Confined Space Entry Training

OSHA Confined Space Entry Training and Certification

Confined Space Training Requirements for Entrants and Attendants

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Confined Space Training Requirements for Entrants and Attendants

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.

CONFINED SPACE TRAINING FOR ENTRANTS AND ATTENDANTS – GENERAL INDUSTRY VERSION

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Requirements for Confined Space Entry Permits

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Confined space entry permit

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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Permit Space Triggers – Other Recognized Serious Safety or Health Hazards

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Other Serious Safety Health Hazards OSHA Confined Spaces

Blog Post #16 – In this post to The Confined Space Training Blog, we examine the fourth and final criteria listed in OSHA’s definition of a permit-required confined space. And that is, any confined space that contains any other recognized serious safety or health hazard.

OSHA Definition of Other Recognized Serious Safety or Health Hazards

In the OSHA confined space standards for general industry or construction, there is no specific definition for the phrase “other recognized serious safety or health hazard.” However, in the preamble to the Confined Spaces in Construction standard, OSHA explains they are taking about “hazards that could impair the ability of an entrant to exit the space without aid.” They continue on in that preamble to state that “The key determination is the likelihood that death or serious harm will occur IF an accident or exposure occurs.”

Examples of Other Recognized Serious Safety or Health Hazards

Based on the above-mentioned statement made by OSHA in the preamble, one example of a serious safety hazard present in confined spaces at many general industry and construction worksites is mechanical hazards such as unguarded fan blades. The same can be said about agitators and mixing blades present inside of a confined space such as a mixer or agitator. Other similar hazards include moving gears, belts and pulleys, or chains and sprockets. Also covered would be equipment that could move and crush a person, such as an elevator car. And, exposed live electrical equipment and uninsulated conductors inside of a confined space could also present a serious safety hazard to entrants. 

A confined space with a high internal temperature, such as a furnace, oven, or boiler, could represent a serious safety hazard to an employee working inside. So would a confined space containing a steam line or related equipment that could burn or scald an employee who is working on it. And any confined space containing water or some other liquid deep enough for an employee to potentially drown is also a serious safety hazard.

Hazardous equipment used in many work activities conducted inside confined spaces must also be considered for the potential to serious harm a confined space entrant. For example, high-pressure abrasive blasting equipment (e.g.: sand blasting), large abrasive-wheel grinders, and saws with large blades could all cause an entrant to suffer deep cuts or lacerations accompanied by heavy bleeding.

Another example of a potentially serious safety hazard inside a confined space is the presence of highly caustic or corrosive materials that could cause injury to an entrant. Biological or radiation hazards present in high levels inside a confined space could also be dangerous in some situations. Even a reasonable potential for venomous snakes and other dangerous animals or insects must be considered in some work environments, as they could represent a serious safety hazard to an entrant.

There is one more potential safety hazard that OSHA discusses at length in the preamble to the OSHA construction standard for confined space entry, and which could also be applicable in some general industry spaces. That is a low-hanging object, such as a beam or piece of angle iron, that a worker could strike their head on and becoming disoriented, or even being rendered unconscious.

So, when you are evaluating confined spaces for “other recognized serious safety or health hazards,” remember that OSHA explains in the preamble to the standard that their concern here is “any hazards that could impair the ability of an entrant to exit the space without aid.”

Additional Examples of Recognized Serious Safety or Health Hazards in Confined Spaces?

There is no doubt many other examples of recognized serious safety or health hazards that could reasonably be expected to be present inside of confined spaces. So, please provide other examples of “other recognized serious safety or health hazards” with a reasonable potential to be present in confined spaces in the comments section below. You can also ask questions there as well.

Then, be sure to come back later and read our next blog post about steps to be taken when you identify permit-required confined spaces in the workplace; this includes steps that need to be taken even if you or your employees do not enter into permit-required confined spaces.

Last but not least, I encourage you to take a moment and spread the word about our confined space training blog by sharing a link to this post with others in your network, so they too can benefit from this information. Thanks – Curtis

Confined Space Hazards – Trapped by Inwardly Converging Walls or Floors

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Confined Space Inwardly Converging Walls or Floors

Blog Post #15 – In this post to The Confined Space Training Blog, we examine one more reason a confined space in the workplace must be classified as a permit-required confined space. And that is when a confined space has walls that converge inward or floors that slope downward and taper into a smaller area which could trap or asphyxiate an entrant. OSHA explains in their documentation this would occur primarily by compressing the torso of the trapped entrant, making it difficult to escape or to breath.

Examples of Confined Spaces with Potential Entrapment Hazards

Some examples of confined spaces where entrapment such as this could occur include, but are not limited to cyclones, hoppers, and similarly constructed discharge chutes on some storage silos. Large industrial baghouses are another type of confined space that, depending on how they are constructed, could also fit into this category. And in a few cases, relatively large ductwork configured to transition down to a smaller size could create an entrapment issue for an entrant. One final example of where this hazard could be present is in underground stormwater collection and retention systems constructed with floors that slope down toward a small-sized drain opening.

Ironically, many of the hazardous situations for entrapment are not exposed until precautions are taken to eliminate another serious hazard inside of a confined space; engulfment. For example, when emptying the contents of a cone-shaped hopper to eliminate an engulfment hazard, we may expose the entrant to an entrapment hazard in the now-empty space. So, always remain aware that sometimes, we create or expose hazards when we eliminate others.

In review, a confined space having walls that converge inward or floors that slope downward and taper into a smaller area which could trap or asphyxiate an entrant must be classified as a permit-required confined space. Entry into such a space requires confined space training for all affected workers and a permit entry system be in place.

Please provide your feedback and/or questions about this blog post on entrapment hazards in confined spaces in the comments section below. And if possible, please provide some other examples where this particular type of hazard could be present in the workplace. Then, be sure to come back later and read our next blog post (#16), where we will discuss the final category of hazards that can trigger the designation of a permit-required confined space.

And as always, I ask that you take a moment to spread the word about our confined space training blog by sharing a link to this post with others in your network so they can benefit from this information. Thanks – Curtis

Confined Space Engulfment Hazards

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Confined space engulfment hazards

Blog Post #14 – In this post to The Confined Space Training Blog, we will examine another reason a confined space identified at your workplace should be classified as a permit-required confined space. And that is when a confined space contains a liquid or material that could potentially engulf the entrant.

What is Engulfment in a Confined Space?

The Federal OSHA definition of engulfment can be found in 1910.146 paragraph B, and includes confined spaces where the entrant could suddenly be surrounded or captured by liquid, trapped inside the space, and drown in the liquid.

Engulfment in liquid sewer confined space

Engulfment by liquid could occur in sanitary and storm sewers, as well as in any pipelines, utility vaults, or process tanks that could suddenly be filled with liquid.

One other form of engulfment is possible whenever a confined space contains a finely divided solid material, such as pellets, chips, grains, granules, dusts, or powders, that can be aspirated by the entrant once engulfed. his could cause death by filling or plugging the respiratory system. In other cases, the material surrounding the trapped entrant can exert enough force on the body to cause death by strangulation, constriction, or crushing. Regardless of the mode of engulfment, these are all a gruesome way to die!

Confined spaces that contain potential engulfment hazards include, but are not limited to, grain elevators and storage bins, as well as other confined spaces that contain materials such as flour, sawdust, powdered cement, or finely pelletized materials.

How Does Engulfment in a Solid Material Occur Inside a Confined Space?

The illustration below demonstrates how a finely divided material can appear from the top to fill a confined space when, in actuality, a hollow void area could develop beneath the surface. This condition is often referred to as “bridging.”

Engulfment - Material bridging inside a confined space

The weight of the employee can cause the bridged material to collapse, and the worker can fall into the void area and be covered by the flowing material.

In this second illustration, the employee is engulfed when the material, which has clung to the side of the wall inside the confined space, collapses and covers the employee.

OSHA definition of engulfment in a confined space

Recap of Engulfment in a Confined Space

So in review, any confined space containing, or with the reasonable potential to be quickly filled with, a liquid or finely divided material that can engulf the entrant must be treated as a permit-required confined space.

Please provide your feedback and/or questions about this blog post on engulfment hazards in confined spaces in the comments section below. Then be sure to come back later and read our next blog post (#15), where we will discuss additional hazards that can trigger the permit-requirements in confined spaces.

And as always, I ask that you take a moment to spread the word about our confined space training blog by sharing a link to this post with others in your network so they can benefit from this information. Thanks – Curtis