Confined Space Entry Requirements for ICI Contractors#

Executive Summary#

Confined spaces—areas large enough to enter but not designed for continuous occupancy—present serious hazards including atmospheric dangers, engulfment, and restricted entry and exit. OSHA's confined space standards require employers to identify confined spaces, evaluate hazards, and implement specific procedures before entry. For ICI contractors whose work may involve tanks, vessels, ducts, or other confined areas, understanding these requirements is essential for worker safety and regulatory compliance.

The Context for ICI Subcontractors#

ICI work may require entering confined spaces: insulating tanks and vessels, working inside ductwork, accessing pipe chases, or working in mechanical rooms with restricted access. These spaces may contain atmospheric hazards, physical hazards, or conditions that could trap or engulf workers.

Confined space incidents can be fatal. According to OSHA, confined space hazards cause multiple fatalities annually—often including rescuers who enter without proper preparation. The regulations exist because the hazards are real and the consequences severe.

Regulatory Framework#

OSHA Standards#

OSHA has two primary confined space standards:

General industry: 29 CFR 1910.146 covers permit-required confined spaces in general industry.

Construction: 29 CFR 1926 Subpart AA covers confined spaces in construction.

The construction standard, effective since 2015, addresses the specific conditions of construction work where confined spaces may be created during construction, conditions change as work progresses, and multiple employers may share responsibility.

What Is a Confined Space#

A confined space has three characteristics:

1. Large enough to enter: A worker can bodily enter and perform work

2. Limited entry and exit: Not designed for continuous occupancy; restricted means of entry or exit

3. Not designed for continuous occupancy: Built for purposes other than human occupancy

Examples include tanks, vessels, silos, storage bins, hoppers, vaults, pits, manholes, tunnels, ducts, and pipelines.

Permit-Required Confined Spaces#

A permit-required confined space is a confined space that has one or more of these hazards:

Hazardous atmosphere: Oxygen deficiency or enrichment, flammable gases, toxic substances

Engulfment hazard: Material that could engulf an entrant (grain, sand, water)

Configuration hazard: Inwardly converging walls or floor that could trap an entrant

Other recognized hazards: Any other serious safety or health hazard

Most confined space requirements focus on permit-required spaces because of their elevated hazards.

Employer Responsibilities#

Space Identification#

Before work begins, employers must:

Identify confined spaces: Determine which spaces at the worksite are confined spaces

Evaluate hazards: Assess whether confined spaces contain hazards making them permit-required

Communicate: Inform workers about confined spaces and their hazards

Written Program#

For permit-required confined space entry, employers must have a written program that includes:

• Measures to prevent unauthorized entry
• Identification and evaluation of hazards
• Safe entry procedures
• Equipment requirements
• Attendant duties
• Entry supervisor responsibilities
• Rescue and emergency procedures
• Review procedures after entries

Coordination (Construction-Specific)#

The construction standard emphasizes coordination among multiple employers:

Host employer: Controls the worksite; must provide information about confined spaces

Controlling contractor: Has overall responsibility for construction; coordinates entries

Entry employer: Directs workers entering confined spaces; implements entry procedures

Each has specific duties to ensure safe entry.

Entry Procedures#

Before Entry#

Before any permit-required confined space entry:

Entry permit: Complete and authorize an entry permit documenting conditions and precautions

Atmospheric testing: Test atmosphere for oxygen, flammable gases, and toxic substances

Hazard elimination or control: Eliminate hazards where possible; control remaining hazards

Ventilation: Provide ventilation if atmospheric hazards exist or may develop

Isolation: Isolate the space from energy sources, material inputs, and other hazards

Equipment: Ensure required equipment is available and functional

Atmospheric Testing#

Atmospheric testing is critical:

Test before entry: Confirm safe atmosphere before anyone enters

Test during entry: Continue testing while workers are in the space

Calibrated equipment: Use properly calibrated testing equipment

Testing sequence: Test for oxygen first, then combustibles, then toxics

Acceptable levels:

• Oxygen: 19.5% to 23.5%
• Flammable gases: Below 10% of lower explosive limit (LEL)
• Toxics: Below permissible exposure limits

During Entry#

While workers are in the confined space:

Attendant: A trained attendant must remain outside the space, monitoring entrants and conditions

Communication: Maintain continuous communication between entrant and attendant

Continuous monitoring: Continue atmospheric monitoring

Emergency readiness: Rescue equipment and procedures must be ready

Permit maintenance: Entry permit must be maintained at the entry point

Entry Permits#

Entry permits must document:

• Space to be entered
• Purpose of entry
• Date and authorized duration
• Hazards present
• Methods of hazard control
• Acceptable entry conditions
• Test results before and during entry
• Communication procedures
• Rescue procedures
• Names of authorized entrants, attendants, supervisors
• Entry authorization signatures

Permits must be reviewed and canceled after entry is complete.

Roles and Responsibilities#

Entry Supervisor#

The entry supervisor:

• Authorizes entry by signing the permit
• Verifies procedures are in place
• Terminates entry when conditions change or problems arise
• Ensures rescue services are available

Attendant#

The attendant:

• Knows hazards including signs of exposure
• Maintains count of entrants
• Remains outside the space throughout entry
• Monitors conditions inside and outside
• Communicates with entrants
• Orders evacuation when necessary
• Summons rescue services when needed
• Does not enter the space (except with proper equipment and backup)

Authorized Entrant#

Authorized entrants:

• Know hazards and signs of exposure
• Use equipment properly
• Communicate with attendant
• Alert attendant to hazards or symptoms
• Exit when ordered or when conditions warrant

Training Requirements#

Who Needs Training#

Anyone involved in confined space entry needs appropriate training:

Entrants: Hazard recognition, equipment use, communication, self-rescue

Attendants: Duties, communication, emergency response, non-entry rescue

Entry supervisors: Overall procedures, permit system, hazard assessment

Rescue team members: Rescue techniques, equipment, first aid

Training Content#

Training must cover:

• Duties specific to the worker's role
• Hazards of the specific spaces
• Equipment operation
• Emergency procedures
• Permit system

Training Documentation#

Maintain records of:

• Who was trained
• When training occurred
• What training covered
• Trainer qualification

Retraining is required when:

• Job duties change
• Space hazards change
• Inadequacies in entry procedures are found
• Workers need refresher training

Rescue Requirements#

Rescue Planning#

Before entry, rescue must be planned:

Rescue method: How will entrants be rescued if necessary?

Rescue team: Who will perform rescue? Internal team or external service?

Equipment: What equipment is needed and is it available?

Response time: Can rescue team respond quickly enough?

Non-Entry Rescue#

Where possible, plan for non-entry rescue:

Retrieval systems: Harnesses and retrieval lines that allow extraction without entering

Positioning: Anchor points and equipment positioned for retrieval

This protects rescuers from becoming victims themselves.

Rescue Team Requirements#

If rescue may require entry:

Training: Rescue team must be trained in rescue procedures

Equipment: Team must have necessary equipment (respirators, retrieval equipment)

Practice: Team must practice rescue operations

Medical capability: First aid and CPR capability

External Rescue Services#

If using external rescue services:

Availability: Confirm they are available and can respond in time

Capability: Verify they have equipment and training for the specific spaces

Information: Provide information about spaces and hazards

Notification: Establish notification procedures

Documentation and Records#

Entry Permits#

Retain completed entry permits:

• Shows entries occurred with proper authorization
• Documents conditions and precautions
• Provides record if questions arise later

Training Records#

Maintain training documentation:

• Who is trained
• What roles they are qualified for
• When training occurred and when retraining is due

Program Records#

Document program elements:

• Written confined space program
• Space evaluations and hazard assessments
• Annual program reviews
• Incident investigations

How Appello Supports Confined Space Compliance#

Appello's Training & Compliance module can track confined space training certifications, ensuring workers assigned to confined space work have required training. The Safety & Forms module enables digital completion and retention of entry permits and related documentation.

By maintaining training records and capturing safety documentation, Appello supports the documentation requirements of confined space programs.

Conclusion#

Confined space entry involves serious hazards requiring specific procedures and trained personnel. OSHA standards establish requirements for identification, evaluation, entry procedures, and rescue planning that protect workers from confined space dangers.

ICI contractors whose work may involve confined spaces must understand these requirements, implement compliant programs, and ensure workers are properly trained. The investment in proper procedures protects workers from hazards that have proven fatal to those who enter unprepared.

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Related Reading:

• Certification and Compliance Requirements for ICI Contractors
• Toolbox Talks: Requirements and Best Practices