Can you name ALL the “documentation” one would need to demonstrate FULL compliance with 1910.146?

OSHA has announced their Information Collection Activities; Submission for OMB Review; Comment Request; Permit-Required Confined Spaces in General Industry Standard.  Some of these announcements have some interesting tid-bits in them.  This PRCS announcement listed all the documentation one would need to fully comply with 1910.146.  Most of us could list many of these items, but some may not come to mind until you read them in OSHA’s posting…

This ICR seeks to extend PRA authority for the Permit-Required Confined Spaces in General Industry Standard information collection requirements codified in regulations 29 CFR 1910.146. The purpose of the information collection is to ensure an Occupational Safety and Health Act (OSH Act) covered employer subject to the Standard systematically evaluates the dangers in permit spaces before entry is attempted and takes adequate measures to make the spaces safe for entry. The major information collection requirements in this Standard require the employer to:

  • Post danger signs;
  • Develop and implement a written permit-space program;
  • Verify the space is safe for entry with a written certification;
  • Exchange information with employees, authorized entrants, attendants, contractors, and rescue services or teams;
  • Document the completion of measures the Standard requires by preparing an entry permit;
  • Make the completed permit available at the time of entry to all authorized entrants by posting the permit at the entry portal or by any other equally effective means;
  • Retain each canceled entry permit for at least one year;
  • Prepare training certification records;
  • Make the Safety Data Sheet (SDS) or written information available to the treating medical facility, if an injured entrant is exposed to a substance for which a SDS or other similar written information is required to be kept at the worksite;
  • Consult with affected employees and their authorized representatives on the development and implementation of all aspects of the permit space program; and
  • Make records developed under standard, including the results of any testing, available for inspection by employees and their authorized representatives.

Did you get them all?  I think most would agree after reading the list, but how many of have this documentation as it relates to our PRCS programs and entries?

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