OSHA cited three employers – a University, a Mechanical contractor and an HVAC contractor – for exposing workers to permit-required confined space hazards associated with underground steam vaults. Proposed penalties for the three companies total $235,962. OSHA received an employer-reported referral from the mechanical contractor after an employee suffered burns from a release of steam while working in a steam vault at the University’s Campus.
OSHA determined that the University contracted mechanical contractor to make needed steam repairs and that neither company implemented adequate permit-required confined space safety measures. OSHA cited the University for failing to provide required information to contractors and coordinate activities, identify and evaluate high-pressure steam as a hazard, isolate steam energy, perform air monitoring, provide required signage, complete entry permits, evaluate their confined space hazard program and ensure the ability to rescue employees from a confined space. The university faces penalties of $105,835 for nine serious violations.
OSHA also cited the mechanical contractor for failing to obtain information from the host employer and coordinate activities, identify and evaluate hazards of the space, isolate steam energy, perform air monitoring, complete entry permits, provide required confined space training and ensure the ability to rescue employees from a confined space. The company faces penalties of $105,835 for nine serious violations.
The HVAC contractor brought in to complete the repairs – faces penalties of $24,292 for four serious violations involving failing to obtain information from the host employer, adequately isolate steam energy, provide required confined space training and complete entry permits.
Here is the breakdown of the citations:
The University Citations
Citation 1 Item 1
Type of Violation: Serious; $12,145
29 CFR 1910.146(c)(2): Where the workplace contained permit spaces, the employer did not inform exposed employees, by posting danger signs or by any other equally effective means, of the existence and location of and the danger posed by the permit spaces:
(a) On October 10, 2019, the University did not inform exposed employees by posting danger signs, or by any other equally effective means, that steam vaults 13, 14, and 15 on the Evanston Campus were permit-required confined spaces and that steam vaults 13, 14, and 15 posed dangers to entrants.
The alleged violations below have been grouped because they involve similar or related hazards that may increase the potential for injury or illness.
Citation 1 Item 2a
Type of Violation: Serious; $12,145
29 CFR 1910.146(c)(8)(i): When an employer (host employer) arranged to have employees of another employer (contractor) perform work that involved permit space entry, the host employer did not inform the contractor that the workplace contained permit spaces and that permit space entry is allowed only through compliance with a permit space program meeting the requirements of 29 CFR 1910.146:
(a) On October 10, 2019, the University arranged to have two separate contractors perform work that involved permit space entry in steam vault 13 and did not inform the contractors that entry into steam vault 13 was allowed only through compliance with a permit space program that met OSHA’s standard for permit-required confined space entry.
(b) On October 10, 2019, the University arranged to have two separate contractors perform work that involved permit space entry in steam vault 14 and did not inform the contractors that entry into steam vault 14 was allowed only through compliance with a permit space program that met OSHA’s standard for permit-required confined space entry.
Citation 1 Item 2b
Type of Violation: Serious
29 CFR 1910.146(c)(8)(ii): When an employer (host employer) arranged to have employees of another employer (contractor) perform work that involved permit space entry, the host employer did not apprise the contractor of the elements, including the hazards identified and the host employer’s experience with the space, that make the space in question a permit space:
(a) On October 10, 2019, the University arranged to have two separate contractors perform work that involved permit space entry in steam vault 13 and did not apprise the contractors of the elements that made steam vault 13 a permit space.
(b) On October 10, 2019, the University arranged to have two separate contractors perform work that involved permit space entry in steam vault 14 and did not apprise the contractors of the elements that made steam vault 14 a permit space.
Citation 1 Item 2c
Type of Violation: Serious
29 CFR 1910.146(c)(8)(iii): When an employer (host employer) arranged to have employees of another employer (contractor) perform work that involved permit space entry, the host employer did not apprise the contractor of any precautions or procedures that the host employer had implemented for the protection of employees in or near permit spaces where contractor personnel would be working:
(a) On October 10, 2019, the University arranged to have two separate contractors perform work that involved permit space entry in steam vault 13 and did not apprise the contractors of precautions and procedures dealing with topics such as adequate isolation of the steam hazard, testing and monitoring of the potentially hazardous atmosphere, the permit system, non-entry rescue, and rescue and emergency services.
(b) On October 10, 2019, the University arranged to have two separate contractors perform work that involved permit space entry in steam vault 14 and did not apprise the contractors of precautions and procedures dealing with topics such as adequate isolation of the steam hazard, testing and monitoring of the potentially hazardous atmosphere, the permit system, non-entry rescue, and rescue and emergency services.
Citation 1 Item 2d
Type of Violation: Serious
29 CFR 1910.146(c)(8)(iv): When an employer (host employer) arranged to have employees of another employer (contractor) perform work that involved permit space entry, the host employer did not coordinate entry operations with the contractor, when both host employer personnel and contractor personnel would be working in or near permit spaces:
(a) On October 10, 2019, the University arranged for a contractor to perform work that involved permit space entry in steam vault 13 and did not coordinate entry operations with the contractors when the host employer’s personnel were also involved in the permit space entry.
Citation 1 Item 2e
Type of Violation: Serious
29 CFR 1910.146(d)(11): Under the permit space program required by 29 CFR 1910.146(c)(4), the employer did not develop and implement procedures to coordinate entry operations when employees of more than one employer were working simultaneously as authorized entrants in a permit space, so that employees of one employer do not endanger the employees of any other employer:
(a) On October 10, 2019, the University did not develop and implement procedures to coordinate entry operations with a contractor for entry into steam vault 13, which involved an entry by a University employee and an entry by a contractor employee for the purpose of observing a steam leak and evaluating valve configuration.
Citation 1 Item 3
Type of Violation: Serious; $12,145
29 CFR 1910.146(d)(2): Under the permit space program required by 29 CFR 1910.146(c)(4), the employer did not identify and evaluate the hazards of permit spaces before employees entered them:
(a) On October 10, 2019, the University had not identified and evaluated the hazards associated with high-pressure steam in steam vaults such as steam vault 13, 14, and 15 before employees entered on October 10, 2019. The employer’s confined space assessments for these spaces did not include the hazard posed by high-pressure steam.
The alleged violations below have been grouped because they involve similar or related hazards that may increase the potential for injury or illness.
Citation 1 Item 4a
Type of Violation: Serious; $12,145
29 CFR 1910.146(d)(3)(iii): Under the permit space program required by 29 CFR 1910.146(c)(4), the employer did not develop and implement the means, procedures, and practices necessary for safe permit space entry operations, including, but not limited to, isolating the permit space:
(a) On October 10, 2019, the University did not develop and implement the means, procedures, and practices necessary to isolate steam vault 13 from the hazard posed by high-pressure steam prior to separate entries by a University employee for (1) the observation of a steam leak and the evaluation of valve configuration and (2) the actuation (closure) of a valve.
(b) On October 10, 2019, the University did not develop and implement the means, procedures, and practices necessary to isolate steam vault 14 from the hazard posed by high-pressure steam prior to an entry by a University employee for the retrieval of a broken part and the evaluation of the need for repairs.
(c) On October 10, 2019, the University did not develop and implement the means, procedures, and practices necessary to isolate steam vault 15 from the hazard posed by high-pressure steam prior to two separate entries by University employees for the actuation (closing and opening) of a valve.
Citation 1 Item 4b
Type of Violation: Serious
29 CFR 1910.146(d)(3)(vi): Under the permit space program required by 29 CFR 1910.146(c)(4), the employer did not develop the means, procedures, and practices necessary for safe permit space entry operations, including, but not limited to, verifying that conditions in the permit space are acceptable for entry throughout the duration of an authorized entry:
(a) On October 10, 2019, the University did not develop and implement the means, procedures, and practices necessary for verifying acceptable conditions related to high-pressure steam and potential atmospheric hazards in steam vault 13 prior to separate entries by a University employee for (1) the observation of a steam leak and the evaluation of valve configuration and (2) the actuation (closure) of a valve.
(b) On October 10, 2019, the University did not develop and implement the means, procedures, and practices necessary for verifying acceptable conditions related to high-pressure steam and potential atmospheric hazards in steam vault 14 prior to an entry by a University employee for the retrieval of a broken part and the evaluation of the need for repairs.
(c) On October 10, 2019, the University did not develop and implement the means, procedures, and practices necessary for verifying acceptable conditions related to high pressure steam and potential atmospheric hazards in steam vault 15 prior to two separate entries by University employees for the actuation (closing and opening) of a valve.
Citation 1 Item 5
Type of Violation: Serious; $8,675
29 CFR 1910.146(d)(5)(i): Under the permit space program required by 29 CFR 1910.146(c)(4), the employer did not evaluate permit space conditions when entry operations were conducted by testing conditions in the permit space to determine if acceptable entry conditions existed before entry was authorized to begin:
(a) On October 10, 2019, the University did not test atmospheric conditions in steam vault 13 for the potential atmospheric hazards identified by the employer (such as oxygen deficiency, hydrogen sulfide, and carbon monoxide) prior to separate entries by a University employee for (1) the observation of a steam leak and the evaluation of valve configuration and (2) the actuation (closure) of a valve.
(b) On October 10, 2019, the University did not test atmospheric conditions in steam vault 15 for the potential atmospheric hazards identified by the employer (such as oxygen deficiency, hydrogen sulfide, and carbon monoxide) prior to an entry by a University employee for the actuation (closure) of a valve.
Citation 1 Item 6
Type of Violation: Serious; $12,145
29 CFR 1910.146(d)(14): Under the permit space program required by 29 CFR 1910.146(c)(4), the employer did not review the permit space program, using the canceled permits retained under 29 CFR 1910.146(e)(6) within 1 year after each entry and revise the program as necessary, to ensure that employees participating in entry operations are protected from permit space hazards:
(a) On October 10, 2019, the University had not reviewed their permit-required confined space program, using cancelled permits, to ensure that employees performing permit-required confined space entries were protected from permit-required confined space hazards.
Citation 1 Item 7
Type of Violation: Serious; $12,145
29 CFR 1910.146(e)(1): Before entry was authorized, the employer did not document the completion of measures required by 29 CFR 1910.146(d)(3) by preparing an entry permit:
(a) On October 10, 2019, the University did not prepare and complete entry permits for steam vault 13 prior to separate entries by a University employee for (1) the observation of a steam leak and the evaluation of valve configuration and (2) the actuation (closure) of a valve.
(b) On October 10, 2019, the University did not prepare and complete an entry permit for steam vault 14 prior to an entry by a University employee for the retrieval of a broken part and the evaluation of the need for repairs.
(c) On October 10, 2019, the University did not prepare and complete an entry permit for steam vault 15 prior to an entry by a Northwestern University employee for the actuation (closure) of a valve.
The alleged violations below have been grouped because they involve similar or related hazards that may increase the potential for injury or illness.
Citation 1 Item 8a
Type of Violation: Serious; $12,145
29 CFR 1910.146(k)(1)(i): When designating rescue and emergency services pursuant to 29 CFR 1910.146(d)(9), the employer did not evaluate the prospective rescuer’s ability to respond to a rescue summons in a timely manner, considering the hazard(s) identified:
(a) On October 10, 2019, the University had not evaluated the Evanston Fire Department’s ability to respond to a rescue summons in a timely manner for steam vaults 13, 14, and 15 prior to entry into those spaces.
Citation 1 Item 8b
Type of Violation: Serious
29 CFR 1910.146(k)(1)(iv): When designating rescue and emergency services pursuant to 29 CFR 1910.146(d)(9), the employer did not inform each rescue team or service of the hazards they may confront when called on to perform rescue at the site:
(a) On October 10, 2019, the University had not informed the Evanston Fire Department of the hazards associated with steam vaults 13, 14, and 15 prior to entry into those spaces.
Citation 1 Item 8c
Type of Violation: Serious
29 CFR 1910.146(k)(1)(v): When designating rescue and emergency services pursuant to 29 CFR 1910.146(d)(9), the employer did not provide the rescue team or service selected with access to all permit spaces from which rescue may be necessary so that the rescue service could develop appropriate rescue plans and practice rescue operations:
(a) On October 10, 2019, Northwestern University had not provided the Evanston Fire Department with access to steam vaults 13, 14, and 15 for rescue planning and practice prior to entry into those spaces.
Citation 1 Item 9
Type of Violation: Serious; $12,145
29 CFR 1910.146(k)(3): To facilitate non-entry rescue, retrieval systems or methods were not used whenever an authorized entrant entered a permit space:
(a) On October 10, 2019, the University did not utilize a non-entry rescue retrieval system at steam vault 13 prior to separate entries by a Northwestern University employee for (1) the observation of a steam leak and the evaluation of valve configuration and (2) the actuation (closure) of a valve.
(b) On October 10, 2019, the University did not utilize a non-entry rescue retrieval system at steam vault 15 prior to an entry by a Northwestern University employee for the actuation (closure) of a valve.
The Mechanical Contractor’s Citations
Citation 1 Item 1
Type of Violation: Serious; $12,145
29 CFR 1910.l46(c)(9)(i): Each contractor who was retained to perform permit space entry operations did not obtain any available information from the host employer regarding permit space hazards and entry operations from the host employer:
(a) On October 10, 2019, the employer did not obtain information regarding the hazards and permit-required confined space entry operations associated with steam vaults 13 and 14 on the Evanston Campus from Northwestern University prior to entry into those spaces.
The alleged violations below have been grouped because they involve similar or related hazards that may increase the potential for injury or illness.
Citation 1 Item 2a
Type of Violation: Serious; $12,145
29 CFR 1910.146(c)(9)(ii): Each contractor who was retained to perform permit space entry operations did not coordinate entry operations with the host employer, when both host employer personnel and contractor personnel would be working in or near permit spaces, as required by 29 CFR 1910.146(d)(11):
(a) On October 10, 2019, the employer did not coordinate entry operations for entry into steam vault 13 on the Evanston Campus with Northwestern University when the host employer’s personnel were also involved in entry into the permit space.
Citation 1 Item 2b
Type of Violation: Serious
29 CFR 1910.146(d)(11): Under the permit space program required by 29 CFR 1910.146(c)(4), the employer did not develop and implement procedures to coordinate entry operations when employees of more than one employer were working simultaneously as authorized entrants in a permit space, so that employees of one employer do not endanger the employees of any other employer:
(a) On October 10, 2019, the employer did not develop and implement procedures to coordinate entry operations with the host employer for entry into steam vault 13 on the Evanston Campus, which involved an entry by a University employee and an entry by an employee for the purpose of observing a steam leak and evaluating valve configuration.
Citation 1 Item 3
Type of Violation: Serious; $12,145
29 CFR 1910.146(d)(2): Under the permit space program required by 29 CFR 1910.146(c)(4), the employer did not identify and evaluate the hazards of permit spaces before employees entered them:
(a) On October 10, 2019, the employer did not identify and evaluate the hazards associated with high-pressure steam and potential atmospheric hazards identified by the University (such as oxygen deficiency, hydrogen sulfide, and carbon monoxide) in steam vaults 13 and 14 on the Evanston Campus before employees were allowed to enter.
The alleged violations below have been grouped because they involve similar or related hazards that may increase the potential for injury or illness.
Citation 1 Item 4a
Type of Violation: Serious; $12,145
29 CFR 1910.146(d)(3)(iii): Under the permit space program required by 29 CFR 1910.146(c)(4), the employer did not develop and implement the means, procedures, and practices necessary for safe permit space entry operations, including, but not limited to, isolating the permit space:
(a) On October 10, 2019, the employer did not develop and implement the means, procedures, and practices necessary to isolate steam vault 13 on the University’s Evanston Campus from the hazard posed by high-pressure steam prior to an entry by a Hill Mechanical Corp. employee for the observation of a steam leak.
(b) On October 10, 2019, the employer did not develop and implement the means, procedures, and practices necessary to isolate steam vault 14 on the University’s Evanston Campus from the hazard posed by high-pressure steam prior to an entry by their employees for the observation of a steam leak and the performance of repairs on the steam system.
Citation 1 Item 4b
Type of Violation: Serious
29 CFR 1910.146(d)(3)(vi): Under the permit space program required by 29 CFR 1910.146(c)(4), the employer did not develop the means, procedures, and practices necessary for safe permit space entry operations, including, but not limited to, verifying that conditions in the permit space are acceptable for entry throughout the duration of an authorized entry:
(a) On October 10, 2019, the employer did not develop and implement the means, procedures, and practices necessary for verifying acceptable conditions related to high-pressure steam and potential atmospheric hazards in steam vault 13 on the University’s Evanston Campus prior to an entry by an employee for the observation of a steam leak.
(b) On October 10, 2019, the employer did not develop and implement the means, procedures, and practices necessary for verifying acceptable conditions related to high-pressure steam and potential atmospheric hazards in steam vault 14 on the University’s Evanston Campus prior to an entry by employees for the observation of a steam leak and the performance of repairs on the steam system.
Citation 1 Item 5
Type of Violation: Serious; $8,675
29 CFR 1910.146(d)(5)(i): Under the permit space program required by 29 CFR 1910.146(c)(4), the employer did not evaluate permit space conditions when entry operations were conducted by testing conditions in the permit space to determine if acceptable entry conditions existed before entry was authorized to begin:
(a) On October 10, 2019, the employer did not test atmospheric conditions in steam vault 13 on the University’s Evanston Campus for the potential atmospheric hazards identified by the host employer (such as oxygen deficiency, hydrogen sulfide, and carbon monoxide) prior to an entry by an employee for the observation of a steam leak.
(b) On October 10, 2019, the employer did not test atmospheric conditions in steam vault 14 on the University’s Evanston Campus for the potential atmospheric hazards identified by the host employer (such as oxygen deficiency, hydrogen sulfide, and carbon monoxide) prior to an entry by employees for the observation of a steam leak and the performance of repairs on the steam system.
The alleged violations below have been grouped because they involve similar or related hazards that may increase the potential for injury or illness.
Citation 1 Item 6a
Type of Violation: Serious; $12,145
29 CFR 1910.146(d)(8): Under the permit space program required by 29 CFR 1910.146(c)(4), the employer did not designate the persons who were to active roles in entry operations, identify the duties of each such employee, and provide each such employee with the training required by 29 CFR 1910.146(g):
(a) On October 10, 2019, the employer did not designate roles for permit-required confined space entry operations (such as authorized entrants, attendants, entry supervisors, and persons to perform tests) for safe entry into steam vault 13 on the University’s Campus and provide the necessary training for those roles prior to an entry by a Hill Mechanical Corp. employee for the observation of a steam leak.
(b) On October 10, 2019, there employer did not designate roles for permit-required confined space entry operations (such as authorized entrants, attendants, entry supervisors, and persons to perform tests) for safe entry into steam vault 14 on the University’s Campus and provide the necessary training for persons in those roles prior to an entry by employees for the observation of a steam leak and the performance of repairs on the steam system.
Citation 1 Item 6b
Type of Violation: Serious
29 CFR 1910.146(g)(1): The employer did not provide training so that all employees whose work was regulated by this section acquired the understanding, knowledge, and skills necessary for the safe performance of the duties assigned under 29 CFR 1910.146:
(a) On October 10, 2019, the employer had not provided the necessary permit-required confined space training to employees required to enter steam vaults 13 and 14 on the University’s Evanston Campus.
Citation 1 Item 7
Type of Violation: Serious; $12,145
29 CFR 1910.146(e)(1): Before entry was authorized, the employer did not document the completion of measures required by 29 CFR 1910.146(d)(3) by preparing an entry permit:
(a) On October 10, 2019, the employer did not prepare and complete an entry permit for steam vault 13 on the University’s Evanston Campus prior to an entry by an employee for the observation of a steam leak.
(b) On October 10, 2019, the employer did not prepare and complete an entry permit for steam vault 14 prior on the University’s Evanston Campus prior to an entry by employees for the observation of a steam leak and the performance of repairs on the steam system.
The alleged violations below have been grouped because they involve similar or related hazards that may increase the potential for injury or illness.
Citation 1 Item 8a
Type of Violation: Serious; $12,145
29 CFR 1910.146(k)(1)(i): When designating rescue and emergency services pursuant to 29 CFR 1910.146(d)(9), the employer did not evaluate the prospective rescuer’s ability to respond to a rescue summons in a timely manner, considering the hazard(s) identified:
(a) On October 10, 2019, the employer had not evaluated a rescue and emergency service’s ability to respond to a rescue summons in a timely manner for steam vaults 13 and 14 on the University’s Evanston Campus prior to entry into those spaces.
Citation 1 Item 8b
Type of Violation: Serious
29 CFR 1910.146(k)(1)(iv): When designating rescue and emergency services pursuant to 29 CFR 1910.146(d)(9), the employer did not inform each rescue team or service of the hazards they may confront when called on to perform rescue at the site:
(a) On October 10, 2019, the employer had not informed a rescue and emergency service of the hazards associated with steam vaults 13 and 14 on the University’s Evanston Campus prior to entry into those spaces.
Citation 1 Item 8c
Type of Violation: Serious
29 CFR 1910.146(k)(1)(v): When designating rescue and emergency services pursuant to 29 CFR 1910.146(d)(9), the employer did not provide the rescue team or service selected with access to all permit spaces from which rescue may be necessary so that the rescue service could develop appropriate rescue plans and practice rescue operations:
(a) On October 10, 2019, the employer had not provided a rescue and emergency service with access to steam vaults 13 and 14 on the University’s Evanston Campus for rescue planning and practice prior to entry into those spaces.
Citation 1 Item 9
Type of Violation: Serious; $12,145
29 CFR 1910.146(k)(3): To facilitate non-entry rescue, retrieval systems or methods were not used whenever an authorized entrant entered a permit space:
(a) On October 10, 2019, the employer did not utilize a non-entry rescue retrieval system at steam vault 13 on the University’s Evanston Campus prior to an entry by an employee for the observation of a steam leak.
(b) On October 10, 2019, the employer did not utilize a non-entry rescue retrieval system at steam vault 14 on the University’s Evanston Campus prior to an entry by employees for the performance of repairs on the steam system.
The HVAC Contractor
Citation 1 Item 1
Type of Violation: Serious; $6,073
29 CFR 1910.146(c)(9)(i): Each contractor who was retained to perform permit space entry operations did not obtain any available information from the host employer regarding permit space hazards and entry operations from the host employer:
(a) On October 10, 2019, the employer did not obtain information regarding the hazards and permit-required confined space entry operations associated with steam vaults 13 and 14 on the Evanston Campus from the University prior to entry into those spaces.
The alleged violations below have been grouped because they involve similar or related hazards that may increase the potential for injury or illness.
Citation 1 Item 2a
Type of Violation: Serious; $6,073
29 CFR 1910.146(d)(3)(iii): Under the permit space program required by 29 CFR 1910.146(c)(4), the employer did not develop and implement the means, procedures, and practices necessary for safe permit space entry operations, including, but not limited to, isolating the permit space:
(a) On October 10, 2019, the employer did not develop and implement the means, procedures, and practices necessary to isolate steam vault 13 on the University’s Evanston Campus from the hazard posed by high-pressure steam prior to an entry by an employee for the performance of repairs on the steam system.
(b) On October 10, 2019, the employer did not develop and implement the means, procedures, and practices necessary to isolate steam vault 14 on the University’s Evanston Campus from the hazard posed by high-pressure steam prior to an entry by an employee for the performance of repairs on the steam system.
Citation 1 Item 2b
Type of Violation: Serious
29 CFR 1910.146(d)(3)(vi): Under the permit space program required by 29 CFR 1910.146(c)(4), the employer did not develop the means, procedures, and practices necessary for safe permit space entry operations, including, but not limited to, verifying that conditions in the permit space are acceptable for entry throughout the duration of an authorized entry:
(a) On October 10, 2019, the employer did not develop and implement the means, procedures, and practices necessary for verifying acceptable conditions related to high-pressure steam in steam vault 13 on Northwestern University’s Evanston Campus prior to an entry by an employee for the performance of repairs on the steam system.
(a) On October 10, 2019, the employer did not develop and implement the means, procedures, and practices necessary for verifying acceptable conditions related to high-pressure steam in steam vault 14 on the University’s Evanston Campus prior to an entry by an employee for the performance of repairs on the steam system.
Citation 1 Item 3
Type of Violation: Serious; $6,073
29 CFR 1910.146(e)(1): Before entry was authorized, the employer did not document the completion of measures required by 29 CFR 1910.146(d)(3) by preparing an entry permit:
(a) On October 10, 2019, the employer did not prepare and complete an entry permit for steam vault 13 on the University’s Evanston Campus prior to an entry by an employee for the performance of repairs on the steam system.
(b) On October 10, 2019, the employer did not prepare and complete an entry permit for steam vault 14 prior on the University’s Evanston Campus prior to an entry by an employee for the performance of repairs on the steam system.
Citation 1 Item 4
Type of Violation: Serious; $6,073
29 CFR 1910.146(g)(1): The employer did not provide training so that all employees whose work was regulated by this section acquired the understanding, knowledge, and skills necessary for the safe performance of the duties assigned under 29 CFR 1910.146:
(a) On October 10, 2019, the employer had not provided the necessary permit-required confined space training to an employee required to enter steam vaults 13 and 14 on the University’s Evanston Campus.
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