Identify before authorising entry
NR-33 applies to organisations that possess confined spaces or undertake work in them. Its definition combines a place not designed for continuous human occupancy, limited entry and exit, and an existing or potential hazardous atmosphere. It also addresses storage spaces with potential for engulfment or drowning under the stated conditions. Identification of confined spaces should not depend solely on a space appearing small or being below ground; the actual characteristics and hazards determine the assessment.
Distinct, coordinated responsibilities
The organisation appoints a technical responsible person and provides resources. That person identifies spaces, adapts the PET permit, prepares procedures and a rescue plan, and coordinates training. The entry supervisor issues the permit and checks conditions and equipment. The attendant remains outside, maintains communication and control of entrants, and activates the planned response when needed. These functions cannot be replaced by simply having an unspecified colleague somewhere near the access point.
What the PET represents
The Permissão de Entrada e Trabalho records measures and conditions for a particular entry. It is not permanent authorisation for the space, nor does a signature guarantee safety. It must correspond to the work, hazards and authorised people, with checks and closure under applicable rules. Changed conditions or unforeseen situations require the specified decisions, including interruption where appropriate. This entry does not supply entry thresholds or an operating sequence for ventilation, atmospheric testing or isolation.
Prepare rescue before it is needed
The organisation must ensure available emergency and rescue services, means to activate them and simulation exercises. The plan needs to consider the space’s scenarios and actual response capability. Calling an external service does not itself establish that it can operate under those conditions. An attendant must not improvise a rescue entry that creates another casualty; response belongs to prepared teams following the defined procedures and arrangements for the particular space.
Example involving a contractor
Before a tank is cleaned, the host and contractor compare the space inventory, risk information, task, roles, equipment and emergency response. Supervision of contracted activities forms part of the stated responsibilities. If the scope changes during the intervention, initial authorisation does not automatically remain valid. Control must follow actual conditions during execution rather than ending when the permit is handed over to the people undertaking the work.
