Effective Confined Space Entry
Team Member Training
By Terry W. Krug
When an employer assembles a team to enter a confined space, each member must receive sufficient training to safely enter and exit the space. The instruction must be comprehensive enough for employees to complete the job and understand the hazards present.
This article discusses key areas of training for the following entry team members: Entry supervisor, attendant, entrant, atmospheric tester and rescue personnel (ANSI/ASSE, 2009b; OSHA, 2012).
The entry supervisor must be selected by the employer for his/her knowledge and experience of the space to be entered. S/he must be aware of all existing or potential hazards in and around the space no matter how minor these hazards seem. For example, hydrogen sulfide measured at 2 ppm around the ground opening at a refinery may be within all regulatory limits. However, because of the location and density of the gas, this could become a serious issue during entry.
The entry supervisor must know the signs and symptoms of exposure/overexposure. In addition, the supervisor must have a current certificate of training on file with the company and be able to:
- Recommend effective controls such as ventilation, lockout/tagout, ground fault circuit interrupter or PPE.
- Perform all the other team members’ duties and select the individual most capable of filling each position on the team.
- Research the rescue team capabilities and response time in case of an emergency, and contact rescue team members prior to commencing entry to ensure their availability, whether an in-house or outside rescue service is used. Verify that communication means are operable.
- Understand all types and limitations of PPE to ensure proper selection.
- Ensure proper selection and explain limitations of all tools and equipment used in connection with entry. Verify that they are working properly and have been inspected prior to use.
- Properly complete and sign the entry permit to authorize the entry to begin. May need to explain why blank areas are not allowed, and why instrument readings must be documented in their time slot and what the readings mean.
- Explain what the test instrument readings indicate. The entry supervisor must be given instruction on test instruments and their limitations and poisons. To evaluate, have the supervisor explain a bump test and solvent flash points.
- Responsibly transfer supervisor control and canceling of the permit if extended shifts are needed to complete the confined space entry task.
- Ensure that canceled permits are collected and retained for at least 1 year for review and training purposes.
- Remove unauthorized individuals who enter or attempt to enter during entry operations.
The person selected as the attendant must have the following qualities and have a current training certificate on file with the company:
- Knows the hazards of the space, and signs and symptoms of exposure/overexposure.
- Aware of possible behavioral effects of hazard exposure on entrants.
- Able to continuously keep accurate count of all authorized entrants.
- Remains outside the space but in constant communication with entrants during the operation.
- Communicates with authorized entrants as necessary to monitor entrants’ status and to alert them in the event that evacuation is required for one of the following reasons:
- attendant detects a prohibited condition (e.g., lightning storm, tank overflow, rupture);
- attendant notices behavioral effects of hazard exposures affecting one or more entrants;
- attendant detects a condition outside the space that could endanger the entrants;
- attendant cannot effectively and safely perform all the duties required.
- Monitors activities inside and outside the space to determine whether it is safe for entrants to remain in the space or if they need to evacuate.
- Summons rescue and other emergency services as soon as s/he determines that the entrants may need assistance. (Professional rescuers have determined that this is the first indication of a problem, and the attendant should not wait for verification of a problem.)
- Takes the following actions when unauthorized persons approach or attempt to enter the permit space:
- Warns the unauthorized person that s/he must stay away.
- Advises the unauthorized person that s/he must exit immediately if s/he has entered the permit space.
- Informs the authorized entrants and entry supervisor that unauthorized persons have entered the permit space.
- Performs nonentry rescue as specified by the employer’s rescue procedures.
- Performs no other activities that might interfere with his/her primary duty to monitor and protect authorized entrants.
The authorized entrant enters the space to perform the assigned work. Not only must s/he be physically able to get into the space, but s/he must also be medically able to wear the necessary PPE and perform the assigned task.
S/he must also be trained in the following prior to entry and have a current training certificate on file with the company:
- Knows the hazards of the space, and the signs and symptoms of exposure/overexposure.
- Properly uses equipment as required by program elements 1910.146 (d)(4).
- Communicates with the attendant as necessary so that the attendant can monitor entrants’ status and alert entrants if evacuation is required.
- Alerts the attendant whenever:
- entrant notices any warning signs or symptoms of exposure to a dangerous situation;
- entrant detects a prohibitive condition.
- Exits the space as quickly as possible whenever:
- an order to evacuate is given by the attendant or entry supervisor;
- entrant recognizes any warning sign or symptom of exposure to a dangerous situation;
- entrant detects a prohibited condition;
- evacuation alarm is activated.
- Aware of activities in the space, from the space’s process energy to activities of other entrants that may affect exposure to hazards.
The atmospheric tester must possess the knowledge, skills and abilities to properly use testing and monitoring equipment. S/he also must be able to interpret results to ensure that all areas where the entry team will be working are within the established acceptable limits under 1910.146 (c)(4),(c)(5),
(c)(7), (d)(4)(i), (d)(5) and (f)(10). The atmospheric tester must have a certificate of training on file with the company as required under (g)(4) following the requirements of (g)(1) to (g)(3). The atmospheric tester must:
- Know proper calibration procedures of all monitoring equipment prior to use as needed.
- Know why, when and how to bump test the instrument.
- Know the limitations of all test instruments.
- Be familiar with the sensor poisons and know when not to use a test meter.
- Have read the manufacturer’s instructions and have used the instrument before.
- Be trained to periodically back up electronic sensors with other methods (e.g., gas bags, detector tubes, photo ionization detectors, flame ionization detectors, metal oxide semiconductor).
- Be familiar with or trained to perform remote sampling techniques.
- Have been designated by the entry supervisor as the atmospheric tester.
If the employer selects an in-house rescue team to perform rescue operations from permit spaces, the personnel selected must have a current training certificate on file with the company. Also, those selected must be physically able to perform rescue tasks in a timely manner depending on the hazards involved, and be medically able to wear the required PPE (fit-tested and trained for respirator use such as self-contained breathing aparatus or airline combination unit). Persons selected for the rescue team must receive training as an authorized entrant and be proficient in the following:
- Have access to the permit space to be entered and practice at least once every 12 months.
- Equipped for and proficient in provided rescue equipment such as harnesses, lifelines, tripod, davit arm, winch and stretcher, able to perform basic first aid and CPR procedures, with at least one member currently certified.
- Horizontal rescue techniques requiring slide boards, backboards or the use of wristlet or anklets.
- Nonentry rescue techniques and setup and when entering the space for entrant packaging to prevent further injury.
- To facilitate nonentry rescue, the entrant shall be equipped with a full body harness with a lifeline attached to the center of the entrant’s back near shoulder level or other attachment point determined by the employer to be best with the other end attached to an anchor point outside or to a mechanical winch, rope and pulley.
- High-angle rescue issues, special equipment and training needed to retrieve entrants from a water tower, ventilation ductwork, bag house or elevated tower.
Subject-matter experts in the topics being taught must conduct the training for all entry personnel and company-selected rescue team. The training must test the proficiency of the entry team member through hands-on application and documented testing to ensure the needed skills are acquired. The program shall include, at a minimum, the following measureable elements:
- needs assessment;
- training topic objectives;
- adult learning application and principles;
- applicable standards and resources available for additional information;
- clear course criteria for completion including passing posttest;
- training delivered by a knowledgeable instructor;
- training evaluation and a continuous improvement system;
- written training program plan and recordkeeping;
- training certificate given to each student upon successful completion (ANSI/ASSE, 2009a).
By following these training recommendations and familiarizing yourself with the referenced documents, you should be able to deliver effective confined space entry team member training.
ANSI/ASSE. (2009a). Criteria for accepted practices in safety, health and environmental training (ANSI/ASSE Z490.1-2009). Des Plaines, IL: ASSE.
ANSI/ASSE. (2009b). Safety requirements for confined spaces (ANSI/ASSE Z117.1-2009). Des Plaines, IL: ASSE.
OSHA. (2012). Permit-required confined spaces (29 CFR 1910.146). Washington, DC: U.S. Department of Labor, Author.
Terry W. Krug, M.S., CSP, CIH, is president and chief scientist for EXOSHA Inc., Bartlett, IL. He is a professional member of the Northeastern Illinois Chapter and a member of the Society’s Standards Development Committee.