December 22, 1997

[Name Withheld]

Dear [Name Withheld]:

This is in response to your letter of July 10, requesting the Occupational Safety and Health Administration (OSHA) to interpret the training requirements for an attendant referenced in 29 CFR 1910.146, the Permit-Required Confined Spaces (PRCS) standard. Please accept our apology for the delay in this response.

For the purposes of consistency, this response is only in terms of activities carried on within or in support of permit-required confined spaces and not confined spaces as OSHA defines them.

In your letter, you stated that the International Brotherhood of Boilermakers, Iron Ship Builders, Blacksmiths, Forgers and Helpers has two positions on the training of attendants. The first is that "an attendant has to be fully versed with what is going on in the confined space, which should be equal to a fully skilled Boilermaker." The second is that "if the attendant does not understand the process, that person is not going to be able to make judgements about conditions within the confined space and react prudently and efficiently when it comes to initiating rescue procedures."

Limiting the training of the attendant to the technical skills of the entrant's speciality is not the intent of paragraph (g) of the PRCS standard.

The preamble of the final rule (58 F.R. 4513, 4517 - 4523) provides insight into the extent of the training needed for each affected employee. First, paragraph (g)(1) requires the training to impart the understanding, knowledge, and skills necessary for safe performance of duties assigned under the standard. By the sheer number and the detail of the attendant duties as compared to that of the entrant or entry supervisor, it is clear that OSHA considers the duties of the attendant to be central to a successful entry operation.

There are two specific paragraphs that speak to your basic contention. Paragraph (i)(1) focuses with great detail on the hazards within the space during an entry. These hazards are those both inherent to the space and to any process introduced into the space as a result of the work being done. Although it is not necessary for the attendant to be credentialed, in order for the hazards to be understood, the procedures that will be undertaken in the permit space must be generally understood, with those tasks creating the hazard being thoroughly understood.

Paragraph (i)(6) requires an attendant to monitor activities inside the space, including requiring the entrant to exit when a prohibited condition is detected. An attendant who is monitoring the activities of a boilermaker in a permit space must have sufficient knowledge of the activities to know when to best communicate, focus on the mode of the hazard for the task at hand and make judgements relative to the entrant's relative well-being.

ln summary, the attendant does not have to have all the skills and knowledge of the tradesman (entrant) performing the work in the permit space, but must be sufficiently informed of hazards of the tradesman's (entrant's) individual tasks for the activities planned as well as the inherent hazards of space where the activities are being performed.

If you have further questions regarding this letter, please contact Mr. Don Kallstrom of my staff at (202) 219-8031, x-109.

Sincerely,

John B. Miles, Jr.,
Directorate of Compliance Programs