Is "competence" for doing a CS evaluation = to "competence" for doing a RECLASSIFICATION
OSHA’s new Confined Space standard for Construction requires a “competent person” in two CRITICAL functions; I should also point out these two functions are also CRITICAL within the General Industry functions as well. These include EVALUATING spaces and RECLASSIFYING a PRCS to a non-PRCS. Evaluation of Spaces 1926.1203(a) Before it begins work at a worksite, each employer must ensure that a competent person identifies all confined spaces in which one or more of the employees it directs may work, and identifies each space that is a permit space, through consideration and evaluation of the elements of that space, including testing as necessary. ... 1926.1203(f) When there are changes in the use or configuration of a non-permit confined space that might increase the hazards to entrants, or some indication that the initial evaluation of the space may not have been adequate, each entry employer must have a competent person reevaluate that space and, if necessary, reclassify it as a permit-required confined space. Reclassification of a PRCS 1926.1203(g) A space classified by an employer as a permit-required confined space may only be reclassified as a non-permit confined space when a competent person determines that all of the applicable requirements in paragraphs (g)(1) through (4) of this section have been met:… But does this mean that the same “competent person” who did the CS Evaluation(s) is also a “competent person” in the requirements to RECLASSIFY a PRCS to a non-Permit Space? |
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