Determining Confined Space Training Requirements

Carefully evaluate employees' duties and weigh each format's advantages and disadvantages.

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 on this topic 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 often will incorporate additional requirements that create a site-specific, more effective training plan.

After evaluation of the confined space training needs, you must determine what type of training to provide. Because confined space training is a very common safety topic, there is training available in many different media. The table in this article will address the pros and cons of these different types of training.

Employer Responsibilities
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 straightforward. 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. But if this is the determination made by the employer, there still remains a responsibility for 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 that could require the space to be reclassified as a permit-required space; and, finally, procedures that address employees of other companies who enter and work 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.

Additional Training Elements
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, 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. Examples of this are developing a site-specific, hazard specific confined space entry permit and using photographs of the company’s confined spaces to clearly communicate the specific hazards employees may encounter during confined space entries.

The regulatory requirement for training addresses the following: a need for employee training before the employees are assigned duties involving permit-required confined spaces; if there is a change in confined space duties; if there is a change in confined space operations that presents a hazard about which the employee has not been trained; or when the employer believes there have been deviations from the established confined space entry program or inadequacies in the employees’ knowledge or performance (29 CFR 1910.146(g)(2)(i) through 1910.146(g)(2)(iv)).

With an employer-directed program, additional training requirements may be established, such as annual or biannual training. Another employer-directed training requirement may be the development of instructional timelines appropriate to employees’ exposure to confined space operations. An example of this would be varying the length of training for different levels of employees, depending on their specific duties or tasks involving confined spaces.

Careful evaluation of an employee’s duties with regard to the level of appropriate training can be an effective tool to control costs associated with conducting training for larger organizations. Employers that choose to create site-specific training programs can benefit from increased productivity and fewer injuries when employees are proficient at conducting safe confined space operations.

Choosing Your Training Format
Selection of the most effective type of training should take effectiveness, durability, and cost into consideration.

Effectiveness addresses whether the training adequately focuses on the standard, hazards, and employee exposure and is practical to the company’s operations.

Durability is the ability for the training to remain applicable over time.

While cost should never be a primary factor in determining an approach to safety, the reality is that all organizations must consider cost when evaluating the type of training that will be selected for employees needing confined space training.

Final Considerations
Employees who perform work in and around permit-required confined spaces are exposed to unique hazards that require appropriate and effective training to help in preventing incidents. Selection of this training can be accomplished by applying the regulatory standards or by using those standards as a minimal outline for training and adding company-specific, site-specific directives to increase the applicability of the training.

Companies must balance the need to train their employees with the type and cost effectiveness of their selected type of training. While there are requirements for confined space training and different means to accomplish that training, the overall goal is to maintain a safe workplace. Additional benefits employers receive from conducting training can be reduced insurance and worker’s compensation expenditures, enhanced employee loyalty, and increased productivity.

Finally, it is important to remember that the federal regulatory standards should be viewed as the minimum requirements. Establishing site-specific confined space training is highly recommended.

This article originally appeared in the February 2009 issue of Occupational Health & Safety.

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