OSHA’s Permit Required Confined Space standard has been around since the mid 1990’s and the requirement(s) to perform “program reviews” has been part of the standard from its very beginning. In a recent OSHRC case, both the Administrative Law Judge and the full commission took issue with a company’s efforts in how they did (or did not do) their “program reviews” and from this case we get an inside view of how OSHA, the ALJ and the OSHRC expects these annual reviews should be done AND how management should respond to the results of the reviews. So lets take a look at these two (2) program review requirements and what’s been established as a baseline for compliance:
