Confined 

Space Program 

Recommendations for 

Dairy Plant Inspectors – 

Nationwide

Diana M. Ceballos, MS, PhD

Scott E. Brueck, MS, CIH

Health Hazard Evaluation Report

HETA 2010-0175-3144

November 2011

DEPARTMENT OF HEALTH AND HUMAN SERVICES

Centers for Disease Control and Prevention

Workplace

Safety and Health

 National Institute for Occupational 

Safety and Health
The employer shall post a copy of this report 

for a period of 30 calendar days at or near 

the workplace(s) of affected employees. The 

employer shall take steps to insure that the 

posted determinations are not altered, defaced, 

or covered by other material during such 

period. [37 FR 23640, November 7, 1972, as 

amended at 45 FR 2653, January 14, 1980].
Health Hazard Evaluation Report 2010-0175-3144 Page i

Report Abbreviations................................................................................................ii

Highlights of the NIOSH Health Hazard Evaluation........................iii

Summary .........................................................................................................v

Introduction ...................................................................................................1

Assessment.....................................................................................................1

Results..............................................................................................................2

Discussion.......................................................................................................8

Conclusions................................................................................................. 10

Recommendations.................................................................................... 10

References.................................................................................................... 13

Contents

Acknowledgments Acknowledgments and Availability of Report................................ 15
Page ii Health Hazard Evaluation Report 2010-0175-3144

Abbreviations

CFR Code of Federal Regulations

HHE Health hazard evaluation

IDLH Immediately dangerous to life and health

MSDS Material safety data sheet

NAICS North American Industry Classification System

NIOSH National Institute for Occupational Safety and Health

OSHA Occupational Safety and Health Administration

PPE Personal protective equipment 
Health Hazard Evaluation Report 2010-0175-3144 Page iii

The National Institute 

for Occupational Safety 

and Health (NIOSH) 

received a request for a 

health hazard evaluation 

from a manager of 

a federal agency to 

assess potential hazards 

encountered by the 

federal agency’s dairy 

equipment inspectors 

during entry into confined 

spaces. The requestor 

was concerned about 

the potential risk of 

oxygen deficiency and 

off-gassing of cleaning 

and disinfection products 

during equipment 

sanitation surveys in dairy 

plants.

Highlights of the

NIOSH Health

Hazard Evaluation

What NIOSH Did

● We visited two dairy plants in March 2011.

● We learned about typical dairy plant processes and 

equipment.

● We observed equipment sanitation surveys and reviewed 

survey forms.

● We reviewed a draft confined space program provided by the 

federal agency.

● We reviewed the confined space entry program at one of the 

dairies.

● We interviewed seven of 13 equipment inspectors about 

confined space entries. We asked them about their entry 

procedure, how often they entered confined spaces, confined 

space training, and if they had any work-related health or 

safety concerns.

What NIOSH Found

● Partial and whole body entries into permit-required confined 

spaces are common.

● Equipment inspectors rely solely on the dairy plant’s 

confined space entry program for their safety.

● Equipment inspectors may not wear the proper personal 

protective equipment even when it is required by the dairy 

plant.

● Dairy plants do not always inform equipment inspectors of 

their confined space program or rescue procedures.

● Some dairy plants do not perform air monitoring before or 

during entry into confined spaces.

● Equipment inspectors do not undergo annual training for 

confined space entry. When training is provided, it is not 

always relevant to the hazards of the dairy industry.

● The draft confined space entry program provided by the 

federal agency was not complete. The program did not give 

specific information about confined space hazards or how to 

protect oneself when entering confined spaces in the dairy 

industry.

● Equipment inspectors reported no injuries or health 

concerns related to entry into confined spaces.
Page iv Health Hazard Evaluation Report 2010-0175-3144

Highlights of the

NIOSH Health

Hazard Evaluation

 (continued)

What Managers Can Do

● Treat all confined spaces as permit required.

● Create specific confined space training for equipment 

inspectors in dairy plants.

● Require all equipment inspectors to take annual confined 

space training.

● Provide equipment inspectors with full body harnesses, 

lockout/tagout locks, confined space air monitors, and 

intrinsically safe flashlights.

What Employees Can Do

● Take annual confined space training.

● Review information about the plant’s permit-required 

confined spaces before your visit.

● Use appropriate safety equipment during equipment 

sanitation surveys. This should be done regardless of the 

dairy plant’s requirements.

● Review rescue procedures before making a full body entry 

into a confined space.

● Ask dairy plants to follow proper procedures for confined 

space entry.

● Monitor the air before making a confined space entry.
Health Hazard Evaluation Report 2010-0175-3144 Page v

NIOSH was asked by 

a federal agency to 

evaluate potential hazards 

encountered by its 

equipment inspectors 

during confined space 

entry in dairy plants. 

Confined space programs 

were also reviewed. 

We found potential 

exposures to oxygendeficient atmospheres, 

chemical disinfectants, 

and mechanical hazards. 

We determined that 

the agency’s draft 

confined space program 

was insufficient and 

should be tailored to 

equipment inspectors 

in the dairy industry. 

Recommendations 

were made to minimize 

confined space hazards.

Summary

NIOSH investigators evaluated a federal agency’s confined space 

program for equipment inspectors in dairy plants on March 1–2, 

2011, after receiving a request from the agency’s health and safety 

manager. The requestor was concerned with potential exposures 

to oxygen-deficient atmospheres and off-gassing of cleaning and 

disinfection products during equipment sanitation surveys in dairy 

plants. No health concerns were specifically reported. We toured 

one dairy plant on March 1, 2011, to learn about dairy plant 

processes and equipment. We evaluated typical procedures during 

an equipment sanitation survey on March 2, 2011, at a second 

dairy plant. We also reviewed the agency’s draft written confined 

space program and interviewed equipment inspectors about 

their confined space practices and work-related health and safety 

concerns.

We learned that dairy plants within the United States are 

increasing in size, which usually means more confined spaces in 

a plant. We observed six partial permit-required confined space 

entries (head and arm/hand into a vessel manhole for less than 

a minute) by an equipment inspector. We also observed several 

inspected pieces of equipment that were not confined spaces. 

The equipment inspector was accompanied at all times by plant 

personnel and usually wore a lab coat, safety glasses, hearing 

protection, bump cap, and a hair net, and used a high-intensity 

portable flashlight.

We found the agency’s draft confined space program hard to 

understand because much of it was written using legal jargon. 

Also, the program was not specific to the dairy industry and did 

not include rescue procedures in case of an emergency during an 

equipment sanitation survey.

Our interviews with equipment inspectors revealed that they 

routinely entered permit-required confined spaces during 

equipment sanitation surveys but were not always familiar with 

the permit-required confined space and rescue procedures of the 

dairy plants. Although equipment inspectors usually wore the 

PPE required by the dairy plant they were inspecting, we observed 

instances where equipment inspectors did not follow all of the 

plant’s requirements (for example, not wearing safety glasses or a 

bump cap when entering a confined space).

We recommend that the equipment inspectors obtain information 

about the plant’s permit-required confined spaces before visiting a 
Page vi Health Hazard Evaluation Report 2010-0175-3144

Keywords: NAICS 926140 (Regulation of Agricultural Marketing and 

Commodities), confined space, chlorine, survey, dairy products, 

oxygen deficiency, cleaning products, disinfection products, 

mechanical hazards

Summary

 (continued) dairy plant. This may include, but is not limited to, a copy of the 

plant’s written confined space entry program, recent calibration 

of the plant’s confined space air monitoring equipment, and 

information on confined space emergency and rescue plans.

We recommend that the agency tailor its confined space program 

to the equipment and hazards found in the dairy industry, 

including rescue procedures. The agency should provide equipment 

inspectors with adequate PPE, calibrated air monitors, and yearly 

training in confined space entry specific to the dairy industry. 

Equipment inspectors should follow plant PPE requirements and 

permit-required confined space procedures during equipment 

sanitation surveys. We recommend that equipment inspectors use 

a bump cap with a chin strap, safety glasses, and intrinsically safe 

flashlights. Inspectors should also have lockout/tagout locks and 

full-body harnesses.
Health Hazard Evaluation Report 2010-0175-3144 Page 1

Introduction

On March 1–2, 2011, we responded to a request for an HHE from 

the health and safety manager of a federal agency. The requestor 

was concerned about partial and full entries into confined spaces 

during equipment sanitation surveys in dairy plants and about 

potential hazards including oxygen deficiency and off-gassing 

of cleaners and disinfectants. No specific health concerns were 

reported. The agency had 13 equipment inspectors nationwide 

who visited different dairy plants throughout the year; each 

equipment sanitation survey lasted 1–3 days.

We visited two dairy plants to learn about typical processes and 

equipment and to observe activities during a typical equipment 

sanitation survey. We also interviewed six equipment inspectors by 

phone to ask about confined space entry practices, confined space 

training, and health and safety concerns during surveys. On March 

21, 2011, we sent an interim letter to the agency manager and an 

employee representative.

Assessment

We toured two dairy plants under normal operating conditions to 

better understand production processes, types of equipment used 

in the industry, and typical activities performed by an equipment 

inspector during an equipment sanitation survey. At both plants 

we met with employer and employee representatives to discuss the 

HHE request. On March 1, 2011, we toured a cheese and whey 

plant that had 225 employees. We asked employees and managers 

about typical confined space procedures for contractors/inspectors 

including entry permit, air monitoring, PPE use, training, and 

emergency rescue procedures.

On March 2, 2011, we visited a dry milk plant that had 125 

employees. We observed work processes, work practices, and 

workplace conditions and spoke with employees, including one 

equipment inspector. We observed the dry milk plant equipment 

sanitation survey performed by the equipment inspector and 

procedures for entry into confined spaces. We asked dairy plant 

employees about typical confined space procedures for visitors/

contractors including entry permit, air monitoring, PPE use, 

training, and emergency rescue procedures. We reviewed the 

plant’s written confined space program, copies of the confined 

space entry permits issued the day of our visit, written procedures 

for entry to specific equipment, and MSDSs of the chemicals used 

to clean the confined spaces inspected. We also reviewed a draft 
Page 2 Health Hazard Evaluation Report 2010-0175-3144

Assessment

 (continued) written confined space program provided by the federal agency 

along with the forms that equipment inspectors used while doing 

the equipment sanitation survey. Finally, because we had the 

opportunity to only talk to one equipment inspector during our 

site visits, we also randomly contacted six equipment inspectors or 

supervisors by phone. We interviewed them about confined space 

hazards encountered when they performed equipment sanitation 

surveys and asked about their training and work-related health and 

safety concerns.

Results

We learned in our visit on March 1, 2011, that cheese producers 

use either open or closed cheese vats and that equipment 

inspectors in large-scale production facilities encounter many 

confined spaces. During our visit on March 2, 2011, entry into 

confined spaces was only necessary when the equipment inspector 

was unable to see all of the processing equipment from outside 

the space. The equipment was inspected during the plant’s first 

shift. We learned that equipment sanitation surveys were usually 

performed after the equipment had been sanitized; therefore 

surveys were often performed during the night shift when 

sanitation was likely scheduled. The equipment inspector was 

always accompanied by one to three plant personnel.

According to the equipment inspector, only partial entry into 

a confined space was usually necessary. However, complete 

entry into a confined space was sometimes required for the 

equipment inspector to be able to see all of the internal processing 

components. 

On March 2, 2011, we observed the equipment inspector entering 

six permit-required confined spaces. Several pieces of inspected 

equipment were not considered confined spaces. During this 

equipment sanitation survey the equipment inspector wore a fullbody harness and lifeline provided by the plant for fall protection 

on a catwalk during a partial permit-required entry survey of a milk 

tanker (Figure 1); the other five permit-required entries during 

this survey did not require fall protection or retrieval equipment. 

During these confined space entries the equipment inspector 

placed his head and one arm and shoulder inside the space (Figure 

2). The equipment inspector did not wear safety glasses during the 

survey of the vessels. However, the dry milk plant’s safety policy 

was for all employees and visitors to wear safety glasses. We noted 
Health Hazard Evaluation Report 2010-0175-3144 Page 3

that the equipment inspector usually removed his bump cap when 

looking into a confined space so that the bump cap would not fall 

off his head.

In some instances there was inadequate communication of entry 

procedures between the plant employees and the equipment 

inspector before confined space entry. In one instance, the 

equipment inspector began entering a confined space, but the 

plant safety manager stopped him because the space was not yet 

ready for entry as the permit had not been issued yet.

All the permit-required confined spaces where the inspector 

performed partial entry had been sanitized prior to entry using 

clean-in-place procedures, which are procedures used to avoid 

disassembly or partial disassembly of dairy production vessels 

[Schmidt 2011]. The clean-in-place supply line usually included 

thermal and chemical sanitation. Thermal sanitation involves 

flushing with hot water or steam at a specified temperature and 

contact time, while chemical sanitation involves the use of an 

approved chemical sanitizer at a specified concentration and 

contact time [Schmidt 2011].

The two plants we visited had different confined space emergency 

rescue procedures. One plant relied on the local fire department, 

while the other plant used an onsite emergency response team. 

Because procedures can differ between dairy plants, equipment 

inspectors must be familiar with the emergency rescue procedures 

at each facility.

Review of Written Confined Space 

Programs

Dairy Plant Written Confined Space Program 

The written confined space program for the dairy plant was 

detailed, easy to read, and customized to the needs of the plant. 

All confined spaces in this plant were treated as permit-required 

confined spaces, as recommended by NIOSH [NIOSH 2011]. 

The written plan included a list of all the confined spaces and 

the hazards within each space. The following is an example of the 

hazard listing for a milk silo:

(1) Product supply line: suffocation if product enters the silo while 

an employee is inside 

(2) Clean-in-place supply line: chemical or hot water burns or 

suffocation

Results

 (continued)

Figure 1. Equipment inspector partially 

enters a milk tanker while wearing 

a full-body harness provided by the 

plant.

Figure 2. Equipment inspector makes a 

partial entry into a cream tank.
Page 4 Health Hazard Evaluation Report 2010-0175-3144

Results

 (continued) (3) Mechanical agitator: pinch points, amputations, lacerations, 

and death

(4) Slips and falls: slippery surface on the tank’s floor from the fat 

in milk

(5) Hazardous atmospheres: various kinds of hazardous 

atmospheres that may exist in a confined space

(6) Conductivity: electrical tools

(7) Chemicals: incompatibility and reactivity

The written program contained general entry procedures for typical 

hazards common to most equipment (e.g., oxygen-deficient or 

enriched, flammable atmosphere, and contaminated atmospheres) 

and specific procedures for processing equipment. We reviewed 

specific confined space entry procedures for a vapor separator, 

evaporator, milk tankers, and silo. All the procedures contained 

detailed entry descriptions, including photos. Equipment was 

rinsed with cold water after cleaning and before entry to minimize 

chemical hazards from cleaners and reduce slippery surfaces. 

Equipment was de-energized using lockout/tagout procedures and 

the atmosphere was tested for oxygen, carbon monoxide, hydrogen 

sulfide, and flammability levels with a 4-gas meter before entry. The 

dairy plant program included guidance for in-house and contract 

rescue procedures.

The confined space permit form used by the plant met the basic 

requirements of OSHA 1910.146. The permit included basic 

but essential information such as date and time, purpose of 

entry, personnel, emergency phone numbers, hazards expected, 

isolation checklist, safety precautions (PPE and communication), 

atmospheric testing (calibration date and air monitor result), 

and authorization. The plant was also in the process of updating 

this to a more detailed permit format. Permits in partial entries 

were properly completed. Because no whole body entries were 

conducted during our visit, we were not able to compare with 

partial entries.

Five MSDSs for equipment cleaning products used in the plant 

listed sodium hydroxide, sodium hypochlorite, nitric acid, 

phosphoric acid, sulfuric acid, and propionic acid. These are 

typical chemicals used in food processing [Schmidt 2011]. Sodium 

hydroxide (caustic soda) is a highly alkaline detergent used in many 

clean-in-place systems [Schmidt 2011]. In the dairy plant cleaning 

products, sodium hydroxide comes mixed with a solution of 

sodium hypochlorite (bleach). Chlorine compounds (like bleach) 
Health Hazard Evaluation Report 2010-0175-3144 Page 5

Results

 (continued) are the most commonly used sanitizers in food processing and 

handling applications because of their broad germicidal spectrum 

[Schmidt 2011]. When bleach is mixed with detergents (known 

as chlorinated detergents), the bleach acts like an oxidizing agent 

to clean protein residues. The inorganic and organic acids listed 

in the MSDSs account for common acid detergents that are 

often used in a two-step sequential cleaning regime with alkaline 

detergents for the prevention or removal of stone films like milk 

stone [Schmidt 2011].

The health and safety disadvantages to the use of alkaline and acid 

solutions are that they are corrosive, can cause burns, and are very 

reactive. Chlorine compounds can also initiate corrosion of many 

metal surfaces (especially at higher temperatures) [Schmidt 2011]. 

Health and safety concerns with bleach are skin irritation and 

mucous membrane damage in confined areas [Schmidt 2011]. At 

low pH (below 4.0), possibly caused by the use of acids, chlorine 

gas in lethal concentrations can form [Schmidt 2011].

Federal Agency Draft Written Confined Space 

Program

We found that the draft written confined space program for 

the agency was generalized to any industry or equipment and 

not specific to the hazards that may be encountered in the dairy 

industry. The draft program also contained legal jargon, making 

it difficult to understand. In addition, rescue procedures for 

equipment inspectors working in confined spaces in a dairy plant 

were missing from the program.

Employee Interviews

We interviewed seven of 13 equipment inspectors; six were 

interviewed by phone and one in a personal interview during our 

March 2, 2011, field visit. Equipment inspectors had worked an 

average of 21 years (range 9 to 30 years) and most performed one 

to three equipment sanitation surveys per week. Some supervisory 

equipment inspectors only did a few equipment sanitation surveys 

a year. All equipment inspectors visited a wide range of dairy 

facilities. All equipment inspectors reported that throughout the 

whole equipment sanitation survey process they were accompanied 

by one or three company personnel to answer questions about food 

safety, production, and equipment entry.
Page 6 Health Hazard Evaluation Report 2010-0175-3144

Results

 (continued) Equipment inspectors indicated that more confined space entries 

had been performed in the past, especially full body entries. Some 

equipment inspectors commented that more stringent safety 

regulations in dairy plants had discouraged confined space entries 

during sanitary surveys. Most equipment inspectors said they still 

regularly performed full body entries, with some stating they always 

had one or more full entries during an equipment sanitation 

survey. Some equipment inspectors said that full entries were 

performed sporadically when there was a need (e.g., need to further 

check internal structural integrity or cleanliness of the equipment). 

Equipment inspectors stated that they would more likely consider 

fully entering a confined space if the dairy plant equipment had 

cooled down after cleaning. Equipment inspectors reported 

remaining in a confined space from 1 to 10 minutes. Equipment 

inspectors reported full entries into the following confined spaces: 

milk tankers, cream tanks, evaporators, silos, driers, double 

enclosed cheese vats, and storage tanks.

All equipment inspectors reported performing partial confined 

space entries (usually head and sometimes hand, arm, and 

shoulder). One equipment inspector estimated that 80% of the 

equipment inspected could be categorized as a confined space and 

that a small plant could have up to nine vessels requiring partial 

entries; large plants would have more. Equipment inspectors 

reported from two to ten partial confined space entries per day 

during an equipment sanitation survey. Estimates of the duration 

for partial confined space entries ranged from 30 seconds to a few 

minutes and included entries into milk tankers, evaporators, and 

silos.

Equipment inspectors reported that they entered into a confined 

space to further assess cleanliness and construction of the 

equipment and look for potential cracks, films, or product build 

up. All inspectors used a flashlight during entry to help them 

properly see inside the space. Inspectors reported that their 

flashlights were not intrinsically safe and were bought by the 

equipment inspectors and compensated by the agency. Most used 

small but high powered emitting diode flashlights. Some described 

their flashlight as a “pen light” or “3 cell Maglite®.”

Equipment inspectors reported compliance with the dairy plant’s 

PPE requirements. Inspectors reported occasionally wearing a 

body harness when conducting a full confined space entry. Body 

harnesses were typically provided by the dairy plant. Partial entries 
Health Hazard Evaluation Report 2010-0175-3144 Page 7

Results

 (continued) usually required a bump cap, hair net, lab coat, safety glasses, ear 

plugs, and occasionally shoe covers. Some equipment inspectors 

reported removing the bump cap before entering the confined 

space to avoid losing it inside the equipment. Some equipment 

inspectors had their own lock for lockout/tagout of equipment.

Some but not all equipment inspectors were familiar with 

procedures for entry into confined spaces. However, some 

equipment inspectors were not sure if dairy plants performed air 

monitoring before entering a confined space and were not familiar 

with procedures or equipment used during air monitoring for 

entry into confined spaces. Most were familiar with lockout/tagout 

procedures before entering into a confined space. Further, several 

equipment inspectors believed that air monitoring and permit 

issuing were needed only for full body entries and not for partial 

entries.

Many equipment inspectors believed that safety awareness in the 

dairy industry had increased over the years, and they felt safe at 

their jobs. One inspector suggested that supervisors encouraged 

them to make decisions on safety, so equipment inspectors felt 

empowered. Some suggested that safety is learned primarily 

through experience on the job. All equipment inspectors agreed 

that training was last given during the national meeting 2 to 3 

years ago. Most equipment inspectors supported annual confined 

space refresher training, especially because national meetings are 

no longer held annually. Some specified that it would be ideal 

to provide online training on confined space so that it was more 

convenient. Many suggested that training should be tailored to the 

needs of the dairy industry, with specific examples of the hazards 

and procedures for the typical equipment that they inspect. One 

suggested creating a video that shows proper entry into confined 

spaces commonly encountered in the dairy industry.

Equipment inspectors reported no health concerns related to work. 

Some described concerns not related to confined space like “bad 

air” at one facility and a pump that was not locked. An equipment 

inspector described an incident many years ago in which he fully 

entered an enclosed cheese vat and had difficulty breathing. The 

inspector promptly and safely exited the vat, and continued the 

equipment sanitation survey.
Page 8 Health Hazard Evaluation Report 2010-0175-3144

Discussion

U.S. domestic dairy consumption has grown over the last 20 

years, with increases in population and per capita consumption of 

dairy products [Cessna 2011]. The increase in production usually 

translates into larger production plants with an increased number 

of confined spaces.

OSHA’s confined space regulations can be found at 29 CFR 

1910.146 [OSHA 2011a]. OSHA defines a confined space as a 

space large enough to physically enter, has limited entry and exit, 

and is not designed for continuous human occupancy. OSHA 

classifies confined spaces as permit required when one or more of 

the following conditions are met:

(1) The space contains or has the potential to contain a hazardous 

atmosphere.

(2) The space contains material that could engulf someone in the 

space.

(3) Internal configuration is such that the entrant could be trapped 

or asphyxiated.

(4) The space contains any other recognized serious safety or health 

hazard.

Under the OSHA confined space regulation, requirements for 

dairy plant equipment inspectors would be similar to those 

for contractors. When a plant arranges to have a contractor 

perform work that involves confined space entry, the following 

requirements apply: informing the contractor of the facility’s 

permit spaces and their hazards, advising the contractor on 

confined space precautions and procedures, coordinating entry 

operations, and debriefing the contractor regarding any hazards 

created or confronted during and at the end of the entry. The 

contractor’s responsibilities are to obtain any available information 

about the permit space hazards and entry operations of the plant, 

coordinate operations with them, and inform the plant of any 

hazards created or confronted during or at the end of the entry. 

The OSHA confined space standard does not specify a frequency 

of training, only that adequate training is provided prior to 

assignment to confined space entry operations.

NIOSH defines a confined space as a space that by design has 

limited openings for entry and exit, unfavorable natural ventilation 

that could contain or produce dangerous air contaminants, and 

that is not intended for continuous employee occupancy [NIOSH 

2011]. In the NIOSH confined space criteria document, confined 

spaces are classified on the hazard potential or existing hazard. 
Health Hazard Evaluation Report 2010-0175-3144 Page 9

Discussion

 (continued) Confined spaces are divided into three classes: class A (IDLH), 

class B (dangerous but not IDLH), and class C (a potential hazard). 

All three classes require atmospheric testing [NIOSH 2011]. 

Continuous monitoring of the confined space is required for 

class A and optional for class B and C. Unlike OSHA, NIOSH 

recommends an entry permit system and the use of rescue 

procedures for all three confined space classifications. Classes A 

and B require a standby person equipped with a self-contained 

breathing apparatus. For class C spaces, rescue personnel must 

use supplied air or self-contained breathing apparatus to remove 

victims. NIOSH recommends training at least annually for any 

confined space entry [NIOSH 2011].

Considering that most confined spaces inspected by equipment 

inspectors in the dairy industry are permit-required confined 

spaces defined by OSHA and NIOSH [OSHA 2011a, NIOSH 

2011], the agency could manage entry into confined spaces for 

equipment inspectors by following the OSHA standard for permitrequired confined spaces (29 CFR 1910.146) [OSHA 2011a]. 

The OSHA standard does allow a permit-required space to be 

reclassified as a non-permit-required space [OSHA 2011a, OSHA 

2011c]. However, to make this determination, the employer must 

document the basis for determining that all hazards in a permit 

space have been eliminated [OSHA 2011a, OSHA 2011c]. On the 

basis of our observations of the dairy processing equipment in this 

evaluation, we assume that an equipment inspector, at a minimum, 

would need to document proper lockout/tagout procedures and 

air monitoring before entry.

Alternatively, the agency could follow NIOSH guidance and 

recommend that equipment inspectors treat all confined space 

entries (both full and partial) as permit required [NIOSH 2011]. 

The advantages of this approach are reduced confusion in 

distinguishing between permit-required and non-permit-required 

confined spaces and documentation of each entry.

Because the quality of confined space programs differs throughout 

the industry, equipment inspectors should have the option of using 

an agency provided and calibrated air monitor before confined 

space entries. It can be used when the plant does not conduct its 

own air monitoring or to verify that the plant’s air monitoring 

results are accurate. The former procedure is used by OSHA 

compliance officers before entering a confined space [OSHA 

2011b]. Additionally, having equipment inspectors involved 
Page 10 Health Hazard Evaluation Report 2010-0175-3144

in the confined space permit issuing procedure may improve 

communication with the plant’s safety personnel in determining 

when it is safe to enter. The agency would need to obtain air 

monitors and provide specific training in their use.

Discussion

 (continued)

Conclusions

On the basis of our site visits and the interviews with equipment 

inspectors, we conclude that equipment inspectors in dairy plants 

routinely enter into OSHA permit-required confined spaces 

when performing equipment sanitation surveys. These entries 

involve partial or whole body entries to assess the cleanliness and 

maintenance of dairy processing equipment. Some entries were 

performed without having had a permit-required confined space 

entry permit completed. Additionally, not all equipment inspectors 

are sufficiently trained in confined space hazards and procedures, 

may not have the necessary entry equipment and PPE, and are not 

always familiar with confined space entry and rescue procedures 

of the dairy plant. Our review of the federal agency confined 

space program suggests that the written draft was too general and 

lacked information regarding specific hazards faced by equipment 

inspectors in the dairy industry and proper rescue procedures.

Recommendations

On the basis of our findings, we recommend the actions listed 

below to create a more healthful workplace. We encourage the 

agency to use a labor-management health and safety committee 

or working group to discuss the recommendations in this report 

and develop an action plan. Those involved in the work can best 

set priorities and assess the feasibility of our recommendations 

for the specific situation at the agency. Our recommendations 

are based on the hierarchy of controls approach. Some of these 

recommendations were provided to management and employee 

representatives in an interim letter dated March 22, 2011.

Engineering Controls

Engineering controls reduce exposures to employees by removing 

the hazard from the process or placing a barrier between the 

hazard and the employee. Engineering controls are very effective 

at protecting employees without placing primary responsibility of 

implementation on the employee.
Health Hazard Evaluation Report 2010-0175-3144 Page 11

1. The agency should continue to provide locks to equipment 

inspectors and promote their use to make sure that lockout/

tagout procedures are enforced during their visits.

Administrative Controls 

Administrative controls are management-dictated work practices 

and policies to reduce or prevent exposures to workplace hazards. 

The effectiveness of administrative changes in work practices 

for controlling workplace hazards is dependent on management 

commitment and employee acceptance. Regular monitoring and 

reinforcement are necessary to ensure that control policies and 

procedures are not circumvented in the name of convenience or 

production.

1. Obtain information about a dairy plant’s confined spaces 

prior to the survey. This may include, but is not limited to, 

a copy of the plant’s written confined space entry program, 

documentation of recent calibration of the plant’s confined 

space air monitoring equipment, and information on confined 

space rescue and emergency plans.

2. Request that the plant always perform a water rinse after 

chemically cleaning equipment and before a confined space 

entry is conducted.

3. Treat all confined spaces as permit-required confined spaces.

4. Update the agency’s written confined space program to include 

detailed descriptions of the specific hazards that equipment 

inspectors may encounter in dairy plants and procedures to 

mitigate these hazards. The program should also have specific 

information about PPE, air monitoring, rescue procedures, and 

training pertaining to confined space entry in a dairy plant.

5. Make calibrated air monitors available for use by inspectors, and 

train equipment inspectors in their use.

6. Provide yearly training in confined spaces, tailored to the 

specific hazards typical in dairy plants. Using online resources 

may be an option considering that equipment inspectors are 

located across the country. Bannen [2009] provides guidelines 

and suggestions for developing an effective confined space 

training program.

Recommendations

 (continued)
Page 12 Health Hazard Evaluation Report 2010-0175-3144

Recommendations

 (continued) Personal Protective Equipment

PPE is the least effective means for controlling employee exposures. 

Proper use of PPE requires a comprehensive program and calls 

for a high level of employee involvement and commitment to be 

effective. The use of PPE requires the choice of the appropriate 

equipment to reduce the hazard and the development of 

supporting programs such as training, change-out schedules, and 

medical assessment if needed. PPE should not be relied upon as 

the sole method for limiting employee exposures. Rather, PPE 

should be used until engineering and administrative controls can 

be demonstrated to be effective in limiting exposures to acceptable 

levels.

1. Instruct equipment inspectors to always wear adequate PPE 

including safety glasses, bump cap, safety boots, and ear 

protection (if in a noisy environment). Inspectors must follow 

any other plant PPE requirements during site visits. A bump 

cap may be used with a chin strap so that it does not fall off the 

inspector’s head into the confined space.

2. Use a full-body harness (where required) provided by the federal 

agency when possible. Always inspect the harness before each 

entry. NIOSH recommends always wearing a full body harness 

in any full body entry typical to this industry, which would be 

considered confined space classes B and C [NIOSH 2011].
Health Hazard Evaluation Report 2010-0175-3144 Page 13

References

Bannen JW [2009]. Determining confined space training 

requirements. Occup Health Saf 78(2):52–54.

Cessna J [2011]. Situation and outlook for the U.S. dairy industry. 

[http://www.usda.gov/oce/forum/2010_Speeches/Speeches/

DairyOutlook2010.pdf]. Date accessed: September 2011.

NIOSH [2011]. Confined space criteria for a recommended 

standard. Cincinnati, OH: U.S. Department of Health and 

Human Services, Centers for Disease Control and Prevention, 

National Institute for Occupational Safety and Health, DHEW 

(NIOSH) Publication No. 80-106.

[http://www.cdc.gov/niosh/80-106.html]. Date accessed: 

September 2011.

OSHA [2011a]. Safety and health topics: confined spaces. [http://

www.osha.gov/SLTC/confinedspaces/index.html]. Date accessed: 

September 2011.

OSHA [2011b]. OSHA field safety and health manual. [http://

www.osha.gov/OshDoc/Directive_pdf/ADM_04-00-001.pdf]. Date 

accessed: September 2011.

OSHA [2011c]. Elevator industry employees working in and 

around pits and equipment. Standard interpretation of August 

19, 1994, from John B. Miles, Director Directorate of Compliance 

Programs, Occupational Safety and Health Administration, to 

Edward A. Donoghue Associates, Inc.

Schmidt RH [2011]. Institute of Food and Agricultural Sciences, 

University of Florida. [http://www.gaps.cornell.edu/Weblinks/

Sanitizing_Equipment_Florida.pdf]. Date accessed: September 

2011.
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Health Hazard Evaluation Report 2010-0175-3144 Page 15

Acknowledgments and

Availability of Report The Hazard Evaluations and Technical Assistance Branch 

(HETAB) of the National Institute for Occupational Safety and 

Health (NIOSH) conducts field investigations of possible health 

hazards in the workplace. These investigations are conducted 

under the authority of Section 20(a)(6) of the Occupational Safety 

and Health Act of 1970, 29 U.S.C. 669(a)(6) which authorizes 

the Secretary of Health and Human Services, following a written 

request from any employer or authorized representative of 

employees, to determine whether any substance normally found 

in the place of employment has potentially toxic effects in such 

concentrations as used or found. HETAB also provides, upon 

request, technical and consultative assistance to federal, state, and 

local agencies; labor; industry; and other groups or individuals to 

control occupational health hazards and to prevent related trauma 

and disease.

Mention of any company or product does not constitute 

endorsement by NIOSH. In addition, citations to websites 

external to NIOSH do not constitute NIOSH endorsement of 

the sponsoring organizations or their programs or products. 

Furthermore, NIOSH is not responsible for the content of these 

websites. All Web addresses referenced in this document were 

accessible as of the publication date.

This report was prepared by Diana M. Ceballos and Scott E. 

Brueck of HETAB, Division of Surveillance, Hazard Evaluations 

and Field Studies. Health communication assistance was provided 

by Stefanie Evans. Editorial assistance was provided by Ellen 

Galloway. Desktop publishing was performed by Greg Hartle.

Copies of this report have been sent to employee and management 

representatives at the federal agency, the two dairy plants 

evaluated, and the Occupational Safety and Health Administration 

National Office. This report is not copyrighted and may be freely 

reproduced. The report may be viewed and printed at http://

www.cdc.gov/niosh/hhe/. Copies may be purchased from the 

National Technical Information Service at 5825 Port Royal Road, 

Springfield, Virginia 22161.
Below is a recommended citation for this report:

NIOSH [2011]. Health hazard evaluation report: recommendations for a confined 

space program for equipment inspectors – nationwide. By Ceballos D, Brueck 

S. Cincinnati, OH: U.S. Department of Health and Human Services, Centers for 

Disease Control and Prevention, National Institute for Occupational Safety and 

Health, NIOSH HETA No. 2010-0175-3144.

To receive NIOSH documents or information about 

occupational safety and health topics, contact NIOSH at:

1-800-CDC-INFO (1-800-232-4636)

TTY: 1-888-232-6348

E-mail: cdcinfo@cdc.gov

or visit the NIOSH web site at: www.cdc.gov/niosh.

For a monthly update on news at NIOSH, subscribe to 

NIOSH eNews by visiting www.cdc.gov/niosh/eNews.

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