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Wortham Davenport,CSP. Thank you for your comment. We review all comments for appropriate content and to filter out Spam, and post them as soon as possible. Read the Preamble! When OSHA issues a new or revised health or safety standard, inevitably questions will arise. Perhaps OSHA did not define a key term used in the standard, or maybe they used some subjective language that could be open to interpretation. On the other hand, if it contains dispensing valves, the equation would change because such equipment can and does leak. Myth: Confined space instruments should be calibrated in accordance with the manufacturer's recommendations.

Fact: Some manufacturer's instruction manuals recommend that instruments be calibrated every 30 days. By quizzing a product engineer who was exhibiting such an instrument at a professional conference, I determined that the day recommendation for his instrument was based on its stability on a lab bench. Most people don't leave their instruments on a bench.

They have them thumping around in the back of a pickup truck or knocking around an equipment storage locker. A lot of things can happen when you jostle an instrument. A wire can break, a sensor can work loose, a trim pot can drift, and a circuit board can crack. Without checking the instrument prior to each use, there is no way to ensure that it is responding properly.

Myth: Instrument manufacturers wouldn't sell instruments that don't do what they say they will.

OSHA - Confined Spaces

Fact: Some handheld monitors sold for evaluating confined space atmospheres are absolutely useless for that purpose. Do the arithmetic yourself. Five percent of 1, ppm is 50 ppm. Putting it a different way, a meter reading zero in an atmosphere containing 50 ppm of CO would be working in accordance with the manufacturer's published specifications even though the CO concentration would be twice the TLV of 25 ppm! This myth stems from a misunderstanding of 29 CFR What some contractors don't seem to understand is that, while they may consider themselves part of the "construction industry," much of the work they do is not really construction, it's maintenance and repair.

Confined space

Moreover, OSHA has made it abundantly clear that maintenance and repair activities are covered by the general industry standard. CPL 2. For example, a new petroleum storage tank, chemical reactor or process vessel being built from scratch is covered by the construction standards until the entity for which it is being built takes possession. At that point, further entry into the spaces is covered by the general industry regulation. The following examples, which are drawn directly from CPL 2.

Matters of Interpretation on the Issues of Confined Space & LOTO -

The important thing to realize is that it's the nature of the work, not the nature of the employer that determines coverage under the standard. Note too that 29 CFR It says that the standard does not apply to construction employment. As a practical matter, it doesn't really make any difference whether contractors are legally covered by OSHA's permit-required confined space regulation because they still need to take a variety of precautions when entering permit-required confined spaces.

Specifically, the agency's enforcement policy stipulates that contractors not covered by the general industry regulations must comply with American National Standards Institute ANSI Standard Z In a letter of interpretation dated Jan.

Regulations (Preambles to Final Rules) | Occupational Safety and Health Administration

In those instances where a hazard is addressed by an existing part of the standard, OSHA will continue to cite the specific standard. In those cases where a hazard is observed that is not addressed by an existing specific construction standard but is addressed in the American National Standards Institute's Z Slip, trip and fall hazards that may exist in a confined space make that space a permit-required space. Fact: This myth stems from 29 CFR The question, then, is what exactly constitutes a "serious hazard?

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Section 17 k of the OSH Act says that a violation is serious if there is " It's important to understand this definition to properly classify confined spaces. For example, just because someone can fall off a ladder in a confined space doesn't necessarily make that space a permit space.

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Yes, falls from elevations can lead to death or serious physical harm, but an OSHA policy considers this to be a walking-working surface issue that is better addressed by other standards. In his Feb. In answering the hypothetical question "Would a pit that meets the definition as a confined space also meet the definition of a permit-required confined space [PRCS] if the only hazard is a potential fall from 21 feet while descending on a ladder within the pit?

Therefore, if the described potential fall hazard is the exclusive hazard within this pit, a permit program would not be required. Myths: Showing employees videotapes or letting them use interactive computer or Web-based instruction meets OSHA's requirements for confined space training. Fact: Regardless of the advertising hype you may see or hear, watching a videotape or spending a few hours in front of a computer isn't sufficient to meet the regulation's training requirements.

A variety of letters of interpretation from OSHA's national office make it abundantly clear that, although video tapes and computerized courses may be used as part of a training program, simply showing employees these materials does not meet the training requirements imposed by the confined space rule. Don't believe me, check out these letters yourself:. Think about it. There isn't a department of motor vehicles in the country that will let someone get behind the wheel of a car and drive away after watching a minute videotape or completing an interactive, computer-based training program.

Because confined space entry demands far more knowledge and skill than driving a car, how can anyone believe that workers would be trained on such a complex topic after watching a videotape or completing an interactive computer program? Fact: First, this presumes that the inspector even evaluated your program.

This “man-sized” door does NOT eliminate “limited means of egress”

First, the host employer must notify the on-site contractor of the existence of any permit space s at their site, and they must also inform them that entry into any of those spaces is only allowed under a program meeting the requirements of the OSHA permit-required confined space standard. Furthermore, the host employer must explain to the contractor the hazards and experience they might have had with the space the contractor will be entering that make it a permit-required confined space, as well as any precautions or procedures if any they have implemented for the protection of any employees located in or near permit spaces where the contractor will be working.

And at the end of entry operations, the host employer must debrief the contractor regarding the permit-required confined space procedures followed and any hazards they might have confronted or created in the permit spaces while conducting their entry operations. As you can see, employers have some level of obligation under the OSHA permit-required confined space standard if there is a confined space at their worksite.

At the very least, they must evaluate the space to determine if it is a permit space, and if so, post a sign or take some other means to notify employees of its existence and prohibitions for entry. And if on-site contractors will be working in their permit space s , there is a mandatory exchange of information that must take place between both parties. So take this opportunity to reexamine your work site to make certain you have not overlooked any confined spaces.