Confined Space Entry: RAVS Requirements and Permit Program Template

Confined space entry is one of the highest-stakes programs in your RAVS submission. The hazards are severe — atmospheric, engulfment, configuration, and entrapment — and the federal standard at 29 CFR 1910.146 is long, specific, and unforgiving. Reviewers know the standard cold, and they expect your written program to mirror its structure.

This guide walks through what your confined space program needs to contain to clear a RAVS review, with citations you can reference directly in your answer.

Does the Standard Apply to Your Company?

Before writing anything, determine whether your workforce actually enters confined spaces. A confined space under 1910.146(b) is a space that:

1. Is large enough and configured so an employee can bodily enter and perform assigned work, and
2. Has limited or restricted means for entry or exit, and
3. Is not designed for continuous employee occupancy.

Examples: tanks, vessels, silos, storage bins, hoppers, vaults, pits, manholes, sewers, HVAC ducts, crawl spaces in some configurations.

A permit-required confined space is a confined space that has one or more of: a hazardous atmosphere, a material with the potential to engulf an entrant, an internal configuration that could trap or asphyxiate (inwardly converging walls or a floor that slopes downward), or any other recognized serious safety or health hazard.

If your employees enter permit-required confined spaces, you need a full program. If they only enter non-permit confined spaces, you still need to document how you evaluate spaces and confirm they're non-permit. If they never enter confined spaces at all, say so plainly in your RAVS answer — but be careful, because reviewers often push back on blanket N/A answers for trades that commonly encounter confined spaces (mechanical contractors, painters, coatings, insulation, utility work).

Section 1: Purpose and Scope

Open with a statement that your company has established this program per 29 CFR 1910.146 to protect employees from the hazards associated with entry into permit-required confined spaces. Define who the program applies to and what job tasks trigger it.

State your company's default position: employees do not enter permit spaces unless the permit program has been implemented for that entry. This framing matters to reviewers.

Section 2: Definitions

Pull definitions directly from 29 CFR 1910.146(b). At minimum include: confined space, permit-required confined space (permit space), non-permit confined space, hazardous atmosphere, acceptable entry conditions, entry, entry permit, entry supervisor, attendant, authorized entrant, engulfment, IDLH (immediately dangerous to life or health), oxygen-deficient atmosphere, oxygen-enriched atmosphere, and rescue service.

If your definitions diverge from the regulatory text, reviewers will flag it. Copy carefully.

Section 3: Identifying and Evaluating Permit Spaces

1910.146(c)(1) requires employers to evaluate the workplace to determine if any spaces are permit-required confined spaces. Your program needs to describe how this evaluation happens:

• Who conducts the evaluation (usually the competent person or safety manager)
• The criteria used (the three-part confined space definition, then the permit-required criteria)
• How spaces are documented — most companies keep a confined space inventory listing each space, its location, its hazards, and its classification
• How the inventory is updated when facilities or job sites change

1910.146(c)(2) requires that if permit spaces exist, the employer inform exposed employees, by posting danger signs or by any other equally effective means, of the existence, location, and danger posed by the permit spaces. Spell out how you post or communicate this at job sites.

Section 4: When Entry Is Prohibited

If your company has decided employees will not enter permit spaces, 1910.146(c)(3) requires you to take effective measures to prevent entry. Document what those measures are: physical barriers, locks, signage, supervisor oversight.

For most contractors, though, the realistic answer is that some entries do occur — in which case skip to the next section.

Section 5: The Written Permit Space Program

1910.146(c)(4) requires a written permit space program when employees enter permit spaces. The program must be available for employees and their authorized representatives to review. State this plainly — reviewers look for it.

1910.146(d) lists the thirteen elements the program must contain. Organize your RAVS answer around these elements. Hitting them in order is the easiest way to pass.

1. Prevent unauthorized entry. Describe barriers, signage, and supervisor controls.

2. Identify and evaluate hazards before entry. Describe the pre-entry hazard assessment process — who does it, what they look for (atmospheric, engulfment, configuration, other recognized hazards), and how it's documented on the permit.

3. Develop and implement means, procedures, and practices for safe entry. This is the operational core. Include at least: specifying acceptable entry conditions, isolating the permit space, purging/inerting/flushing/ventilating as needed, providing pedestrian/vehicle/other barriers, and verifying conditions remain acceptable throughout entry.

4. Provide equipment at no cost to employees. Atmospheric testing instruments, ventilation equipment, communications equipment, PPE, lighting, barriers, ingress/egress equipment (ladders, tripods, retrieval systems), and rescue/emergency equipment. Maintain and calibrate the equipment.

5. Evaluate permit-space conditions during entry operations. Continuous or periodic atmospheric monitoring, as applicable. Testing in the order required by 1910.146(d)(5)(iii): oxygen first, combustibles second, toxic gases third. Document calibration.

6. Provide at least one attendant outside the space during entry. Describe attendant duties per 1910.146(i): knowing hazards, continuously maintaining accurate entrant count, remaining outside the space, communicating with entrants, monitoring activities inside and outside, ordering evacuation when necessary, summoning rescue.

7. Designate roles and responsibilities for employees with active roles. Entry supervisor, attendant, authorized entrant. Each role has specific duties in 1910.146(h)–(j) — list them.

8. Develop and implement procedures for summoning rescue and emergency services. Cover this in Section 8 of your program (below). Reviewers examine rescue arrangements closely.

9. Develop and implement a system for the preparation, issuance, use, and cancellation of entry permits. See Section 6 below.

10. Develop and implement procedures to coordinate entry operations when employees of more than one employer are working simultaneously in a permit space. The host employer and contractor exchange information on hazards, prior experience, and restrictions. 1910.146(c)(8) and 1910.146(c)(9) spell out the exchange in both directions.

11. Develop procedures for concluding entry. Close out the permit, remove equipment, return the space to its secured state.

12. Review entry operations when there is reason to believe the program's measures may not protect employees. Revise the program as needed.

13. Review the permit space program at least annually. Use canceled permits from the past 12 months to audit the program. Document the review.

Section 6: Entry Permit Contents

1910.146(f) lists what must appear on each entry permit:

• The permit space to be entered
• The purpose of the entry
• Date and authorized duration
• Authorized entrants
• Personnel serving as attendants
• The entry supervisor (with a space to indicate acceptance by signature)
• Hazards of the permit space
• Measures used to isolate the space and eliminate or control hazards (LOTO, blanking, blinding, lockout of lines, purging, ventilation)
• Acceptable entry conditions (atmospheric limits, other parameters)
• Results of initial and periodic tests with the tester's name/initials and time of tests
• Rescue and emergency services contact information and how to summon them
• Communication procedures between attendants and entrants
• Required equipment (PPE, testing, alarm, rescue, communication)
• Other information necessary for safe entry
• Additional permits issued (hot work, LOTO, etc.)

Attach your permit form as an appendix to the written program. Reviewers want to see the form.

Section 7: Atmospheric Testing

Cover testing per 1910.146(d)(5) and Appendix B of the standard:

• Order of testing: oxygen, then combustible gases and vapors, then toxic gases and vapors
• Acceptable entry conditions: oxygen 19.5%–23.5%, combustibles below 10% LEL, toxic substances below the PEL
• Calibration: bump test before use, full calibration per manufacturer
• Recordkeeping: results recorded on the permit with time and tester

Describe how re-testing is handled if conditions change or entry is paused and resumed.

Section 8: Rescue and Emergency Services

1910.146(k) is one of the most heavily scrutinized sections. Your program must describe how rescue will occur. There are three general approaches:

• In-house rescue team: your own employees trained and equipped for rescue, with practice entries at least once every 12 months in representative spaces.
• Off-site rescue service (municipal fire department, etc.): you must evaluate the service's ability to respond in a timely manner, evaluate their ability to function proficiently, and inform them of the hazards. Reviewers expect documentation of this evaluation — a handshake agreement with the local fire department is not sufficient.
• Non-entry (retrieval-line) rescue: an entrant wears a chest or full-body harness with a retrieval line attached to a mechanical device or fixed point outside the space. Mechanical devices are required for vertical permit spaces more than 5 feet deep.

Describe which approach applies to each space type, and attach any evaluation letters or agreements with off-site rescue services.

Section 9: Training

1910.146(g) requires training for each employee whose work is regulated by the standard, before initial assignment, before a change in duties, whenever there's a change in operations that presents a hazard for which an employee has not been trained, and whenever the employer has reason to believe deviations or inadequacies exist.

Training must establish employee proficiency and introduce new or revised procedures. Certify training with the employee's name, the trainer's signature, and the date.

Cover roles separately: entrants, attendants, entry supervisors, and rescue personnel have different duties and different training requirements.

Common RAVS Rejection Reasons

• Rescue section just says "call 911" with no evaluation of the responding service
• No permit form attached or referenced
• Atmospheric testing order not specified (oxygen must come first)
• Attendant duties not described, or the program allows attendants to enter the space (they cannot, except under the limited conditions in 1910.146(i)(9))
• Contractor coordination (1910.146(c)(8)/(c)(9)) not addressed
• Annual program review not mentioned
• Training section doesn't distinguish entrant, attendant, and entry supervisor roles

PrequalPilot gives you a RAVS-ready permit-required confined space program template mapped section-by-section to 29 CFR 1910.146, with a compliant entry permit form, atmospheric testing log, and rescue service evaluation form. Start a free trial →