OSHA Confined Space Entry

Permit-Required Confined Space (PRCS) Entry per 29 CFR Part 1910.147 found in the OSHA Regulations for General Industry and per 29 CFR Part 1926 – Subpart AA found in the OSHA Regulations for the Construction Industry – as related to acceptable safety policies and procedures that apply to employees that enter such spaces.

• OSHA regulations related to PRCS entry. OSHA organizational groups responsible for overseeing the safe working conditions provided to employees. Class discussion of practical examples of confined spaces that exist in the municipal (public sector) and private sector work environment. OSHA Citation Structure and Penalties; Overview and examples of actual citations to municipal and other employers; General Duty Clause; Other PRCS safety regulations enforced by OSH Officers through Incorporation by Reference Clause. Class discussion of consequential civil case liability for municipalities and contractors stemming from OSHA citations along with a discussion of actual cases in the Carolinas. Other discussion topics include citations issued to municipalities and controlling employers directly resulting from working with and around contractors. Three different ways municipal employees can create employer liability for OSHA citations, even when municipal employees have not yet entered the space or been exposed to a particular hazard.
• Two basic categories of permit space entry procedures allowed in the OSHA regulations, along with specific examples of field and utility plant installations that would likely qualify for each procedure. Class discussion of administrative systems for permit issuance, collection and post-entry review, as required by OSHA regulations. Key differences between the general industry and construction industry confined space standards. Other “vertical” confined space entry standards that apply specifically to selected types of work activities.
• Class discussion and review of actual entry permit forms used by public and private sector employer organizations. Class discussion about working around other employee groups, contractors and the public while attempting to perform work that involves PRCS entry. Class discussions of symbol-based warning signs and entry permits. Class discussion of practical examples of work related conditions inwhich entry should not be attempted. When it might be strategically appropriate to contract work to outside organizations for necessary maintenance and repairs.
• Overview of OSHA lockout / tagout regulations – class discussion of: 1) mechanical and other systems where maintenance or repair activities require multiple lockouts/tagouts, and 2) practical examples of system maintenance and repair activities where lockouts/tagouts are required; OSHA Appendices containing additional procedures and equipment specifically targeting employees engaged in PRCS entry operations. OSHA regulations create significant citation exposure for municipalities when repair work is contracted out and the work involves entry into PRCS. Discussion of which portion of regulations would apply and necessary entry procedures.