Confined Space Entry Training

OSHA Confined Space Entry Training and Certification

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

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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.

When it is Necessary to Reclassify Non-permit Confined Spaces as Permit-required Confined Spaces

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Reclassification of Non-permit required confined space to a permit-required confined space

Blog Post #18 – In the previous blog posts, we discussed how there are two categories of confined spaces; non-permit required confined spaces, and permit-required confined spaces. But one of the hardest things for many people to get their head around is that the classification of a confined space can change due to various factors. So, the focus of this blog post is why and when non-permit spaces must be reclassified as permit-required spaces.

When Must You Reassess a Non-permit Required Confined Space?

By definition, a non-permit required confined space is a space that meets all three of the elements of a confined space, but does not meet any of the requirements of a permit-required confined space. If a confined space is classified by an employer as a non-permit required confined space, that space does not have to be identified with a warning sign, no permit is required to be filled out prior to entering the space, and no precautions listed in the permit-required confined space standard need be taken for their employees to enter, with this one exception; each entry employer must have a person (more specifically, a competent person per the construction standards) re-evaluate a non-permit required confined space if there are any changes to the use or configuration of that space that might increase the hazards to entrants, or if there is some indication that the initial evaluation of the space may not have been adequate.

Reclassifying a Non-permit Confined Spaces as a Permit Required Space

If an actual or potential serious health or safety hazard is subsequently identified in a non-permit space, the space must be reclassified as a permit-required confined space for as long as the hazard(s) remain. The requirements to conduct this reassessment are found in 1926.1203(f) for construction, and 1910.146(c)(6) for general industry.

Below is one example of when a non-permit required confined space would have to be reclassified as a permit-required confined space.

A new stainless steel process tank is installed in a manufacturing facility. This tank has never contained any material, has no mechanical hazards such as an agitator, no fill lines attached, and no other safety hazards present; therefore, this tank was classified by the employer as non-permit required confined space. However, before turning the equipment over to the customer, an employee must enter the tank to conduct a final inspection. Before leaving the tank, the entrant must then decontaminate the interior of the tank by wiping the entire interior surface with isopropyl alcohol. This creates a potentially hazardous atmosphere due to the flammable and toxic properties of the isopropyl alcohol. Therefore, this tank must be reclassified as a permit-required confined space and entry made under a permit, at least while this hazard-producing task is being performed.

As you can imagine, there are many other possible scenarios where non-permit required confined spaces would need to be reclassified as permit-required confined spaces due to similar circumstances. If you wish, feel free to provide an example in the comments section below. You can also use the comments section to ask questions about this topic.

Be sure to come back later and read our next blog post about the converse of this topic, when we discuss OSHA’s procedures for temporary reclassification of a permit-required confined space to non-permit required status. 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

OSHA Requirements for Signage and Notifications for Permit-required Confined Spaces

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Confined space signs and notification requirements

Blog Post #17 –The OSHA 1910 and 1926 confined space entry standard requirements address one of the employers’ first responsibilities at worksites where permit-required confined spaces are identified in the workplace; Informing affected workers and others of the existence and dangers of the permit spaces. Be aware that there are multiple ways this can, or must, be accomplished.

OSHA Requirements for Signs at Permit-required Confined Spaces

Paragraph 1910.146(c)(2) of the general industry standard for permit-required confined spaces and paragraph 1926.1203(b) of the confined spaces in construction standard states if the workplace contains one or more permit-required confined spaces, the employer who identifies, or who receives notice of, a permit space must inform exposed employees by posting danger signs, or by any other equally effective means, of the existence and location of, and the danger posed by, the permit spaces. This requirement must be met even if the employer will not have any of its workers enter any of the permit spaces. Both standards go on to note that a sign reading “DANGER – PERMIT-REQUIRED CONFINED SPACE, DO NOT ENTER” or other similar language would satisfy the requirement for a sign.

Alternatives to Posting Signs at Permit-required Confined Spaces

Due to their location or configuration, it may not be practical or possible to place a sign on some permit-required confined spaces. Therefore, the OSHA standards allow the employer to use “any other equally effective means” as an alternative to a sign. The goal of the OSHA standards is to ensure workers know of the existence, location, and danger of the permit-required confined spaces in the work place. And the preamble to the 1910 general industry permit-required confined space standard provides some guidance in this area that may be useful. It states that, as an alternative to a sign, employers can provide sufficient training to all employees to ensure they are aware of the location and hazards of the permit-required confined spaces at the jobsite. However, OSHA clearly states their preference for use of a sign where possible.

One other option presented in the 1910 preamble is to secure the entry porthole to the confined space with a lock or special fastener. Then, only employees who have been trained and authorized to enter the permit-required confined space would possess the key or tool needed to access the space.

Other Notification Requirements Regarding Permit-required Confined Spaces

In addition, those employers having permit spaces on site must inform, in a timely manner and in a manner other than posting, its employees’ authorized representatives, which are essentially their union representative, where applicable, of the existence and location of, and the danger posed by, each permit space. And the construction standard also requires employers who identify permit spaces at a construction site to also notify the Controlling Contractor at the site. Per OSHA definitions listed in this standard, the Controlling Contractor is the employer that has overall responsibility for construction at the worksite. This generally applies to the General Contractor, but this responsibility could fall to the host employer when no General Contractor is utilized.

Controlling Contractors at construction sites may or may not even have employees entering permit spaces, or they may not even be on the site at all times. But OSHA makes it very clear in the preamble to the construction standards for confined space entry that they consider the controlling contractor to be the “information hub for confined-spaces information sharing and coordination” at a construction site. More on the specific responsibilities of the Controlling contractor will be presented in later blog posts.

And for general industry worksites, 1910.146(c)(8) states that when an employer (host employer) arranges to have employees of another employer (contractor) perform work that involves permit space entry, the host employer shall inform the contractor that the workplace contains permit spaces and that permit space entry is allowed only through compliance with a permit space program meeting the requirements of this section. They must also apprise the contractor of the elements, including the hazards identified and the host employer’s experience with the space, that make the space in question a permit space.

What if No Employees Will Enter Confined Space?

Once affected employers have identified all of the permit-required confined spaces at their job-site, they are each presented with two options. Option one, an employer decides the employees it directs are NOT authorized to enter a permit space, or, option two, the employees they direct WILL enter a permit space. If an employer decides its employees will NOT enter a permit-required confined space, they still must comply with the requirements of Paragraph 1926.1203(c), which requires the employer to take effective measures to prevent its employees from entering the permit space.

So, even if an employer does not authorize their workers to enter permit spaces, they must still ensure that required danger signs are posted at permit spaces, and they must inform their employees and their designated representatives of the existence and hazards of the permit spaces. They must also inform employees and their designated reps of the company’s No Entry policy, where applicable. Last but not least, employers must inspect for compliance and enforce that policy.

Re-evaluation and Reclassification of Non-permit Required Confined Spaces

In addition, employers who have employees working in or near non-permit spaces must remember the requirements of paragraphs 1910.146(c)(6) and 1926.1203(f). They both require employers or their designated competent persons must reevaluate any non-permit confined space when there is a change to the use or configuration that might increase the hazards to entrants, as well as when there is some indication that the initial evaluation of the space may not have been adequate. And if a serious safety or health hazard is detected, the space must be reclassified as a permit-required confined space (with sign posted near points of entry) if necessary.

Comments About Communication and Signage Requirements for Permit Spaces

Please post your comments and questions about signage and notification requirements for permit-required 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, which addresses the steps that can be taken to temporarily reclassify permit-required confined spaces in the workplace to non-permit status; a big time-saver when working in eligible permit 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

Definition of a Hazardous Atmosphere – Airborne Combustible Dust =/> LFL

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Combustible dust LFL

 Blog Post #10 – In this post, we will examine the second category listed in the Federal OSHA definition for a hazardous atmosphere, which is an atmosphere with airborne combustible dust at a concentration that meets or exceeds its LFL (which stands for Lower Flammable Limit). LFL represents the minimum quantity of combustible dust that must be suspended in the air within the space to be able to cause a flash fire or dust explosion if ignited. In these conditions, the airborne dust is considered to have met or exceeded its lower flammable limit, or LFL.

OSHA’s 5-foot Rule of Thumb for Dust Measurement

The LFL of combustible dusts depends on many factors, including the type of material that makes up the dust, the size of the dust particles, the moisture content in the dust particles, and the density of the dust particles within the airspace.

There are instruments available that can measure the amount of combustible dust in the air to determine if it meets or exceeds its Lower Flammable Limit (LFL). However, for airborne dust measurement purposes, OSHA’s definition of a hazardous atmosphere due to airborne combustible dust refers to the use of the “5-foot rule of thumb”. That means that if the combustible dust suspended in the air is so dense that the entrant cannot see more than five feet from the end of their nose, there is a high risk of a flash fire or dust explosion.

In cases where this condition exists, or is likely to exist, inside of a confined space at any time during entry operations, it must be classified as a permit-required confined space.

Examples of Combustible Dusts

Here are examples of some, but not all, of the various types of airborne combustible dusts that could be present inside of some confined spaces during entry operations: Aluminum powder, dust from animal feed, coal dust, corn starch, cosmetic powders, dry fertilizer dust, dust from dry food and spices (coffee, tea, flour . . .), grain dust, powdered metal, plastic dust, powdered chemicals, rubber dust, sugar dust, textile fibers, and wood dust.

How Dust Fires and Explosions Occur

Combustible dust flash fires, a process called deflagration, is a rapid combustion process that produces a flame front which can quickly spread through a dust cloud if the concentration of combustible dust in the air is dense enough. And in some cases where the airborne dust fire is contained within a confined space, pressure quickly builds and an explosion can occur.

Here is a brief overview of the steps leading up to a combustible dust flash fire and explosion inside a confined space:

  1. A cloud of combustible dust is created in the air within a confined space, either through a process like grinding, mixing or other material handling activities, or by a settled dust being disturbed by other work activities such as cleaning with compressed air.

  2. A small portion of dust within the cloud is then ignited by a spark, flame, or other ignition source. Even static electricity must be considered as an ignition source.

  3. If the airborne combustible dust cloud is dense enough, the burning dust particles spread to others nearby, and those in turn ignite other airborne particles, resulting in a fire quickly spreading through the dust cloud. This process is called deflagration.

  4. The rapid spread of burning dust particles not only causes temperature inside the confined space to rapidly rise, it also creates a pressure wave that increases the internal pressure within the confined space.

  5. In the right conditions, the pressure wave can cause an explosion, leading to severe damage to the structure of the confined space.

  6. The burning dust cloud can continue to burn and expand. And the percussion from additional explosions may lead to more combustible dust inside the space being introduced into the air, adding even more fuel to the fire.

When a dust fire or explosion occurs, it can obviously lead not only to structural damage, but possible injury or death to anyone nearby. See an example of a dust explosion in this YouTube video showing a grain elevator explosion.

Classify All Confined Spaces with Potential for Airborne Dust Fires or Explosions as Permit-required Confined Spaces

So, consider the confined spaces present at your workplace, and take care to identify those with an actual or reasonable potential for a dense cloud of airborne combustible dust developing during entry operations, as those spaces will have to be classified as permit-required confined spaces.

Here are examples of some, but not all, types of confined spaces that, depending on materials they have contained, could produce heavy levels of airborne combustible dust during entry operations:

  • Conveyor systems
  • Cyclone separators
  • Duct work and air-handling systems
  • Dust collectors and bag houses
  • Grain storage bins, elevators, and silos
  • Hoppers and chutes
  • Mixers and blenders
  • Ovens and furnaces
  • Powder processing equipment such as mills and pulverizers
  • Truck and rail-car hoppers and tanks

In our next blog post (#11), we will examine the third criteria of a hazardous atmosphere that could be present inside of a confined space (oxygen deficiency or enrichment). In the meantime, please provide your feedback and questions to this blog post about airborne combustible dust at levels exceeding its lower flammable limit, or LFL, in the comments section below.

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