Which six words am I talking about? There are a lot of requirements in 1910.146 and 1926.1201-.1213 that get missed on entries. Luckily, missing a few here and there USUALLY does not equate to a tragic accident. However, the six words I speak of are a CRITICAL PATH in a “permitted entry” into a PRCS. And it is hardly ever done by entry supervisors, although most written programs and training will specifically mention the six words.
When the facility learns what these six words entail, they quickly realize there is a lot more to comply with OSHA’s minimum expectations for entries using entry permits. Here are those six words…
Verifies that rescue services are available
In both the GI and Construction standards for Permit-Required Confined Spaces, OSHA has this responsibility listed under those for the Entry Supervisor.
1910.146(j)(4) Verifies that rescue services are available and that the means for summoning them are operable;
and the newer construction standard even includes a special requirement… (emphasis by me)
1926.1210(d) Verifies that rescue services are available and that the means for summoning them are operable, and that the employer will be notified as soon as the services become unavailable;
These six little words mean that the facility has to have a means set up in advance as to how the entry supervisor will CONTACT the rescue service to be used and to VERIFY they are available. If this is the local fire department, this does NOT mean calling 911, as you do not have an emergency BEFORE entry has taken place. The facility must establish how this verification will be accomplished and include it in the entry supervisors’ training. And as pointed out above, the newer construction standard also requires that the rescue service (i.e. the local fire department) agree to notify the entry supervisor when they get called out and are no longer “available” – meaning the entry MUST be terminated until such time the rescue service is available once again.
