Standard Interpretations - (Archived) Table of Contents|
| Standard Number:||1910.10|
|MEMORANDUM FOR:||Regional Administrators|
Regions II, III, V, and VI
|THROUGH:||Leo Carey, Director Office of Field Programs|
|FROM:||Patricia K. Clark|
Directorate of Compliance Programs
|Subject:||Clarification of Paragraph H.1 of OSHA Notice CPL 2, and On-site Contractor Issues|
1) OSHA Notice CPL 2 calls for all contractors on-site to be inspected-- Are the Area Offices required to inspect all contractors on-site?The intent of the PETROSEP is to focus primarily on contractors whose activities involve conditions that may result in catastrophic events. The contractors who contribute to the potential of catastrophic failures, normally include welding contractors, and maintenance contractors involved in replacing and cleaning pipes, valves, pumps, tanks, and other fittings. While inspecting these contractors, emphasis should be placed on hazard communication program, and on their work permit procedures such as hot work, line-breaking, confined space entry, lockout/tagout, and emergency escape procedures. However, other hazards observed while inspecting these contractors shall be noted for citation issuance purposes. Contractors engaged in activities such as grading, painting, construction of new units, etc., whose activities would not create or contribute to catastrophic events, need not be inspected. In any event, all contractors engaged in activities that may result in catastrophic events must be inspected. This would also include contractors that through their activities could introduce ignition sources in classified areas.
2) The contractors may be actively involved in their contract work one day, and may not be on-site for the next several days. How can an Area Office handle such a flux of contractors, when their presence on-site is staggered?
|Standard Interpretations - (Archived) Table of Contents|
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