Confined Space Rescue Training Requirements Explained

Confined Space Defined

The Occupational Safety and Health Administration (OSHA) standards for Confined Spaces (29 CFR 1910.146) outline a number of requirements for Confined Space entry and Rescue. Under these standards a Confined Space is a space that is entered with limited means of egress. The space could be an area that has the possibility to contain hazardous atmosphere. Areas that are considered Confined Spaces include: tanks, silos, pits, bins, hoppers, tunnels, sewers manholes, vessels, etc.
As of writing this article, there are no OSHA standards for Construction Confined Space (29 CFR 1926 Subpart, AA). Additionally, there are no widely accepted definitions for Confined Space in Construction other than a Confined Space is defined as a space into which it would be hazardous to enter due to the configuration of the space, materials or equipment inside the space (29 CFR 1910.147) and there is limited means of egress. The Confined Spaces in Construction (35) definition can be viewed here.
According to OSHA under the Hazard Communication Standard (29 CFR 1910.1200), a confined space must have the following three characteristics: 1) It is large enough and so configured that an employee can bodily enter and perform assigned work; 2) Has limited or restricted means for entry and exit; and 3) Is not designed for continuous occupancy by a worker.
The National Institute for Occupational Safety and Health (NIOSH) lists Confined Space as: A space that is enclosed, either totally or partially, and where the purpose of entry is, or could reasonably foreseeably be, the performance of work. The space has limited openings for entry and exit, and poor ventilation. These spaces may contain or have the potential to contain a hazardous atmosphere, contain a material that has the potential for engulfing an entrant, or has any other serious safety or health hazard. Examples of Confined Spaces include: tank, vessel, silo, vault, manhole, tunnel, cistern, storage bin, utility vault, pit or pipeline.
The Tank Industry Consultants also have a definition for Confined Space that includes the requirement for one of the three hazards to be present. The hazards are: 1) has the potential for a hazardous atmosphere, including conditions that may: a) explode, b) ignite, c) asphyxiate, d) erode, dissolve or change the dermis layer, e) poison, f) damage eyes, g) create burns, h) electrocute, i) rupture or collapse, 2) has limited or restricted means of entry or exit , 3) that is not designed for continuous employee occupancy.
It is important to know that as of today there are no laws governing the definition of Confined Space in Construction. The definitions that govern Construction are general "limited means of egress" and "limited or restricted means of entry or exit". At times these definitions are thought to be interchangeable or loose in meaning, but in reality they are different. In Confined Space Rescue Training, understanding the difference between entry/egress and entry/exits is imperative.
Limited means of entry means that the opening is smaller than the individual’s torso and could contain an exploding or imploding hazard. Egress means that the person can get through the opening but might have to crawl or squeeze themselves through, but when it comes to exit, there is usually no way out without additional equipment or opening wider the point of entry.
It should be noted that small openings that only allow access for equipment and tools are usually excluded from the definition of Confined Spaces and limited or restricted means of entry, as there does not need to be enough room for an employee to fit in just because they can crawl or shimmy through an opening.
These definitions have been the subject of some debate over the years and OSHA’s definition of Confined Space has evolved over the years. At times it was more restrictive and at other times it was more broad. A symbolic list of the definitions can be found on Construction Knowledge [here].
Although OSHA does not regulate Confined Space Training in Construction, the potential for hazards and injury is real. Construction sites are known for trenching activities such as tunneling and digging. Under the standard: "a trench is considered a confined space if it meets the qualifications of limited or restricted means of entry or exit. It is therefore very important for all construction workers to understand Confined Space training and its applicable hazards.
Training is the best way to understand the hazards of Confined Space. This risk is even higher when you deal with Trench Rescue and Recovery, and successfully conducting these types of rescues requires very specific training. The Rescue Rate for confined Spaces is also very poor, at less than 25%. The purpose of this article was to address the confusion around the definitions of Confined Space and the limited means of egress or exit so that workers can know the hazards they face when entering these spaces, to avoid injuries and fatalities.

Legal Mandate for Confined Space Rescue Training

Due to the inherent dangers of performing rescue operations, the U.S. Occupational Safety and Health Administration (OSHA) mandates rescue teams be properly trained and equipped to carry out confined space rescues. Training requirements are specifically outlined in OSHA regulations [1910.146(e)(1), 1910.146(c)(2), 1910.134(g)(3)(i)], which include the following:
"1910.146(c)(2) – The employer shall evaluate the effectiveness of the rescue team’s performance at least annually."
"1910.134(g)(3), [Respiratory Protection] – The employer shall provide a medical evaluation to determine the employee’s ability to use a respirator using the medical evaluation questionnaire in Appendix C of this section. The employer shall provide the opportunity for the employee to discuss the employee’s health status with the physician or other licensed health care professional. The employer shall pay for the medical evaluations required by this paragraph. A physician or other licensed health care professional who performs the medical evaluations shall be a person (e.g., employee of the employer or employee of a contractor) who is: (i) Physiologically able to perform the required duties as determined by a licensed health care professional; and (ii) Sufficiently knowledgeable about any medical conditions that would impair the employee’s respiratory function."
Failure to Training and Evaluate
While OSHA does not specifically dictate the required number of hours for training, employers must show compliance to hazardous rescue operations through proper training of their confined space rescue teams and the effectiveness of such training through performance evaluations. Confined space entry operations are dangerous, and having a properly trained and equipped rescue team is critically important for the safety of workers. A thorough assessment conducted by experienced industrial safety trainers and rescue trainers will ensure both adequate planning and training.

Rescue Training Required Elements

An effective confined space rescue program should, at a minimum, cover the following core elements.
Use of Equipment and Personal Protective Equipment
Rescue training can range from one day to five days, with a variety of topics covered. The training topics for Recovery Personnel may include OSHA’s Permit-Required Confined Space regulation (the "Confined Space Rule"), site layout and hazards, roles of trained personnel and the emergency entry team, use of equipment and personal protective equipment ("PPE"), decontamination, medical evaluation and fitness for duty, standby and entry rescue personnel qualifications, and rescue procedures. As discussed below, the safe use of equipment by recovery personnel is critical to a successful and safe rescue.
Hazards
Common hazards may include, among other things, the following: The rescue plan should include information on these common hazards, as well as any hazards unique to the facility or situation.
Equipment
The rescue plan should include information pertaining to the types of equipment available to rescue personnel (such as retrieval systems, hoists, winches, respiratory protection, air supply systems, and monitoring equipment) and should describe how it is to be used.
Decontamination Procedures
The recovery plan should describe the decontamination procedures that will be used for personnel and equipment used in a medical emergency and/or in a contaminated space. If contaminated space is involved, the recovery plan should specifically describe: The recovery plan should also cover post-entry decontamination procedures, such as how and where to wash and clean equipment after teams leave the area.
Medical Evaluation and Fitness for Duty
The rescue plan should specify whether rescue personnel are required to undergo medical evaluations and physicals, how often, and what aspects of fitness for duty are tested and evaluated. The Occupational Safety and Health Administration ("OSHA") Confined Space Rule requires such evaluation and testing, and employers must generally ensure that entrants and rescue personnel are qualified, fully trained, and fit for duty. Supervisory personnel should also be qualified and trained, although the Confined Space Rule does not require medical examinations for supervisory personnel. For the most part, rescue personnel must have an opportunity to observe the space, know the hazards confront the entrant, and wear the appropriate PPE, including respiratory protection when needed.
Standby and Entry Rescue Personnel Qualifications
The rescue plan should address rescue personnel’s requirements for qualification. The rescue plan should also specify how the Rescue Personnel will be treated if an actual emergency occurs, and how the personnel will communicate during the emergency. Personnel entering the confined space must have a method of communication (e.g., radios). The qualification program should require that personnel are knowledgeable about both permits required for entering permit-required confined spaces and the operation of any equipment that will be used during the rescue, including breathing equipment. OSHA has determined that employers are to require such familiarity and training particularly for personnel who will use complex equipment or equipment that is unfamiliar to them or to the space. Employers should also ensure that personnel are familiar with the potential hazards of the space being entered, and are knowledgeable about the specific hazards there. OSHA has found that employers are to ensure that rescue personnel understand the nature of each potential hazard in the space, and are familiar with and able to operate all equipment required for rescue personnel to deal with the potential hazards of the space.

Types of Emergencies in Confined Spaces

Workers performing confined space operations may encounter a variety of emergencies that require rescue. The truth is that workers will experience emergencies in a confined space regardless if it is planned for or not. Depth of the emergency will solely depend on the severity of the emergency and the overall exposure factors to the worker. When you consider rescue training for confined space, it is important that a wide range of potential emergencies be considered when determining the program content necessary.
Confined Space Entry Emergencies:
Here are just a few of the many potential emergency situations that could occur in a confined space;
Near Suffocation
Heart Attack
Stroke
Unconsciousness
Seizures
Fainting
Skin or Eye Burns
Deep Cuts
Shocking
Lacerations
Falls and Other Injuries
Fire and Smoke
Explosions
Choking
Fires
Smoke
Toxic Gas Exposure
Liquid Exposure
Sudden Pressure Changes
Loss of Power
Chemical Spills
Floods
Water In Flow
Slips and Falls
Grain Entrapment
Asphyxiation
Asphyxiation is defined as the loss of consciousness or life due to insufficient oxygen or build up of dangerous gases in the small, enclosed space. The lack of oxygen in many confined spaces can pose one the greatest threats to workers. Invisible dangers such as toxic gas, dust or fumes can accumulate rapidly and expose workers at a moment’s notice causing possible injury or death. Rescue training for this type of emergency is crucial to preventing additional injuries when an atmospheric hazard is present during an entry or escape attempt.
Loss of Consciousness
Loss of consciousness is defined as the state or fact of no longer having awareness. Loss of consciousness is often referred to as fainting. During a confined space entry, a worker may suffer a loss of consciousness due to a heart attack, stroke, seizure, exposure to toxic gas, panic attack, etc. Rescue training prepares the rescuer to understand how to account for the cause of a loss of consciousness when preparing for a rescue. For example; an atmosphere hazard may have exposed the victim to a lethal amount of a toxic gas in the confined space. In a situation like this, a rescuer would need to ensure that they have the necessary PPE to enter the confined space for rescue.
Exposure to Water in Confined Space
Exposure to water in a confined space can lead to drowning. Simply having a confined space flooded with water can expose a worker at any time while performing work in a confined space. A rescuer who has been trained in performing a confined space water rescue will have the skills necessary make a safe and successful rescue.
Exposure to Electric Shock
Basement spaces, pits, silos or other enclosed places may have live electrical exposure which can electrocute an unsuspecting worker performing work in the confined space. In like fashion, rescue training will provide information and skills to both the worker and rescuer to protect themselves from shock and prevent a secondary victim on the rescue.
These are just a few of the many types of potential emergencies that workers will experience while performing work in a confined space. It is important to remember that the Emergency Response and Rescue Program (ER&R) outlined in OSHA Subpart J will help to prepare the worker and rescuer to tackle the threats faced by workers in confined spaces. While performing confined space EMS training for employer required training, it is important to keep in mind that the most common threats will be loss of consciousness, electrical shocks and water exposure.

Who Requires Special Confined Space Rescue Training

Three groups of people are affected by confined space rescue training requirements. The first group is those who are required to be trained in the process such that they are fully competent in rescue. These are what OSHA considers the "rescue service". Originally, the regulation made no distinction between rescuers and employees exposed to confined space entry. This resulted in a very cautious interpretation by some employers who simply took the position that everyone working near a confined space had to be fully trained in rescue, which was unmanageable in many circumstances.
When more clarity was brought into the regulation by OSHA in 2001, this was further clarified. OSHA included in the preamble to the revised confined space standard a lengthy discussion of rescue versus non-rescue personnel, referencing OSHA’s general directory on assisted rescues, safety and health programs, and general duty requirements. The agency concluded that employers conducting rescue must consider the nature of their business , size and organizational structure and "the level of competence necessary to implement a rescue program and conduct an effective rescue. We believe that in many circumstances, those qualified to perform such activities are fire departments or other specialized rescue services."
So, the first group requiring training in rescue is personnel assigned full-time to the rescue of employees in permit-required confined space. The second group is personnel who require training in confined space entry operations when the employer has chosen not to have a rescue service on site. These are group employees who may be exposed to confined space hazards, including lone workers and manufacturing and construction personnel. Although the employer does not have to arrange a formal rescue service, under the regulation those with rescue responsibilities must be trained and equipped to perform non-entry rescue, while notifying and summoning a rescue service in the event of an emergency. Finally, supervisory personnel must be trained in hazards of confined space entry operations so they can recognize confine space hazards and avoid exposing workers to those hazards.

Assessing & Choosing Rescue Training Programs

There are many factors to consider when evaluating available confined space rescue training programs. It is important that these programs have been developed by certified or accredited organizations, as this will help ensure that the training will meet or exceed the minimum required training component conduct by the sponsor.
When evaluating potential organizations that offer confined space rescue training, it is very important to pay particular attention to the sponsor’s accreditation. There are several recognized accreditations bodies that are highly regarded within the rescue and emergency response community; I would suggest that you look for organizations accredited with one of these three agencies:
However, in assessing a training organization, it is equally important to verify their instructor’s experience and qualifications pertaining to confined space rescues, Kecius et al. (2014) reported in the Journal of Emergency Medical Services (JEMS), "…when hiring rescue trainers seek out individuals that are certified or credentialed as a rescuer."
Confined space rescue trainers should be from the fire service, EMS, private industry, or a noted academic institution. In addition to verifiable certifications and or credentials, confined space rescue trainers should be able to exhibit a broad depth of field experience in all areas of emergency response. Organizations that are accredited by the ANSI-ASQ National Accreditation Board under the scope for training development are also highly recommended.

Staying Current with Ongoing Training

In addition to initial training, OSHA and other regulatory agencies require ongoing education or re-certification of confined space entry personnel. Recertification is required on a regular schedule, and additionally, the standard requires that employers refresh the training of all confined space entry personnel whenever the employer has reason to believe there are deviations from permit space entry procedures, or when there are changes in permit space operations that might result in a hazard.
It is clear that OSHA wants employers to have well-trained participants in their confined space programs. This does not mean just that employees attend hundreds of training classes, but that the training they get is truly effective and applicable to their job functions. As noted above, OSHA requires periodic retraining in the space, and where changes occur, employees receive additional training at that time.
Having a quality training program that continuously educates employees about potential hazards and equipment, creates a culture of safety. If employees are knowledgeable about, and involved in, safety efforts in the workplace, they are likely to pay attention to process safety when entering confined spaces .
Here is a great example of the value of ongoing training programs for all confined space personnel. One program provided by OSHA, which was developed in conjunction with the American National Standards Institute (ANSI), is the Confined Space Entry Program from the American Society of Safety Engineers (ASSE). This program has been in place for over 60 years, going back to 1947. It is available through eLearning; the format is two hours per lesson, followed by an online assessment. Any employee who successfully completes the training will receive a free certification.
OSHA recently updated its online training guidelines, which have been in place for almost a year. The changes include additional guidance on how to better evaluate training and assessment programs. The guidelines encourage organizations to include serious accidents, incidents, and how employers can meet safety expectations, while providing employees with resources to assist them in their safety endeavors. Employers may want to include similar materials in their own training programs.
Thorough initial training combined with ongoing training and re-certification, in addition to the use of solid educational tools, results in a very well-trained and skilled work force, which is the goal of every employer.