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QUESTION:

Do I need an industrial hygienist to monitor my confined spaces, or can I train a line employee to operate the instrumentation?

ANSWERS:

Gas monitoring instruments for use in confined spaces are designed to be very straightforward and user-friendly. In routine applications, confined space workers need only to understand that if the readings exceed the set points for limiting action or entry into the confined space, entry should cease immediately until the situation is corrected and normal readings are obtained. This minimizes the need for any industrial hygienist involvement.

But the IH does play a vital role in interpreting the situation when the readings fall outside of the acceptable range and the instruments indicate abnormal atmospheric conditions.

David D. Wagner, Manager, Customer and Product Services, Industrial Scientific Corporation

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Yes and yes. The potential hazard within a confined space needs to be assessed first. An IH can be called in to employ a variety of instruments to evaluate the situation and produce an analysis. There may be several hazardous gases present existing at different levels and concentrations within that confined space. Once a recommendation is made by the IH and the proper instrumentation is procured, then an employee may be trained to operate those instruments for ongoing monitoring.

Ron Baughman, Portable Instrument Product Group Manager, MSA Instrument Division

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It all depends on the employer’s confined space entry program, and the regulations that govern the entry procedures. All programs, however, must ensure that the individuals who undertake duties such as testing the atmosphere in the space are properly trained.

OSHA 29 CFR 1910.146, “Permit-Required Confined Spaces,” requires the designation, identification and proper training for persons who have an active role in the PRCS entry, including persons who test or monitor the atmosphere in a permit space, but leaves it up to the employer to decide what additional credentials may be required for individuals tasked with specific confined space duties.

Permit space entry team members can only function effectively and safely when they fully understand their responsibilities and duties. Thorough training is essential. Permit spaces are by definition inherently dangerous.

Mistakes are “Not Permitted!”

Bob Henderson, Vice President Business Development, BW Technologies

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Our feeling is that it is important that a pre-entry test and confined space monitoring must be performed by someone competent to carry it out, and that testing must be carried out in compliance with the procedures of the organization. The product used must be suited to the purpose and have a current valid calibration certificate. The instrument should have a bump test prior to going into service each day.

All of those areas are best supervised by an industrial hygienist, but with simple one-button instruments now available, the actual function of testing could be carried out by a trained line employee.

Phil Saxton, General Manager, Crowcon USA

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The Permit-Required Confined Spaces safety regulation as enforced by state and federal OSHA does not specify the skill level of the individual conducting the air quality testing of such spaces. The OSHA regulation is essentially “silent” on the issues of level of training of the operator and the frequency of calibration of the instrument. However, calibration should be performed in accordance with the instrument-maker’s written instructions, and “due diligence” suggests minimally a one-hour “hands on” training session for the instrument operator.

Dr. Verne R. Brown, Founder and President, ENMET Corporation

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A well-designed confined space monitor can be used by operators with little or no background in instrumentation with minimal training required. Gas monitoring instruments are available with fewer control buttons to simplify operation. A typical instrument will have one button for on/off control, one button to zero the instrument, and another for display options. A variety of tools are available to assist employee training, such as pocket reference cards, videos, and interactive computer-based training.

Mike Johnson, Marketing Manager, RKI Instruments, Inc.