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OSHA clarified the standard in July 22, 1998 Letter of Interpretation in which the agency says “Once an employer has determined a permit–required confined space exists (a confined space with an actual or potential hazard), the employer is obligated by paragraph 1910.146(c)(2) to inform exposed employees either by posting a sign or other effective means. Since the purpose of this paragraph is to provide the exposed employees with information to protect them from the hazard, the ‘when’ an employee must be informed is before the next entry.”
In the compliance directive on permit–required confined spaces (CPL 2.100) OSHA states, “Ordinarily, information about permit spaces is most effectively and economically communicated through the use of signs. Consequently, signs would be the principal method of warning under the standard. Alternative methods, such as additional training, may be used where they are truly effective in warning all employees who could reasonably be expected to enter the space. It is the employer’s obligation to assure that an alternative method is at least as effective as a sign. In some cases, employers may have to provide training in addition to signs, to protect employees who do not speak English or who would have difficulty understanding or interpreting signs.”
OSHA’s directive considers locked entry ports and states, “If a space has a locked entry cover or panel, or an access door that can only be opened with special tools, the use of signs may be unnecessary if the employer ensures that all affected employees are informed about such spaces and know that they are not to be opened without taking proper precautions, including temporary signs, to restrict unexpected or unknowing entry.”