Attached is the written program for General Industry facilities which incorporate OSHA’s newer Confined Spaces in Construction requirements. It is my recommendation that we UPDATE our written program that was based on the older 1910.146 standard to include all the improvements in 1926.1201 – .1213. We should also understand that even though our facility may fall within OSHA “General Industry” standards, we could easily have a situation within one of our PRCS’s that would trigger the Construction Standard requirements. One particular situation would be “installing a new process vessel which has an agitator”. Installing this new tank is “construction work” and any entry into the vessel, such as installing the agitator blades, would be considered “construction work” and thus the entry to do this work must comply with 1926.1201 – .1213. The attached program is meant to be a STARTING POINT for your facility to transition from the old 1910.146 based program to the newer requirements. Please note that this program was written based on the OSHA standard but there are several significant upgrades from OSHA minimums – you may change them at your desire – BUT BEWARE, these upgrades are considered LIFE SAFETY CRITICAL and should remain in the program for the protection of entrants, attendants, and rescuers.
MANY THANKS for my friend Todd Eastham (MEA) for his assistance in upgraded the Non-Entry Rescue section with specific NFPA requirements for the non-entry rescue assemblies.
