Perhaps the most commonly confused topic in confined space entry that I hear out in the wild is the difference between the terms entry and bodily enter. And it makes sense because, at face value, these two things sound incredibly similar. However, when we dig a little deeper and put into context, we’ll find out that they have two entirely different meanings and applications. So, let’s dive in!

To set the stage, let’s do a quick overview of the three characteristics that define a confined space. OSHA says that a confined space is a space that:

• Has limited means of access and egress, and
• Is not designed for continuous human occupancy, and
• Is large enough to bodily enter and perform work.

Remember that the space must contain all three characteristics for it to be considered a confined space. Notice the 3rd bullet point – large enough to bodily enter and perform work. We must be able to physically fit our body into the space and perform the assigned task. Now, the use of the term bodily enter stops with the definition.

Next, let’s look at what defines an entry. OSHA says an entry has occurred when any part of the entrant’s body breaks the plane of an opening into a confined space. Notice that making entry into a confined space does not necessarily mean entering with the whole body. In fact, only reaching your arm into the opening of the confined space constitutes an entry.

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"So, here’s the difference. The ability to bodily enter is one of the three characteristics that define a confined space, whereas the term entry is the action of breaking the plane with any part of the body – not necessarily the whole body."

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At this point, you may be thinking this is nothing more than semantics; however, this is an incredibly important differentiation.

When we understand that making entry into a confined space does not have to involve entering with our entire body, we may realize that workers in our area may have been making a lot more confined space entries than we realized. I’ve heard on numerous occasions and even seen it firsthand, where a worker sticks their arm in to turn valves or pokes their head in for a quick peek at something without going through the permit-required confined space entry procedure. After all, it’ll only take a second!

The reason this is important, and why it’s more than just semantics, is that even though a worker may be only just sticking their arm or head into a space, they could still be exposed to the hazards inside of that space. In some cases, that could have some serious consequences! For example, there may be exposed and activated rotating equipment inside of the space; so, sticking your arm or hand in may result in you being less handy around the worksite than you used to be! Alternatively, atmospheric hazards don’t just magically stop becoming hazardous right at the plane of the opening. The immediate area around the opening of the space could likely contain hazardous atmospheres as well. Sticking your head in for a quick look could be a fatal mistake.

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"The time you save isn’t worth your life."

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Understanding the difference between the two terms is critical for ensuring the safety of workers in and around confined spaces. The difference between the two carries significant weight, not only in definition but also in practical application. Knowing that crossing the opening of a confined space, even with just a limb, constitutes an entry and potential exposure to serious safety and health hazards is a basic fundamental concept that all workers should be well informed. So, the next time you think – I’ll just reach in and turn that valve or take a quick look – slow down and think! The time you save isn’t worth your life.

ONLINE REFERENCES:

OSHA 1910.146 PRCS

Chris McGlynn, M.S., CSP is a Certified Safety Professional and Nationally Registered Paramedic who serves as the Director of Safety and VPP Coordinator for Roco Rescue. He currently serves as Director-at-Large on the VPPPA Region VI Board of Directors and is past President of the American Society of Safety Professionals Greater Baton Rouge Chapter. Chris also represents ASSP on the ANSI Z117 Confined Space and Z390 Hydrogen Sulfide Training Standard Development Committees. He is also an active OSHA Special Government Employee within the Voluntary Protection Program.

 

Medical calls make up the majority of contacts with the public for emergency responders. Technical rescue calls make up a much smaller segment of emergency response. While the response numbers are at opposite ends of the response spectrum, they are invariably tied together.

Oftentimes, technical rescue responses originate after medical responders determine that their patient is in an untenable position. Other times, we just need more muscle than the people we responded with can muster. That is where one Western New York Ambulance Service melded EMS response with rope rescue ingenuity to provide a positive outcome for a 600-lb. bariatric patient.

Wellsville Volunteer Ambulance Corps takes the concept of self-sufficiency seriously. Located in rural western New York, 15 miles north of the Pennsylvania border, they are remote, but they know how to get things done.

In early August 2024, Wellsville was hosting Roco Rescue and Roco Chief Instructor Bob Kauer for four days of Rope Rescue and Confined Space training. At 4PM on the second day of class, EMS was dispatched for a man down in a residence. That call triggered a multi-faceted response as responders quickly learned that a 600-lb. man had been down on the floor since 9:30 the previous night. The race was on to get the patient in respiratory distress to definitive care.

While EMS responders started patient care, students from the Roco class quickly broke down rescue gear and loaded on to response vehicles. This included Roco Instructor Kauer who was happy to lend his experience and training to the response.

The first obstacle was getting the patient off the floor. He was unable to assist rescuers who were now faced with lifting the 600-lb. man. A stokes basket was brought into the living room where the man was located. A group of ten rescuers was able to slide four sheets under the patient, and a couple of additional pieces of webbing were positioned for better handling of the patient. The man was then lifted into the basket stretcher.

While responders were moving the man into the basket, rescuers were working to build a system to move the patient to the waiting ambulance. Chainsaws were fired up and the front door was rapidly converted to a garage door to make room. A support beam for the porch had to be removed, requiring rescuers to place spot shores under the porch to provide for patient and rescuer safety during the move. Ramps were built using plywood and 4” x 4” lumber to remove the stairs from the equation.

Meanwhile, outside the house, rescuers, including Chief Kauer, established an elevated anchor on a large tree. A CMC Clutch by Harken became the progress capture device in a 5:1 horizontal mechanical advantage system. Quickly extended into the residence, the system was attached to the top of the stokes basket and tensioned. The haul team began to move the patient in the stokes basket across the floor and the emergency ramp system they had constructed, which allowed the victim to slide straight onto the gurney.

The patient was loaded into the ambulance and delivered to the hospital for definitive care in less than an hour, which was excellent.

Roco extends our congratulations to Wellsville (NY) Volunteer Ambulance Corps for a well planned and executed rescue. Good job!!

When out in the field for a rescue stand-by job, one of the first things we do is track down the Confined Space Attendant (Hole Watch). At Roco, we've made it a priority to strike up a conversation with the attendant to establish rapport and ensure they understand the work being done, their knowledge of confined space operations, and their role on the “team.” In the confined space world, think of the attendant as the “quarterback” of a football team. Just like a quarterback, the attendant is the pivotal position in executing the entry supervisor’s game plan; which, in this case, is the safe and successful completion of the confined space entry.

Unfortunately, the “hole watch” is too often the low person on the totem pole or the greenest hand on site. Imagine you’re putting together a football team and deciding that the quarterback position is where you’re going to hide your least experienced player. You’ll lose more games than you win, I promise. This is exactly what happens at job sites all over the country every day. Workers get hurt and sometimes killed due to the lack of knowledge and experience in the attendant role.

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"Workers get hurt and sometimes killed due to the lack of knowledge and experience in the attendant role."

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Much like a quarterback receives a game plan from the head coach, the attendant takes their direction from the entry supervisor. It’s their job to understand the “plays”—the roles and responsibilities laid out by OSHA’s Confined Space Regulation (29 CFR 1910.146)—and to ensure that every part of the operation runs smoothly. The attendant isn’t just a passive player; they’re actively observing the situation, similar to when a quarterback reads the defense on the field.

Take, for example, atmospheric monitoring. Does an untrained person intuitively understand the risks of striated atmospheres? Would they understand how and when to calibrate or bump a monitor? Do they know how to avoid short circuiting or recirculating when using ventilation? They surely couldn’t navigate troubleshooting these situations without proper training. I’ve witnessed firsthand situations where a ventilation fan was placed too close to a bank of gas-powered welding machines, causing carbon monoxide levels inside the space to skyrocket. These normally “untold” stories are far too common and most certainly avoidable – most of us in the standby field have seen this type of misstep repeatedly.

When a quarterback steps up to the line of scrimmage and sees that the defense is set to shut down the play, they call an audible, or change the play. This quick switch could be the difference between a successful drive and a disastrous turnover. In the same way, a well-trained attendant has to be ready to make critical decisions on the spot. If the conditions inside or outside the space change, or if a hazard suddenly arises, the attendant must “call an audible” by ordering an evacuation and consulting the entry supervisor for an adjusted game plan. The confidence and training to pull off this maneuver has saved lives time and time again.

There was a situation about ten years ago where a skilled attendant was overseeing an entry into an underground vault where the entrants were installing a new valve. The attendant had been involved in shutting down and isolating the space, much like a quarterback, who’s been studying the defense all week. When it came time to re-pressurize the line, the attendant made a crucial call. He ordered the entrants to exit the space while the pipe was brought up to pressure, despite their protests that they needed to stay in to handle any potential leaks. It was the equivalent of calling an audible. The line ruptured, and the vault filled with water in a matter of seconds. The attendant’s decision saved lives—just like a quarterback’s quick thinking can turn a losing play into a game-winning moment.

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"The attendant’s decision saved lives—just like a quarterback’s quick thinking can turn a losing play into a game-winning moment."

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In both football and confined space operations, success hinges on the ability to execute a plan, adapt to changing conditions, and communicate effectively. The confined space attendant, like a quarterback, is much more than just a player in the game—they’re the key to making sure everyone gets out safely.

Learn More

 

Chris Warrick, NRP, is a Nationally Registered Paramedic, Confined Space Rescue Technician, and EMS educator who serves as Medical Program Manager at Roco Rescue. Most recently, he has taken on the added responsibility of Marketing Coordinator. Chris is an avid photographer and videographer, who spends lots of time at the Roco Training Center – where all of the action is. He also writes and publishes blogs on our website, RocoRescue.com. Between the two major responsibilities, Chris keeps very busy and enjoys his work.

The following fatality reports were summarized from recent OSHA News Releases (osha.gov).

CONFINED SPACE FATALITIES

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Welder Fatality in Confined Space

PALATKA, FL – As he had many other days, the morning shift welder arrived to work at 5 a.m. on Aug. 28, 2023. Tasked with doing some fabrication work in a 4-foot by 8-foot space in a ship’s hull, the employee began work unaware that fatal suffocation would soon end his life.

Less than two hours after entering the ship, a supervisor found the unconscious welder and signaled for help, only to fall unconscious as well. A third employee appeared, alerting EMS and the Palatka Fire Department, who soon transported all three workers to a nearby hospital. Despite emergency treatment, the welder died from a lack of oxygen. The supervisor and the third worker received medical treatment and were released.

OSHA inspectors determined that the shipbuilder exposed workers to oxygen deficiency by sending the welder into a confined space without first testing the air for oxygen content. The presence of welding gas in the space created an oxygen-deficient atmosphere.

"Following proper maritime industry protocols could have prevented this worker from losing his life," explained OSHA Area Office Director Scott Tisdale. "The ship building company must perform hazard assessments and implement safety procedures to ensure a tragedy like this does not recur. Every employer should make health and safety a core value in their workplaces."

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"Following proper maritime industry protocols could have prevented this worker from losing his life"

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The Bureau of Labor Statistics reports more than 1,030 U.S. workers died from 2011 to 2018 from workplace injuries related to confined spaces.

 

Fatality in Houston Tank Cleaning Incident

HOUSTON, TX – A La Porte tank cleaning company again chose to disregard federal safety standards that may have protected their employees from hazardous working conditions and prevented another employee from suffering a fatal injury. Just two days before Christmas, the wife and son of an employee at the company grew concerned when he didn't return after his shift. Later that day, he was found unresponsive.

A workplace safety investigation by the U.S. Department of Labor's Occupational Safety and Health Administration determined that the employer of the fallen worker had failed to ensure that atmospheric testing was done inside the tank before allowing the 53-year-old employee to enter it.

Even more tragically, the same company had been cited for the same violations four years earlier after two workers succumbed while cleaning inside a tanker truck.

"Had the company acted responsibly and made the safety reforms as required in 2020, another employee would not have lost their life," explained OSHA Area Director Larissa Ipsen in Houston.

In addition to identifying the company's failure to conduct required testing, OSHA cited the company for seven serious violations, including the following:

• Failing to implement measures to prevent unauthorized entry into a permit-required confined space.
• Not providing an attendant while employees entered permit-required confined spaces.
• Numerous failures related to the confined space entry permit, including:
• Not identifying the authorized duration of entry.
• Which rescue and emergency services are to be summoned?
• How to summon emergency services.
• Failing to specify personal protective, rescue, and communications equipment and alarm systems.
• Overexposing employees to carbon monoxide.
• Not protecting conductors that entered an electrical panel box from abrasions and leaving an electrical outlet without a cover plate.

"This employer's complete disregard for its employees' safety is unacceptable. Complying with safety and health standards is not optional,” added Ipsen.

 

TRENCH INCIDENT

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Fatal Trench Cave-In Investigation

BRIDGEPORT, CT – A concrete and earthwork contractor could have prevented an employee repairing an underground water line from suffering fatal injuries in a trench collapse at a work site but failed to follow federal safety standards for excavations.

Five employees were exposed to cave-in, engulfment, or struck-by hazards when the employer did not do the following:

• Provide cave-in protection for the more than 12-foot-deep vertical walled trench, which resulted in the death of an employee.
• Train employees on how to recognize and avoid trenching hazards.
• Ensure an excavator is kept more than two feet from the trench's edge.
• Verify the location of underground utilities and/or structures prior to excavation.

"Despite prior warnings, the company ignored trench safety protections, and that decision cost an employee their life," said OSHA Area Director Catherine Brescia in Bridgeport, Connecticut. "All employers should make workplace safety a priority or risk being responsible for leaving the family, friends, and co-workers of one or more of their employees to grieve this kind of preventable death."

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"Despite prior warnings, the company ignored trench safety protections, and that decision cost an employee their life"

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FATAL FALLS

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29-story Fall Fatality from Damaged Fall Pro & Rope Equipment

Employer’s failure to inspect and replace damaged fall protection equipment leads to a 29-story fatal fall…

BRAINTREE, MA – The U.S. Department of Labor has determined a window cleaning company's failure to inspect and replace damaged or defective equipment contributed to an employee's fatal 29-story fall from a building in downtown Boston's financial district in October 2023.

The department's Occupational Safety and Health Administration found that the employer willfully exposed employees to fall hazards by not ensuring personal fall protection systems and a rope descent system workers used were in proper working condition at the work site. Specifically, OSHA investigators learned the company had not inspected the rope and equipment adequately for damage and other deterioration and did not remove defective components from service before each work shift and replace them.

OSHA's investigation determined that the employer:

• Failed to adequately train employees on how to inspect ropes for maximum allowable wear, to recognize defects and conditions that warrant removal from service, and on proper use of the rope descent system. The ropes used in the rope descent systems were not effectively padded or otherwise protected to prevent them from being cut or weakened.
• Allowed the use of rope descent system ropes, lifelines, and lanyards for personal fall protection that were not compatible with connectors and unprotected from damage such as cuts and erosion.
• Failed to use only certified building anchorage for the rope descent system.
• OSHA cited the company for two willful, four serious, and two repeat violations and assessed $447,087 in proposed penalties, an amount set by federal statute.

"To ensure the safety of employees who work at heights, employers must make their responsibility to provide comprehensive training on inspecting rope descent systems and fall protection equipment and components before each use an absolute priority," said OSHA Regional Administrator Galen Blanton in Boston. "The U.S. Department of Labor will continue to hold employers accountable when they fail to take the necessary steps to protect their workers."

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"To ensure the safety of employees who work at heights, employers must make their responsibility to provide comprehensive training on inspecting rope descent systems and fall protection equipment and components before each use an absolute priority,"

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A Construction Worker Falls 23 Feet After Employer Neglects Equipment and Training

The worker’s fatal fall was preventable if the contractor had provided employees with fall protection equipment, training…

SYRACUSE, NY – A construction contractor could have prevented an employee’s fatal fall at a New York job site by providing adequate fall protection and training employees in its effective use, a U.S. Department of Labor investigation found.

OSHA Inspectors found that the contractor failed to provide the worker who was fatally injured and three other employees with effective fall protection, exposing them to falls of 23 feet as they replaced an aluminum standing seam roof on a building.

OSHA also determined that the company neglected to ensure that its employees were trained on fall hazards, in the use of personal fall arrest systems, and on the correct procedures for installing, maintaining, and inspecting the fall protection systems on site.

In addition, the employer designed, installed, and used fall protection systems at the worksite without the supervision of a qualified person, which was in violation of OSHA requirements. The limited fall protection systems in place were neither installed nor used correctly.

“Falls are the leading cause of construction industry deaths, and yet this company chose to ignore federal standards and exposed four employees — including the deceased — to this deadly hazard,” said OSHA Area Director Jeffrey Prebish in Syracuse, New York. “This led OSHA to cite and fine the company for the lack of fall protection on an instance-by-instance basis – one citation for each of the four exposed workers.”

“As is often the case in workplace falls from elevations, this tragedy could have been prevented had the contractor followed and maintained basic, commonsense, and legally required safeguards. Employers must commit to providing and using effective fall protection systems and equipment and training workers in their use,” added Prebish.

The Bureau of Labor Statistics reported 395 people died in workplace falls from elevation in 2022.

 

54-year-old Dies After Falling Through Unprotected Skylight

The employer allowed employees to work 19 feet high without protective harnesses…

ATLANTA – A five-man crew's first day working to remove tar and stone from metal roof panels at a Macon warehouse ended abruptly when a 54-year-old laborer tragically suffered fatal injuries after stepping on a skylight and falling about 19 feet.

A U.S. Department of Labor investigation found Georgia construction contractor could have prevented the incident by providing their employees with required fall protection.

An ambulance rushed the worker, who suffered severe injuries, to a nearby hospital, where they succumbed to their injuries hours later. In addition, the company failed to notify OSHA of the incident within the required 8 hours.

OSHA's inspection found the company failed to protect its employees by not using fall protection systems and leaving skylights without safety guardrails on the roof on the day of the fatal incident. Despite this tragic incident, agency inspectors once again found that the company allowed employees to work without these life-saving measures 2 months after OSHA was notified of the violations.

"After more than 20 years of experience as a roofing and framing contractor, the company should know the work its employees do is dangerous and potentially fatal, especially when safety protocols are ignored," said OSHA Area Director Joshua Turner. "Falls are widely known as the leading cause of death in the construction industry and had required fall protections been in place in this case, a worker's family, friends and co-workers would not be left now to grieve a terrible loss."

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"Falls are widely known as the leading cause of death in the construction industry and had required fall protections been in place in this case, a worker's family, friends and co-workers would not be left now to grieve a terrible loss."

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Fire Chief C.A. “Pete” Shelton

(1932-2024)

by Kay L. Goodwyn, President/CEO 

I was 20 years old when I walked into the Beaumont (TX) Central Fire Station to interview for an administrative job. I had actually applied with the City of Beaumont – and it just so happened the available opening was for Fire Chief C. A. Shelton and the Beaumont Fire Department. Fortunately, I was selected for the job, and as they say, “The rest is history.” 

Soon, Chief Shelton became my “forever boss” and lifelong mentor. He was everything you think of in a Fire Chief – he was a big man with a very commanding presence. And, when it came to the fire department and his beloved City of Beaumont, he was very serious and all business. He was tough, no doubt about it. And he wanted things (every-thing!) done right; and, of course, done immediately. He set the standards high for himself and everybody else within the department he loved so deeply.  

Chief was also very hands-on and involved in every aspect of the department – nothing missed his careful inspection. I saw how stressful his job was as the leader of a 240+ person department. And he lived it 24 hours a day. I watched him make many tough calls from that big desk as well as from the fire ground during a major emergency. But he always wanted to do the right thing in the right way, no matter what the task. 

During my first couple of years at the BFD, I fell in love with the fire service. I wanted to know everything about it – and Chief expected me to as well. My dad had been in the U.S. Forest Service, so I remembered when he had to occasionally go out to fires in the Piney Woods of Deep East Texas – and I especially remember the Smokey Bear coloring books he brought home! There has been a long appreciation in my life for emergency responders. 

Chief Shelton gave me every opportunity to work with the various divisions within the department – and I loved it all.! A few years into my employment, Chief knew I wanted to do more… Yes, I wanted to try out for the Fire Academy. While he was not crazy about idea, he supported me and encouraged me along the way. I studied for the Civil Service exam while preparing for the dreaded physical agility test seven days a week. I had never worked so hard. I came in second on the written exam and completed all of the agility test except the darn pull ups – and you were allowed to miss two of the segments and still pass the test. So, with advice from a local female police officer, I learned how to scale a six-foot wall – it just took a special technique and lots of bruises.  

Because I had worked with most of the firefighters and staff at the fire department for several years, I had the support of most of them. In fact, some of the older guys would volunteer to work with me in learning how to drive the older fire trucks that were out at the Training Center. So many people helped me – and I will never forget them. 

Then, in the freezing cold of January 1976, Chief Shelton welcomed me to the Beaumont Fire Academy. It was at the BFD Training Center where I attended with 25 other rookies from surrounding fire departments (Beaumont, Port Arthur, Nederland, etc.). I didn’t know any of them, so it was quite interesting, and I definitely have many, many stories to tell. Three months later most of the group graduated from the academy as the best of friends. But, no doubt, those guys nearly drove me crazy – and we were together seven days a week! 

For eight years, I enjoyed my time at the BFD and working for Chief Shelton – he afforded me so many opportunities to learn and grow. He and others taught me about writing detailed specifications for purchasing everything from 5-inch fire hose to 100-ft. aerial trucks. And, yes, getting a new fire truck was a big day, for sure. I think the most trucks we had delivered at one time was three, but it was quite a task getting them outfitted right down to the “gold leaf” numbering on the doors. Chief was strict to uphold the traditions of the fire service while always progressing, always advancing and being the best at everything we did. 

Chief was instrumental in making the BFD and its Fire Training Center one of the best in the country. He was relentless when it came to budget time – and he never thought about backing down – whether it was facing the city manager or the mayor! Again, he made sure we were always growing and progressing.  

During the years, we conducted numerous regional fire academies at our Training Center and there was also a large fire school each year with hundreds of people – Chief was in his glory! And he never failed to help outfit a small volunteer group if they were short on their gear. He really loved helping people – especially those that loved the fire service like he did. 

Chief Shelton was so good to me; however, we did butt heads over one major topic…Angel, the dalmatian fire dog. I had always been an animal nut and insisted Angel have the best in medical care and accommodations. Chief did not share my animal craziness, so it really put him to the test at times. Then Angel got so fond of me that she would not leave my side – from leaping into the jump-seat on the engine with me when we made a run to strutting into the Chief’s office completely unannounced. In fact, she would scratch the paint from Chief’s office door if I happened to go in there without her. Angel, ironic name, was always getting into trouble. Because we worked at the downtown fire station, there were numerous people walking by on their way to lunch. More than once, Angel stole a brown lunch bag right out of a stranger’s hands. She was reported to the Fire Chief multiple times – and more complaints came in weekly about MY dog! 

When I left the BFD to move to Baton Rouge, it was a very sad day. But Chief was understanding and wished me all the best. My next challenge was just ahead – I had never owned or operated a business, although I was excited about the new little company called Roco Rescue. For the next 40 years, Chief Shelton and I remained in contact. He has always been a guiding force in my life. I remain committed to his goals of excellence and being the best possible. I truly believe his mentorship has had much to do with the success I’ve enjoyed in business and in life. He will never be forgotten. Here’s to you, Chief. 

https://broussards1889.com/obituary/c-a-pete-shelton/