… Providing each authorized entrant or that employee’s authorized representative with the opportunity to observe any monitoring or testing of permit spaces. How many of us have this compliance requirement written into our CS Entry program or permitting procedure? During an inspection, the OSHA CSHO will be looking for evidence this requirement is being met. It is NOT acceptable to claim “anyone can watch the testing whenever they want”, we must ensure that entrants know their “rights” (my words – not OSHA’s).
So why did OSHA revise 1910.146 in 1998 to include this new requirement in the standard? Remember that at the same time this air monitoring provision was added, they added section (l) Employee Participation.
They did this to allow for greater employee participation in the permit-space program and employee access to program information developed under the standard. The Agency believes that these revisions are necessary to ensure that permit space entrants, whose work often requires entry into potentially life-threatening atmospheres, have the information necessary to protect themselves and their co-workers from confined space hazards. Allowing authorized entrants or their authorized representatives to observe the testing of the spaces they are required to enter will help to ensure that the testing has been done properly, that the respirators and other personal protective equipment being worn are appropriate, and that the entrants understand the nature of the hazards present in the space.
Here is what OSHA stated regarding this requirement and their responses to those who felt it would be a “logistical nightmare.”
