Training for Enclosed Spaces: What OSHA says and the employer’s responsibilities

By Chuck Kelly | Mar 15, 2023
Getty Images / shotbydave
Line contractors encounter many types of hazards during the day, including enclosed spaces. 




Line contractors encounter many types of hazards during the day, including enclosed spaces. According to the Occupational Safety and Health Administration, an enclosed space is “A working space, such as a manhole, vault, tunnel, or shaft, that has a limited means of egress or entry, that is designed for periodic employee entry under normal operating conditions, and that, under normal conditions, does not contain a hazardous atmosphere, but may contain a hazardous atmosphere under abnormal conditions.”

OSHA’s take

“OSHA does not consider spaces that are enclosed but not designed for employee entry under normal operating conditions to be enclosed spaces for the purposes of this subpart. Similarly, the Occupational Safety and Health Administration does not consider spaces that are enclosed and that are expected to contain a hazardous atmosphere to be enclosed spaces for the purposes of this subpart. Such spaces meet the definition of permit spaces in subpart AA of this part, and entry into them must conform to that standard.”

The above statements come from 29 CFR 1926 Subpart V. Section 1926.953 breaks down the enclosed space and permit-­required confined space specifics. It does not apply to vented vaults, if the employer makes a determination that the ventilation system is operating to protect employees before they enter. 

This section applies to routine entry into enclosed spaces. The requirement covers the routine entries where the hazards remaining in the enclosed space do not endanger the entrant’s life or interfere with their escape.


While it is important to be familiar with all the specifics of the standard, I want to focus on training. Too often, employers fail to provide complete training in a manner that ensures the employee completely understands what they are taught. We cover the basics because we believe the potential of an incident occurring is minimal. 

However, we should make sure to emphasize the need to monitor the atmosphere for hazards and train employees to calibrate the testing equipment to ensure proper readings. After all, what good is a measurement for a safe atmosphere if the equipment calibration is off? 

Do we practice rescue procedures to ensure that if something does go wrong, we can save the exposed employees? Company owners can probably say they have completed these tasks initially with their employees, but would have trouble demonstrating consistent retraining. This is not for a lack of focus on safety. It’s mostly due to us getting into a routine with our crews and “knowing” that they know what to do if the need arises.

Proper preparation

While the potential for working in an enclosed space may be limited compared to other types of work, it is essential to know what precautions to take before starting. Just like hazardous energy, enclosed spaces can kill you if you’re not prepared.

As employers, it is our responsibility to properly prepare our workers. When dealing with enclosed spaces, we need to ensure our employees are capable of evaluating the potential hazards. Start with the entrance. Before any cover is removed, a determination should be made to ensure that it is safe to do so. Is there an indication that a hazardous atmosphere is present? Does the cover exhibit any temperature difference or show signs of pressure build-up on the other side? If so, action plans need to be in place to eliminate such hazards. 

Once the cover has been removed, a barrier needs to be erected to prevent those outside of the space from falling through the opening, and air monitoring needs to take place to ensure there are no hazardous gases present and oxygen levels remain safe for employee entrance. 

Employees inside the space need to be monitored by someone outside to ensure their safety. If we have all these items in place, it will make for a safe operation and employees will be protected. Specific OSHA information can be found in 29 CFR 1926 Subpart V, Section 1926.953.

Header image: Getty Images / ShotByDave

About The Author

KELLY, president of Kelly Consulting & Mediation Services, has worked with utility industry leaders on safety, labor relations and human resources for more than 30 years. Reach him at 540-686-0118 or [email protected]

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