3.3 Entrant, attendant, entry supervisor

1 Designating people, and the one person who can hold two roles

1910.146(d)(8) requires the employer to designate the persons who are to have active roles in entry operations — authorized entrants, attendants, entry supervisors, and the persons who test or monitor the atmosphere — to identify the duties of each, and to provide each with the training of paragraph (g). 1926.1204(h) is identical for construction, pointing at 1926.1207.

Note that testing is listed as a role in its own right. The person reading the meter has a designated function with its own training, which is why the log records who took each reading — 1910.146(f)(10) requires the names or initials of the testers on the permit.

Roles can be combined, with a limit. The note to the definition of entry supervisor at 1926.1202: an entry supervisor may also serve as an attendant or as an authorized entrant, as long as that person is trained and equipped as required by this standard for each role he or she fills. It adds that the duties of entry supervisor may be passed from one individual to another during the course of an entry operation. What cannot be combined is the attendant with anything that takes them away from the portal — and an attendant who becomes an entrant has left the space unattended, which is the subject of section 3 below.

2 The authorized entrant

1910.146(h) — and 1926.1208, which tracks it closely — gives the entrant five duties. The employer must ensure that all authorized entrants:

1. 1
   Know the hazards that may be faced during entry, including information on the mode, signs or symptoms, and consequences of the exposure — (h)(1).
2. 2
   Properly use the equipment required by (d)(4) — testing, ventilating, communications, PPE, lighting, barriers, ladders, rescue equipment — (h)(2).
3. 3
   Communicate with the attendant as necessary to let the attendant monitor entrant status and alert entrants of the need to evacuate — (h)(3).
4. 4
   Alert the attendant whenever they recognize any warning sign or symptom of exposure to a dangerous situation, or detect a prohibited condition — (h)(4).
5. 5
   Exit as quickly as possible whenever an order to evacuate is given by the attendant or entry supervisor, whenever they recognize a warning sign or symptom of exposure, whenever they detect a prohibited condition, or whenever an evacuation alarm activates — (h)(5).

Duty 1 is the one that most often exists only on paper. “Signs or symptoms” means the entrant can recognize the early effects in themselves — a headache, a metallic taste, dizziness, a sudden loss of the smell they had been noticing. And “consequences” means they know why that matters here rather than in a well-ventilated shop.

Duty 5 is written without conditions on purpose. There is no clause allowing the entrant to finish the bolt, look for the cause, or ask the attendant to double-check. Four triggers, one response: out, as quickly as possible.

3 The attendant: ten duties, and two of them are prohibitions

1910.146(d)(6) requires at least one attendant outside the permit space for the duration of entry operations. 1926.1204(f) says the same. Both allow one attendant to cover more than one space, provided every duty can still be effectively performed for each — and 1910.146(d)(7) then requires the program to include the means and procedures that let the attendant respond to an emergency in one space without distraction from the duties owed to the others.

1910.146(i) — and 1926.1209 — lists what the attendant does:

(i)(2) and (i)(6)(ii) together are the most sophisticated thing in the standard. The attendant is not watching for someone to collapse; they are watching for behavioral change — slurred speech, repeating a question, fumbling a tool, an unexplained cheerfulness, a delay before answering. Those arrive before the collapse, and the attendant is the only person positioned to notice.

(i)(10) is the prohibition that keeps being broken by good intentions: no other duties. Not signing for a delivery, not moving the truck, not running for a fitting, not taking the call from the office. And (i)(6)(iv) turns that into an evacuation trigger — if the attendant cannot perform all of the attendant duties safely and effectively, the correct action is not to do their best. It is to order everyone out.

4 The attendant who goes in

(i)(4) says the attendant remains outside until relieved by another attendant. The note to that paragraph gives the only exception, and it has three conditions: where the employer's permit entry program allows attendant entry for rescue, attendants may enter to attempt a rescue if they have been trained and equipped for rescue operations as required by (k)(1) and if they have been relieved as required by (i)(4). 1926.1209(d) carries the same note.

Read the conditions in order and it is clear what the standard is protecting against. An attendant who enters without being relieved has left the remaining entrants with nobody counting, nobody watching and nobody to call for help — and has usually entered the atmosphere that just incapacitated somebody else. Part 4 is entirely about that failure.

5 The entry supervisor

1910.146(j) — and 1926.1210 — gives six duties, and the first three are the reason the role exists:

• (j)(1) Knows the hazards, including the mode, signs or symptoms and consequences of exposure.
• (j)(2) Verifies, by checking that the appropriate entries have been made on the permit, that all tests specified by the permit have been conducted and that all procedures and equipment specified are in place, before endorsing the permit and allowing entry to begin.
• (j)(3) Terminates the entry and cancels the permit as (e)(5) requires. In construction, 1926.1210(c) allows cancelling or suspending under 1926.1205(e).
• (j)(4) Verifies that rescue services are available and that the means for summoning them are operable. 1926.1210(d) adds: and that the employer will be notified as soon as the services become unavailable.
• (j)(5) Removes unauthorized individuals who enter or attempt to enter the permit space during entry operations.
• (j)(6) Determines, whenever responsibility for the entry is transferred and at intervals dictated by the hazards and operations performed within the space, that entry operations remain consistent with the terms of the permit and that acceptable entry conditions are maintained.

(j)(2) is a verification duty, not an approval duty. The supervisor signs because they checked; the signature is the record of the check. And 1910.146(e)(2) is unambiguous about the sequence: before entry begins, the entry supervisor identified on the permit shall sign the entry permit to authorize entry.

(j)(4) is the one that gets treated as a formality and should not be. “Available” means the service exists and is on shift today; “the means for summoning them are operable” means somebody has actually tried the radio or the phone. A plan written in March does not prove the rescue team is staffed this afternoon.

(j)(6) covers the shift change, and it is where entries quietly drift. The permit is written for a set of conditions; four hours later the work has moved, a second crew has arrived, a line has been opened. Someone has to make the judgment that the entry is still the entry the permit describes.

6 Where the three roles meet

Two provisions exist purely to keep multiple crews from harming one another. 1910.146(d)(11) requires procedures to coordinate entry operations when employees of more than one employer are working simultaneously as authorized entrants in a permit space, so that one employer's employees do not endanger another's. 1926.1204(k) goes wider: coordination, in consultation with the controlling contractor, when employees of more than one employer are working in a permit space or elsewhere on the worksite where their activities could foreseeably result in a hazard within the confined space.

That “or elsewhere” is the escalator case from Chapter 1 of this part, and it is the vault with a paving crew overhead. The person creating the hazard is not in the space and may not know the space exists.

Finally, one duty that belongs to none of the three roles and to all of them. 1910.146(l): employers shall consult with affected employees and their authorized representatives on the development and implementation of all aspects of the permit space program, and shall make available to them all information the section requires to be developed. The people who fill these three roles are the ones who know where the program does not match the site.