Request For Sale (Rfs 08-07) - AZ Water Association

Determining
Confined Space Training Requirements
By John W. Bannen,
Workplace Safety Specialists
AZ WATER ASSOCIATION 14 January 2009
Entering and working in confined spaces is
established as a hazardous activity and effective
training needs to be accomplished as a means to
help protect employees from these hazards. Some
of the most frequently posed questions to
consultants and training organizations have to do
with what is needed in conducting training and
how often the training is needed. Needs can be
broken into the two categories of regulatory
mandated and employer directed. Accomplishing
training in accordance with federal, state or local
requirements requires review of the published
standards and general familiarity with formal
language used in the rules and regulations.
Employer directed training must meet the
regulatory standards but will often incorporate
additional requirements that create a site-specific,
more effective training plan. After evaluation of
the confined space training needs, a
determination of what type of training must be
completed. As confined space training is a very
common safety topic, there is training available in
many different medias. The table on the next
page will address the pros and cons of these
different types of training.
OSHA states, “The employer shall provide training
so that all employees whose work is regulated by
this section acquire the understanding, knowledge,
and skills necessary for the safe performance of the
duties assigned under this section.” (29 CFR
1910.145(g)(1). The training requirements for
confined space entry operations are straight
forward. After an employer has determined there
are permit required confined spaces and whether or
not employees will be allowed to enter these
confined spaces, an appropriate training plan can be
formulated. Employers do have the option of
restricting employees from entering permit required
confined spaces. If this is the determination made
by the employer, there still remains a responsibility
of the employer to make sure employees are trained
at an awareness level about confined spaces in order
to prevent employees from entering and working in
these spaces. This training, sometimes considered
an awareness level training, should address the
following: the company’s policy and confined space
program limiting the employees’ access to confined
spaces and their hazards; recognizing the confined
space warning and identification signs; changes in
use or configuration of non-permit spaces could
require that the space be reclassified as a permit
required space; and finally procedures that address
employees of other companies entering and
working in the permit required confined spaces of
the employer. When an employer determines
employees will enter and work in permit required
confined spaces, 29 CFR 1910.146(g) clearly
outlines the requirements and specifics that must be
addressed during training.
Employers that have established a need for a
confined space program and accompanying
employee training typically add additional
requirements into the confined space training
curriculum. These additional items are used to help
create a more effective and site-specific training.
While the regulatory requirements for training
items address confined space entry operations in a
general language, a company specific plan can
thoroughly address specific hazards and work
practices. An example of this is developing a sitespecific,
hazard specific confined space entry
permit or using photographs of the company’s
confined spaces to clearing communicate the
specific hazards employees may encounter during