UPDATED on 9/19/2015 @ 12:25 pm – As I sit here in my truck eating lunch, I thought I would update this posting after having a very nice and interesting phone call with some of the nice and very helpful folks @ OSHA. Please see the bottom of this post for more info for those of you in General Industry as to how the new CONSTRUCTION CONFINED SPACE standard will indeed impact us.
On May 4, 2015, OSHA issued a new standard for construction work in confined spaces, which went into effect on August 3, 2015. Although you will want to refer to the “Temporary Enforcement Policy for Construction Work in Confined Spaces” for how OSHA will enforce this new rule, the rule, for the most part, is in place, and we should be implementing it. So the questions I have come across in this first month of compliance are:
- Does 1926.1201 apply to a contractor entering a vessel at a PSM covered process or does 1910.146 apply?
- When a facility is installing a new vessel(s), does the installation work involving entry into the vessel (e.g. to install agitator) fall under 1926.1201 or 1910.146?
