Confined Space
Confined spaces must be labeled. Where do you draw the line on what gets labeled though?
Realistically there are tons of vents and ducts that “could “ be disassembled and entered. And would be prcs if they did.
Where do you draw the line between what is and is not labeled ?
I’m looking for best practice. Specifically I say a 36 bolt test port on a vertical air vent that was not labeled but big enough to be entered if needed should it be removed.
Obviously it’s a confined space if you were to rake it apart and then crawl in. But it’s not designed for that use.
If the would be access is not designed as an entry port , but could be used as one , does it legally HAVE to be labeled ?
Comments (1)
If it's a permit-required confined space, then you must "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." Two different OSHA letters of interpretation state the following:
"Ordinarily, information about permit spaces is most effectively and economically communicated through the use of signs. Consequently, signs would be the principal method of warning under the standard. Alternative methods, such as additional training, may be used where they are truly effective in warning all employees who could reasonably be expected to enter the space. It is the employer's obligation to assure that an alternative method is at least as effective as a sign. In some cases, employers may have to provide training in addition to signs, to protect employees who do not speak English or who would have difficulty understanding or interpreting signs. (One method by which OSHA can gauge an employer's effectiveness is through random interviews of affected employees.)
If a space has a locked entry cover or panel, or an access door that can only be opened with special tools, the use of sign's may be unnecessary. If the employer ensures that all affected employees are informed about such spaces and know that they are not to be opened without taking proper precautions, including temporary signs, to restrict unexpected or unknowing."
Keep in mind signage is only required for permit-required confined spaces, not non-permit spaces. Vents and ducts, in my cases, are only considered non-permit spaces and would, therefore, not require any signage.