Confined Spaces: Managing Risk of Entering Tanks Used to Transport Cargo (Updated)

By Matt Sokol, VP Sales and Marketing

Cargo tanks are often unrecognized as a confined space hazard.

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However, the tankers do have a completely enclosed storage vessel, which could put inspectors, technicians, and workers performing any maintenance at risk.

At APC, we strive to be a world-class coatings solution provider, and with that comes the commitment to stay on top of tank safety. This article covers the real risks associated with confined spaces, what companies can do to reduce the risks, and why it's time to reevaluate tank safety and reduce injuries and fatalities related to them.

Cargo Tanks are Confined Spaces

By definition, a cargo tank means an assembly used for transporting, hauling, or delivering liquids and that consists of a tank having one or more compartments mounted on a wagontrucktrailerrailcar, or wheels.

What are Confined Spaces?

Confined spaces have limited or restricted means for entry or exit and are not designed for continuous occupancy. Examples of an enclosed space include tank containers, road tank trailers, tank railcars, and maritime cargo tanks.  

Real Risks Associated with Confined Spaces

There are life-threatening risks for people who work in confined spaces.

  •  Limited Openings for Entry and Egress - Confined spaces are not designed to be regularly entered and exited by workers. This means that entry and egress of confined spaces is often a slow process. When something goes wrong inside an enclosed space, it can be impossible for a worker to escape in time. The slow process of entry can inhibit rescue attempts.
  •  Inadequate Ventilation - Unlike spaces designed for worker occupation, gases cannot move freely in and out of confined spaces. This can lead to dangerous environments developing within enclosed spaces that lack oxygen to breathe. Workers can quickly asphyxiate in these environments.
  • Not Designed for Long-Term Worker Operation - Because confined spaces are not designed for continuous occupancy, they present many dangers to those who must work within them. Their design can make them difficult to escape in the event of an emergency. Additionally, their harsh yet unassuming environment presents a risk to rescuers.

Occupational Safety and Health Administration (OSHA) Regulates Workplaces 

OSHA ensures safe working conditions by setting and enforcing standards and providing training, education, and assistance.

According to the federal standard 1910.146(g)(1), employees are required to demonstrate appropriate skills related to performing in any confined space.

The standard 1910.146(g)(1) states:

"The employer shall provide training so that all employees whose work is regulated by this section acquire the understanding, knowledge, and skills necessary for the safe performance of the duties assigned under this section."

These skills could include:

  • Facilitating a confined space rescue—using emergency retrieval equipment and operating a gas tester to determine whether a tank has safe entry conditions.
  • To comply with OSHA requirements, employees working with cargo tank trucks must also demonstrate their knowledge of personal protective equipment. 1910.132(f)(2) cites:

"Each affected employee shall demonstrate an understanding of the training specified in paragraph (f)(1) of this section, and the ability to use PPE properly, before being allowed to perform work requiring the use of PPE."

How Can Companies Reduce the Risks Associated with Working in a Confined Space and Ensure Safe Work Practices? 

  • Provide employees with awareness training (training and instruction specific to enclosed space working) to heighten awareness of the risks.
  • Implement procedures designed to prevent injuries.
  • Ensure that workers secure assistance before entering confined spaces.
  • Continuously test areas for oxygen levels or any changes to the atmospheric content of the enclosed space while performing any work.
  • A competent "watcher" should always be present to monitor the working environment. You need a method of communication between workers inside the space and those outside. This is the first step in emergency response.
  • Develop an emergency rescue plan.
  • Conduct regular drills to ensure the effectiveness of your plan.
  • Conduct risk assessment of the task, the working environment, working materials and tools, the competence of the workers, arrangements for emergency response before performing any work in a confined space.
  • Ensure that proper equipment for confined space retrieval or rescue is on hand.
  • Ensure that the person working in the enclosed space is not claustrophobic and is adequately trained to operate any breathing gear.
  • Maintaining a zero-tolerance policy for unplanned entries into confined spaces that violates company safety rules. — American Society of Safety Professionals  


Industry must mitigate the risks associated with enclosed spaces to prevent any fatalities surrounding them. This can be done by ensuring safe work practices are used throughout the industry. 

When companies act and set an example, the safety culture can be strengthened. Employers must provide workers with proper equipment, training, and safe methodologies to secure entry into confined spaces.

As a global coatings solution provider, we look to increase awareness of the risks surrounding confined spaces to help prevent accidents in the years to come.


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