October 15, 1993

Mr. Doug Schreur
Summit Training Sources, Inc.
620 Three Mile Road, N.W.
Grand Rapids, Michigan 49504

Dear Mr. Schreur:

This is in response to your telephone conversation with Mr. Roger Clark, Director, Directorate of Compliance Programs and your request for review and comments on Summit's training program on Confined Space Entry. Please accept our apology for the delay in getting this review to you.

As you already know, OSHA policy prohibits any form of endorsement or approval of private sector developed training material.

General

The next time the training program is revised, the semantic differences between confined space as you use it in the training program and how it is used in 1910.146 should be explained.

There should be a statement that informs the audience the terms used in the training tape and those used by the employer may be different.

The tape and the facilitator guide both make reference to confined spaces in new construction. This training program is based on the general industry standard which does not cover construction. This comment is not to say that this training program could not be of benefit to construction industry, but that there are different OSHA standards which address confined spaces in construction.

Training Tape

The title is reflective of the final rule but the content of the program is framed around the proposed rule.

The definition of confined space used in the beginning is from the proposed rule not the final rule.

At the end of the section "What is a Confined Space", the tape suggests when in doubt check with your supervisor..... You might consider making reference to the employer's continuing obligation under the standard to evaluate the work place for PRCSs and if employees suspect a confined space has changed by the introduction of a hazard they should also bring this to the attention of the supervisor or safety coordinator for evaluation.

Tests for atmospheric hazards must be conducted before entry. The discussion on the ventilation of the space should remind the audience that the hazardous products being removed by the blower or suction device should not discharge to a location so as to cause a hazard in the surrounding area(s).

Harnesses and other devices associated with fall protection can be part of PPE discussion. The reference to safety harnesses, life lines, and retrieval equipment, when used for rescue purposes, should not be considered PPE but as rescue equipment.

The language toward the end of the tape addressing differing workplace conditions should be redone. It alludes to the "low hazard spaces" of the proposed rule and this category is not in the final rule.

Facilitator Guide

In addition to the answer to question 3 on page 6, if a sign is used by the employer to identify a Permit Space, a copy of the sign should be included in the visual aids.

The answer to question 6 should be expanded to emphasize knowledge of the hazards of the space including the identification of the hazards and what are the acceptable entry conditions and whether they have been met.

The standards summary on page 7 must be updated to reflect the final rule.

Your definition of "confined space" on page 9 reflects the proposed rule.

In the discussion of atmospheric hazards on page 10, the reference to the "oxygen enriched" being a value over 22 percent should be modified to reflect the final rule which is 23.5 percent.

Your discussion of "airborne combustible dust" on page 11 needs further discussion of the hazard. The preamble of the final rule should be of assistance.

Thank you for your patience. Should you have further questions concerning this response, please contact Mr. Don Kallstrom in the Office of General Industry Compliance Assistance (202) 219-8031.

Sincerely,



Raymond E. Donnelly, Director
Office of General Industry
Compliance Assistance