So, who is responsible for Confined Space Evaluations, and when must they be conducted?
The short answers are ALL General Industry (1910) employers, and at the time the standard was promulgated, and before each entry. Let me explain…
1910.146(c)(1), which requires the evaluation of the entire facility, APPLIES TO ALL GENERAL INDUSTRY workplaces, regardless of whether the employer sends their employees into these spaces.
1910.146(c)(2) requires the employer to inform exposed employees, by posting danger signs or by any other equally effective means, of the existence and location of and the danger posed by the permit spaces. This APPLIES TO ALL GENERAL INDUSTRY workplaces, regardless if the employer will not send their employees into these spaces.
1910.146(c)(3) applies ONLY to employers who will not be sending in their employees. It requires the employer to take effective measures to prevent its employees from entering the permit spaces and shall comply with paragraphs (c)(1), (c)(2), (c)(6), and (c)(8) of this section. Let me explain this further: (c)(1) and (c)(2) are, as stated above, doing the evaluation and informing employees of the PRCS through posting the spaces or some equally effective means.
Section (c)(6) covers spaces not identified as PRCS in the initial evaluation but could become a PRCS when its use and/or configuration is changed. A good example of this is the shell-and-tube heat exchanger used in plants. These spaces cannot be bodily entered when opened, as the tube bundle fills the entire space; however, when the tube bundle is removed, the space can now be bodily entered, thus making it a PRCS. Another example of how (c)(6) could come into play is when a vessel is modified in some way AFTER the initial evaluation. For example, an open-top vessel that is only 3.5′ high is closed by welding a top on it, and an agitator is added to the vessel. The facility puts a 24″ manway on the vessel’s side to work on the agitator. We just CREATED a PRCS, and this space SHOULD BE included in the facility’s PRCS program. Section (c)(8) is for when the employer hires a contractor to enter these PRCSs. This is an often overlooked section, and many employers forget to “debrief their contractor entrants” after their entry work.
So far, I have written about the evaluation that ALL employers in 1910 General Industry MUST DO as an initial step for complying with 1910.146. The other REQUIRED evaluation is JUST BEFORE entry into one of these PRCSs is authorized. 1910.146(d)(2) requires the employer to “Identify and evaluate the hazards of permit spaces before employees enter them.” This could be looked upon as a layer of protection. So often, a facility conducted its initial evaluation in the mid-1990s, and it may be many years before a reason to enter the space arises. OSHA recognized this, and to ensure the space is safe, the standard requires the employer to evaluate the space hazards BEFORE entry.
