Similar to other types of safety training, confined space training needs to include more than just information about the new OSHA regulations, hazards, controls and proper procedures for safe entry into a confined space. NUCA’s revised Confined Space Entry program includes all of that and then some, however, it does not include hands-on training in how to use the equipment needed to safely enter into confined spaces. This is because construction companies around the nation use a wide variety of brands and types of equipment. Just as they use different makes and models of heavy equipment, they purchase confined space entry equipment from different manufacturers and suppliers. In the classroom, instructors will address the types of equipment that will be needed but it would be impossible for an instructor to teach students how to use all the different types of equipment provided by hundreds of different manufacturers.
There is no doubt that the best place to begin confined space entry training is in the classroom. Beyond classroom training, it is the employer’s responsibility to ensure that their workers know how to use the equipment that is provided by the company.
It is also important to remember that most adults learn from hands-on experience, which helps reinforce what they have learned in the classroom. During this additional training, employees will have a chance to learn about the specific equipment the company is providing for their safety and how to use it.
Where to Begin
Following the classroom training and before employees are actually expected to enter into confined spaces, the company safety director, trainer or consultant should plan for the additional training. Start by gathering all the equipment that workers will be expected to use to perform a safe entry, including things such as gas monitors, ventilation equipment, tripod and retrieval device, harnesses, personal protective equipment (hardhats, eye protection, gloves), etc.
It is important for workers to know how to use all this equipment properly. The following is just some of the equipment they may need to be familiar with when working in confined spaces:
• The gas monitor is probably the most important safety device needed to enter into a confined space. Modern gas monitors are very similar and easy to use; however, from manufacturer to manufacturer, they do operate a little differently, which is why employees should be instructed in their use. One of the best ways to accomplish this is to get out the instructions and/or video and show the workers how to use the unit(s).
Obviously, they need to know how to turn it on and off, what the readings on the device mean and how to bump test the monitor. Most gas monitors go through a self-calibration cycle that verifies the sensors are working. The workers should know what they are expected to do if the device fails to turn on or fails the self-calibration. Bottom line: they should not use it or depend on it until the problem is corrected.
According to OSHA, employees involved in confined space entry have a right to observe the atmospheric testing of the space, which is one reason all workers should understand what the readings mean. One safety director told me about a foreman who had reportedly been testing confined spaces before entry until the safety director found out that the gas monitor the foreman was supposedly using had a dead battery and was not turned on in six months. Knowing that he had not been testing confined spaces for months, the foreman was fired immediately.
Not everyone needs to know how to physically calibrate the gas monitoring equipment but they should know how to check that the device has been calibrated within the time period stated by the manufacturer. Formal calibration with known test gas is generally performed by the safety director or the manufacturer.
• Another piece of equipment that is important for safe confined space entry is the ventilator, which, as most everyone knows, is used to blow fresh air into the confined space to help ensure the air inside the space is safe to breath. Also available from many different manufacturers, ventilators are similar in their operation, but, different ventilators often provide different volumes of air. Workers need to know how they are energized and how to set them up to ensure that fresh air is injected into the work area within the confined space. In order to help workers determine if enough air is provided for the size of the confined space check the label for the volume of air that is provided by the ventilator and how it is affected by the number of bends in the flexible duct. The recommended number of air changes per hour for ventilation is generally considered to be between 6 and 10. Your company should decide on the number of air changes per hour for the type of work being performed.
Workers should be instructed not to set the intake anywhere near a source of contamination such as vehicle exhausts, hazardous materials, sewage or drainage pipe openings, etc. Something that many workers may not know is flexible intake ducts can be installed on many ventilators to aid in the collection of fresh air. Note: ventilators must push air into the confined space creating positive airflow; OSHA does not allow the use of exhaust type ventilation (negative pressure) as the only means of ventilation in confined spaces.
• When a confined space is designated as a permit-required confined space, and entry into the space to perform rescue may be necessary, a rescue team must be designated and evaluated. The preferred method of rescue is non-entry rescue. This is accomplished by simply setting up a tripod or similar device with a retrieval device (winching system designed to lift humans) to extract a worker from the confined space. However, employees need to be instructed in how to set up and use the equipment. For example, a tripod or davit arm system should be set up at a height that will permit the worker to be attached to the retrieval device without having to stand over or sit in the opening because that creates a fall hazard. Workers need to know how to correctly assemble the tripod or davit arm system and how to attach and secure the retrieval device to the system. The chains at the bottom of the tripod should be set to prevent the legs from spreading when loaded. Workers should also be instructed in how to use the retrieval device because, once again, different systems operate differently.
• When a tripod or davit arm retrieval system is used, the worker should be wearing a properly fitted approved harness that is secured to a retrieval line. Before any worker is permitted to wear a harness, he or she should be instructed in how to inspect the harness to ensure that none of the stitching is pulled or damaged, the straps are not cut, worn, burned or damaged, and all fittings are in good condition. Harnesses should be removed from service and disposed of when any damage to the harness is observed. Workers should also be shown how to properly wear a harness.
• One area that is often overlooked during training is the type and use of personal protective equipment (PPE). Workers should be instructed to wear PPE when entering a confined space. At the very least, they should wear eye protection, gloves and a hard hat. Note: standard hard hats or full brim utility hard hats are often problematic when worn inside a confined space because of the brims; approved brimless hard hats are available for confined space entrants.
Requiring workers to wear respirators in a confined space should be required as a last option for preventing exposure to hazardous materials in a confined space. If respirators are necessary because the atmosphere cannot be controlled by ventilation, then employers must also comply with the Respirator Protection standard 1926.103 which refers to the requirements set forth in general industry standard 1910.134.
• Workers should also be instructed in how to use, maintain and care for any other equipment that may be required for performing confined space entry or rescue.
Demonstration of Knowledge
After showing workers how to use the equipment, instructors should have them demonstrate their knowledge of the confined space requirements and how to use the equipment. In some situations, instructors will require the workers to perform entry into a controlled confined space or to go through all the motions of performing a safe entry. Practice is always better in a controlled environment. In either situation, the instructor should evaluate their knowledge and make corrections where necessary. We all know that the real learning occurs when workers get out into the field where conditions are never perfect. Therefore, classroom learning followed by hands-on demonstrations of equipment can help to ensure that when workers get out into the field, they are prepared to follow the regulations and how to use the equipment they have been provided.
George Kennedy is NUCA’s vice president of safety.