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What a Confined Space Program Actually Includes (Section by Section)

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What a Confined Space Program Actually Includes (Section by Section)

If your facility has confined spaces and your employees enter them, California requires a written confined space program.

If your facility has confined spaces and your employees enter them, California requires a written confined space program. Knowing that doesn’t tell you what the document looks like, what goes in each section, or how to tell whether yours is complete.

This is a section-by-section walkthrough of what a Cal/OSHA-compliant written program contains. The structure below matches what CDMS uses when we write one: ten sections, each tied to a specific requirement in 8 CCR §5157.

For the broader overview of when a program is required and how CDMS delivers it, see our confined space program guide. This piece focuses on the document itself.

Two workers reviewing facility plans together

Why the Structure Matters

When a Cal/OSHA inspector or a customer auditor asks to see your confined space program, they look for a specific set of components. A program that names confined spaces but skips rescue, or covers entry permits but omits contractor procedures, reads as incomplete on its face.

When we walk a facility for an IIPP review or a gap assessment, the most common deficiency we find isn’t the absence of a program. It’s a program that exists but is missing two or three required sections. Usually rescue procedures, contractor language, or training documentation.

The ten sections below mirror the structure of the program template CDMS uses for California facilities and the operative requirements in 8 CCR §5157.

The Ten Sections of a Written Confined Space Program

1

Introduction (Definitions, Job Descriptions, Employee Designations)

The first section establishes the vocabulary. It defines confined space, permit-required confined space, entry, hazardous atmosphere, and the other regulatory terms. It also assigns roles by job title: who is an authorized entrant, who is an attendant, who is the entry supervisor.

The job descriptions matter because Cal/OSHA wants to see that responsibilities are tied to positions, not just to specific people. When an attendant leaves the company, the position still has the duties.

2

Permit-Required Confined Spaces (Location, Description, Hazards)

This section is the inventory. Every permit-required confined space at the facility is listed by location, with a description of the space, the hazards it presents, the conditions under which entry can be safe, and the testing and monitoring required.

It also addresses unauthorized entry: how the facility prevents employees who are not authorized entrants from going into permit spaces. Signage, locks, and labeling go here.

The most common gap we find in this section is a confined space list that hasn’t been updated after operational changes. A new tank, a reconfigured vault, or a process change can introduce a space that nobody added to the program.

3

Entry Permit Procedures

Section 3 describes how the entry permit system works at the facility: who issues permits, who signs them, how long they remain valid, what conditions cause cancellation, and where they are stored.

This is the procedural backbone of the program. The permit form itself lives in Section 7. For what goes on the form, see confined space entry permits explained.

4

Rescue and Emergency Services

Section 4 documents the rescue plan. Cal/OSHA requires that rescue arrangements be made and verified before entry, not at the moment a rescue is needed.

The plan must specify how rescue will happen: by trained on-site rescuers, by a contracted standby team, by non-entry retrieval using a tripod and winch, or by some combination. “We’ll call the fire department” is not a sufficient rescue plan, and it’s the single most common assumption we have to correct during program development. Most municipal fire departments are not trained or equipped for confined space entry, and response times can easily exceed the window where rescue is still meaningful.

5

Personal Protection and Monitoring

This section covers the protective equipment required for entry into each permit space: respiratory protection, fall protection, communication equipment, and atmospheric monitoring instruments.

It also documents what continuous monitoring looks like during entry. Oxygen, flammable gas (measured against the Lower Explosive Limit, or LEL), and specific toxic substances are tested based on the hazard assessment for each space.

6

Contract Employees

If contractors enter your confined spaces (which is common in California for tank cleaning, vault work, manhole entry, and roof drain maintenance), the program must address how the host employer coordinates with them.

This includes informing contractors about the hazards, the host facility’s program, and any precautions required. It also documents how the host verifies that the contractor has their own compliant program or follows yours.

Contractors entering your space do not shift liability away from you. A 2026 conference presentation by Cal/OSHA’s local CUPA partners (the agencies that enforce hazardous-materials rules at the county or city level, which may be a county environmental health department, fire department, or another local agency depending on jurisdiction) emphasized this point directly: a hiring company can still be held liable if a contractor incident occurs.

Not sure whether your existing program covers contractor entry?Call (925) 551-7300. We’ll review what you have and tell you where the gaps are.
7

Entry Permit (the Operational Form)

Section 7 contains the actual entry permit form. This is the document filled out at the time of each entry, listing the entrant names, the space, the date, the atmospheric test results, the equipment in use, the isolation steps (including lockout/tagout if applicable), and the authorizing signatures.

A standard permit runs through about twenty fields. Missing one is the most common deficiency inspectors cite after the permit has been used.

8

Canceled Entry Permits

Section 8 covers what happens to permits after entry is complete. California requires retention of canceled permits and an annual review of them, with documentation of any problems encountered during entries.

The annual review is a feedback loop. Patterns in canceled permits (recurring atmospheric issues, equipment problems, near-misses) should drive updates to the program.

9

History of Accidents and Incidents

Any confined space accident, near-miss, or incident at the facility is logged in this section. The point is institutional memory. A new entry supervisor reading the program should understand what has happened before and what was changed in response.

For facilities with no incident history, the section states that and notes the date it was last verified.

10

Permit Space Training Program

The final section describes the facility’s training program: who is trained, on what content, in what language, how often, and how training records are kept. California requires training before initial assignment, when duties or operations change, when deficiencies in the program are discovered, and on a periodic refresher schedule.

For details on California training requirements and how training is delivered, see confined space training requirements in California.

What the Document Should Not Be

A confined space program is not the IIPP. Facilities sometimes try to embed everything inside their Injury and Illness Prevention Program (the document required by 8 CCR §3203), and the result is usually a combined document so long that nobody reads it and nobody can train against it.

A standalone confined space program lets the people who need it (entrants, attendants, entry supervisors, and contractors) work from a focused document. It also keeps the IIPP usable for general employees, who don’t need to read forty pages about atmospheric testing.

Common Gaps We Find

When we audit existing confined space programs, the same gaps show up:

  • The confined space inventory is outdated, missing spaces added during operational changes
  • Rescue procedures reference “calling 911” without verifying that the local fire department actually performs confined space rescue
  • Contractor coordination procedures are missing entirely
  • Training records live in a separate system and aren’t referenced in the program
  • The entry permit form has not been filled out in years, suggesting permits aren’t being issued for actual entries

These aren’t violations until Cal/OSHA cites them. They are deficiencies, and they’re typically straightforward to close once identified.

Before writing a program, you also need to know whether you need one at all. For that question, see do you need a permit-required confined space program.

Want a section-by-section review of your existing confined space program?Call (925) 551-7300. We’ll walk through your document, identify the gaps, and tell you what it would take to bring the program current with 8 CCR §5157.

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BSY started working with CDMS last year after our in-house EHS person departed the company. CDMS reviewed our existing operational permits as well as any additional Federal, State and Local regulations that could apply and helped us to create a comprehensive compliance calendar to track regulatory deadlines and submittal due dates. The CDMS team does an excellent job of tracking everything and can be relied upon to complete the forms accurately and assist with submittals, allowing me to focus on our business.
Gerona Goethe · General Manager · Bay Ship

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