OSHA's permit-required confined space standard (PRCS) went into effect April 15, 1993. This standard (1910.146), arguably the second most difficult of OSHA's standards to comprehend, second only to recordkeeping (1904), likely is the hardest with which to comply. After 18 years, most employers, including many with sound safety systems, are still not in compliance, based on the author's experience. What makes compliance so difficult? What is it employers are not doing?
As a safety consultant, the author has been an expert witness in confined space litigation. He also has conducted audits of clients' confined space systems throughout the U.S., and not a single audit has been without findings. This article shares some common findings encountered to help employers improve their confined space systems. It also examines some misconceptions about the confined space standard. The following findings are presented in no particular order.