We are still in the Temporary Enforcement Period granted by OSHA for the Construction Confined Space Standard. During this time, many are preparing for the full enforcement of the rule by updating their written programs, entry permits, rescue equipment, and employee training. Life is easy if you are in a state governed by OSHA. If you are in a state-plan state, things might be a little murkier.
At least eight state-plan states were determined by OSHA to have construction confined space rules that already comply with “some or all” of the new Federal OSHA standard. Those states are Alaska, California, Kentucky, Maryland, Michigan, Minnesota, Virginia, and Washington. The rest of the state-plan states and territories are in rule-making process to meet the OSHA deadline of six months from the promulgation of the final rule, sometime in early February 2016.
If you work for a multi-state operation within multiple state-plan states, OSHA has a handy directory of state-plan standards and regulations here. Note that some states, like Connecticut and Indiana, adopt the federal standards identically.
Independent of the above, it is good practice as a safety professional to use the new federal standard as a guideline. Your state-plan state rule will eventually be equal or more strict to this rule. While you may have a longer time frame for compliance, the end result will be the same: your program needs a refresher!
Here’s some resources for compliance, no matter where you live and work:
Full text of the new regulation – You need to read this if you have not already!!!
Preamble to the final rule – A must-read, use Control-F to find key terms that apply to your industry. For example, if you work in sewer and water settings, search for “pipe plugs” and you’ll learn a lot!
www.conconspace.com – Downloadable and customizable written program and employee training templates