Permit-Required Confined Space (PRCS).

Archive Notice - OSHA Archive

NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

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 2, 1993

Mr. George S. Kennedy, CSP
Director of Safety
National Utility Contractors Association
Suite 360
4301 N. Fairfax Drive
Arlington, Virginia 22203-1627

Dear Mr. Kennedy:

Thank you for your letter of April 7, to Art Buchanan, OSHA - General Industry Compliance Assistance. You made seven specific requests for interpretation regarding the Permit-Required Confined Space (PRCS) standard 1910.146. This response follows the question sequence which is reflected in your letter.

Clarification of maintenance vs. construction activities; standards applicable to the removal and replacement of steel tanks and structural steel supports.

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.

November 18, 2003

Mr. Raymond V. Knobbs
Minnotte Contracting Corporation
Minnotte Square
Pittsburgh, PA 15220

Confined space standard for general industry.

Archive Notice - OSHA Archive

NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

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.

October 8, 1993

Ms. Suey Howe
Director, Federal Regulations
Associated Builders and Contractors, Inc.
1300 North 17th, 8th Floor
Rosslyn, VA 22204

Dear Ms. Howe:

This is in response to your April 8 letter requesting an interpretation on the scope of the Occupational Safety and Health Administration's (OSHA) confined space standard for general industry. I apologize for the delay in responding to your inquiry.

Federal posting requirements applicable to an employer with no more than 10 employees.

Archive Notice - OSHA Archive

NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

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.

December 30, 1993

The Honorable Robert S. Walker
United States House of Representatives
Washington, D.C. 20515

Dear Congressman Walker:

This is in further response to your inquiry of November 8, 1993 on behalf of your constituent, Mr. Edward E. Birchall, who resides in Lancaster, Pennsylvania. In the copy of the October 30, 1993 letter from Mr. Birchall you provided, he asked for federal posting requirements, particularly those applicable to an employer with no more than 10 employees.

Questions regarding the Permit-Required Confined Space standard, 1910.146, and the Grain Handling standard, 1910.272.

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.

February 8, 2005

Mr. Ronald R. Demaray
Regulatory Consultants, Inc.
140 West 8th Street
Horton, KS 66439

Dear Mr. Demaray:

Evaluation of a box van of a truck carrying hazardous materials meeting the definition of a confined space in a hazardous material release/response situation.

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.

March 8, 2005

Mr. Ron Sands
HSE Solutions, Inc.
124 Rodney Avenue
Walnut, Illinois 61376-9912

Dear Mr. Sands:

Thank you for your letter to the Occupational Safety and Health Administration's (OSHA's) Calumet City Area Office. Your letter has been referred to the OSHA's Directorate of Enforcement Program's (DEP's) Office of General Industry Enforcement for an answer to your question regarding OSHA's permit-required confined spaces standard 29 CFR 1910.146. Your scenario and question has been restated below for clarity.

CPR training is a required element in some OSHA general industry standards.

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.

November 1, 2005

Mr. David Nakama
Manager - Sales Administration
Vantec World Transportation (USA), Inc.
Los Angeles Headquaters
991 Francisco Street
Terrance, California 90502

Dear Mr. Nakama:

Mechanical equipment, such as an unguarded agitator, posing a hazard within a permit space must be locked out or tagged.

Archive Notice - OSHA Archive

NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

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.

March 3, 1994

Mr. Clay Detlefsen, Assistant Director
Environmental & Workers Safety Issues
International Dairy Foods Association
888 Sixteenth Street, N.W.
Washington, D.C. 20006

Dear Mr. Detlefsen:

This is in further response to your October 6, 1993 letter, requesting an interpretation of the Control of Hazardous Energy (Lockout/Tagout) standard, 29 CFR 1910.147, with respect to permit space isolation required by 29 CFR 1910.146.

Requirements for developing entry procedures for permit-required confined spaces.

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.

September 21, 2006

Mr. Fred N. Rubel
Dewling Associates, Inc.
1605 Vauxhall Road
Union, NJ 07083

Dear Mr. Rubel:

Thank you for your March 13 letter to the U.S. Department of Labor's Occupational Safety and Health Administration (OSHA). Your letter has been referred to OSHA's Directorate of Enforcement Program's Office of General Industry Enforcement for an answer to your questions regarding OSHA's Permit-Required Confined Spaces standard, 29 CFR 1910.146. Your questions have been restated below for clarity.

Qualifications required under 1910.269 for entry into manholes/vaults to perform work on energized conductors.

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.

November 21, 2006

Mr. Edgar R. Mings
Business Manager
International Brotherhood of Electrical Workers, Local 196
2400 Big Timber Road
Bldg. B, Suite 208
Elgin, IL 60123

Dear Mr. Mings: