allows passage for a person in protective equipment.
Document alternate entry and permit retention
Alternate entry status Washington State Department of Labor & Industries explains that alternate methods allow entry into a permit-required confined space in place of full entry requirements under certain conditions. The space remains a permit-required confined space even when these alternate methods are used, according to Washington State Department of Labor & Industries.
Exempted permit sections Oregon Secretary of State Administrative Rules state that when employees enter permit spaces under alternate entry, specific rule paragraphs do not apply to those entries. Oregon Secretary of State identifies paragraphs (5), (6), (8), (9), (12), and (13) as the requirements exempted under this alternate entry provision. Oregon Secretary of State
Permit retention period Section 5157 of the California Code of Regulations, Title 8, requires employers to retain each canceled entry permit for at least 1 year. California Department of Industrial Relations specifies this retention period facilitates the review of the permit space program required by subsection (d)(14). California Department of Industrial Relations
Daily log action Record the specific alternate entry method used and the date the permit was canceled in your daily site log. Keep the canceled permit on file for at least 1 year.
Worked example for a crew lead
A crew lead plans an entry into a storage tank. Before anyone goes in, the daily log entry covers these items:
- Space evaluation: the workplace review is noted and the tank is marked as a permit-required space.
- Air testing: the oxygen reading is written down and compared with the threshold above.
- Ventilation: if a flammable hazard appears, the tank is purged, ventilated and retested before entry.
- Energy isolation: each line and energy source is noted as isolated or locked out.
- Entry opening: the opening is checked against the protective equipment the worker will wear.
- Permit retention: the canceled permit is kept for at least 1 year.
This example is illustrative only and does not describe a specific site.
Start your permit log today
Pull your most recent canceled permit and check it against the eight topics above. Note any topic it does not cover, and add it to your next daily log entry.
Confined space permit FAQs
How long must a canceled confined space entry permit be retained?
The California Department of Industrial Relations requires employers to retain each canceled entry permit for at least 1 year. This retention period facilitates the review of the permit space program required by subsection (d)(14) of the California Code of Regulations, Title 8, Section 5157, according to California Department of Industrial Relations.
What oxygen percentage indicates an enriched atmosphere in a confined space?
An atmosphere is considered enriched when it contains more than 23.5 percent oxygen by volume. The California Department of Industrial Relations defines this threshold, according to California Department of Industrial Relations.
Can an employer use alternate entry methods to skip certain permit requirements?
Under Oregon's rule, yes: specific paragraph requirements do not apply when employees enter permit spaces under alternate entry conditions. The Oregon Secretary of State Administrative Rules state that you do not need to comply with the requirements of paragraphs (5), (6), (8), (9), (12), and (13) for those entries, according to Oregon Secretary of State.
Who is responsible for identifying all permit-required confined spaces at the worksite?
The employer has the responsibility to identify all permit-required confined spaces at the worksite. The Washington State Department of Labor & Industries assigns this duty to the employer, according to Washington State Department of Labor & Industries.
What must be done to hazardous energy sources before entry?
All potentially hazardous energy sources must be de-energized or isolated and locked out prior to entry. CCOHS specifies that sources such as electrical, mechanical, hydraulic, pneumatic, chemical, or thermal energy must be secured so that equipment cannot be turned on unintentionally, according to CCOHS.
Bottom line
Check your most recent canceled permit against the eight topics above. Keep each canceled permit for at least 1 year.