Confined Space Entry Requirements Under 1926 Subpart AA
A manhole, vault or other enclosed space should be assessed by its actual features and hazards, not by its name. Subpart AA defines a confined space and the conditions that make it permit-required.
Start with the space itself
Under 29 CFR 1926.1202, a confined space is large enough for an employee to enter bodily, has limited or restricted entry or exit, and is not designed for continuous occupancy. A manhole, vault or wet well is assessed against those criteria; its name alone does not determine its classification.
When a permit is required
A confined space is permit-required if it has one or more characteristics listed in 29 CFR 1926.1202, such as a hazardous atmosphere, engulfment hazard, inwardly converging walls or floor, or another recognized serious safety or health hazard. The employer evaluates the space and its conditions against the standard.
Before a permit-space entry
Construction work can involve a host employer, controlling contractor and one or more entry employers. 29 CFR 1926.1203 sets out employer duties for identifying permit spaces, evaluating hazards, using a written permit-space program and coordinating information among employers. For a permit-required entry, the employer identifies the hazards, follows the permit procedures and assigns the roles of entrant, attendant and entry supervisor. The permit and standard determine what atmospheric testing and monitoring are needed. Rescue arrangements must fit the hazards and the entry; see 29 CFR 1926.1211.
For a permit-space entry, work through these questions:
- Has the employer evaluated the space and determined whether a written permit-space program applies?
- If entry is permit-required, is the permit completed and available to the people involved?
- What atmospheric testing and monitoring does the permit require before and during this entry?
- Have entrants, attendants and entry supervisors received the training required for their assigned duties?
- Can the designated rescue service reach the space and respond to the hazards with suitable equipment?
- How will the entry employer share the required permit-space information with the host and controlling employers?
- If the employer reclassifies the space, is the written certification required by the standard completed and available?
Recheck conditions for each entry
A permit from an earlier entry does not establish that today’s conditions are unchanged. Consider flow, connected systems, nearby work, atmosphere and access each time; the employer evaluates the actual space and entry conditions. A space’s name or an old permit does not settle the question. If you have a written safety-document request related to this work, send the requirement and the information you have. I’ll confirm whether it fits a defined written-program or JHA scope. Blueprint Safety works remotely and does not perform onsite entry evaluations, atmospheric testing or rescue operations. Request a free 30-minute preliminary consultation.