POST #2 – Special care and attention must be given when determining which OSHA requirements for confined space entry apply to your specific work situation. Federal OSHA health and safety regulations pertaining to confined space entry operations can be found in the 29th Code of Federal Regulations, or CFR. More specifically, the Federal OSHA confined space entry standards are located in three different parts of the CFR. Those are:

The Part 1910.146 confined space standards, which apply to general industry operations;
The Part 1915 confined space standards, which apply to the maritime industries; and,
The Part 1926 subpart AA confined space standards, which apply to the construction industry.

OSHA Confined Space Standards for General Industry

The worksites regulated under the Federal OSHA permit-required confined space entry standards for general industry found in 1910.146 include, but are not limited to, most fabrication and manufacturing operations, chemical and processing plants, transportation and warehousing operations, and most service industries. Be aware, however, that there are many other sections of the 1910 General Industry standards for confined space entry that could also apply to work conducted inside confined spaces at general industry worksites, and which must not be overlooked. These include, but are not limited to, 1910 Subpart I, which contain the standards for Personal Protective Equipment, also known as PPE. That subpart also contains the standards for implementing a Respiratory Protection Program to protect workers from hazardous atmospheres, where applicable.

1910 Subpart J contains the rules for “the Control of Hazardous Energy”. These standards, which are also known as the OSHA lockout-tagout standards, often come into play when isolating a confined space from certain hazards before entry. And 1910 subpart Z lists the various permissible exposure limits, or PEL’s, for general air contaminants. That subpart also includes the OSHA 1910.1200 Hazard Communication standard, which addresses Safety Data Sheets and other forms of communication about hazardous chemicals and products present in the workplace, including inside many confined spaces. Another 1910 general industry rule that could have application during work involving confined space entry include 1910.268 – Telecommunications, which addresses entry into underground tele-com vaults and manholes. In addition, section 1910.252(c)(4) of the OSHA welding standards apply to ventilation when welding inside of confined spaces.

OSHA Confined Space Standards for Construction

Federal OSHA also has health and safety standards that regulate the construction industries, and those are found in Part 1926 of the CFR. Originally, the construction rules did not contain a comprehensive confined space entry standard. But in 2015, which is more than 20 years after they published their confined space entry standard for general industry, OSHA finally published a new confined spaces in construction standard. It is located in Subpart AA of the OSHA construction standards. That standard applies not only to confined spaces found at new construction projects, but also to confined spaces at major renovation worksites, as well as those encountered at demolition work sites. The bulk of the newer 1926 construction standards for confined space entry are very similar to the previously-discussed 1910 confined space entry standards for general industry, but with a few major requirements when it comes to responsibilities of general contractors and the Competent Person at construction sites.

There are also a few 1926 construction standards outside of Subpart AA that apply to work conducted inside of confined spaces at construction sites. Those include, but are not limited to, 1926.59 – Hazard communication, 1926 Subpart E – Personal protective and lifesaving equipment, 1926.57 – Ventilation, 1926.55 – Gases, vapors, fumes, dusts, and mists, and 1926.353 – Ventilation and protection in welding, cutting, and heating.

OSHA Confined Space Entry Standards for Maritime

Last but not least, the OSHA CFR also has confined space standards which regulate the maritime industry. Part 1915, Subpart B, contains standards for confined space entry during ship building, ship-breaking operations, and all other areas of shipyard employment. There are also several other related standards sprinkled throughout the 1915 standards. Most of the shipyard standards are significantly different than the confined space standards for general industry and construction. For example, most work conducted inside confined and enclosed spaces in maritime operations is overseen by a Marine Chemist who is registered with OSHA, or by a Certified Industrial Hygienist. Furthermore, OSHA distinguishes between “confined spaces” and “enclosed spaces” in shipyards.

Exceptions to OSHA’s Confined Space Entry Standards

One other thing to know about this subject is, you should always read the section of OSHA confined space entry regulations titled “Scope”, as that will usually provide specific guidance on where a particular OSHA standard or subpart does, or does not, apply. For example, section 1926.1201(b) of the OSHA confined spaces in construction standard, which is titled “Exceptions”, states that the standard does NOT apply to the following: (1) Construction work regulated by subpart P, Excavations; (2) Construction work regulated by subpart S, Underground Construction, Caissons, Cofferdams and Compressed Air; and, (3) Construction work regulated by subpart Y, Diving.

Further Guidance on Confined Space Entry Standards and Requirements

Further guidance on the application of OSHA’s confined space entry standards can be obtained via our comprehensive online confined space entry training courses for construction and for general industry, or in an on-site class conducted by one of our confined space trainers.

Final Note: Please help spread the word about our confined space entry training blog. Send a link to this blog post to others in your network who could benefit from this information. Thanks, Curtis

Welcome to the Confined Space Entry Training Blog

Blog for OSHA permit-required confined space entry training

POST #1 – Welcome to the very first post on our brand-new Confined Space Entry Training Blog. As the name implies, this blog is dedicated to helping readers achieve a better understanding of the requirements of the Federal OSHA permit-required confined space entry standards. And not just a cursory understanding, but an in-depth understanding on a broad range of confined space-related topics. Areas covered in our blog will include, but not be limited to, OSHA’s requirements for employers’ confined space entry programs, confined space entry permits, identifying and controlling hazards present within confined spaces, and the selection and use of confined space entry equipment. We will also go in-depth into the OSHA confined space training requirements for all workers involved in permit-required confined space entry operations, including the entrants who actually go into the spaces, the attendants stationed outside the space, the entry supervisor in charge of entry operations, rescue and emergency medical personnel, and gas detection equipment operators.

Why did I decide to start this new blog related to confined space entry training? Because there continue to be fatalities and serious injuries suffered by workers involved in all phases of confined space entry work. According to the Bureau of Labor Statistic’s National Census of Fatal Occupational Injuries published in 2020 (the latest data available at the time of this post), 1,030 workers involved in confined space entry work died in the U.S. between 2011 to 2018. While this overall number represents a relatively small percentage of all workplace fatalities, not many people work in confined spaces, so the rate of fatalities among confined space workers is high. Surprisingly, 60% of confined space-related fatalities were would-be rescuers who rush unprepared into a confined space to assist a coworker, and they died.

The Risks of Confined Space Work

So, why is confined space work often so dangerous? Because being inside of a confining area can easily compound the severity of hazards in the space. You’re often working in close proximity to hazards, so they’re difficult to avoid. And, it’s harder to escape from inside the space should you become incapacitated. Also, because you’re often out of sight of coworkers, you’re often out of mind as well, and no one checks on you until it’s too late. A good confined space entry program addresses hazards in a systematic manner that strives to eliminate confined space hazards when possible, or minimize them to a safer level, through a series of steps that are documented on an entry permit.

By the way, my name is Curtis Chambers, and I am the author of this confined space training blog. I’m qualified to blog on this topic dues to my 35+ years of working as an occupational safety and health manager, corporate director, safety officer in a State OSHA Consultation program, and prolific trainer on numerous health and safety topics, including permit-required confined space entry. I’ve even developed comprehensive online confined space entry training courses for entrants, attendants, entry supervisors, and the competent person in construction and general industry operations. I’m also a board certified safety professional (CSP) since 1993, have a Master of Science degree in Occupational Health and Safety from Southeastern Oklahoma State University, and am an OSHA-authorized Outreach trainer in both construction and general industry. I’ve also testified over 100 times as a recognized OSHA expert in legal matters related to, among other things, permit-required confined space related accidents, injuries, and fatalities.

Of course, I am not so naive as to think I have seen it all or know it all when it comes to this topic. That is why our blog is set up to receive comments from readers, including some who will no doubt share a wealth of knowledge and experience in confined space entry work from which others can benefit. So, please feel free to participate in a dialogue with me and with each other if you have any questions, or if you have something of value (be aware that comments are held until moderated, to prevent anything spammy) to share on a post.

Last but not least, know that the purpose of this blog is not to provide legal advice, or replace the expertise of an on-site safety professional. Consult your safety manager, safety consultant, or other technically qualified person for guidance to ensure proper entry and emergency response/rescue procedures are in place, and that all necessary equipment is selected and in proper working order before conducting entry operations. Because ultimately, only the employer can decide, based upon his or her knowledge of, and experience with their permit spaces, what the best entry procedures, types of atmospheric testing instrument, ventilation system, and rescue procedure must be used for a specific entry operation.

Here’s to a productive and informative blog! – Curtis