Training is critical to safe confined space entry operations. A well-trained crew can, to an extent, compensate for inadequacies in other areas of your confined space process. The reverse is not true â€” a poorly trained crew is in constant danger during entries even if the other components of your process are adequate.
An effective base of knowledge and skills allows the crew to have the flexibility they need to handle safety issues as they occur, even if the issues are not specifically covered by your policies and procedures.
1) Training for confined space safety, like any effective training, should begin with establishing performance objectives. Identify the specific knowledge and skills that your personnel need during entries.
Being specific is one of the keys to this process. â€œKnow how to use an atmospheric monitorâ€ is not an adequate objective. A better example is: â€œDemonstrate the use of a four-gas atmospheric monitor to conduct a prior-to-entry evaluation of a below-grade vault.â€
2) Training must be site and task specific. Generic training will not provide for the level of performance that is required in confined space work. To be effective training objectives must flow from the types of confined spaces you enter, the types of work performed in those spaces by your personnel, and the confined space process and equipment used in your facility.
3) Knowledge of the types of confined spaces and the characteristics of each type is important so that your personnel can recognize spaces. Fatality reports (NIOSH) often mention a failure to recognize an area as a confined space as part of what led to the death. If the crew does not think the work area is a confined space then no special precautions will be taken.
4) Each member of the crew must be aware of their role during the entry and the responsibilities of each position within the crew. Entrants, attendants, and entry supervisor are the three roles required for safe confined space entries. Entrant and attendant training should be conducted as a combined program so that personnel become qualified for both roles and can switch off during entry operations. Entry supervisors must be qualified at the entrant/attendant level and have additional training for their extra responsibilities.
5) Your personnel should be familiar with your safety policies and must understand the importance and proper use of your procedures.
6) Personnel must be familiar with all of the hazards that may be present during entries. They should also be taught how to conduct basic hazard assessments prior to all entries. These assessments form the basis of an effective hazard elimination and control process.
An effective assessment considers the inherent hazards of the space, external hazards that may impact the operation, and hazards that may be created by the work process. The hazards the entry crew thought of prior to the entry will not usually be the ones that create problems for them. The hazard(s) they did not recognize will be what gets them into trouble.
7) Atmospheric hazards are the most frequent cause of death in confined space operations (NIOSH) so effective monitoring is critical to safety. Your personnel must be able to select the appropriate monitoring equipment and use it effectively. This portion of training is one of the most important and should include both classroom and practice elements.
8) Ventilation is used to correct or prevent atmospheric hazards and for general comfort within the space. Proper ventilation techniques must be covered during the training.
9) Isolation refers to all of the activities completed to separate the space from sources of energy and other issues that may create a hazardous condition within the space. This topic includes hazardous energy control processes that are usually covered in lockout/tagout training. It may also cover issues concerning pipe isolation techniques such as blanking if that is appropriate to your processes.
10) Ideally, entries will be completed without the need for personal protective equipment (PPE). At times though PPE will be necessary during a confined space entry. Your personnel must know how to select the appropriate PPE for the task or know where to find assistance to make the correct selection. Proper use is also important with PPE, particularly if respiratory protection is required.
11) Many other types of safety equipment in addition to PPE may be required for confined space entry. For example, harnesses and retrieval devices. Your personnel must be familiar with the setup and operation of all of the safety equipment available to them.
12) Lighting is a simple but important part of conducting safe entries. Your training should cover the equipment your organization uses including safety issues such as the use of ground-fault circuit interrupters (GFCI) and explosion-proof lighting (if this is necessary in your facility).
13) Communications, particularly between the entrant(s) and the attendant, are essential to safety during entries. In environments such as high noise areas where equipment must be used to supplement voice communications, it is imperative that your personnel know how to setup and use this equipment properly.
14) We hope we never need to implement emergency procedures but we must have them and our personnel need to be well-trained on implementing them if something goes wrong during an entry.
15) When preparing confined space training take advantage of other training that your target audience may have already completed.
For example, all personnel should have completed hazard communications training that at a minimum taught them how to read a material safety data sheet (MSDS). This skill is an important part of hazard assessment in confined space entry.
Also, many of the personnel that will be involved in confined space entry may have had lockout/tagout training for their other job duties. At least some of this training should apply to confined spaces. Training that was originally conducted for another purpose but applies to confined space entry does not need to be repeated.
16) Confined space entries involve physical skills. Training should include practice with equipment. Practice sessions should provide as realistic a situation as practical. Remember, a confined space entry for practice will require all of the same preparations that an actual work entry would need.
17) OSHA regulations (1910.146(g)) do not require routine refresher training for entry personnel. From a practical perspective periodic refresher training is important. How frequently it should be completed will depend upon several things including: how often your personnel make entries, the type of entries they make, risks associated with your entries, and potentially many other issues.
Training is a key element of any effective confined space process. It is the element that ties all of the other components together so your personnel can perform safe entries.
April 8, 2006