OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at https://www.osha.gov.

July 6, 1995

Joanne B. Linhard
Organization Resources Counselors, Inc.
1910 Sunderland Place, N.W.
Washington, D.C. 20036

Dear Ms. Linhard:

This is in response to your letter of June 3, 1993, requesting an interpretation regarding the relationship, if any, between training requirements for those who will perform permit space rescue services in accordance with the Permit-Required Confined Spaces (PRCS) standard (1910.146) and the Hazardous Waste and Emergency Response standard (1910.120). Unfortunately your original request was misfiled. Please accept our apology for the delay in responding.

The specific question you asked is:

Do employees or other personnel who will perform rescue services to rescue persons for permit-required confined spaces that may contain a toxic, oxygen-deficient, or explosive atmosphere [in accordance with the requirement of 1910.146(k)] also need to be trained in accordance with the requirements of 1910.120(q)(6)?

Our response is as follows:

The answer is yes, if the operations are covered by 1910.120. The training requirements of 1910.146(k) are geared primarily toward the particular difficulties involved in rescues in permit-required confined spaces. The requirements of 1910.120(q)(6) are directed for the most part toward teaching workers how to deal with hazardous substances. However, it is certainly not OSHA's intent that duplicate training be provided.

The last paragraph of your letter seems to suggest that the rescuers would not be responding to situations covered by 1910.120. If the case is that, under no circumstances, would the rescuers confront a situation covered by 1910.120, there would be no need to provide them with the 1910.120(q)(6) training.

If you have further questions on this response, please contact Mr. Donald Kallstrom in the Office of General Industry Compliance Assistance at (202) 219-8031 x109. A copy of the program directive has also been enclosed for your information and future reference.


John B. Miles, Jr., Director
Directorate of Compliance Programs