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…
so to review the OSHA requirements:
1910.146(c)(8) When an employer (host employer) arranges to have employees of another employer (contractor) perform work that involves permit space entry, the host employer shall:
…
1910.146(c)(8)(v) Debrief the contractor at the conclusion of the entry operations regarding the permit space program followed and regarding any hazards confronted or created in permit spaces during entry operations.
Every time a contractor enters one of our spaces, regardless of the method used (e.g., (c)(5), (c)(7), or a permitted entry), the contractor(s) MUST be debriefed on their entry. This debrief/discussion is meant to review how well they felt our entry program was and any hazards that may have been confronted or created in the space that was NOT captured by our pre-entry evaluation(s). PRCS is one of my specialties, but over the years, I have learned a lot from contractors who do entries every day. These guys and gals see many more mistakes and great programs than I could see as a site safety and health manager, so their insight into how our program may fall short should be welcomed feedback.
I will agree with most who argue that “hazards confronted or created in permit spaces during entry operations” should result in TERMINATION of the entry and permit and an investigation begun. But some hazards may arise within the space that are not necessarily PRCS hazards that would result in the termination of the entry. Only the entrants can identify these hazards because they are present inside a space that is quite possibly invisible to those walking by and maybe even the attendant.
Nonetheless, it is our responsibility to “debrief” the contractor(s) after each entry seeking their feedback “regarding the permit space program followed and regarding any hazards confronted or created in permit spaces during entry operations”. As noted above, this is an OSHA requirement, so how can we validate this is taking place? OSHA can (and will) interview the contractors who appear on the permits (which we are required to maintain for a year) and determine if this debrief is occurring. During SAFTENG audits, we will interview a few of the actual entrants from some of the “nested contractors” and just ask them… “Have you ever been asked by XYZ for your feedback regarding XYZ’s permit space program or about any hazards confronted or created in permit spaces during your entry operations”? Some argue that the interview question is unfair because the entry took place X weeks/months earlier; however, if you ask this question on a site that does a debrief after EACH entry, there is NO DOUBT it is being done because every entrant or job supervisor over entries will quickly say “Yes, they ask us after each entry if we think their program is adequate for that specific entry and if we encountered any hazards that may have been missed in the pre-entry evaluation and during our entry”.
Trust me when I say it is clear to the auditor (and OSHA) when these debriefs are occurring. Both guest and nested contractors will remember the debrief because SO FEW do them that when it is done, it is seen as “weird” by the contractors. So “weird” that they oftentimes will say to us… “we thought it was a trick question… them asking us about their program”.
The easiest way to document the debriefs occurring…
include the debrief in your “Permit Termination” procedures and on the actual entry permit or the “reclassification” form. Have the contractor supervisor sign off on the terminated contractor and answer two yes/no questions:
- Do you have any questions or concerns regarding the permit space program followed?
- Do you have any questions or concerns regarding any hazards confronted or created during entry?
Provide a space for them to comment and we have documented our debriefing of contractors involved in that entry.
Now at the end of the “year” when we sit down to do our PRCS evaluation, using our closed entry permits (1910.146(d)(14), we now have ALL the contractor debriefs in front of us to consider during our annual review. We also have clear documentation that we are debriefing our contractors and documenting any concerns they may have had and any hazards they may have confronted during their entry(s). I can almost promise you that if your PRCS entry program is a SERIOUS program with a lot of emphasis by all involved, debriefing contractors will always result in some great feedback. We just have to ask, as most contractors do NOT believe it is their place to provide feedback to the hiring host; however, when their work involves entry into PRCS it actually is OUR RESPONSIBILITY to ASK and THEIR RESPONSIBILITY to RESPOND.
