There are several steps the employer needs to take prior to conducting training. The first step is to develop a written confined space program. This includes a listing of all potential spaces. Then, the employer must decide if there is a way to complete the necessary activity without a person entering the space. One of the most overlooked issues at this stage is can non-entry(retrieval) rescue be performed for permit required spaces. If not, then how is the rescue team developed. Simply calling 911 is not adequate.

If it is decided that the employee is to enter the space, the employer must be committed to doing it right. This typically involves a substantial investment. To perform a proper confined space entry and accomplish a task that previously involved no entry procedures will increase the amount of time both in production and administration. Future work scheduling activities must allow for this extra time and management expectations should be adjusted accordingly.

The training requirements related to confined space entry are performance based and need to be employer specific. This means that the training must relate to the employers’ written confined space program. The actual length of time varies depending on the specific activities of the individuals and how long it takes to achieve proficiency at the needed competencies.

Developing the Training Program

Step One – Training Needs Analysis
This is used to determine who needs what. The analysis breaks down the overall operation into activities associated with individuals. These individuals are then grouped by similar functions associated with the confined space entry. They are then trained on their specific activities and duties related to the confined space. This would include an evaluation of the types of spaces entered, what duties the employee will be performing, rescue options, potential chemical and physical hazards, and the amount and content of previous training.

A review of other training requirements is conducted to determine if any overlap exists. If overlapping content is found, then the training program is designed to satisfy both requirements at the same time. For example, employees are required to be trained in proper lock-out, tag-out procedures. The requirement is also found in confined space training. Other areas of potential overlap are hazard communication, respiratory protection, and emergency response.

Step Two – Identify the Audience
The particular make up of the audience is critical to delivering the training at the appropriate technical level. The actual duties and types of spaces are another audience sorting factor. Certain duties such as welding would require different training than someone doing visual inspections. Those persons entering a chemical process vessel or boiler may differ in their training needs from someone entering sanitary sewers.

It is also critical to train with the equipment the employees will have access to. Although most air monitoring equipment operates in the same basic manner, each model will have peculiarities that are unique. Entry and retrieval equipment also have unique characteristics. Even full body harnesses vary on how a person straps into them.

Within each group, it is important to have those employees who will be functioning as entrants, attendants and supervisors together so they will understand the others’ duties. This is also a good time to review the employer’s confined space entry program. Many times the plan is written without input from those employees who will have to function under it. This approach will also facilitate the team approach which is necessary to the operation succeeding.

Those employees who have been designated as the rescue team must have specialized training in addition to that required for attendants. This is not the place to short cut. Rescue training should be upwards of 40 hours initially, and continuously practiced.

Step 3 – Scheduling

The training must be successfully completed prior to the employee entering a confined space. Additional training may be required if the conditions regarding the activities or the space the employee is entering changes.

The length of the training is dependent on several factors such as the technical background of the employees, the characteristics of the spaces to be entered, and the specific reasons for entering the confined space. Usually sessions are 8 to 24 hours in length, with rescue training an additional 8-24 hours.

The important point on which to focus is that the employee must actually have an understanding of the material presented and be able to function at their assigned duties. The actual length of the training must be adequate to accomplish this.

The training sessions should be scheduled in advance with the employee understanding why the training is being conducted. The sessions should also be scheduled during the employees’ normal work hours. If possible, the sessions should be scheduled for those times when representative spaces will be available for practice entries. These spaces should be similar to what the employee may encounter during their normal course of work.

While there is no requirement for annual refresher training for normal entry activities, a review of problems or areas for improvements would be prudent, even for those conducting frequent entries. Rescue personnel are required to conduct annual training, although more frequent practice is strongly encouraged.

Step – 4 Follow Up

As part of the written confined space program, continuous feedback is needed from the participants. Areas for improvement need to be identified and dealt with. The program administrator should periodically monitor the entire confined space entry process to determine if the original training was adequate. This is especially important for the infrequent participants. As regulations develop and change, the written program must change accordingly. This is also true for changes in the work involved with the confined spaces.

Workers involved with confined spaces are required to be trained according to 29 CFR 1910.146. This course will focus on hazard assessment, air monitoring, hazard control measures and non-entry rescue. Details will be based upon the employers written confined space entry program.