In confined space work, ensuring air quality is a top priority. With directives from OSHA and consensus recommendations from ANSI & NFPA, understanding the ins and outs of atmospheric monitoring is key. This article will briefly review what OSHA requires as well as what ANSI, NFPA and Roco recommend for practices that ensure worker safety remains the top priority in working in these challenging environments. While the OSHA General Industry standard allows for periodic monitoring and sets no exact timespan between testing – however, as a safer way, Roco recommends continuous air monitoring any time workers are in the space.

OSHA 1910.146 refers to testing the internal atmosphere before an employee enters the space and testing as necessary to maintain acceptable entry conditions. Testing should be based on the hazard assessment for a given space as well as how rapidly those hazards could cause a change in the atmosphere, which may require additional action for safe entry.

OSHA’s Confined Spaces in Construction (1926-Subpart AA) also references monitoring frequency. It states continuous monitoring is required unless periodic monitoring is sufficient to ensure entry conditions are maintained, or continuous monitoring is not commercially available.

Note: Also take into consideration any previous work activities that may have introduced atmospheric hazards into the space as well as any known history of hazardous atmospheric conditions.

"Roco strongly encourages continuous monitoring while workers are inside a permit-required confined space."

Looking at best practice consensus standards, ANSI Z117 advocates for continuous monitoring in situations when a worker is present in a space where atmospheric conditions have the potential to change.

The national consensus standard, NFPA 350 Guide for Safe Confined Space Entry and Work 2022, also generally refers to “continuous air monitoring” when possible. Here’s a quote from NFPA 350, Section 7.13.1 (www.nfpa.org), Continuous Atmospheric Monitoring, “Atmospheric conditions can change quickly or gradually over time; without continuous atmospheric monitoring, air contaminants may increase, or the oxygen percentage may decrease or increase, creating dangerous confined space atmospheric conditions.” NFPA adds, “Entrants, Attendants, and other personnel may be unaware of changing conditions if the air quality was only initially monitored and determined to be acceptable. The atmosphere within and outside the confined space should be monitored continuously to ensure continued safe working conditions.”

PRE-ENTRY TESTING

Although OSHA does not define a specific timeline to conduct pre-entry monitoring, Roco uses as a guideline that a “baseline test” is to be conducted approximately 30 minutes prior to the entry and then again immediately prior to entry. If ventilation is being used as a control measure for atmospheric hazards, initial atmospheric monitoring should be conducted without ventilation to establish a baseline atmosphere.

A comparison of these readings could indicate that atmospheric changes have occurred inside the space. If a space has been vacated for a period of time, it is recommended that similar baseline testing be repeated. This is critical as it may reveal the presence of previously unrecognized or unanticipated atmospheric hazards.

Again, confined space work is inherently hazardous – and atmospheric hazards are a leading cause of fatalities. Do everything you can to keep your people safe. Don’t let your guard down even for a minute!

Additional Resources: 

Frequently Asked Questions: OSHA PRCS Standard Clarification 

How much periodic testing is required?

The frequency of testing depends on the nature of the permit space and the results of the initial testing performed under paragraph (c)(5)(ii)(c). The requirement in paragraph (c)(5)(ii)(F) for periodic testing as necessary to ensure the space is maintained within the limits of the acceptable entry conditions is critical. OSHA believes that all permit space atmospheres are dynamic due to variables such as temperature, pressure, physical characteristics of the material posing the atmospheric hazard, variable efficiency of ventilation equipment and air delivery system, etc. The employer will have to determine and document on an individual permit space basis what the frequency of testing will be and under what conditions the verification testing will be done.
 
What does testing or monitoring "as necessary" mean as required by 1910.146(d)(5)(ii) to decide if the acceptable entry conditions are being maintained?

The standard does not have specific frequency rates because of the performance-oriented nature of the standard and the unique hazards of each permit space. However, there will always be, to some degree, testing or monitoring during entry operations which is reflective of the atmospheric hazard.

Some of the factors that affect frequency are:

* Results of test allowing entry.
* The regularity of entry (daily, weekly, or monthly).
* The uniformity of the permit space (the extent to which the configuration, use, and contents vary).
* The documented history of previous monitoring activities.
* Knowledge of the hazards which affect the permit space as well as the historical experience gained from monitoring results of previous entries.

Knowledge and recorded data gained from successive entries (such as ventilation required to maintain acceptable entry conditions) may be used to document changes in the frequency of monitoring.

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Confined spaces and excavations 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.

Trench collapses are among the most serious dangers in the construction industry. Excavations can collapse in seconds and can potentially bury workers under cubic yards of soil, each weighing as much as 3,000 lbs. In 2022, OSHA reported that at least 39 industry workers died. From 2011 to 2018, the Bureau of Labor Statistics reports 166 workers died in trench collapses.

The following summaries are from OSHA News Releases (osha.gov). These tragedies serve as reminders to employers and rescuers of the inherent dangers involved in confined space entry and trench work.

Company’s Safety Failures Led 19-Year-Old Worker to Suffer Fatal Injuries Inside Concrete Mixer

CANTONMENT, FL — A Georgia-based concrete pipe manufacturer could have prevented a 19-year-old worker from suffering fatal injuries after a concrete mixer restarted while the teen tried to clean the machine's inside in Cantonment in March 2023.

OSHA found that two workers had climbed inside the mixer initially to use a hammer and chisel to chip away hardened concrete. As one of the workers left the mixer, the machine restarted with the other inside.

OSHA inspectors cited the company for willfully exposing workers to crushed-by hazards by allowing them to enter the mixer without making sure to first follow energy-control procedures. The agency also found the company exposed workers to confined spaces hazards by not making sure a safe atmosphere existed inside the mixer before the workers entered and by failing to have an attendant ready to retrieve workers safely.

“Failure to implement well-known safeguards cost the life of a worker just beginning their adulthood,” said OSHA Area Office Director Jose A. Gonzalez in Mobile, Alabama. “This preventable tragedy should serve as a reminder of the importance of complying with safety and health standards, as required by law.”

Project Manager’s Death in Trench Collapse

OKLAHOMA CITY – A U.S. Department of Labor workplace safety investigation found that a contractor could have prevented a trench collapse that fatally injured a project manager at a work site in May 2023.

Investigators learned that the project manager and other workers were putting gravel rock around a newly replaced 24-inch sewer line in a 10-foot-deep excavation when the trench collapsed. OSHA determined that — by not following federal safety standards for trenching and excavation work — the company exposed its employees to trench hazards.

OSHA cited the company for one willful violation for not using protective systems in a trench deeper than five feet. The agency also identified serious violations for:

• Failing to secure obstacles on the surface area near the trench.
• Not providing safe entry into or exit from the trench.
• Allowing standing water in the trench.
• Failing to perform daily inspections.

“A worker has lost their life because the company disregarded its responsibility to ensure the safety of its employees,” said OSHA Area Director Steven Kirby in Oklahoma City. “Employers are required by law to follow safety and health procedures that are put in place to prevent tragedies like this from occurring.”

Grain Silo Operator Failed to Provide Required Safety Procedures in Deadly Engulfment

COLQUITT, GA — A federal investigation into how a 59-year-old worker at a grain silo became engulfed and suffocated in April 2023 found the operator could have prevented the fatality by following required grain-handling safety regulations.

An employee entered a half-full bin to unclog clumps of grain as the bin's auger turned below. As they stood atop the grain, the pile shifted and quickly engulfed them. One other worker onsite rushed over and saw a rope that was tied to the worker disappearing into the grain but could not rescue their co-worker.  

OSHA cited the company for nine serious violations for exposing employees to engulfment hazards and failing to do the following:

• Train workers on how to safely enter a grain bin.
• Issue a permit and adequately evaluate hazards before employees enter a bin.
• Require augers and other equipment components to be de-energized and effectively locked out.
• Keep employees from performing tasks that require them to walk on moving grain inside a bin.
• Make sure body harnesses and lifelines were adequate to avoid engulfment hazards.
• Employ adequate communication methods, including communication with an observer to support workers inside a bin.
• Provide rescue equipment for employees entering a bin.

“Our investigation found that following required federal safety standards might have saved this worker's life,” said OSHA Acting Area Director Heather Sanders in Savannah, Georgia.

OSHA investigators also found the company exposed employees to caught-in hazards related to the powered auger system by not following required lockout and tagout procedures to shut down the system and prevent the auger from moving. Additionally, they failed to test oxygen levels inside the bin to protect workers before they entered.

Contractor Endangered Employees in Trench, Despite Knowing the Risks…  

GUAM — Two weeks after federal workplace safety inspectors warned a construction company of hazardous conditions facing employees working in an excavation, they returned to find the company again exposing workers to potentially deadly trench hazards as they installed a sewer line.

Following a May 2023 OSHA inspection, two serious violations were issued related to the company's failures to provide adequate means to enter and exit the trench within 25 feet of the workers and test oxygen levels in the trench before employees entered.

"Working in a trench is demanding and dangerous work that requires specific precautions and protections to keep workers safe," explained OSHA Area Office Director Roger Forstner in Honolulu. “By running soil compactors and excavators within 20 feet of workers in the trench and failing to provide accessible ladders, the company chose to put production before safety, endangering the lives of its employees.”

Additional Resources

• Attendant Safety Requirements Poster (pictured here)
• Confined Space Entry Checklist
• OSHA Campaign for Safe Trench Operations

Simply put, No. We get this question all the time. Sure, with proper vetting of the rescue service and mutual agreement, you can list 911 as your rescue plan within your Permit Required Confined Space Entry program. However, there are clear precautions that must be taken and put into place.

In the world of OSHA Standard language, we have a clear answer in this case. OSHA 1910.146, Appendix F spells it out very clearly.

“The employer should meet with the prospective rescue service to facilitate the evaluations required by 1910.146(k)(1)(i) and (k)(1)(ii). At a minimum, if an off-site rescue service is being considered, the employer must contact the service to plan and coordinate the evaluations required by the standard. Merely posting the service's number or planning to rely on the 911 emergency phone number to obtain these services at the time of a permit space emergency would not comply with paragraph (k)(1) of the standard.

You cannot get a much clearer answer than that from an OSHA Standard. And, keep in mind, while Appendix F is listed as “non-mandatory,” this does not mean that you do not have to comply with it. Using the method described is the non-mandatory part.

So, no, you cannot simply list 911 as your rescue service. You can however make an agreement with a private or municipal rescue service to provide that service provided you have evaluated the service to determine that they can perform the confined space rescue services needed for your facility.

If the rescue service becomes unavailable while an entry is underway, does it have the capability of notifying you so that the entry operation can be canceled?

For the employer, this is where an evaluation of the rescue service comes into play. OSHA 1910.146 Appendix F clearly outlines the need for employers to evaluate a prospective rescue service before relying on their services.

Once that occurs, one of the biggest challenges is determining how to make sure the municipal rescue service is available when you need them. Will they be available when you are ready to make entry, and what if the rescue service gets another call? If the rescue service becomes unavailable while an entry is underway, does it have the capability of notifying you so that the entry operation can be canceled?

Evaluating Rescue Response Capabilities

According to OSHA, the rescue service must be evaluated for:

• Ability to respond in a timely manner considering the hazards identified.
• Proficiency with rescue-related tasks and equipment.
• Ability to function appropriately while rescuing entrants from types of permit spaces identified.

The rescue service selected must be:

• Capable of reaching the victim(s) in a timely manner appropriate for the hazards identified.
• Equipped and proficient in performing the needed rescue services.
• Willing to provide the service. Employers may not rely on an outside service that is unwilling to provide rescue services.

Appendix F provides a valuable means to ensure that both the rescuers and the employer know the requirements and that proper agreements are in place prior to confined space entry operations. Roco Confined Space Compliance Guide and Types Chart includes Appendix F along with information and checklists for conducting an (A) Initial Evaluation, and (B) Performance Evaluation.

Critical factors include response time and availability. According to OSHA, the response time must be appropriate for the types of known or potential hazards affecting the confined spaces at the employer’s facility – and the rescue service must be available to respond in a timely manner during entry operations.

It is the employer’s responsibility, both morally and legally, to engage with the rescue service that is being considered. If you have identified an off-site team as the contracted rescue service in your confined space program, which includes municipal rescue, it is crucial that you take all the necessary steps to vet the agency as being a good fit to protect your employees. To document the arrangement, a written agreement is highly recommended. Click here to view a Sample Agreement to Provide Rescue Response.

Confined Spaces Require Special Rescue Skills and Equipment

Other than larger municipal departments, it is rare for local emergency responders to have the required confined space rescue resources including specialized training and equipment. Any shortfalls in an effective response must be addressed by the employer or confined space owner. This includes training, equipment, staffing, or other requirements to ensure a response appropriate for the types and hazards of the spaces onsite. Any rescue service would need to be trained and equipped in advance to face the many hazards and obstacles of permit-required confined space rescue.

OSHA states in section (d)(4) of 1910.146 that “the Employer shall provide rescue and emergency equipment needed to comply with paragraph (d)(9) of this section, except to the extent that the equipment is provided by rescue services…” This is where an employer and a public safety agency may enter a cooperative arrangement beyond what is expected of the emergency responder's normal response duties.

Conclusion

With careful planning, thorough communications, and proper training and equipment, relying on a private or municipal rescue response for confined space rescue can work. As an employer, it is your responsibility to make sure the rescue service is adequately prepared, equipped, and willing to provide confined space rescue services.

Additional OSHA References:

1910.146(d)(9) Develop and implement procedures for summoning rescue and emergency services, for rescuing entrants from permit spaces, for providing necessary emergency services to rescued employees, and for preventing unauthorized personnel from attempting a rescue;

1910.146(k)(1) An employer who designates rescue and emergency services, pursuant to paragraph (d)(9) of 1910.146(k)(1)(i). Evaluate a prospective rescuer's ability to respond to a rescue summons in a timely manner, considering the hazard(s) identified;

1910.146(k)(2)(i) Provide affected employees with the personal protective equipment (PPE) needed to conduct permit space rescues safely and train affected employees so they are proficient in the use of that PPE, at no cost to those employees;

1910.146(k)(2)(ii) Train affected employees to perform assigned rescue duties. The employer must ensure that such employees successfully complete the training required to establish proficiency as an authorized entrant, as provided by paragraphs (g) and (h) of this section;

1910.146(k)(2)(iii) Train affected employees in basic first-aid and cardiopulmonary resuscitation (CPR). The employer shall ensure that at least one member of the rescue team or service holding a current certification in first aid and CPR is available; and

1910.146(k)(2)(iv) Ensure that affected employees practice making permit space rescues at least once every 12 months, by means of simulated rescue operations in which they remove dummies, manikins, or actual persons from the actual permit spaces or from representative permit spaces. Representative permit spaces shall, with respect to opening size, configuration, and accessibility, simulate the types of permit spaces from which rescue is to be performed.

Note to paragraph (k)(1)(i): What will be considered timely will vary according to the specific hazards involved in each entry. For example, 1910.134, Respiratory Protection, requires that employers provide a standby person or persons capable of immediate action to rescue employee(s) wearing respiratory protection while in work areas defined as IDLH atmospheres.

Additional Resources

• Confined Space Types Chart (pictured here) 
• Evaluating Your Rescue Service 
• Agreement to Provide Rescue Response
  
• Requirements for Rescue Plans

ANSWER: As a Paramedic, I strongly feel that having your rescue personnel trained to the EMR (Emergency Medical Responder) level is extremely beneficial for any industrial site. While EMR training is not required, it can truly make the difference in a life-or-death situation. From my personal experience, we found time and time again how this extra medical care made all the difference when responding to an incident.

Not only is the skill-level of first responders critical in an industrial emergency – many times the industrial site is fairly isolated. This can increase response times when rapid, critical care is so vital. Plant access and finding the exact location may also present potential delays to medical care. With EMRs initially on scene with your rescue team, you can know that your personnel are receiving a higher level of care when it matters most.   

To clarify, an Emergency Medical Responder (EMR) is a well-versed medical responder who can attend to basic needs in a critical need situation. EMR’s are nationally certified or state-licensed medical responders generally tasked with providing immediate emergency care to the sick and injured before an ambulance or higher level of care arrives.

While basic first aid and CPR may be the minimum required for rescue personnel OSHA 1910.146(k)(2)(iii), an EMR is trained to provide more enhanced care – particularly, inside a confined space or for a worker who is stranded at height. Plus, they can be there almost immediately with your rescue team to provide aid. The EMR can help with airway protection, bleeding control, mechanical ventilation, symptom recognition and support of vital functions until more advanced care is reached.

So, minimally, someone on your team needs to be certified in first aid and CPR training. And, while the techniques taught in most nationally recognized First Aid and CPR courses are great for lay folk responding in environments tamer than the industrial setting – the skills, clinical knowledge, and logistic awareness taught in the typical EMR class are a far better fit for confined space rescuers. If you’re looking to give your organization the greatest peace of mind and the best chance to avoid tragedy, we highly recommend EMR training.

Key Medical Questions for ERT Coordinators include:

• Based on hazards identified at your facility, what types and degrees of injuries could patients sustain while at your facility?
• What is the estimated response time for EMS/Fire Department? Is the service familiar with your facility and the potential hazards? Chemical, Mechanical, etc.
• How will EMS access your site, or will the patient be taken to a staging area?
• If air medical transport is necessary, has the facility coordinated a landing zone with EMS/Fire/Sheriff's office?
• Who at the facility will assess the patient and give the information about the patient's condition to EMS?
• Where is the nearest emergency room? Is the ER familiar with your facility and the potential hazards? Chemical, Mechanical, etc.
• What types of drills can your facility conduct, with or without EMS/Fire, to better prepare facility personnel for an emergency?

Prior to coming to work for Roco Rescue, Chris Warrick worked the street as a paramedic for three years, and then three years as a paramedic instructor. He was the section leader for “Cardiology” as well as “Anatomy and Physiology,” and “EMS Operations” at various times. Chris holds an AAS in Paramedicine from South Louisiana Community College and is also certified to teach BLS and ACLS through the American Heart Association. He is also a licensed EMS educator in Louisiana. As a Paramedic, Chris has responded to hurricanes: Harvey, Michael, Laura, Delta, and Ida. As Medical Program Manager for Roco Rescue, Chris oversees medical protocols, procedures, equipment, and education alongside our medical director. 

Follow Chris 

Additional Resources

• What to Look for When Choosing Medical Training for Emergency Response and Rescue Teams

• Emergency Medical Responder Course

• First Aid CPR and AED Training Course