How much periodic testing is required?
The frequency of testing depends on the nature of the permit space and the results of the initial testing performed under paragraph (c)(5)(ii)(c).
Paragraph (c)(5)(ii)(F) requires periodic testing, as necessary, to ensure the space is maintained within the limits of the acceptable entry conditions. OSHA believes that all permit space atmospheres are dynamic due to variables such as temperature, pressure, physical characteristics of the material posing the atmospheric hazard, variable efficiency of ventilation equipment, and air delivery system, etc.
The employer will have to determine and document on an individual permit space basis what the frequency of testing will be and under what conditions the verification testing will be done.
Our space has a door, does that mean it does not have limited or restricted means of entry or exit and therefore is not a confined space?
A space has limited or restricted means of entry or exit if an entrant’s ability to escape in an emergency would be hindered. The dimensions of a door and its location are factors in determining whether an entrant can easily escape. However, the presence of a door does not automatically mean that the space is not a confined space.
For example, a space such as a bag house or crawl space that has a door leading into it, but also has pipes, conduits, ducts, equipment, or materials that an employee would be required to crawl over or under, or squeeze around in order to escape, has limited means of exit. A piece of equipment with an access door, such as a conveyor feed, a drying oven, or a paint spray enclosure, will also be considered restricted means of entry or exit if an employee has to crawl to gain access to his or her intended work location. Similarly, an access door or portal which is too small to allow an employee to walk upright and unimpeded through is considered to restrict an employee’s ability to escape. OSHA published a technical amendment to the preamble in Federal Register Vol. 59, No. 213/Friday, November 4, 1994, page 55208.
How many people can enter at a time?
The competent person and/or supervisor of the entry needs to determine how many people can safely enter and operate in a confined space. This needs to be done on a case-by-case basis or entry-by-entry basis.
How many rescuers are needed, one per entrant?
OSHA does not set the actual number of rescuers. This number will be determined by the rescue team, and it is based on a variety of factors.
Can the rescue team double as attendant as well?
OSHA has letters of interpretation that speak to this. The long answer is yes, but there’s a lot of steps that must happen if/when the rescue team is called into duty. We prefer that every CSE have their own dedicated attendant.
Can you just send one member of your rescue team, and we’ll pair them with others on site?
IS&R will never send one rescue team member to accommodate a client. By nature of the word TEAM, it is more than one. Our minimum team is two members and depending on the scope of work, that number can increase accordingly.
Do we need to be trained before entering?
All involved in CSE should have initial training, as well as refresher training as often as possible.
There’s more than one egress point, so it’s not really a confined space.
OSHA defines a confined space as having limited means of egress, so it doesn’t matter if there’s more than one egress point.
We checked the air, and the oxygen levels are fine, so we’re going to declassify
OSHA does not limit its list of known hazards to just the existence of oxygen or lack there of as a means of declaring a confined space to enter without a permit.
It’s not really a confined space but the GC is making us hire a rescue team.
We usually question the level of the training of those performing work, when these comments are made. IS&R prides itself on coaching anyone involved in CSE.
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Our Team Will Provide You With
Standby rescue services
All IS&R employees are trained first responders, EMTs, Paramedics, and/or Firefighters with the ability to rescue and provide medical attention if needed.
Training for your employees
Our team is OSHA authorized to train your employees and enforce all confined space rules and regulations. We also present guidelines on how to safely enter and exit the confined space you’re working in.
Rescue plans
OSHA requires a written rescue plan before employees enter a permit required confined space. IS&R can work with you to create and write a procedure outlining the best possible work environment in compliance with OSHA standards.
Confined Space Rescue Resources
On-Site, Not Just On Call
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