Whats Wrong With This Picture?

| OSHA, USF Safety Florida

Photographs are powerful learning tools in identifying and preventing of workplace hazards. Thank you to David Ashman, our USF SafetyFlorida contributor for January. What is wrong with this picture?  A keen eye should reveal several potential problems.


There are multiple issues with this situation, including, but not limited to, the following:

  • The employer did not have an active permit, nor was the general contractor, who knew of the confined space, aware of this activity.
  • The employee was only provided an oxygen sensor.
  • Incorrect rescue equipment was being used.
  • Flowing water could be heard in the space.
  • The ladder did not reach the access point.
  • A generator was running in proximity to the opening.
  • If a competent person was present, they were not fulfilling their responsibilities.
  • The supervisor/foreman for the company, which was present, knew a permit was required.
  • Employees were huddled around the space watching the employee working, which would suggest that employees have not been properly trained or company policies are not being enforced.  

Applicable Standards:

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, and identifies each space that is a permit space, through consideration and evaluation of the elements of that space, including testing as necessary.

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. The written program must be made available prior to and during entry operations for inspection by employees and their authorized representatives.

1926.1203(h) Permit space entry communication and coordination.

(1) Before entry operations begin, the host employer must provide the following information, if it has it, to the controlling contractor: 1926.1203(h)(1)

(ii)  The hazards or potential hazards in each space or the reason it is a permit space; and 1926.1203(h)(1)(ii) 

(iii)  Any precautions that the host employer or any previous controlling contractor or entry employer implemented for the protection of employees in the permit space. 1926.1203(h)(1)(iii) 

1926.1203(h)(3)(ii) Inform the controlling contractor of the permit space program that the entry employer will follow, including any hazards likely to be confronted or created in each permit space.

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.

1926.1205(c) The completed permit must be made available at the time of entry to all authorized entrants or their authorized representatives, by posting it at the entry portal or by any other equally effective means, so that the entrants can confirm that pre-entry preparations have been completed.

1926.1211(a) An employer who designates rescue and emergency services, pursuant to §1926.1204(i), must:

1926.1211(a)(2) Evaluate a prospective rescue service’s ability, in terms of proficiency with rescue-related tasks and equipment, to function appropriately while rescuing entrants from the particular permit space or types of permit spaces identified.

1926.1211(b) An employer whose employees have been designated to provide permit space rescue and/or emergency services must take the following measures and provide all equipment and training at no cost to those employees:

1926.1211(b)(4) Ensure that affected employees practice making permit space rescues before attempting an actual rescue, and at least once every 12 months, by means of simulated rescue operations in which they remove dummies, manikins, or actual persons from the actual permit spaces or from representative permit spaces, except practice rescue is not required where the affected employees properly performed a rescue operation during the last 12 months in the same permit space the authorized entrant will enter, or in a similar permit space. Representative permit spaces must, with respect to opening size, configuration, and accessibility, simulate the types of permit spaces from which rescue is to be performed.


  • Asphyxiation from engulfment by water or the displacement of oxygen by the generator running nearby or other means.
  • Poisoning by exposure to toxic gases. Possibility of electric shock or electrocution by working with a portable electrical device connected to a temporary flexible cord.
  • A fall from the ladder, which could result in sprains, strains, fractures, contusions, concussion, or death as a result of using a ladder that was not secured, that did not extend beyond or level with the entry, and not being provided anchored fall protection.

Corrective Actions:

  • Remove the employee from the confined space.
  • Ensure generators are not being used next to an opening of a confined space.
  • Ensure permits are being completed, followed and that all parties are notified of the entry.
  • Include the water hazard in the permit, with ways to protect the employee from shock (while using electrical equipment) or engulfment.
  • Provide the employee with a four-gas meter.
  • Provide the proper rescue equipment.

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David Ashman, PCG, PCC
Safety Consultant
USF SafetyFlorida Consultation Program