4.4 Training, contractors and keeping the program honest

1 Training: four triggers, not an annual event

1910.146(g)(1) sets the objective: training so that all employees whose work is regulated by the section acquire the understanding, knowledge, and skills necessary for the safe performance of the duties assigned. Not awareness — the duties assigned. Then (g)(2) sets when it happens, and none of the four triggers is a date on a calendar:

(g)(3) requires the training to establish employee proficiency in the duties required and to introduce new or revised procedures as necessary. And (g)(4) requires the employer to certify that the training has been accomplished, with a certification containing each employee's name, the signatures or initials of the trainers, and the dates of training, available for inspection by employees and their authorized representatives.

Construction, at 1926.1207, adds three things worth knowing. Training is at no cost to the employee (a). It must be provided in both a language and vocabulary that the employee can understand (b)(1). And the records must contain each employee's name, the name of the trainers and the dates, and be available for the period of time the employee is employed by that employer (d). 1926.1207(a) also carries the rescue clause from Chapter 1 of this part: the training must produce an understanding of the dangers of attempting an entry rescue, for those not authorized to perform one.

2 What this course is, and what it is not

This is the right place to be blunt about the limits of what you are reading. This course explains 1910.146 and 1926 Subpart AA. It cannot do any of the following, and nothing that calls itself online training can:

• It cannot cover your permit spaces, their hazards, or your employer's written program — which is what (g)(1) requires the training to do.
• It cannot designate you as an authorized entrant, an attendant or an entry supervisor. Only your employer does that, under (d)(8).
• It cannot establish proficiency in duties it has never watched you perform — (g)(3).
• It cannot produce the certification of (g)(4) or the records of 1926.1207(d), which carry your name, your trainer's name and your dates.

Nothing is issued for finishing this course — no card and no document of any kind — and it satisfies no regulatory training requirement. What it should do is let you read your own program critically and notice when it does not match the site. That is a genuinely useful thing for an entrant to be able to do, and 1910.146(l) gives you the standing to say so: employers must consult affected employees and their authorized representatives on the development and implementation of all aspects of the permit space program, and make available to them all the information the section requires to be developed.

3 Contractors: the information has to move both ways

Part 1, Chapter 3 covered the construction structure. Here is the general industry version and what it has in common. 1910.146(c)(8) — the host employer, when it arranges for a contractor to perform permit space entry, must:

• inform the contractor that the workplace contains permit spaces and that entry is allowed only through compliance with a compliant program;
• apprise the contractor of the elements — including the hazards identified and the host employer's experience with the space — that make it a permit space;
• apprise the contractor of any precautions or procedures the host has implemented for the protection of employees in or near those spaces;
• coordinate entry operations when host and contractor personnel will both be working in or near permit spaces, as (d)(11) requires;
• debrief the contractor at the conclusion of entry operations about the program followed and any hazards confronted or created.

And 1910.146(c)(9) puts the mirror-image duties on the contractor: obtain the available information from the host, coordinate, and inform the host of the program it will follow and of any hazards confronted or created — through a debriefing or during the entry operation.

The clause that carries the most value is “the host employer's experience with the space.” That is the vault that reads low after rain, the tank that off-gasses when the sun hits the shell, the line somebody once found still charged, the manhole where the radio does not work. None of it is on a drawing, and a contractor cannot discover it by looking. In construction the same knowledge is routed through the controlling contractor under 1926.1203(h), before entry and after it — and 1926.1203(i) puts the controlling contractor's role onto the host employer where there is no controlling contractor on site.

4 Two reviews, two clocks

The immediate review is the one with teeth, because of the phrase “before subsequent entries are authorized.” It is a stop-work provision in the form of a paperwork requirement. And its trigger list includes two items that are not incidents at all: a hazard that was not on the permit, which means the assessment was wrong, and an employee complaint, which means the people doing the work think the program does not fit.

The annual review only works if the permits carry something worth reading. 1910.146(e)(6): any problems encountered during an entry operation shall be noted on the pertinent permit so that appropriate revisions to the program can be made. A drawer of permits with nothing written in the margins produces an annual review that finds nothing.

5 Preventing entry, which is also a program duty

1910.146(d)(1) is the first item in the program list and the easiest to forget: implement the measures necessary to prevent unauthorized entry. 1926.1204(a) is identical. It pairs with (c)(2) and 1926.1203(b)(1) — informing exposed employees by danger signs or other equally effective means — and with (c)(3) and 1926.1203(c), which require effective measures to keep employees out of spaces the employer has decided nobody will enter.

Physically, that is covers that are bolted or locked, hatches secured, barricades and signage around an open portal, and the guarding required when an entrance cover is removed — 1910.146(c)(5)(ii)(B) requires the opening to be promptly guarded by a railing, temporary cover or other barrier, both to prevent a fall through it and to protect the person inside from objects dropping in.

Procedurally, it is the attendant warning unauthorized people away under (i)(8) and the entry supervisor removing them under (j)(5). And an unauthorized entry is one of the events on the (d)(13) list that stops further entries until the program has been reviewed. The standard treats an unauthorized entry as a program failure, not as a personnel matter — which is the correct reading, because the person who climbed in was usually never told not to.

6 Eight questions to take back to your own program

Everything in this course reduces to eight questions. If your program answers all eight with a document and a name, it is in good shape. If it answers any of them with “we would figure that out,” that is where to start.

1. 1
   Where are the spaces, and who found them? A list, and a competent person's name on it for construction work — 1910.146(c)(1), 1926.1203(a).
2. 2
   Which route are we using, and can we prove it? Full permit, ventilation-only with monitoring data and a written certification, or reclassification with elimination documented — (c)(4), (c)(5), (c)(7).
3. 3
   What are the acceptable entry conditions for this space, and who set them? — (f)(9), (d)(3)(i).
4. 4
   How is the space isolated, item by item? Blinds by line number, valves locked, energy sources locked out with stored energy released — (f)(8), 1910.147.
5. 5
   Who is the attendant, who relieves them, and what else are they doing? The correct answer to the last part is nothing — (d)(6), (i)(10).
6. 6
   Who is the rescue service, when did we last evaluate them, and when did they last practice on a space like this one? — (k)(1), (k)(2)(iv), App. F.
7. 7
   Who is not allowed to go in, and have we said so out loud? — (d)(9), 1926.1207(a).
8. 8
   Where are last year's permits, and what is written in the margins? — (e)(6), (d)(14).

Three free tools on this site follow the same paragraphs, print on Letter and send nothing anywhere: the entry permit generator for all fifteen elements, the atmospheric testing log for the readings that (f)(10) requires, and the rescue plan generator for the document behind (f)(11). The confined space entry practice test is the place to check what stuck.