Requirements for PRCS attendants; Fall arrest system anchorage point

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.

August 28, 1995

Christopher Seniuk M.P.A., C.S.P., C.I.H.
Assistant Vice President
Director of Safety and Health Services
Lovell Safety Management Co., Inc.
161 William Street
New York, N.Y. 10038-2675

Dear Mr. Seniuk:

This is response to the questions in your letter of May 10, 1995. The questions and responses are as follows:

Q 1.

Are attendants always required anytime employees enter a permit-required confined space (PRCS)?

R.

Confined space requirements for a testing chamber with/without limited access.

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 15, 1999

Ms. Kelly Boyle
American Safety Training, Inc.
317 W. 4th Street
Davenport, Iowa 52801-1204

Dear Ms. Boyle:

Thank you for your October 28, 1999 letter to the Occupational Safety and Health Administration's (OSHA's) Office of General Industry Compliance Assistance (GICA) for an answer regarding OSHA's Permit-Required Confined Spaces standard, 29 CFR 1910.146. Based on your telephone conversation with Mr. Patrick Kapust of my staff, your specific questions have been further revised and restated below for clarity.

Centralized Monitoring 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.

April 15, 2014

Mr. Edwin G. Foulke, Jr.
Fisher & Phillips, LLP
1075 Peachtree Street, NE
Suite 3500
Atlanta, GA 30309

Dear Mr. Foulke:

Construction of aboveground storage tanks and confined space; §§1926.21(b)(6) and 1910.146; General duty clause

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 10, 2006

John E. Williams III
Pasadena Tank Corporation
15915 Jacintoport Boulevard
Houston, TX 77015

Dear Mr. Williams:

This is in response to the January 18, 2006, letter you sent to the Occupational Safety and Health Administration, inquiring about the applicability of confined space requirements to aboveground storage tank construction. We apologize for the delay in our response.

We have paraphrased your questions as follows: