Manhole Entry Requirements: Before, During and After Entry

Before anyone enters a manhole or manway that is a permit-required confined space, the space must be evaluated, the atmosphere tested, an attendant and entry supervisor assigned, rescue arranged and a signed entry permit issued. During entry, conditions are monitored and the attendant stays outside. Whenever the cover is off, the open manhole must be guarded and people must be warned of the danger.

Below is a practical summary of US OSHA rules and the UK Confined Spaces Regulations 1997. It is not legal advice; always read the regulation that applies to your site.

Is your manhole a permit-required confined space?

Under 29 CFR 1910.146(b), a confined space can be bodily entered to perform work, has limited or restricted means for entry or exit, and “is not designed for continuous employee occupancy.” Tanks, vessels and pits are named as examples. It becomes a permit-required confined space (permit space) when it:

• contains or has a potential to contain a hazardous atmosphere;
• contains a material that could engulf an entrant;
• has an internal configuration that could trap or asphyxiate an entrant; or
• contains any other recognized serious safety or health hazard.

The employer must evaluate the workplace for permit spaces ((c)(1)) and inform exposed employees by posting danger signs or any other equally effective means ((c)(2)).

Before entry: what must be in place

The measures of (d)(3) are documented in an entry permit before entry is authorized ((e)(1)), and the entry supervisor signs it before entry begins ((e)(2)).

Pre-entry checklist

• Acceptable entry conditions specified ((d)(3)(i)).
• Isolation of the permit space ((d)(3)(iii)).
• Atmospheric control by purging, inerting, flushing or ventilating as needed ((d)(3)(iv)).
• Barriers: “pedestrian, vehicle, or other barriers as necessary to protect entrants from external hazards” ((d)(3)(v)).
• Atmospheric testing before entry is authorized ((d)(5)(i)), first for oxygen, then combustible gases and vapors, then toxic gases and vapors ((d)(5)(iii)).
• Equipment from (d)(4): testing, ventilation, communications, PPE, lighting, barriers and shields, ladders and rescue equipment.
• Retrieval: retrieval systems or methods for each entrant, unless they would increase overall risk or not aid rescue, with a mechanical device for vertical permit spaces “more than 5 feet (1.52 m) deep” ((k)(3)).
• Rescue service evaluated, selected and informed of the hazards ((k)(1)).
• Permit completed per (f), verified by the entry supervisor ((j)(2)) and available to entrants at the time of entry ((e)(3)).

During entry

Conditions are tested or monitored during entry ((d)(5)(ii)). Under paragraph (i), the attendant keeps an accurate count of entrants, remains outside until relieved, communicates with entrants, orders evacuation and summons rescue when needed. If unauthorized persons approach, the attendant must “Warn the unauthorized persons that they must stay away from the permit space” ((i)(8)(i)). A clearly visible barrier at the manhole supports that job.

After entry

The entry supervisor cancels the permit when the work is completed or a condition not allowed by the permit arises ((e)(5)). Cancelled permits are kept for at least one year, with any problems noted ((e)(6)). Until the cover is back on, the open manhole still needs guarding.

Guarding an open manhole when nobody should enter

Paragraph (c)(3) of 1910.146 says that if the employer decides its employees will not enter permit spaces, “the employer shall take effective measures to prevent its employees from entering the permit spaces.” For construction, 29 CFR 1926.1203(c) is similar.

For entries under the alternate procedures of 1910.146(c)(5), paragraph (c)(5)(ii)(B) states: “When entrance covers are removed, the opening shall be promptly guarded by a railing, temporary cover, or other temporary barrier that will prevent an accidental fall through the opening and that will protect each employee working in the space from foreign objects entering the space.” The construction standard, 1926.1203(e)(2)(ii), uses similar wording and requires the opening to be “immediately guarded.”

Important: CableSafe confined space barriers restrict entry and warn personnel. They are not fall protection. Where a fall through the opening is possible, use guarding that is designed to prevent falls, and use CableSafe barriers to mark and restrict the opening.

Which CableSafe barrier fits which opening

The Manhole Entry, Skirt and Quick Barriers suit openings of metal, wood, masonry, brick, polycarbonate, rubber or plastic, with a 15 cm round reflective sign. Browse the full confined space safety range or request a quote with your opening sizes.

UK and EU sites

In Great Britain, regulation 4(1) of the Confined Spaces Regulations 1997 states that “No person at work shall enter a confined space to carry out work for any purpose unless it is not reasonably practicable to achieve that purpose without such entry.” Regulation 4(2) requires a safe system of work, and regulation 5(1) requires “suitable and sufficient arrangements for the rescue of persons in the event of an emergency.” HSE L101, “Safe work in confined spaces” (third edition, 2014), is the Approved Code of Practice. Elsewhere in Europe, check your national rules.

Frequently asked questions

Does leaning into a manhole count as entry?

Yes. Under 29 CFR 1910.146(b), entry “is considered to have occurred as soon as any part of the entrant’s body breaks the plane of an opening into the space.”

Can a manhole barrier replace the attendant?

No. The attendant duties in 1910.146(i) still apply. A barrier gives a physical and visual warning at the opening; it does not take over those duties.

Are CableSafe manhole barriers fall protection?

No. CableSafe confined space barriers restrict entry and warn personnel. They are not fall protection. If a fall through the opening is possible, use guarding that is designed to prevent falls.

How do I choose the right barrier size?

Measure the opening and compare it with the datasheet sizes in the table above. The Manhole Quick Barrier is also available in a custom size. Certificates are available on request.

Sources

• 29 CFR 1910.146 Permit-required confined spaces (eCFR)
• 29 CFR 1910.146 (Cornell LII full text)
• 29 CFR 1926.1203 General requirements, Confined Spaces in Construction (Cornell LII)
• Confined Spaces Regulations 1997, regulation 4
• Confined Spaces Regulations 1997, regulation 5
• HSE L101 Safe work in confined spaces