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 http://www.osha.gov.

October 18, 1995

Mr. Mark S. Rund
AFSCME
Department of Research
American Federation of State,
County and Municipal Employees
1422 North Pennsylvania St.
Indianapolis, IN 46202

Dear Mr. Rund:

This is in response to your letter requesting an interpretation of 29 CFR 1910.146 regarding permits and multiple sewer entries along a common line. Please accept our apology for the delay in this response.

You posed the question,... "If 5 manholes along the same sewer line are being used, is a permit required for each manhole entry?"

Our response is "yes". The standard, however, does not mandate a separate permit for each manhole entry along the same sewer line. Employers must uniquely identify and list all the manholes to be entered on the permit. The results of initial and periodic tests must also identify the space being entered.

Please note, although the standard does not prohibit several permit spaces from being listed on the same permit, they must be associated as required by paragraphs (e)(4) and (f)(2) [by reference].

If you have further questions on this response please contact Mr. Don Kallstrom in the Office of General Industry Compliance Assistance (202) 219-8031. Again please accept our apology for the delay in responding to you.

Sincerely,



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