Standards developed by NIOSH, ANSI, NFPA, and API referred to as National Consensus Standards
"National Consensus Standard" means any occupational safety and health standard that has substantial agreement on its adoption
Unless referenced or incorporated into a governing standard, consensus standards are "Best Practice" advice only
OSHA 29 CFR 1910.146
Permit Required Confined Spaces
Requirements for practices and procedures to protect employees in general industry from the hazards of entry into permit-required confined spaces
Does not apply to:
Agriculture
Construction
Shipyard employment
Vertical vs. Horizontal Standards
Vertical standards apply to specific industries or activities
If an employee is working in an industry where a vertical or industry-specific standard applies, then the entry is subject to the vertical standard
If vertical standard not applicable, general industry standard prevails
A list of vertical standards is found in Appendix B of CPL 2.100, p. 8
Construction
Even though the activity is taking place in a confined space, 1910.146 does not apply to construction
The activity is regulated by the appropriate vertical standard (e.g. trenching and shoring)
Construction now has its own proposed CS standard: rule has not been finalized
Construction Exception
29 CFR 1910.146 is not applicable to construction
However, when construction companies perform work other than construction they are subject to the confined space standard
For example, maintenance and repair activities, even if performed by a construction company, DO fall under 29 CFR 1910.146
1910.146 General Requirements
Employers Must:
Identify Confined Space hazard areas
Inform employees by posting signs where feasible
Prevent entry by unauthorized persons
Establish procedures and practices to allow safe entry (Permit system)
Train employees
Provide required equipment
Control hazards where possible through engineering or work practices
Ensure procedures and equipment necessary for rescue
Protect entrants from external hazards
Enforce established procedures
Employers must provide required equipment:
Testing and monitoring
Ventilation
Communications
Lighting
Barriers
Other personal protective equipment
Any required rescue and emergency equipment
Options for entry into Permit Required Confined Space (PRCS)
Reclassification
Alternate entry procedures
Permit program
Reclassification as non PRCS
A PRCS can be reclassified as a non-permit space IF AND ONLY IF the space contains no actual or potential atmospheric hazards, and if all other hazards can be eliminated without entry into the space
Reclassification requires that no ongoing measures are required to keep the space safe
The reclassification is valid only as long as the hazard is eliminated
When hazards are reintroduced into a space, the space becomes a permit space again
The employer must certify that all hazards from the space have been eliminated and provide that certification to all employees entering that space
The reclassification is valid only as long as the hazard remains eliminated.
Elimination of hazardous conditions
In order to reclassify the space, all serious hazards must be eliminated prior to entry
