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Confined space entry job hazard analysis (JHA) template

A confined space can hold bad air, engulfment or a trapped worker, and the danger often cannot be seen. OSHA's construction confined space standard requires a competent person to identify confined spaces and permit spaces before work begins (29 CFR 1926.1203(a)), and a written program, a permit and an attendant for entry. Do not enter until the permit is signed.

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The task

Entering a permit-required confined space such as a vault, manhole, tank or pit on a construction site, with an entry permit, atmosphere testing, an attendant and a rescue plan.

Steps, hazards and controls

Controls run from most effective to least. A citation beside a control means an OSHA paragraph requires it; with no citation it is good practice.

StepHazardControls
1. Identify the space and the hazardsWorkers enter a space nobody has evaluated
  1. Eliminate: Do the work from outside the space, with extended tools or cameras, so nobody has to enter.
  2. Administrative control: Have a competent person identify all confined spaces and permit spaces before work begins. (29 CFR 1926.1203(a))
  3. Administrative control: Evaluate the hazards of the permit space before employees enter. (29 CFR 1926.1204(b))
  4. Administrative control: Prevent unauthorized entry with signs, barriers or covers. (29 CFR 1926.1204(a))
2. Prepare the permit and the programEntry begins without documented controls
  1. Administrative control: Have a written permit space program in place at the construction site before employees enter. (29 CFR 1926.1203(d))
  2. Administrative control: Prepare an entry permit that documents the completed measures before entry is authorized. (29 CFR 1926.1205(a))
  3. Administrative control: Have the entry supervisor sign the permit before entry begins. (29 CFR 1926.1205(b))
  4. Administrative control: Post the permit or make it available to the entrants at the time of entry. (29 CFR 1926.1205(c))
3. Isolate energy and ventilateHazardous energy, flow or atmosphere reaches the entrants
  1. Eliminate: Close, blank or disconnect lines and lock out energy sources before entry.
  2. Engineering control: Provide ventilating equipment needed to obtain acceptable entry conditions. (29 CFR 1926.1204(d)(2))
  3. Engineering control: Install lighting that meets the minimum illumination and is approved for any ignitable atmosphere. (29 CFR 1926.1204(d)(5))
  4. Administrative control: Use the means, procedures and practices necessary for safe entry in the program. (29 CFR 1926.1204(c))
4. Test the atmosphereOxygen deficiency, flammable gas or toxic gas
  1. Engineering control: Test the conditions before entry is authorized to begin and before natural ventilation is changed. (29 CFR 1926.1204(e)(1))
  2. Engineering control: Test first for oxygen, then combustible gases and vapors, then toxic gases and vapors. (29 CFR 1926.1204(e)(3))
  3. Engineering control: Monitor continuously for atmospheric hazards unless periodic monitoring is enough as the standard describes. (29 CFR 1926.1204(e)(2))
  4. Administrative control: Provide testing and monitoring equipment, and make sure the tester is trained. (29 CFR 1926.1204(d)(1))
5. Brief the team and assign rolesRoles are unclear when something goes wrong
  1. Administrative control: Designate each authorized entrant, attendant, entry supervisor and tester, and identify the duties of each. (29 CFR 1926.1204(h))
  2. Administrative control: Review the hazards, the communication method and the stop signals with the whole team.
  3. Administrative control: Confirm the rescue plan and contact numbers before entry. (29 CFR 1926.1204(i))
6. Enter and workEntrant is overcome with no one aware
  1. Engineering control: Use non-entry rescue with a retrieval system, so the entrant can be pulled out from outside, unless retrieval equipment would increase the risk or would not help the rescue. (29 CFR 1926.1211(c))
  2. Administrative control: Keep at least one attendant outside the space for the duration of entry operations. (29 CFR 1926.1204(f))
  3. Administrative control: Have the attendant remain outside until relieved by another attendant. (29 CFR 1926.1209(d))
  4. Administrative control: Keep communication between the attendant and entrants as often as needed to check their status. (29 CFR 1926.1209(e))
  5. PPE: Wear the PPE and use the equipment the program and permit call for, such as a harness and retrieval line or a respirator. (29 CFR 1926.1204(d))
7. Monitor and respond to a changeAtmosphere or conditions change during entry
  1. Administrative control: Exit as quickly as possible whenever an alarm, a prohibited condition or an order to evacuate occurs. (29 CFR 1926.1208(e))
  2. Administrative control: Have the attendant order entrants out if there is a prohibited condition or the behavioral effects of exposure are apparent. (29 CFR 1926.1209(f))
  3. Administrative control: Summon rescue as soon as the attendant decides entrants may need help. The attendant stays outside until relieved by another attendant. (29 CFR 1926.1209(g))
8. Exit, close the permit and remove protectionThe space is re-entered without re-evaluation
  1. Administrative control: Cancel the permit when the work is done, as the permit system requires. (29 CFR 1926.1204(j))
  2. Administrative control: Reclassify a permit space as non-permit only when a competent person determines the conditions in the standard are met. (29 CFR 1926.1203(g))
  3. Administrative control: Cover or secure the opening before leaving.

Required PPE

What the standard says

  • A competent person must identify confined spaces and permit spaces. (29 CFR 1926.1203(a))

    “Before it begins work at a worksite, each employer must ensure that a competent person identifies all confined spaces in which one or more of the employees it directs may work”

  • A written permit space program is required if employees will enter. (29 CFR 1926.1203(d))

    “If any employer decides that employees it directs will enter a permit space, that employer must have a written permit space program that complies with § 1926.1204 implemented at the construction site.”

  • Test oxygen first, then combustibles, then toxics. (29 CFR 1926.1204(e)(3))

    “When testing for atmospheric hazards, test first for oxygen, then for combustible gases and vapors, and then for toxic gases and vapors”

  • Provide at least one attendant outside the space for the duration of entry. (29 CFR 1926.1204(f))

    “Provide at least one attendant outside the permit space into which entry is authorized for the duration of entry operations:”

  • Prepare an entry permit before entry. (29 CFR 1926.1205(a))

    “Before entry is authorized, each entry employer must document the completion of measures required by § 1926.1204(c) by preparing an entry permit.”

  • The entry supervisor signs the permit before entry begins. (29 CFR 1926.1205(b))

    “Before entry begins, the entry supervisor identified on the permit must sign the entry permit to authorize entry.”

  • The attendant remains outside until relieved. (29 CFR 1926.1209(d))

    “Remains outside the permit space during entry operations until relieved by another attendant”

Training

The employer must train each employee whose work is regulated by this standard, at no cost to the employee, so the employee has the understanding, knowledge and skills for assigned duties (29 CFR 1926.1207(a)). Training must be in a language and vocabulary the employee understands, and given before first assigned duties, before a change in duties and when entry operations change in a way that presents a new hazard (29 CFR 1926.1207(b)).

Frequently asked questions

Does OSHA require a JHA for confined space entry?
OSHA does not require a written JHA for confined space entry, but it does require much more: a written permit space program, an entry permit signed by the entry supervisor, atmosphere testing, an attendant and rescue arrangements (29 CFR 1926.1203, 29 CFR 1926.1204, 29 CFR 1926.1205). A JHA can support the permit.
What goes in a confined space entry JHA?
Include space identification, the permit, isolation and ventilation, testing, the briefing, entry with an attendant, monitoring and emergency response, and exit and cancellation. Name the entrants, attendant, entry supervisor and rescue service.
Can the attendant go in to rescue an entrant?
Not while acting as the attendant. The attendant stays outside until relieved by another attendant and summons rescue services as soon as entrants may need help (29 CFR 1926.1209(d) and (g)). A relieved attendant may enter for rescue only when the program allows it and the attendant is trained and equipped for rescue.

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