OSHA published a Letter of Interpretation making it clear that we can use “alternative entry” methods such that when the physical hazard(s) can be ELIMINATED OR ISOLATED through engineering controls, AND any atmospheric hazards can be CONTROLLED through forced-air ventilation and continuous atmospheric monitoring, the space may be entered using the alternate procedures set forth in 29 CFR 1926.1203(e), instead of full permit space entry procedures. We discussed this June of last year (Does OSHA’s new PRCS in Construction allow the use of Alternative Entry and Reclassification on the same PRCS?) and I just missed this older LOI at the time. So here is the actual language that allows us to use Energy Isolation, forced air ventilation, and continuous atmospheric monitoring to enter the PRCS using these ALTERNATIVE methods over making the entry via an Entry Permit and all the requirements that go with this entry method. But the LOI makes no mention of…
(emphasis by me)
