OSHA Requirement for a Competent Person to Identify Permit Required Confined Spaces

October 21, 2022 by Curtis Chambers Leave a Comment

Post #5 – The success of an organization’s confined space entry program is ultimately predicated on having a competent person with the ability to identify and evaluate the confined spaces at their work sites to determine whether or not they meet the OSHA definition of a permit-required confined space. And that takes a person with sufficient training and experience to do the job right. But exactly whose job is it to identify and evaluate confined spaces?

Here’s what the OSHA confined space regulations say about that.

OSHA Requirements to Evaluate Confined Spaces

The first paragraphs from the general requirements sections of the OSHA confined space entry standards for general industry and construction, respectively, are listed below:

GENERAL INDUSTRY

1910.146(c)(1) – The employer shall evaluate the workplace to determine if any spaces are permit-required confined spaces.

CONSTRUCTION

1926.1203(a) – Before it begins work at a worksite, each employer must ensure that a competent person identifies all confined spaces in which one or more of the employees it directs may work, and identifies each space that is a permit space, through consideration and evaluation of the elements of that space, including testing as necessary.

As you see, both of these performance-based confined space standards place the onus on employers, either individually or through a designated Competent Person, to evaluate their workplaces to determine if any confined spaces are present. Then, they must determine if any of those confined spaces are to be categorized as a permit required confined space, or alternatively, as a non-permit-required confined space.

Special Qualifications or Certifications Needed to Evaluate Confined Spaces?

While OSHA requires employers to ensure the confined spaces at their worksites are identified and evaluated, their standards do NOT require the completion of any specific training class or “competent person certification” for confined spaces for the person conducting the evaluations. Instead, an OSHA compliance officer would simply speak with whomever the employer has appointed as their competent person to perform the confined space evaluations, and determine if they seem to have adequate experience, training certification, and knowledge needed to do the job competently.

Duties of the Competent Person Evaluating Confined Spaces

The competent person who is designated to evaluate the confined spaces at a worksite to determine whether or not they are permit spaces must be capable of effectively performing the following three tasks for the worksite in question:

Identify all confined spaces at the worksite after consideration of all facets of the OSHA definition of a confined space;
Determine if each confined space identified at the site will be categorized as a permit-required confined space, or as a non-permit confined space;
When conditions demand, re-evaluate (and possible reclassify) a non-permit confined space, should the configuration of that space change in a manner that could cause it to become a permit-required confined space (especially true during progression of the construction process when building a confined space such as a tank). Re-evaluation of a non-permit required confined space must also be performed every time there is a work process or activity taking place inside of, or near, any non-permit confined space which could potentially introduce new hazards that require the non-permit space be reclassified as a permit-required confined space.

In many cases, an employer also will have the person designated as their competent person for confined space identification to serve as the entry supervisor for their confined space entry crew. However, doing so is not a strict requirement of the confined space standards, as those two roles could be filled by different personnel.

OSHA Documentation Requirements for Confined Space Evaluations

In case you were wondering, there is no requirement in the federal OSHA confined space entry standards requiring the employer to document their confined space evaluations; however, some employers may choose to do so anyway.

Identifying Permit-Required Confined Spaces at Multi-employer Worksites

OSHA gives employers working at a multi-employer job-site such as but not limited to construction sites the option to collaborate on identifying permit spaces at a worksite, by agreeing to use one designated competent person to perform the initial surveys. Or they can choose to use their own designated competent person to perform the surveys. But either way, each employer who has an employee who will enter into a confined space is ultimately responsible for compliance with the requirements of the OSHA confined space entry standards, and must therefore utilize due diligent before deciding to count on another employer’s competent person to perform the evaluations.

Designation of a Person Competent to Identify Permit-required Confined Spaces

Obviously, the wide variety in types of confined spaces and the assortment of potential hazards inside of those spaces will vary greatly from site to site. So, a competent person with training and experience in dealing with only one specific type of confined space may be capable of evaluating the spaces in a worksite if it only contains the same types of spaces with which they are already familiar. But that same person may or may not be suitable for evaluating the confined spaces of a type they have not experienced before. Only the employer can decide, based upon his or her knowledge of, and experience with permit required confined spaces, who is adequately prepared and able to be designated as being their competent person responsible for identifying permit-required confined spaces at the workplace.

Coming up in the next blog post (#6); we will start a deep dive into understanding the OSHA definition of a confined space.

Final Note: Thanks for reading the blog. Please help spread the word about our confined space entry training blog by sending a link to the blog to others in your network who could benefit from this information. Thanks – Curtis

Understanding the Scope and Application of OSHA’s Various Permit Required Confined Space Entry Standards

October 11, 2022 by Curtis Chambers Leave a Comment

Which OSHA Confined Space Entry Standards Apply

Post #4 – As mentioned in an earlier blog post (#2), OSHA has three different sets of confined space entry standards; one applies to construction work, and another applies to general industry work. OSHA also have a standard that applies to confined space work conducted in the Maritime industry, but that standard will not be discussed in this blog post.

It is imperative that you understand which of the OSHA standards apply to your particular confined space entry operations, and conversely, which one does not, as the requirements of each standard differ. And the way to make sure you understand is to refer to the sections that list the scope and the application for each of the OSHA confined space entry permit requirements.

Scope of the OSHA Confined Space Entry Standards Applicable to General Industry

1910.146(a) lays out the scope of the OSHA permit-required confined space entry standards for general industry workplaces. It states:

“This section contains requirements for practices and procedures to protect employees in general industry from the hazards of entry into permit-required confined spaces. This section does not apply to agriculture, to construction, or to shipyard employment (parts 1928, 1926, and 1915 of this chapter, respectively).”

To reiterate information provided in post #2, general industry work typically consists of activities performed during the manufacturing of goods or products, including those at chemical plants and refining operations. General industry work also includes most general maintenance activities. Service industries such as telephone and cable companies, restaurants, coffee shops and bakeries are also covered by the OSHA 1910.146 general industry standards for confined space entry, as are warehousing and logistics operations and the healthcare industry. 1910.146 would even apply to work involving entry operations at establishments such as bowling allies and amusement parks.

Scope of the OSHA Confined Space Entry Standards Applicable to Construction

For the construction industry, 29 CFR 1926, paragraph 1201(a) explains the scope of the confined spaces in construction standards. This paragraph states the following:

“This standard sets forth requirements for practices and procedures to protect employees engaged in construction activities at a worksite with one or more confined spaces.”

According to 1910.12(b), work regulated under 1926 subpart AA construction standards applies only to confined space entry operations related to construction, alterations, and/or repairs, which include painting and decorating. This would include, but is certainly not limited to, confined space entry work involved in the construction of a brand-new structure, major renovation or repair of all or part of an existing structure, repainting portions or all of a structure, and demolition work.

Which Confined Space Standard Takes Precedence?

Here is the tricky part; while the 1926 subpart AA confined spaces in construction standard does not apply to general industry work, that standard does apply to construction work conducted inside of a confined space that happens to be located at a general industry worksite.

Consider the following hypothetical of how entry into a tank, which as we will see in an upcoming blog post is usually considered a confined space, could feasibly be regulated by both the OSHA confined space entry standards for construction and also the confined space standards for general industry, switching back-and-forth over the course of time. Notice how the determination depends on the work activities that are taking place, and not the location.

A large tank is fabricated in the shop at a manufacturing company, including having a protective lining sprayed onto the interior tank surfaces by a worker: this work is regulated under 146 General Industry requirements for confined space entry.
The tank is erected at a chemical plant expansion project, where workers enter the tank to install fill lines and drain pipes: this work is regulated under 1926 Subpart AA Construction requirements for confined space entry.
After the chemical plant is up and running in normal production, entry is made into the tank once a year to conduct an inspection of the protective lining on the interior surfaces of the tank to determine its general condition: this preventive maintenance work is regulated under 146 General Industry requirements for confined space entry.
After an annual inspection discovers damage to the lining caused when the tank was previously struck by a forklift, a lining crew enters the tank to blast out the old lining and reapply a new tank lining: this repair work is regulated under 1926 Subpart AA Construction requirements for confined space entry.
Subsequent annual entries are made to conduct inspections of the interior lining to determine its general condition: this preventive maintenance work is regulated under 146 General Industry requirements for confined space entry.
After 30 years of use, the tank has been deemed obsolete, and is scheduled to be demolished. A crew enters the tank to cut loose interior braces and baffles as part of the tank demolition process; this demolition work is regulated under 1926 Subpart AA Construction requirements for confined space entry.

As the previous set of scenarios demonstrate, the over-riding factor to determine which set of OSHA confined space entry permit requirements apply to a given situation is usually the type of work (general industry or construction) being performed inside the confined space, as opposed to the location where the confined space work happens to be taking place.

Application – Workplaces Where OSHA Confined Space Standards Do Not Apply

I will wrap up this blog post by touching certain employers to whom the OSHA confined space entry permit requirements do not apply. The OSH Act of 1970, which establishes coverage of federal OSHA standards, was originally written to apply only to private sector employers in the U.S. and its territories. That means public employers like state and local government agencies (e.g.: municipalities and counties) are not regulated by the OSHA standards, including those for confined space entry operations, unless they happen to be located in one of the states or territories operating under a State Plan OSHA program, as explained in a blog post #2.

Also exempt from coverage by the OSH Act, and therefore exempt from the federal OSHA confined space entry standards, are workplaces for which other federal agencies have laws that regulate employee safety in certain operations. For example, entry into underground mines, which logically seem to be confined spaces, are actually covered by the Mine Safety and Health Administration (MSHA) regulations, and are therefore exempt from OSHA standards for confined space entry. And construction work conducted at worksites overseen by the U.S. Army Corp of Engineers must follow the EM-385-1-1 requirements for confined space entry.

Do Federal Confined Space Entry Requirements Apply to the Feds?

One last interesting factoid; the OSH Act originally did not apply to Federal agencies, meaning federal employers were not required by Congress to follow OSHA’s confined space entry standards; in fact, not even OSHA was required to follow their own confined space entry regulations! However, because of an executive order issued in 1980, federal agencies do now have limited coverage by OSHA standards, and must therefore comply with applicable OSHA confined space entry requirements (and all other applicable OSHA standards) during their entry operations.

Additional Information and Training on Confined Spaces

Hopefully this blog post helps clarify which OSHA confined space entry requirements apply to work being conducted at your site. Or, it may make you realize OSHA lacks jurisdiction over confined space entry operations at your worksite, and that you must figure out what alternate set of regulations may apply. You can learn more about this and other topics by taking one of the online confined space training courses available on our website.

In the next blog post (#5), we will address exactly who is responsible for making sure all permit-required confined spaces at the worksite are properly identified.

Final Note: Thanks for reading the blog. Please help spread the word about our confined space entry training blog by sending a link to the blog ( https://confinedspacetraining.net/confined-space-training-blog/ ) to others in your network who could benefit from this information.

Thanks, – Curtis

Key References Needed to Understand the OSHA Confined Space Entry Standards

September 23, 2022 by Curtis Chambers Leave a Comment

OSHA confined space standards preamble in federal register and letters of interpretation plus CSE FAQs

Post #3 – In the previous post to the confined space training blog, I identified various OSHA standards governing confined space entry work for construction and general industry work (as well as the maritime industry). However, many of the terms used in these confined space standards are not well defined, if defined at all, whereas other parts of these standards are vague and seem to be open to interpretation. These issues often lead to uncertainty about whether or not you are in compliance with the requirements of the OSHA confined space entry standard.

Fortunately, OSHA provides many key documents that expand on their various confined space entry requirements, offering much needed information that helps clarify their standards. (Note: from this point forward in my blog posts, I will focus primarily on the OSHA confined space entry standard for general industry and construction, and not on the OSHA maritime regulations for confined spaces). The following is a recap of some of the more helpful OSHA documents.

Appendices to the OSHA 1910 Permit-required Confined Space Entry Standards

The permit-required confined space entry standard for general industry has several appendices that provide useful information when developing or evaluating your confined space entry program. Below is a listing of those appendices:

1910.146 App A – Permit-required Confined Space Decision Flow Chart

1910.146 App B – Procedures for Atmospheric Testing

1910.146 App C – Examples of Permit-required Confined Space Programs

1910.146 App D – Confined Space Pre-Entry Check List

1910.146 App E – Sewer System Entry

1910.146 App F – Non-Mandatory Appendix F — Rescue Team or Rescue Service Evaluation Criteria

Currently, the Confined Spaces in Construction standards have no appendices. However, those provided with the general industry standard will also prove to be informative for people in the construction industry when setting up their permit-required confined space entry programs.

Federal Register Preambles to The OSHA Confined Space Entry Standard

When OSHA sets out to create a new or revised standard, they must first publish it in the form of a proposed rule in the Federal Register. This is done so interested parties can review the proposed standard and provide written or verbal feedback during a mandatory public comment period. Then, OSHA will review these comments for consideration when they formulate a final rule. When OSHA publishes the final rule, again in the Federal Register, that document includes not only the text of the new standard, but also a very valuable section of the preamble titled “Summary and Explanation of the Standard” (usually in section III). The preambles to the final confined space entry rules for construction and general industry are available for access at https://www.osha.gov/laws-regs/preambles.

The “Summary and Explanation of the Standard” section of the preambles lists the verbiage of each paragraph of the proposed rule as it was originally written, comments, if any, submitted about each proposed paragraph gathered during the public comments period for the new or revised rule, and OSHA’s responses, if any, to those comments. The preamble also includes OSHA’s final reasoning and determination regarding any revisions to the final language of each paragraph of the final rule. It is in OSHA’s responses to those public comments that you can glean very valuable information about how OSHA interprets and/or plans to enforce each paragraph of a new or revised standard.

The preamble to the OSHA 1910 general industry permit-required confined space entry standard was published in Federal Register volume 58, number 9 on January 14, 1993, beginning on page 4462. The preamble to the 1926 Subpart AA confined spaces in construction rule was published in Federal Register volume 80, No. 85 on Monday, May 4, 2015. I will point out helpful information appearing in specific portions of these documents in many future blog posts.

OSHA Compliance Directive (CPL) for 1910.146 Permit-required Confined Space Entry Standard

OSHA occasionally issues a compliance directive (CPL) or standard directive (STD) on some of their more complex standards or policies. These directives are primarily intended to be used as instruments for OSHA compliance officers and directors to refer to during inspections, helping ensure uniform understanding and enforcement of the associated standard or policy.

On May 5^th, 1995, OSHA issued Instruction CPL 2.100, which is a compliance directive on the subject of the “Application of the Permit-Required Confined Spaces (PRCS) Standard, 29 CFR 1910.146”. OSHA updated that particular CPL on September 1 of 2015. There is a wealth of information in the directive that employers and other interested persons can use to better understand how OSHA interprets and enforces the 1910.146 standard. And much of that same information can also be applied to the 1926 Subpart AA construction standard.

Letters of Interpretation – OSHA Confined Space Entry Standards for General Industry and Construction

OSHA receives thousands of inquiries about their various standards every year, with several of those posing questions about the OSHA confined space entry standards for construction or for general industry. In many cases, OSHA formally responds to those inquiries via a “letter of interpretation”, often referred to as a LOI. Because these letters of interpretation are considered public records, OSHA makes them available to the general public (like you and me) for review on their website.

The OSHA letters of interpretation for the 1910.146 general industry standards for permit-required confined space entry and for the 1926 Subpart AA confined spaces in construction standard are all accessed through OSHA’s LOI search page. Be aware that OSHA letters of interpretation for their confined space standards are only intended to apply to the specific circumstances discussed in that letter, and that they should not be applied to other circumstances, no matter how similar. Also, OSHA letters of interpretation are occasionally withdrawn because OSHA changed their mind; these letters will be marked as withdrawn, but are still available for reference as archived material.

Frequently Asked Questions and Answers (FAQs) for OSHA Confined Space Entry in Construction Standards

Anticipating questions about their (then) newly-promulgated 1926 Subpart AA confined spaces in construction standard, OSHA published on their website a “Frequently Asked Questions” (FAQ) page about that standard. At the time of this post, there were more than 70 questions and associated answers available on the OSHA confined spaces in construction FAQ page. Readers can get a much better understanding of the OSHA confined space entry requirements not only for the construction industry from these FAQs, but also for many of the similar confined space requirements for general industry workplaces.

OSHA Confined Space Advisor

OSHA developed a resource titled “Confined Space Advisor” on their website. This online tool is essentially a decision flow chart that asks the user questions, and based on their answers, guides them through the various steps of identifying permit-required confined spaces, and subsequently, developing and implementing a permit-required confined space entry program.

The OSHA confined space advisor e-tool is pretty basic in its coverage, and in my opinion, does not adequately answer questions about all confined space entry standards and terms that are vague. However, it does, on occasion, clearly indicates how OSHA defines or interprets a few of them; in fact, there are a couple of instances where I incorporate information taken from the online advisor in the online confined space training courses available on our website.

State OSHA Standards and Requirements for Confined Space Entry

Last but not least; it would be remiss of me not to mention that several states and US territories have opted to form their own State Plan OSHA program, covering most private and public employers in some of these states, and just the public employers in other states. All of these State Plan OSHA programs are required to either adopt the equivalent of the Federal OSHA regulations, or develop and publish their own state regulations that meet or exceed the protections offered in the associated Federal OSHA standards.

In most cases, the Federal OSHA standards for confined space entry in construction and for general industry were adopted verbatim by the various State Plan programs (reference all State Plan program rules at https://www.osha.gov/stateplans/statestandards). However, a few of the state programs created similar standards with a few slight tweaks to reflect other state-specific standards referenced within their rules. For example, the confined space entry standards promulgated by the state of California State Plan program (often referred to as Cal-OSHA) are nearly the same as those published by Federal OSHA, although CA did utilize a different numbering system when they codified their standards. But in the definitions for a “hazardous atmosphere”, which is one of the triggers for classifying a confined space as “permit required”, the CA state rule is slightly different (see both definitions below):

DEFINITION (for both Federal and Cal-OSHA confined space entry standards) –

“Hazardous atmosphere means an atmosphere that may expose employees to the risk of death, incapacitation, impairment of ability to self-rescue (that is, escape unaided from a permit space), injury, or acute illness from one or more of the following causes:

FEDERAL OSHA –

(4) Atmospheric concentration of any substance for which a dose or a permissible exposure limit is published in subpart D of this part (Occupational Health and Environmental Control), or in subpart Z of this part (Toxic and Hazardous Substances), and which could result in employee exposure in excess of its dose or permissible exposure limit;

Cal-OSHA –

(4) Atmospheric concentration of any substance for which a dose or a permissible exposure limit is published in Article 4 of the Construction Safety Orders and Group 16 of the General Industry Safety Orders;”

This slight difference in language can make a huge difference in how these two varying standards are applied. For example, the permissible exposure limit (PEL) for carbon monoxide (CO) incorporated by reference in the 1910 Federal OSHA standard is 50 parts per million (PPM). However, the PEL for CO incorporated by reference in the Cal-OSHA state standard is only 25 PPM. This represents a big variance between the Federal and Cal-OSHA thresholds for when a confined space containing CO is considered to contain a hazardous atmosphere, and therefore classified as a permit-required confined space.

OSHA Confined Space Training Resources

In closing, remember that it is important to be thoroughly familiar with the language contained in the actual OSHA confined space entry standards that apply to your operations. However, there are also many other important OSHA documents available that provide a wealth of information and guidance on how these confined space standards should be interpreted, implemented, and ultimately enforced in the workplace. Links to the resources outlined above, as well as many other valuable resources for confined space entry programs, are available via the course materials tabs associated with the online confined space entry training certification courses for entry supervisors and the competent person offered on our website.

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

OSHA Requirements for Confined Space Entry

September 1, 2022 by Curtis Chambers Leave a Comment

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 that provides 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

Confined Space Entry Training Blog

August 12, 2022 by Curtis Chambers 4 Comments

Welcome to our Free 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 free confined space training 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 free confined space training 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.

Confined Space Expert

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 due 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 free confined space training 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