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Copyright 2023 J. J. Keller & Associate, Inc. For re-use options please contact copyright@jjkeller.com or call 800-558-5011.
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According to the preamble of the permit-required confined space standard, at 1910.146(c)(7)(iii) OSHA expects that employers who reclassify a permit space to document the basis for the determination that all hazards have been eliminated. This certification must contain the date, location of the space, and the signature of the certifying individual.
The information is basically equivalent to paragraphs (c)(5)(i)(E) and (c)(5)(ii)(H). This includes monitoring and inspection data, as well as all pre-entry measures that have been taken to eliminate the hazards. If you have entered the space to take air samples, lock out equipment, purge contents, etc., then you will have developed an entry program based on the requirements of 1910.146(d)-(f). You should retain this information which verifies that the space was entered according to the required procedures.
If you had to implement a permit program prior to entering the space, you will have an entry permit which you will need to retain for one year. OSHA does not address how or when you should cancel the permit. You may want to wait until all work is done and the entry has been completed. OSHA looks at this type of entry as a temporary situation in which you control the hazards during entry, but upon completion of the work and reenergizing the equipment, etc, the space becomes a permit space again.
This is a performance-oriented standard. That means OSHA spells out the outcome, but leaves the “how to” up to the employer. It allows you to customize the program to the particular spaces in your workplace. However, OSHA likes to see documentation. It’s a good idea to retain all data pertaining to this type of space entry. Also, it will be useful to you, the next time you need to enter the space.
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