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OSHA has announced a 60-day temporary enforcement policy of its Confined Spaces in Construction standard, which becomes effective Aug. 3, 2015. The agency is postponing full enforcement of the new standard to Oct. 2, 2015, in response to requests for additional time to train and acquire the equipment necessary to comply with the new standard.
During this 60-day temporary enforcement period, OSHA will NOT issue citations to employers who make good faith efforts to comply with the new standard. Employers MUST be in compliance with either the training requirements of the new standard* or the previous standard. Employers who fail to train their employees consistent with either of these two standards will be cited.
Factors that indicate employers are making good faith efforts to comply include:
I do not work on construction sites so I have not been following the roll-out of OSHA Confined Space standard for the Construction Industry (1926.1200) all that closely. But my phone has not stopped ringing with clients who have received a ton of advertising about how this “new OSHA rule will impact you”. Some of this literature is just disgusting in how it misleads an unsuspecting manager who wants to do the right thing. But as I began to research some of these claims I did take notice that this new CS standard for construction can be a glimpse into OSHA’s 2nd attempt at writing a CS standard and some of the new definitions and requirements should be included in our general industry program(s).
The Technical Committee has completed the second draft revisions and, absent any Notice of Intent to Make a Motion (NITMAMs), the new guide will be released this coming November! This document explains “how to” comply with provisions in the existing confined space regulations and standards by providing more detailed guidance on subjects such as
You can stay on top of what is happening with NFPA 350 by signing up for email alerts at www.nfpa.org/350.
As the debate rages on regarding rescue services, there is ONE LITTLE SIMPLE requirement that would STOP ALL entries before rescue services are VERIFIED to be “available”…
1910.146(j) Duties of entry supervisors. The employer shall ensure that each entry supervisor:
1910.146(j)(4) Verifies that rescue services are available and that the means for summoning them are operable;
This Entry Supervisor REQUIREMENT could not be any more clear… it is their JOB (and SOLELY their job) as Entry Supervisor to VERIFY that what ever rescue service they plan to use (on-site vs. offsite) the service/team is available and the means the attendant will use to summon them to the space is “operable”.