Consider for a moment the issue of fall protection and the confined space attendant overseeing entry operations for workers in a vault or manhole (top down entry).

A question I often ask our students is: "Does the confined space attendant need to be tied off?" That is, if the fall hazard is greater than four feet (which it almost always is), does OSHA require the attendant to use some sort of fall protection? In this imaginary scenario we need to assume the the only fall hazard the attendant faces is the fall into manhole or vault. Clearly an attendant on top of a silo with no guardrails would need some type of fall protection.

This is one of the issues, among many others, that we'll tackle in our next Confined Space Train the Trainer class.

Given that it's a question asked in a safety class many students will automatically answer, yes, which is fine. But then the question becomes, "have you ever seen a confined space attendant tied off next to manhole?" The answer to that is generally "no" which begs the question, "Why not?"

So how can we answer this question which seems to lie at the confluence of several different standards? I guess we need to take it piece by piece.

Here are some things to consider: