How do you comply with debriefing contractors after they exit your PRCS?

This is a slippery slope for us and OSHA to walk.  It is clearly a requirement when contractors enter our Permit Required Confined Spaces (PRCS), but how do we demonstrate that we are indeed “debriefing” these contractors as required by 1910.146(c)(8)(v)?  What do we have on hand that can show all entries involving contractors involved in a “debrief” at the conclusion of entry operations? 

Several years ago, I explained the reason why OSHA requires this debrief, and the responses were all over the place, from I was crazy, and OSHA never requires such a thing “Wow, I guess we are not as thorough as I thought.”  This article is about how we can easily DOCUMENT our “debriefs” after each entry…

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