Finding the right approach. What do you mean, this is a non-permit required confined space?
While not a big fan of the non-permit confined space designation, I have come to believe the approach can work if done properly. However, it is this author's opinion that the designation of a confined space as non-permit required in any work environment should be the exception rather than the rule. The up-front determination that a space is "non-permit-required" should necessarily consume more time and resources than assuming the space is "permit-required" because so fewer controls are in place. Most certainly, this decision must be based on the knowledge that no hazards are present or have the potential to develop, rather than on "convenience" or "resource limitations"; assumptions should never play a part in the decision. Attention to proper evaluation of confined spaces, documentation of actual conditions over time, and communication to those entering the spaces are all critical components of a safe confined space entry program, whether the space be permit-required or not.
Brown
Robert
R
EHS Compliance & Training Programs for specialty Technical Consultants Inc, Oakland, CA, USA. bbrown@stcenv.com
D019983:Guideline Adherence; D006801:Humans; D016272:Occupational Health; D017751:Safety Management / Q000592:standards*; D014481:United States; D014489:United States Occupational Safety and Health Administration / Q000592:standards*