Permit Required Confined Spaces Archives - Confined Space Entry Training

Confined Space Training Requirements for Entry Supervisors

April 7, 2026 by Curtis Chambers Leave a Comment

Confined Space Entry Supervisor Training Requirements (OSHA 1910 & 1926)

When it comes to confined space entry, few roles carry more responsibility than the Entry Supervisor. Under both 29 CFR 1910.146 for general industry and 29 CFR 1926 Subpart AA for construction, OSHA places clear expectations on employers to ensure that individuals designated as Entry Supervisors are properly trained and capable of performing their duties.

Understanding these requirements is essential, not just for compliance, but for preventing serious injuries and fatalities.

What Does an Entry Supervisor Do?

The duties of the Entry Supervisor are outlined in 1910.146(j) for general industry, and in the construction standard in 1926.1210. Although these two standards use slightly different wording, the core responsibilities remain consistent across both standards.

At a fundamental level, the Entry Supervisor is responsible for ensuring that confined space entry operations are safe, properly planned, and fully compliant before and during entry.

This begins with a thorough understanding of the hazards of the particular confined space to be entered and work to be performed.

Hazard Recognition and Communication

An Entry Supervisor must know the hazards that are present or could potentially be present within the confined space. These may include atmospheric hazards such as oxygen deficiency, toxic gases, or flammable vapors, as well as physical hazards like engulfment or hazardous mechanical energy.

Just as important, the Entry Supervisor must understand the signs and symptoms of overexposure to these hazards.

This information must be clearly communicated to designated entrants and attendants prior to entry. Effective communication at this stage is critical and often determines whether hazards are properly recognized once work begins.

Verifying Safe Conditions Before Entry

Before authorizing entry, the Entry Supervisor must verify that all conditions required by the permit have been met.

This includes ensuring that:

All required atmospheric and other testing has been conducted
Test results are properly documented on the permit
Required procedures are in place
Necessary equipment is available, functional, and properly used

Only after confirming these elements can the Entry Supervisor sign the permit and authorize entry into the confined space.

Ensuring Rescue and Emergency Preparedness

One of the most critical responsibilities of the Entry Supervisor is confirming that rescue and emergency services are available.

Before entry is authorized, the Entry Supervisor must verify that:

Designated rescue services are available
The means to summon emergency assistance are operable

If rescue services become unavailable at any point, the employer must be notified immediately, and entry operations must be reevaluated.

This is an area where OSHA frequently identifies deficiencies during inspections.

Controlling Access and Maintaining Safe Operations

During entry operations, the Entry Supervisor plays an active oversight role.

They must ensure that:

Unauthorized individuals are immediately removed from the permit space
Entry operations remain consistent with the conditions outlined on the permit
Acceptable entry conditions are continuously maintained

At appropriate intervals—based on the hazards and work being performed—the Entry Supervisor must reassess the operation to confirm that conditions remain safe.

Terminating Entry Operations

The Entry Supervisor is also responsible for formally ending the entry operation.

This includes:

Canceling the permit at the conclusion of work
Terminating entry if a non-correctable hazard is identified

This authority is critical. If conditions become unsafe and cannot be corrected, entry must stop immediately.

OSHA Training Requirements for Entry Supervisors

OSHA does not specify a fixed number of training hours for Entry Supervisors. Instead, both standards require that employees receive training sufficient to acquire the understanding, knowledge, and skills necessary to perform their duties safely.

Effective Entry Supervisor training should include:

Hazard identification and evaluation
Atmospheric testing procedures and equipment
Permit system requirements and documentation
Roles and responsibilities of entrants, attendants, and supervisors
Emergency procedures and rescue coordination
Communication methods and protocols

Training must be provided:

Before the employee is first assigned duties
When job duties change
When new hazards are introduced
When there are indications that performance is inadequate

Common Questions About Entry Supervisors

Can an Entry Supervisor also be an entrant or attendant?

Yes. According to the footnotes for the OSHA definitions of “Entry Supervisor” in 1910.146 and 1926 Subpart AA, an individual may serve in multiple roles, including entry supervisor, provided they are properly trained, equipped, and capable of performing all assigned duties safely.

Can Entry Supervisor responsibilities be transferred during an operation?

Yes, responsibility can be transferred to another qualified individual.

However, the oncoming Entry Supervisor must verify that all conditions and protections specified on the permit are in place and effective. They must then sign the permit to formally assume responsibility for the operation.

Are the Competent Person and Entry Supervisor roles for confined space entry operations one and the same?

Under the construction confined space standard, 29 CFR 1926 Subpart AA, you will often see overlap between the roles of the competent person and the entry supervisor.

In many cases, especially on smaller job sites, the same individual may be designated to serve in both roles. When this happens, that person must be fully trained and capable of performing all responsibilities associated with each role.

However, it is important to understand that these are not automatically the same position.

The competent person is responsible for identifying existing and predictable hazards in the work environment and has the authority to take prompt corrective measures to eliminate those hazards.

The entry supervisor, on the other hand, is responsible for overseeing the confined space entry operation, verifying that all permit conditions are met, and authorizing entry.

On larger or more complex projects, these roles may be assigned to different individuals. When that is the case, clear communication and coordination between the competent person and the entry supervisor are essential to ensure that hazards are properly identified, evaluated, and controlled before and during entry.

Whether these roles are performed by one person or shared between multiple individuals, the key requirement remains the same: hazards must be identified, conditions must be verified as safe, and corrective actions must be taken without delay.

Common Mistakes Employers Make

Based on real-world observations, several issues appear repeatedly:

Failing to properly verify rescue service availability
Incomplete or improperly filled-out permits
Inadequate hazard communication to workers
Lack of periodic reassessment during entry operations

These are not minor issues; they are frequently cited by OSHA and can lead to serious consequences.

Final Thoughts

The Entry Supervisor is more than just a required designation; it is a critical safety control within any confined space program.

This individual serves as the final checkpoint before entry begins and as an ongoing authority throughout the operation. Proper training ensures that hazards are recognized, controls are verified, and unsafe conditions are addressed without hesitation.

Get OSHA-Compliant Entry Supervisor Training

Serving as an Entry Supervisor carries significant responsibility. Make sure you and your team are fully prepared.

Our online confined space training courses are designed to meet OSHA requirements under 29 CFR 1910.146 and 29 CFR 1926 Subpart AA, while providing practical, real-world guidance you can apply immediately.

Train on your schedule. Stay compliant. Keep your team safe.

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Confined Space Training Requirements for Entrants and Attendants

July 24, 2025 by Curtis Chambers Leave a Comment

Blog Post #23 – Ever wonder what it really takes to safely work in and around confined spaces? It’s not just about squeezing into tight spots with a hard hat and flashlight. OSHA has an entire standard – 29 CFR 1910.146 for general industry and 1926 Subpart AA for construction – that outlines specific training requirements for anyone who enters, monitors, or supports permit-required confined space operations, including the people stationed just outside the space.

Let’s break down what that means for entrants and attendants, two roles that are absolutely vital to safe operations.

Training for Entrants – What They Need to Know

Authorized entrants – those employees physically entering the permit space – have responsibilities laid out in 1910.146(h) and 1926.1208. Their training must cover:

The hazards they may face,
Signs, symptoms, and effects of exposure to those hazards,
The proper use of PPE, gas monitors, communication devices, and rescue equipment,
Procedures for communicating with the attendant, and
The importance of exiting the space immediately if a hazard arises or if they’re told to evacuate.

This training must be site-specific. Entrants should review the permit and get briefed on conditions by their entry supervisor before each entry.

Training for Attendants – The Front-Line Safety Watch

Designated attendants, whose duties are detailed in 1910.146(i) and 1926.1209, may never step into the confined space themselves, but they are the frontline defense if something goes wrong.

They must be trained to:

Understand the hazards inside the space and recognize signs of exposure in entrants,
Keep an accurate list of all workers inside,
Maintain constant communication with entrants,
Order immediate evacuation when necessary, and
Prevent unauthorized entry into the space.

They also need to know when and how to summon emergency medical and rescue services and, if assigned, perform non-entry rescues using retrieval systems.

Importantly, 1926.1209(c) says attendants must perform no other duties that interfere with their responsibility to monitor and protect entrants. That means full focus; no phones, no distractions, no wandering off to take a break.

Why This Training Matters

Working in a confined space isn’t like any other job. These environments can hide silent killers like toxic gases, low oxygen, or the threat of engulfment. When something goes wrong, it goes wrong fast. That’s why OSHA requires employers to provide thorough training as outlined in 1910.146(g) and 1926.1207.

Training for affected personnel must be completed:

Before the worker’s first assignment,
Whenever their duties change,
When a new or unrecognized hazard arises, or
If there’s reason to believe that previous training wasn’t effective.

And under 1926.1207(a)(4), OSHA made it clear that training must be provided at no cost to the employee. Furthermore, OSHA expects all required training to be provided in a language and vocabulary the employees understand.

Confined Space Refresher Training and Updates

According to 1910.146(g)(2) and 1926.1207(b), refresher training must be provided any time:

There’s reason to believe procedures aren’t being followed,
An incident or near miss occurs, or
There are changes to the hazards, procedures, or equipment.

Employers are also required to revise training whenever necessary to ensure continued compliance with OSHA standards.

Confined Space Training Certification Requirements

Under 1910.146(g)(4) and 1926.1207(d), employers must certify (document) that training was completed. Each certification must include:

The name of the employee trained,
The name(s) of the trainer(s), and
The date of the training.

These records must be maintained for the duration of each employee’s tenure with the company.

Confined Space Training Required for Your Temporary Workers, Too

Here’s something many employers overlook: If you bring in part-time or temporary workers to help with confined space operations, YOU are still responsible for their training.

That’s right; under OSHA’s confined space rules, especially clarified in 1926.1207(a)(3), host employers must ensure that any worker they direct, including those supplied by a staffing agency, receives the same level of training as full-time employees.

Too often, companies assume the temp agency handles it. But if you’re supervising that worker, OSHA says you’re on the hook for making sure they understand the hazards and procedures before they set foot near a permit space.

The Bottom Line

Entrants and attendants aren’t just part of the team, they’re essential to the safety of confined space operations. Training them properly isn’t just a good idea, it’s the law. OSHA’s confined space regulations exist to save lives in some of the most hazardous work environments out there.

If your workers are involved in confined space entry, make sure their training is thorough, documented, and up to date. And stay tuned for our next post. We’ll cover the training requirements for entry supervisors and rescue personnel.

Got questions or feedback?

Leave them in the comments section below. And last but not least, I encourage you to share a link to this Confined Space Training Blog post with others in your network so they can benefit from this information.

Want to dig deeper?

Click the buttons below to learn more about our comprehensive online confined space training courses – designed specifically for authorized entrants and designated attendants. Get your team trained, compliant, and confident.

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Is Confined Space Hazard Awareness Training Required for Non-Authorized Employees?

March 3, 2025 by Curtis Chambers Leave a Comment

Hazard awareness training confined space

Blog Post #22 – Most employers are well aware that OSHA’s confined space standards for general industry and construction require extensive training for employees authorized to participate in permit-required confined space entry operations. We’ll explore that training in depth in future blog posts.

But what about workers at sites where confined spaces exist, yet some (or all) of employees are not assigned to work in those spaces? Is training for them mandatory?

What Do OSHA Standards Say About Training Unauthorized Workers on Confined Space Hazards?

Unauthorized entry into permit spaces—by employees or anyone else—cannot be tolerated. However, OSHA does not specifically state in the training section of their confined space standards that “all unauthorized workers must be trained to stay out of permit-required confined spaces.”

However, OSHA addresses this issue indirectly in other sections of its confined space standards, specifically in paragraph 1910.146(d)(1) of the general industry standards and paragraph 1926.1204(a) for construction. These sections clearly state that entry employers must implement measures to prevent unauthorized entry into any permit-required confined space.

Employers typically fulfill this requirement in several ways:

Including a clear policy in their written confined space program that forbids unauthorized entry.
Enforcing the policy through a disciplinary program.
Covering this policy during training sessions for entry supervisors, entrants, and attendants.

However, it has been my experience that very few employers actually take time to address this topic with training for their non-authorized employees.

Additionally, OSHA standard 1926.21(b)(2) requires that all workers be trained to recognize and avoid unsafe conditions at construction sites. Since unauthorized entry into confined spaces presents significant hazards, training workers to stay out of them aligns with this requirement.

Why Training Unauthorized Workers About Confined Space Hazards Is Necessary

Even though OSHA confined space standards do not specifically require this training, prudent employers should take the time to educate all unauthorized workers about this topic, including:

What permit-required confined spaces are.
The hazards these spaces present.
A list of actual or example permit spaces at their worksites.
The fact that entry into any permit space is strictly prohibited for unauthorized workers.

Too often, many employers fail to provide this training, and tragedy occurs. Here are two real-world examples from cases I’ve worked on as an expert witness where training could have helped prevent the incident:

Case #1: The Fatal Auger Shroud Incident

A two-man repair crew from an industrial services company was sent to a cattle feedlot to replace a worn auger in an 18-inch diameter, 15-foot-long discharge auger shroud connected to a large grain bin. No entry into the bin or shroud was anticipated, and neither crew member was trained as an entrant or attendant, nor were they trained to stay out of confined spaces.

When grain from the bin began seeping into the shroud after the old auger was extracted, thereby blocking the new auger’s insertion, the foreman attempted to clear it manually with a scoop welded on the end of a long piece of rebar. When that failed to work, he made the fatal decision to slide headfirst into the shroud with a rope tied around his waist, instructing his helper to pull him out if needed.

Tragically, he became trapped. The helper could not pull his co-worker out by hand. So, in a panic, he tied the loose end of the rope to the hitch of their crew truck and attempted to pull him out. The effort resulted in horrific injuries suffered by the foreman, and he did not survive.

Case #2: The Manufacturing Plant Tragedy

At a large manufacturing plant, a maintenance tech was dispatched to repair a faulty drainage valve affixed to the exterior of a process tank. Company policy dictated that employees would not enter tanks; outside contractors were hired for such tasks.

When the tech failed to report back, a helper was sent to check on him. The helper eventually found the tech’s toolbox near a tank, with tools scattered around. Climbing onto the tank, the helper noticed a raised hatch cover and, upon looking inside, saw the maintenance tech lying motionless on the tank floor.

The helper radioed for assistance but then made the deadly decision to climb inside the tank to help his coworker. Both men ultimately perished due to oxygen deficiency caused by evaporated chemical vapors inside the tank displacing breathable air.

Further investigation revealed that while employees knew they were not allowed to work inside tanks, many did not perceive merely entering an empty tank as a serious risk. Some even admitted to having done so before, unaware of the life-threatening dangers.

The Takeaway: Train Your Unauthorized Workers About Confined Space Hazards, and Document It

In both of these cases, and many more like them, lives were lost because unauthorized workers did not understand that entering these spaces—even for seemingly minor reasons—could be deadly. Had their employers explicitly informed them that entry into such spaces was never permitted under any circumstances, these tragedies could have been prevented.

Employers, take the time to train your unauthorized workers about confined space hazards. And document that training so you have tangible proof during safety audits and regulatory inspections. If you need assistance, scroll down to see how we can help you implement effective training

IMPORTANT NOTICE:

Here is an easy and effective way to send the message to your un-authorized workers about the dangers of permit spaces, and why it is crucial that they never enter one for any reason. Register them for our online “Confined Space Awareness Training Course for Unauthorized Workers.”

The online course is short and sweet, to the point, and can help keep your workers safe and your business OSHA compliant.

Why Choose This Awareness Level Confined Space Training Course?

Flexible Learning: Employees can train at their own pace, logging in and out from any compatible device.

Convenient Registration: Employees can sign up individually, or you can enroll your team through a free Learner Manager account, which also enables you to track progress and manage certifications.
Proof of Compliance: Upon successful completion, employees receive a personalized training certificate, which serves as tangible proof of compliance during safety audits and regulatory inspections.

Click the button below be directed to our online confined space training page where you can read more and then sign up for this online Confined Space Hazard Awareness course. And while you are on our website, check out the comprehensive online courses we offer for entry supervisors, entrants, attendants, and the competent person.

CLICK HERE

Share Your Point of View About Confined Space Hazard Awareness Training

Does your company provide training to unauthorized workers on confined space hazards? If so, how is the message delivered, and how effective has it been? Or perhaps you have a story about an accident that occurred under similar circumstances?

Please share your thoughts in the comments section below. And if you find this information valuable, share this post with others who could benefit from it.

Requirements for Confined Space Entry Permits

October 31, 2024 by Curtis Chambers Leave a Comment

Blog Post #21 – If one or more employees will enter a permit-required confined space without using the alternate or reclassification procedures discussed in our previous blog posts, their employer must designate an entry supervisor to complete, sign, and post a confined space entry permit before entry operations begin.

Purpose of the Confined Space Entry Permit

The purpose of the entry permit is to document information about the hazards within the permit space and verify the completion of all required measures that must be implemented before allowing employees to enter. The entry permit will also list additional details, such as the emergency response procedures to follow if medical or rescue assistance is needed.

Common Misconception About Confined Space Entry Permits

So, where does one obtain a confined space entry permit? Many people mistakenly believe that an employer must apply to OSHA for a permit authorizing their workers to enter a permit-required confined space. While understandable, this belief is incorrect. Confined space entry permits are generally created by the entry employer, then completed and posted at the confined space by a designated entry supervisor.

The Confined Space Entry Permitting Process

Before allowing workers to enter a permit-required confined space, the entry employer must implement a permitting process that meets the requirements of OSHA standard 1910.146, section E (for general industry) or 1926.1205 (for construction). As part of that permitting process, OSHA requires the entry employer to prepare an entry permit per the requirements listed in standard 1910.146(f) for general industry, or 1926.1206 for construction.

Required Information on a Confined Space Entry Permit

The information required on the confined space entry permit is detailed in 1910.146, subparagraphs (f)(1) through (14) for general industry, and in 1926.1206, paragraphs (a) through (o) for construction. This includes, where applicable:

The identity of the permit space to be entered;
The specific purpose of the entry;
The date and authorized duration of the permit;
The identity of all authorized entrants in the space, listed by name or other means (e.g., rosters or tracking systems) to allow the attendant to quickly determine which authorized entrants are inside the permit space. Note: This requirement does not mandate that entrants place their signature on the entry permit;
The name of each designated attendant monitoring the entrants and entry area;
Identification of any and all hazards associated with the space. This includes any existing hazards, and those that could potentially develop in or near the permit space during entry operations;
Measures to isolate, control, or eliminate hazards in the confined space. Examples include:
- Implementing lock-out/tag-out procedures for switches or valves;
- Installing a pipe blank or blind or disconnecting a section of line;
- Purging or pumping contents from inside the space;
- Flushing residual contents from inside the confined space;
- Installing ventilation equipment; and/or,
- Inerting a flammable atmosphere.
Acceptable entry conditions, including the range for atmospheric hazards associated with the space being entered. For example, the permit must state that oxygen levels must be between 19.5% and 23.5% by volume, where applicable;
Initial test results for air monitoring, and results of any post-ventilation tests. Note that actual test results must be documented on the permit, rather than noting only “okay” or “safe.” The permit must also show the time and location of tests conducted and the name or initials of the person conducting the testing;
The method for detecting increases in atmospheric hazards during entry operations. OSHA’s standard requires conducting continuous monitoring when commercially feasible; otherwise, periodic checks are acceptable;
The identity of, and means to summon, designated emergency medical and rescue services;
Communication methods between entrants and the attendant;
Required equipment for entry operations, which may include;
- Personal protective equipment (PPE);
- Air monitoring devices;
- Ventilation equipment;
- Communication equipment;
- Alarm systems; and/or,
- Rescue equipment.
Any other information needed for safe entry, if applicable, must also be documented on the permit. Also, additional required permits, such as hot work permits, may be referenced or attached to the entry permit to prevent redundancy.

Finally, the designated entry supervisor must add their name and signature to the confined space entry permit after verifying that all necessary precautions and procedures have been implemented, and that all required information is documented.

All details listed above that are applicable to an entry are required by OSHA to be documented on the permit. And employers are free to include additional information on their entry permits if they wish. However, any items listed above that are irrelevant to a particular entry do not need to appear on the permit. For instance, if only physical hazards are present in a permit-required confined space, with no possibility of atmospheric hazards, then atmospheric testing need not be conducted or documented on the entry permit.

Confined Space Permit Posting Requirements

After completion and signing by the entry supervisor, the entry permit must be posted at or near the confined space entry point, accessible for review by authorized entrants and their representatives. Entry operations are limited to the time and tasks listed on the permit.

OSHA’s Formatting Requirements for Confined Space Entry Permits

As previously noted, the entry permit does not have to follow a particular format or order. Some permits are open form with sections to fill in, such as our confined space entry permit template (long version) provided with the course materials for our comprehensive online confined space entry training courses. Alternatively, some entry permits are customized for entering specific spaces, with pre-filled information and check-boxes for the entry supervisor to verify before signing and posting. The main thing is to make certain there is a means to clearly document all necessary information required to be on the entry permit.

Termination, Suspension, and Retention of Confined Space Entry Permits

The entry supervisor must terminate entry operations and cancel the confined space entry permit when entry operations are completed. Employers must also retain canceled permits for at least one year to facilitate an annual review by the employer of their confined space entry program.

If the job duration, scope, or hazards change during entry, or if any conditions that do not align with the permit arise in or near the permit space, the entry supervisor must temporarily suspend or terminate entry operations. Then, they must reevaluate hazards and conditions in the space, take any measures needed to ensure safe entry operations, revise the permit as necessary, and then reissue the permit before entry operations can resume.

Carefully preparing an entry permit for confined space entry is essential for worker safety. Missing steps in entry preparation or during operations can have serious consequences.

Where to Get a Free Template for a Confined Space Entry Permit

Sample confined space entry permits are available from various sources, including our free confined space entry permit template (Word) provided here. A template is also provided with the course materials provided with our online confined space training courses. Of course, any sample or template for an entry permit must be revised as necessary to reflect actual conditions and entry procedures needed at the job-site.

Please share any comments or questions in the section below, and stay tuned for our next posts, where we will discuss additional requirements for implementing a comprehensive permit-required confined space entry program.

Finally, feel free to share a link to this post with others in your network who may benefit from this information.

Thanks, Curtis Chambers – Confined Space Expert

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OSHA Alternate Entry Procedures for Permit-required Confined Spaces

August 13, 2024 by Curtis Chambers Leave a Comment

OSHA Alternate Entry Procedures for Confined Space Entry

Blog Post #20 – Some permit-required confined spaces qualify to be entered under the alternate entry procedures listed in 1910.146(c)(5) of the general industry standards for permit-required confined spaces, and in 1926.1203(e) of the confined spaces in construction standards. These procedures, which allow entry into permit spaces that contain only atmospheric hazards which the employer demonstrates can be sufficiently controlled with forced air ventilation alone, differ from those discussed in the previous blog post, which explained how and when you can temporarily reclassify a permit space to non-permit space status.

The advantages to utilizing the alternate entry procedures listed in section 1910.146(c)(5) and 1926.1203(e) are that once the permit space has been certified as safe for entry under these procedures, the following elements of a full permit entry are not required:

No written confined space entry procedure or entry permit is required for workers to enter the space, only a brief written certification;
It is not mandatory to have an attendant stand by the entry point to the confined space during entry operations;
Workers in the space do not have to receive the extensive training required for a permit space entrant;
No entry supervisor is required to oversee all entry operations during alternate entry procedures; and,
A confined space rescue team is not required to be on standby during this entry.

As you can see, the benefits of utilizing these alternate confined space entry procedures, when allowed, can make entry into eligible spaces quicker and more cost-effective, while still maintaining a safe work environment for entrants.

When do the OSHA Alternate Entry Procedures for Permit-required Confined Spaces Apply?

The OSHA 1910 general industry confined space standards for alternate entry, which were published in the early 1990’s, state that they apply to permit spaces with actual or potential atmospheric hazards only, and in which continuous forced air ventilation alone can maintain the atmosphere inside the space safe for entry. The wording of this general industry standard does not make it clear if that means the space must never present any non-atmospheric (physical) hazards at any time (pre and post entry) to qualify for entry under the alternate procedures, or if any such hazards must simply be addressed before entry is allowed.

Fortunately, the wording of the 1926 confined spaces in construction standard rule differs slightly, clarifying that alternate entry procedures can be utilized in those permit spaces where continuous, forced air ventilation can maintain the atmosphere inside the confined space safe for entry, and all other unsafe conditions (if any) which are non-atmospheric in nature are eliminated or isolated before the cover on the space is removed.

Recall that in the previous blog post, we explained OSHA’s definition of the term “isolation,” which means the process by which a permit space is removed from service and completely protected against the release of energy and material into the space.

Defining “Safe for Entry” in the OSHA Alternate Entry Standards

As stated above, these alternate entry procedures both require that continuous, forced air ventilation can maintain the atmosphere inside the confined space “safe for entry.” However, neither standard define what that term means.

Fortunately, the preamble to the 1910 general industry standard (see accompanying excerpt from page 4488 of Federal Register / Volume 58, No. 9) sheds some light on the meaning of this terminology.

Alternate Entry OSHA Federal Register Excerpt Safe for Entry

This particular section of the Federal Register states that the atmospheric hazards must remain at no more than one-half (50%) their regulated levels to be considered “safe for entry” when using the alternate entry procedures.

So, as an example, flammable gas in the atmosphere is considered hazardous by Federal OSHA when it exceeds 10% of its LEL, so “safe for entry” would be an atmosphere maintained by forced air ventilation at levels not exceeding 5% LEL. And the Federal OSHA PEL for carbon monoxide is 50 ppm, so “safe for entry” would be an atmosphere containing no more than 25 ppm CO. Note: some State Plan OSHA programs have lower PELs for certain atmospheric hazards such as CO; refer to state regulations when applicable to your workplace.

Requirements for Forced Air Ventilation Utilized During Alternate Entry Operations

When using the alternate entry procedure, forced air ventilation (e.g. a hose blower or similar ventilation equipment), must be installed and operating efficiently and continuously before and throughout entry. The blower hose must be directed to ventilate the immediate areas where an employee is present, or will be present, within the space, and must continue to operate until all employees have exited the space.

The ventilation system should provide an adequate volume of air needed to allow enough time for all entrants to escape the confined space without overexposure should the ventilation system unexpectedly stop working. Determining what would be an adequate time for escape, in turn, is a function of the concentration the contaminant, the rate of generation or introduction of the contaminant into the space, and the distance to the exit. Because of the complexities of making such an evaluation, only a technically qualified person should make this determination.

Also, the employer must ensure the source of make-up air for ventilation equipment is clean and safe. So, make sure there are no sources of contamination, such as open drums of hazardous chemicals or pieces of equipment with an internal combustion engine running near the air intake of any confined space ventilation equipment.

Additional Requirements When Utilizing OSHA Alternate Entry Procedures

There are a few additional conditions that must be met if an employer chooses to utilize the alternate entry procedures listed in both OSHA confined space standards, including making sure other unsafe conditions are eliminated or isolated before the cover on the space is removed. This could include measures such as making certain to bleed off any pressure that may have built up inside of a confined space before opening the lid or removing its cover, where applicable, as the pressure could cause the lid or cover to fly off and strike someone.

Also, once the lid or cover has been removed, the opening into the space being entered under alternate procedures must be immediately guarded so that no person or object can fall into the confined space, where applicable. Devices such as portable barricades with toe-boards are available to help meet this requirement.

Then, the internal atmosphere in the space must be tested before entry using a calibrated, direct reading instrument, for oxygen, LEL, and toxics, in that order (the reason for using this specific testing order will be explained in a later blog post about atmospheric testing). Atmospheric testing is necessary to determine that the atmosphere inside the space is “safe for entry” before entry operations, and additional testing must be conducted as needed throughout entry to ensure the atmosphere is maintained. Furthermore, the employer must develop and maintain adequate monitoring and inspection data that demonstrates the ventilation system can maintain the atmosphere at safe levels throughout entry.

In those instances where it is necessary for a worker to conduct initial atmospheric testing or isolate a physical hazard from inside the space, this initial entry must be made under a full entry permit program until the hazards are isolated and the atmosphere has been deemed safe for entry.

Moreover, any activities carried out within or outside of the space must not create new atmospheric (or non-atmospheric) hazards. This includes introducing into the space any hazardous amounts of flammable or toxic substances, or performing hot work within the space, as they could introduce risks that were not considered when determining that the atmosphere inside the confined space is safe for entry.

Finally, if any hazardous atmosphere is detected during entry during alternate entry procedures, all entrants must immediately evacuate the confined space. Then the entry employer must make certain to reevaluate the space to determine why the hazardous atmosphere developed, and then implement adequate corrective measures to protect employees before any subsequent entry takes place.

OSHA Requirements for Safe Entry and Egress of Personnel

Employers must also provide a safe method of entering and exiting the space during alternate entry operations. If a hoisting system is used, it must be designed and manufactured for personnel hoisting; this requirement was clarified by OSHA in their newer confined spaces in construction standard. However, a job-made hoisting system is permissible if it is approved for personnel hoisting by a registered professional engineer, in writing, prior to use.

Documentation Requirements When Using Alternate Entry Procedures

An employer utilizing this alternate entry procedure is not required to prepare a regular confined space entry permit. Instead, the employer must simply verify that the space is safe for entry, and that all required measures have been taken prior to entry, by preparing a written certification. This written certification must identify the location of the space, the date of entry, and the signature of the person certifying the space is safe, per the OSHA confined space standards for alternate entry.

This written certification must be made available to affected employees or their designated representatives before entry by posting it at or near the entry point of the confined space for the duration of entry operations.

What if Alternate Entry into a Permit Space is Not Feasible?

If a permit required confined space cannot, or will not, be entered under the alternate entry procedures listed in OSHA standards (or if it cannot be reclassified as a non-permit space under the procedures discussed in a previous blog post), then the space must be entered under a full permit-required confined space entry program (which will be covered beginning in the next blog post).

Remember also that the space must be returned to permit-required status when the work is completed, or if at any time during entry under alternate entry procedures a hazardous atmosphere develops inside the space.

Closing

As you can see, OSHA’s alternate entry procedures, when allowed and properly implemented, can result in safer, more efficient, and compliant management of eligible confined space entries because the relatively-lower risks associated with these type spaces can easily be controlled.

Please provide any comments or questions about the OSHA alternate entry procedures in the COMMENTS section appearing at the bottom of this page. And be sure to come back soon to see our next blog posts, which delve into the requirements for implementing a full permit-required confined space entry program.

Last but not least, I encourage you to share a link to this Confined Space Training Blog post with others in your network so they can benefit from this information. Thanks – Curtis

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