Under 29 CFR 1910.146(c)(4), if an employer decides its employees will enter permit spaces, it must develop and implement a written permit space program that complies with 1910.146, and make it available for inspection by employees and their representatives.
The 14 required program elements
1910.146(d) says the program must:
- Prevent unauthorized entry (barriers, locks, signs, training).
- Identify and evaluate the hazards of permit spaces before entry.
- Develop and implement the means, procedures and practices for safe entry, including specifying acceptable entry conditions, letting entrants observe monitoring, isolating the space, purging, inerting, flushing or ventilating, providing barriers, and verifying conditions throughout entry.
- Provide, maintain and ensure use of equipment (testing, ventilation, communications, PPE, lighting, barriers, ladders, rescue) at no cost to employees.
- Evaluate permit space conditions: test before entry, test or monitor during entry, test oxygen then flammables then toxics, and let entrants observe and request retesting.
- Provide at least one attendant outside the space for the duration of entry.
- If one attendant monitors multiple spaces, include the means and procedures to respond to an emergency in one space without neglecting the others.
- Designate the people with active roles (entrants, attendants, entry supervisors, testers), identify their duties and provide training.
- Develop procedures for summoning rescue and emergency services, rescuing entrants, providing emergency services, and preventing unauthorized rescue attempts.
- Develop a permit system for preparing, issuing, using and canceling permits.
- Coordinate entry operations when employees of more than one employer work in a permit space at the same time.
- Develop procedures for concluding entry, such as closing the space and canceling the permit.
- Review entry operations when there's reason to believe the measures may not protect employees, and revise the program before further entries.
- Review the program at least annually using canceled permits kept for at least a year, and revise as needed.
A practical outline
1. Purpose, scope and responsibilities
Which sites and spaces are covered, which standard applies (1910.146, Subpart AA, or both), and who owns the program, from the program administrator to entry supervisors.
2. Confined space inventory
Every confined space, its location and ID number, classification (permit, non-permit, alternate procedures, reclassified), hazards, and the date evaluated. Use our hazard evaluation checklist.
3. Preventing unauthorized entry
Signs, locks, barriers and training for employees who aren't authorized.
4. Hazard controls and entry procedures
Space-specific isolation lists, cleaning and purging, ventilation setup, acceptable entry conditions and PPE.
5. Atmospheric testing
Instruments, bump test and calibration procedures, testing order, sampling technique and recordkeeping. See atmospheric testing.
6. Roles and training
Duties of entrants, attendants and entry supervisors, training content, proficiency checks, retraining triggers and training certification (name, trainer signature or initials, dates).
7. Permit system
Your permit form (see our entry permit template), who issues and signs it, posting, duration, cancellation and retention.
8. Rescue and emergency services
Rescue method by space, retrieval systems, rescue service evaluation and confirmation, practice drills, first aid and CPR, and SDS handoff to medical providers.
9. Contractors and multi-employer entries
How you inform contractors of spaces and hazards, coordinate simultaneous entries, and debrief afterward (1910.146(c)(8) and (c)(9)).
10. Alternate procedures and reclassification
Which spaces qualify, the supporting monitoring data and the written certifications.
11. Program review
Post-entry reviews when problems occur and the annual review using canceled permits.
Sources and official references
Last reviewed: October 25, 2026 · Free general education based on OSHA 29 CFR 1910.146 and 29 CFR 1926 Subpart AA. It does not replace the site-specific training, written program and hands-on evaluation your employer must provide, and it does not issue a certificate. Nothing you enter on this page is saved or sent.