Attendant and entrant squawk talk

Responding is Rayaz Qureshi-Chishti, workplace safety editor, J. J. Keller & Associates Inc., Neenah, WI.

OSHA’s construction and general industry standards, 1926.1204(d)(3) and 1910.146(d)(4)(iii), respectively, require an employer to provide all communication equipment necessary to ensure the attendant (often referred to as the “hole watch”) can communicate effectively with entrants in a permit-required confined space.

However, OSHA doesn’t require attendants and entrants to use any specific type of equipment for effective communication. Rather, OSHA requires employers to establish communication procedures for the attendants to maintain contact with the entrants. Employers have the option to use electronic communication equipment if that would be most effective, or any other form of communication that it finds safe and effective.

Examples of when communication equipment may be needed include:

• If the entrants cannot hear the attendant.
• If an alternate form of communication, such as knocking or use of signals, would become confused with the work activity.
• When workers are inside a complex PRCS and cannot be seen by the attendant.
• The attendant is assessing entrants’ status in multiple PRCSs.

When the attendant is monitoring a single PRCS, non-electronic forms of communication may be easier to use. When the attendant must monitor multiple PRCSs, the task of monitoring entrants can become much more challenging without using electronic forms of communication.

Knock, knock – who’s there?

Audio and video communication equipment can enable the attendant to see what’s occurring inside PRCSs without having to, simultaneously, be physically present at each PRCS entrance.

If an employer requires an attendant to assess entrants’ status in multiple PRCSs, the employer must provide all the equipment necessary for the attendant to fulfill those duties. A safety assessment should be performed to determine what hazards and challenges are present and what form of communication is most effective between the attendant and entrants.

OSHA believes that expecting an attendant to adequately monitor entrants without the necessary communication equipment will jeopardize the health and safety of the entrants. Non-electronic communication can be used between the entrants and the attendant; however, it’s not always the most effective or efficient form of communication.

Traditional forms of communication, such as knocking, can become confused with the work process, or the attendant may not hear it because of surrounding noise from other work activity in the area. Also, when workers are inside a complex confined space, the attendant doesn’t always have a direct line of sight to workers from outside the entrance. Even though entrants may be able to talk directly or loudly to the attendant, direct verbal communication may be difficult to hear or could be misunderstood over surrounding noise.

Coffee cans and yarn

OSHA doesn’t limit the types of electronic communication the attendant and entrants can use with one another. For example, cellphones and two-way handheld radios can be used if it’s effective and safe to do so.

If signal strength is weak or unpredictable when using the device, it would not comply with OSHA’s requirement for the attendant to maintain constant communication with the entrants. In that case, the attendant must remove the entrants until the attendant is situated to perform the required duties effectively. Many entrants prefer having direct communication and a direct line of sight with the attendant. It’s important to have reliable communication equipment. It’s common nowadays to lose communication even on the most sophisticated cellphones. It would be unsettling for an entrant to lose communication with his or her lifeline – the attendant. Have a backup plan in case communication issues occur.

Effective, reliable communication is essential in relaying information to attendants, entry supervisors and other authorities regarding potentially dangerous changes in PRCS conditions. Such information is critical to assess the hazards within the PRCS and provide information regarding methods appropriate for protecting or removing employees from those hazards. Using communication equipment is an option for employers to consider doing this, but employers may use alternative methods. An evaluation of the PRCS and the hazards should help determine what method of communication would be most effective and reliable.

Editor's note: This article represents the independent views of the author and should not be construed as a National Safety Council endorsement.