Who needs permit-required confined space training?

Who must be trained

1910.146(g)(1) requires training so that all employees whose work is regulated by the section acquire the understanding, knowledge, and skills necessary to safely perform their assigned duties. In practice that covers the three defined roles in a permit space entry.

Authorized entrants must know the hazards of entry, use required equipment, communicate with the attendant, and alert the attendant and exit when required (1910.146(h)). Attendants must know the hazards, monitor entrants, and summon rescue (1910.146(i)). Entry supervisors must know the hazards, verify the permit and that rescue services are available, and terminate entry when needed (1910.146(j)).

When training is required

Under 1910.146(g)(2), training must be provided to each affected employee: before the employee is first assigned duties under the section; before there is a change in assigned duties; whenever a change in permit space operations presents a hazard on which the employee has not been trained; and whenever the employer has reason to believe there are deviations from the entry procedures required by (d)(3) or inadequacies in the employee's knowledge or use of those procedures.

The standard sets no annual retraining interval for entrants, attendants, or supervisors. Training must establish proficiency in the required duties and introduce new or revised procedures as necessary ((g)(3)).

Rescue and emergency services

Employees designated to provide permit space rescue have added requirements under 1910.146(k)(2). The employer must provide the PPE needed for rescue and train them to be proficient in its use, at no cost to the employees; train them to perform assigned rescue duties; and ensure they complete the training required to establish proficiency as an authorized entrant under (g) and (h).

Rescue team members must be trained in basic first aid and CPR, and at least one member holding current first aid and CPR certification must be available ((k)(2)(iii)). They must practice permit space rescues at least once every 12 months using simulated rescues from the actual or representative permit spaces ((k)(2)(iv)). This 12-month practice is the only annual training element in the standard.

When an outside rescue service is used, 1910.146(k)(1) requires the employer to evaluate and select a service that can respond in a timely manner and is equipped and proficient, inform it of site hazards, and give it access to the spaces for planning and practice.

Certifying training

1910.146(g)(4) requires the employer to certify that the training in (g)(1) through (g)(3) has been accomplished. The certification must contain each employee's name, the signatures or initials of the trainers, and the dates of training, and must be available for inspection by employees and their authorized representatives.

Scope note

This guide covers general industry under 1910.146. Confined spaces in construction are covered by a separate standard, 29 CFR 1926 Subpart AA, which has its own training provisions.