You’ll spot them everywhere – from a local utility company working in your neighborhood to your workplace at an industrial or manufacturing facility during construction. It’s way too common to see an open trench unattended and unprotected. And, as we know, it’s only a matter of time until it collapses.

More and more of our customers are asking questions to address safety-related concerns. For example, who’s signing off on the trench project? Is the person you have signing off that a trench is constructed properly and safe for entry trained to know what to look for? Do they have the authority to act (competent person), or are they assuming that the contractor is “doing the right thing”? It is all too common that supervisors are signing off on trench permits without having any trench safety training or experience. Therefore, they cannot be considered competent persons.

Of course, this is troubling. It’s troubling due to the hazards involved and the personnel who will be entering the trench. A trench collapse happens in seconds, making an escape very unlikely once the soil starts moving. Due to the weight of the soil and the speed of the collapse, most do not survive.

Trench safety starts with the Competent Person. If none are available, who is watching out for the safety of the entrants? Not just anybody will do. According to 1926.650(b), the Competent Person is “one who is capable of identifying existing and predictable hazards in the surroundings, or working conditions which are unsanitary, hazardous, or dangerous to employees, and who has authorization to take prompt corrective measures to eliminate them.” Who on your site is responsible for this? Do they have the authority to correct hazards immediately?

Hopefully, we’ve convinced you of the importance of a trained and experienced Competent Person. Now, what about rescue in case the worst does happen? You’ve got an extremely hazardous situation – is your rescue service prepared for this? Your emergency response team may be trained for most emergencies, but what about this one?

Trench is one of the most dangerous rescue disciplines. It requires special knowledge, such as soil classification, hazard analysis and mitigation, understanding tabulated data, and the proper installation of shoring and shielding systems, just to name a few. It also requires specialized equipment that many response organizations simply don’t possess. This seems to be true for most municipal and industrial teams. With specialized training and equipment required for safe operations, it’s a commitment that most rescue teams just can’t make.

With trench rescue, timeliness is everything. Although it is often a slow and tedious process, proper training and equipment can be the difference between a rescue and a body recovery. Don’t ignore this hazard that may be located on your street or worksite. Take a careful look around, we think you’ll be surprised with the number of trenches and excavations that are occurring on a daily basis.

Did You Know?

After researching many of the questions we have received concerning trench operations, we came across this OSHA Letter of Interpretation that was reviewed most recently on November 8, 2018.
Note: It is always important to review all standards and regulations in their entirety.

Here are some excerpts:

1. Can workers enter a trench with water accumulation if the workers are protected from cave-in by shoring, shields or sloping, and the water level is controlled?

Paragraph .651(h) of 29 CFR 1926 allows workers to work in a trench with water accumulation, provided adequate precautions have been taken to protect employees against the hazards posed by water accumulation. The precautions necessary to comply with the standard vary with each situation, and the precautions you listed, such as additional shoring and control of the water level may not, in all cases, provide the required employee protection. 

2. The Stairways and Ladders Standard requires that a stairway or ladder shall be provided at points of access where there is a break in elevation of 19 inches or more. The Excavation Standard requires a ladder or other means of access and egress when the trench is 4 feet or more. Which of these requirements is applicable to trenching operations?

Be advised that since the specific excavation standard also addresses means of access and egress, the more general requirement in the stairways and ladders subpart is not applicable. A ladder, stairway, ramp or other safe means of access is required only when the trench is four feet or more in depth. Paragraph 651(c)(2) also states…as to require no more than 25 feet (7.62 m) of lateral travel for employees.

3. Must rescue equipment be available at every trenching jobsite that is located near or passes by a gas station, refinery, gas line, sewer main, etc.? Can a contractor rely on the local rescue squad since they are probably better equipped to handle a rescue?

Emergency rescue equipment is required to be readily available where a competent person determines, based on the conditions at each jobsite, that hazardous atmospheric conditions exist or may reasonably be expected to develop during work in an excavation.

In regard to whether a contractor can rely on a local rescue squad instead of providing the rescue equipment, please be advised that many emergency situations associated with the hazards involved with hazardous atmospheres in trenches would normally require an immediate response within a few minutes or even seconds.

A rescue squad would be unable to provide the necessary response and therefore could not be used to comply with 1926.651(g)(2).

4. If a contractor has several of the same make and model trench shields at a jobsite, does he have to have separate manufacturer's tabulated data on hand for each specific shield? We have been told that the shields and the data sheets must have the same serial number in order to be in compliance.

Be advised that only one set of tabulated data is required for each different shield design. If a contractor uses several shields of the identical make and model, only one set of tabulated data would be required for them.

5. Do excavations greater than 20 feet have to be designed by an RPE (Registered Professional Engineer) or can manufacturer's tabulated data be used in lieu of an RPE? For example, a contractor may have boxes rated for depths greater than 20 feet.

Protective systems that are designed using a manufacturer's tabulated data can be used in trenches deeper than 20 feet provided the use is within the limits of the data, including depth limitations and soil type. It should be noted that all tabulated data, by definition (1926.650), must be approved by an RPE.

6. We clearly understand that a ladder has to be secured, but we are not sure how. Contractors have informed us that compliance officers have told them that they cannot secure a ladder to the shoring system or in some cases the trench shield. These same contractors have been told to secure the ladder by driving a stake into the ground and to tie the ladder off to the stake. This alternate method presents three different problems: 1) It is not always possible to drive a stake through concrete or asphalt sidewalks or pavement; 2) This method creates a tripping hazard next to the trench; 3) Some contractors believe that driving a stake could create a stress crack. Please clarify these requirements for us?

Paragraphs 1926.1053(b)(6) and (7) address ladder footing displacement which is not normally a problem in trenches. If a ladder needs to be secured against tipping, it may be secured to a shield or member of a protective structure provided the ladder does not alter the effectiveness of the protective system.

7. Does the competent person have to be standing by the trench at all times during the work shift or can he/she go off site for short periods of time, such as lunch, meeting, or maybe to pick up supplies at the local builder’s supply store? Can the competent person move around the jobsite away from the trench? Often the foreman is the competent person and he may have other responsibilities at the jobsite.

It is not normally necessary for a competent person to be at a jobsite at all times. However, it is the responsibility of a competent person to ensure compliance with applicable regulations and to make those inspections necessary to identify situations that could result in possible cave-ins, indications of failure of protective systems, hazardous atmospheres, or other hazardous conditions, and then to ensure that corrective measures are taken. Consistent with these goals, the competent person may perform other duties.

8. Must an RPE approve all work when digging below a footing, foundation, retaining wall, sidewalk or pavement? We recognize the need for an RPE to design a system to support buildings and structures. However, we don't agree that an RPE is needed to layout a system to support sidewalks, pavement, and in some cases small structures like a small retaining wall. It is often very difficult to find an RPE who is willing to take on small incidental projects.

An RPE approval is not required when the excavation is not "reasonably expected to pose a hazard to employees." In situations where it is reasonably expected to pose a hazard, an RPE approval is not required when a support system, such as underpinning, is provided to ensure the safety of employees and the stability of the structure, or the excavation is in stable rock.

9. At what point and under what conditions would OSHA consider a trench a confined space?

Under normal circumstances, a trench would not be considered a confined space. The excavation standards address the hazards associated with employees entering potentially harmful atmospheres by requiring atmospheric testing and controls where hazardous atmospheres exist or could reasonably be expected to exist.

10. Some compliance officers are telling contractors that they must use a penetrometer or shearvane to estimate the compressive strength of soil and that the thumb test is unacceptable. Keeping in mind that these are field tests. We realize that the thumb test is not accurate, but neither is the penetrometer that many compliance officers swear by. What is OSHA's interpretation for using a thumb test versus an instrument?

Be advised that the thumb penetration test is one of the acceptable methods of estimating soil compressive strength. The compressive strength can be determined by laboratory testing, or estimated in the field using a penetrometer, shearvane, thumb penetration tests, as well as by other methods.

Source: OSHA Letter of Interpretation: Construction standards addressing excavations (reviewed November 8, 2018)

Additional Resources

If you’re concerned that your rescue service may not be adequately prepared, give us a call or check out these resources for more information on how to keep you and your personnel safe around trenches.

Trench Safety & Rescue Articles: Read More

Trench Training: Competent Person | Trench Rescue Technician

Firefighters perform rescues every day in many different situations. These two incidents this month show how regular training sessions ensure the success of dangerous rescues.

12/1/2021 – Broward County, Florida Rope Rescue

Two workers on a suspended platform required rescue after the platform partially collapsed. One worker was suspended from the dorsal attachment of his fall protection harness and the other was partially entangled in the teetering platform approximately 70 feet above the ground.

Broward Sheriff Fire Rescue responded and first lowered a rescuer down to perform a line transfer, or “pick-off”, and lowered the pair the rest of the way to the ground. The second worker was disentangled from the platform and lowered using the aerial (ladder truck).
Source: WVSN 7 News, Miami

12/21/2021 – Atlanta, Georgia Confined Space Rescue

A worker fell almost 20 feet into an underground ventilation shaft. Atlanta Fire Rescue lowered a firefighter into the shaft to assess and package the injured worker, who was alert and complaining of leg pain. He was then raised from the shaft in a Stokes basket using a TerrAdaptor tripod.

Source: Fox5, Atlanta

Additional Resources

Roco’s Quick Drills focus on tasks like patient packaging, tripod use, building anchors and setting up safe and efficient systems.

Roco Videos demonstrate patient packaging techniques, mechanical advantage systems, and more.

Confined spaces continue to present fatal hazards to workers, and OSHA continues to take notice. While OSHA lists fewer confined space accidents in 2021 than in 2020, 100% of them involved fatalities. the following summaries are from OSHA News Releases. These tragedies serve as reminders to employers and rescuers of the inherent dangers involved in confined space entry. Don't take chances when confined spaces are involved – the cost is simply too high.

8/2/2021 Dallas – Initiative to Protect Workers from Confined Space Dangers¹

OSHA Regional Emphasis will target the transportation tank cleaning industry in Texas, Oklahoma, Arkansas, and Louisiana.

This special initiative is designed to focus on industries involving tank cleaning activities, including trucking, rail and road transportation, remediation services, material recovery and waste management services. Transportation tanks on trucks, trailers or railcars require cleaning and inspecting before they are refilled for transport. The workers who clean these tanks risk exposure to toxic vapors from chemicals, decaying crops, waste and other substances, and to asphyxiation, fires and explosions.

The agency reported that a worker cleaning the inside of a tank trailer in Pasadena, Texas, in December 2019 fell victim to hazardous vapors, as did a co-worker who attempted rescue. Then, in August 2020, two workers entered a natural gas tanker on a railcar in Hugo, Oklahoma, and fell victim to its vapors (see the 2/10 release below). Due to these incidents, four lives were lost in the tank cleaning industry in less than a year – a troubling trend of preventable workplace deaths in the region.

“Too often, employers allow workers to enter tanks without testing atmospheric conditions, completing confined space entry permits or providing adequate respiratory protection,” said OSHA Regional Administrator Eric Harbin.

8/2/2021 Chicago – Initiative to Protect Workers in Tank Cleaning Industry from Atmospheric, Confined Space Hazards²

OSHA Regional Emphasis was issued for the Midwest after multiple deaths occurred in tank trucks. The report listed two examples of instances:

• A worker tasked with cleaning a chemical tank trailer collapsed upon entering the tank. Hearing the employee’s call for help, a nearby truck driver entered the tank. Both succumbed to fatal toxic fumes.
• A worker opened the lid of a tanker trailer containing toluene and was found a short time later lying across the open dome and unresponsive. He survived after being treated at a local hospital for respiratory failure and cardiac arrest.

OSHA Chicago reported that 23 deaths and 97 incidents have occurred in the region since 2016. The most common violations included the failure to prevent inhalation of harmful substances and to follow procedures for permit-required confined spaces.

7/23/2021 Georgia – Six Preventable Confined Space Deaths at Poultry Processing Plant³

On January 28, 2021, six workers went to work at a poultry processing plant unaware that they would not be returning home. Just after their shift began, a freezer malfunctioned, releasing colorless, odorless liquid nitrogen that displaced the oxygen in the room.

Three maintenance workers entered the freezer room without precautions – never trained on the deadly effects of nitrogen exposure – and were overcome immediately. Three other workers entered the room and were also overcome. Five of the workers died immediately, a sixth died on the way to the hospital. At least a dozen other workers needed hospital care.

Of the numerous violations, the company failed to perform a hazard assessment for exposure to liquid nitrogen and also failed to implement a permit-required confined space program for workers who entered the freezer. In addition, they did not notify contractors who are required to work inside the liquid nitrogen freezer that it was a permit-required confined space.

3/29/2021 Ohio – Production Facility Cited for Exposing Employees to Dangerous Confined Spaces and other Hazards⁴

A January 2021 investigation found that machine operators and maintenance employees entered powder-coated ovens routinely without testing atmospheric conditions or securing natural gas lines and operating machine parts. The company also exposed workers to multiple safety and health hazards by failing to designate the ovens as permit-required confined spaces. The employer also failed to isolate natural gas lines and mechanical energy, i.e., lockout/tagout.

“Confined spaces often expose workers to atmospheric and mechanical hazards,” said OSHA Area Director Ken Montgomery. “OSHA has specific regulations for implementing required training and safety procedures to protect workers who must enter confined spaces, including atmospheric testing and ensuring equipment and energy sources are disabled before workers enter these spaces.”

2/10/2021 Oklahoma – Two Confined Space Deaths at Railcar Company⁵

Here is additional information concerning a railcar incident that was mentioned in the August release above.

A worker entered a natural gas railcar for cleaning on August 12, 2020. He became unresponsive shortly after entering the tank. A second employee entered the space and was also overcome in an attempt to rescue the fallen worker. Both workers were eventually recovered and later pronounced dead at a local hospital.

OSHA found that the company failed to require a permit to allow entry into the railcar, ventilate the space, monitor hazards inside the space and complete entry permits for work inside a confined space. The company was cited for 11 serious violations and two willful violations.

“Work inside confined spaces is a dangerous job and federal workplace safety standards must be followed to avoid disaster,” said OSHA Area Director Steven Kirby. “As is the case here, failing to follow OSHA standards can be the difference between life and death.”

Additional Resources

• Attendant Safety Requirements Poster (pictured here)
• Confined Space Entry Checklist
• Common Causes of Confined Space Fatalities
• Limitations of Atmospheric Monitors

As you're planning for your annual OSHA compliance, maintaining certifications, or training new rescue team members, take a look at our 2022 Open Registration dates. And if you're planning training for your whole team, get a quote for a private course.

See typical course progressions on our Paths Chart:

First of all, don’t let the jargon “hole watch” fool you. The attendant’s role is key to the safety of the entry operation, and especially for the entrants inside the space. Lives are literally on the line – including the attendant’s if a bad decision is made to enter the space.

As you can see from the graphic, the hole watch (attendant) is the “eyes and ears of safety” and a crucial part of the Safe Entry Team. This position is critical to watching out for the entrants and recognizing the need for calling emergency services – and, of course, the quicker the better. One more reason the position of hole watch cannot be taken lightly.

It is also the responsibility of the employer or entry supervisor to make sure that the attendant receives adequate training prior to the entry. The attendant needs to be capable of monitoring the entrants and reacting properly in an emergency. This may include the operation of retrieval systems should evacuation become necessary.

If there are any changes to the entry operations, the attendant may require additional training depending on the hazards. Re-training is also required if there are any deviations from the permit space procedures – or if the employer feels the attendant is inadequately prepared.

Hole Watch is critical for entrant safety and knowing when to call emergency services–and, of course, the quicker the better.

As a reminder, employers or entry supervisors are required to…

• Provide the support that attendants need to fulfill their role.
• Provide informational resources concerning the hazards or potential hazards.
• Provide the necessary equipment and training as required.
• Determine if the attendant will be authorized to perform non-entry rescue (retrieval) and clearly communicate this to the attendant.

“Do’s and Don’ts” for the Confined Space Hole Watch

Diligence is critical for the hole watch or attendant. It’s a very important position. Pay attention and know your job! Here are a few “Do’s” and “Don’ts” to remember if you’re assigned the task of hole watch.

"Do's" for the Confined Space Attendant:

“Don’ts” for the Confined Space Attendant:

Hole Watch: A Crucial Connection

Once again, we can’t overemphasize the importance of the attendant or hole watch. Don’t take this position lightly. These individuals are the first line of protection for those inside the space. When selecting an attendant, make sure they are capable of handling the responsibilities of the job. They should be trained and prepared to act in an emergency. The timeliness of their response is crucial to the safety of the entrants. Failure to properly perform these duties has led to multiple fatalities – both for the entrants and the attendants themselves.

Additional Resources

• Attendant Safety Requirements Poster (pictured here)
• Confined Space Entry Checklist
• Common Causes of Confined Space Fatalities
• Limitations of Atmospheric Monitors