**[Important (and NEW) classifications and definitions of confined
spaces:]{.underline}**

1.  **Continuous System- Permit required confined space** **(CS-PRCS**)
    -- Is part of a larger confined space (for ex., sewers) and the
    employer cannot isolate it from the larger confined space. This type
    of confined space has the potential of hazard release from the
    larger confined space.

2.  **Permit required confined space** **(PRCS)** -- Contains a
    hazardous atmosphere, trapping hazards or any other physical
    hazards.

3.  **Controlled Atmosphere confined space** **(CACS)** -- Ventilation
    alone will control the atmospheric hazards. No physical hazards are
    present.

4.  **Isolated Hazard confined space** **(IHCS)** -- All physical and
    atmospheric hazards are isolated, (eliminated or removed).

**[Overview]{.underline}:**

The 1926 standard for confined spaces contains more sections and
detailed specifications that the 1910 rules (**See table A1**). A basic
outline for the new proposed rule is as follows:

**Section 1926.1201**---Introduction

**Section 1926.1202** -- Scope

**Section 1926.1203** -- Definitions

**Section 1926.1204** -- Worksite evaluation, Information exchange and
coordination.

**Section 1926.1205** -- Atmospheric Testing and Monitoring

**Section 1926.1206** -- Classification and Precautions

**Section 1926.1207** -- Reassessment

**Section 1926.1208** -- Permit-Required Confined Spaces (**PRCS)**

**Section 1926.1209** -- PRCS -- Initial Tasks

**Section 1926.1210** -- PRCS -- Preparing for entry

**Section 1926.1211** -- PRCS -- During entry

**Section 1926.1212** -- PRCS -- Terminating Entry

**Section 1926.1213** -- PRCS -- Rescue Criteria

**Section 1926.1214** -- PRCS -- Entry permits

**Section 1926.1215** -- Continuous System -- PRCS (**CS-PRCS)**

**Section 1926.1216** -- Controlled Atmosphere Confined Spaces --
**(CACS)** Requirements for Classification and Accident Prevention
Protection.

**Section 1926.1217** -- Isolated -- Hazard Confined Spaces **(IHCS)**
-- Requirements for Classification and Accident Prevention and
Protection.

**Section 1926.1218** -- Equipment

**Section 1926.1219** -- Records

[**Notes**:]{.underline}

**Weakness points and unanswered questions are red. *Strengths are green
and in italics*. Questions or doubts are left bolded in black.**

The 29 CFR Part 1926 proposed rules for Confined Spaces in Construction
is more comprehensive and detailed than the already written rule for
General Industry, (**although this program is NOT required to be
written, vs. a required written program in 1910**). Basic differences
and interesting points include: (See also Table 1 on the proposed 1926
rule).

-   [The program is not required to be written, but, most of the
    elements in the program HAVE to be supported by written
    documentation]{.underline}.

-   Four different classifications of confined spaces were **added**,
    such as: 1) Continuous System- Permit required confined space
    **(CS-PRCS)**, 2) Permit required confined space **(PRCS)**, 3)
    Controlled Atmosphere confined space **(CACS)**, and 4) Isolated
    Hazard confined space **(IHCS)**.

-   These classifications are related to the hazard(s) level. (CS-PRCS
    are more hazardous than IHCS).

-   The proposed rule will apply to confined spaces AND will supplement
    any other pertaining standards that are already implemented. Ex:
    Welding in confined spaces. **(???Does this also apply to trenching
    and excavations???)**

-   A difference between host employer and controlling contractor is
    established, **(Not clear).**

-   Also, establishes the responsibilities of the host employer and
    controlling contractor vs. the contractors present at the site.
    **Host employer and controlling contractors are *REQUIRED to share
    information and coordinate activities between ALL the contractors on
    site*.** **(The host employer or controlling contractor is not
    responsible for obtaining any information that it does not have).**

-   Under 1926.1204, paragraph (b), "[contractors]{.underline} are
    REQUIRED to first determine what spaces are confined spaces and
    whether or not they are subjects to any hazards."
    *Paragraphs (b) (1) thru (b) (4) list specific instructions on how
    this will be conducted. Paragraph (c) makes the contractors
    responsible for sharing this information with the host employer or
    the general contractor.*

-   The proposed rule gives more flexibility to the contractor on how to
    classify a confined space, and how to address the identified
    hazards. **If the employer determines that the confined space is not
    subject to any hazards, it will not be classified as above and no
    safety precautions need to be taken.---see 1926.1201 paragraph b(1).
    (Note: The proposed rules also state that a confined space is prone
    to contain hazards that "tend to be unseen and unrecognized until it
    is too late to escape". A knowledgeable or competent person's role
    in identification and classification of the confined space IS NOT
    addressed in this section.)**

-   The contractor will also be responsible for training and informing
    its employees about identified hazards and methods to ensure the
    safety and health of employees. **(Again, a knowledgeable or
    competent person's role in identification and classification of the
    confined space IS NOT addressed in this section.)**

-   The rule specifies that employers are encouraged to try to eliminate
    any physical or other hazards in order to classify the confined
    space with the lowest hazard level possible*. It makes the
    distinction that a CS-PRCS or a PRCS can be documented as CACS or
    IHCS ONLY if physical and atmospheric hazards are eliminated or
    isolated. This does not restrict the employer to classify a lower
    hazard level confined space (CACS) as a higher hazard level confined
    space (PRCS).*

-   There is a Workplace evaluation, information exchange and
    coordination standard, 1926.1204. **(Although a written program is
    not required, supporting documentation will be necessary to comply
    with the rules in this standard.)**

-   Reassessment procedures are discussed in 1926.1207. (*A list of
    events that will require a reassessment of the confined space is
    provided, although it clearly states that the list will not be
    limited to the listed events).*

-   Monitoring is addressed in 1926.1205 paragraphs (a). The terms
    "periodically" and "as necessary" are used to determine the
    frequency of monitoring. **(Gray area determining monitoring
    requirements. Also, contradictory to the "continuous monitoring
    required in latter paragraphs).**

-   Nevertheless, on 1926.1211 paragraph (b) states that "monitoring
    must be continuous unless the employer can demonstrate that the
    equipment is not commercially available or periodic monitoring is
    sufficient." (*It gives special emphasis to the difference between
    general industry and construction, since in a construction setting
    it is more difficult to predict hazardous levels of contaminants in
    the atmosphere*).

-   1926.1205 paragraph (b) requires employers to provide medical
    facilities that treat employees exposed to certain atmospheric
    hazards. **(Another gray area over who will be ultimately
    responsible for this; host employer/controlling contractor or
    contractors??)**

-   1926.1209 provides more "specific information to employers about how
    to limit PRCS access to authorized entrants at construction
    worksites."

-   Among the requirements to limit the entry to PRCS are:

    -   Use of barriers or physical restrictions

    -   Post signs

    -   Sharing of information with the controlling contractor and the
        measures used to prevent entry

    -   Only "authorized entrants" will be allowed to enter

    -   Training -- Inform employees about the responsibilities assigned
        according to who will be entry supervisors, attendants,
        authorized entrants, and rescue-service employees.

-   *Even though the program does not have to be written, paragraph
    (d)(5) states that the "employer will be required to maintain
    training records for each employee"*.

-   As for PRCS entry and rescue operations, there are many similarities
    with the general industry standard; nevertheless, differences and
    important (more detailed) specifications were added to the standard
    applicable for construction. These include:

    -   *A hazard assessment will be required before "[any cover is
        removed]{.underline}".* [(1910.146 states that "Any conditions
        making it unsafe to remove an entrance cover shall be eliminated
        before the cover is removed" -- Involves hazard assessment, but
        is not as direct as the construction standard)]{.underline}

    -   Specifies that if a hoisting system is used for personnel
        rescue, this will gave to be designed and manufactured for
        personnel lifting. "*Commercial hoisting systems not designed
        and manufactured specifically for personnel hoisting will not be
        permissible*". (This rule also gives the employer the
        flexibility of allowing a professional engineer to approve a
        job-made system).

    -   A "mechanical retrieval device" must be provided and used for
        retrievals involving vertical lifelines over five feet. (No
        simple pulleys or anchor points -- See p. 67377 second column,
        paragraph (a)(3)).

    -   [Movable equipment present at the job site may be used as an
        anchor point for an employee life line, if heavy enough to serve
        as an anchor point and only if effectively locked out and tagged
        out.]{.underline}

    -   [INTERESTING: Paragraph (a)(4) has a more detailed description
        of the types of equipment that is not allowed or suitable for
        PRCS retrieval.]{.underline} (Ex: equipment that increases the
        overall risk of an entrant, retrieval lines that could become
        entangled, wristlets or ankle straps "would be prohibited from
        being used as attachment points for retrieval lines).

    -   *As mentioned above, continuous monitoring is required, unless,
        periodic monitoring is proved to be enough for employee
        protection.*

-   During rescue operations, similar to the general industry standard,
    the rule allows the employer flexibility on how to attach the
    harness to the employees' body. (Performance- based provision -- see
    1926.1213 paragraph (a) (2) (iv) (A).

-   *The standard specifies that employers have to ensure that "rescue
    service employees practice the removal of dummies, mannequins, or
    people from a PRCS or from a simulated PRCS.*

-   Entry permits for PRCS in construction are VERY similar to the
    General Industry requirements.

-   1926.1214 paragraph (b) (2) requires employers to review any other
    information from previous entry operations when reviewing the PRCS
    entries. This means that employers have to obtain this information
    from "sources [other]{.underline} than cancelled permits". This is
    in addition to the similar requirements in 1910.146

-   *CS-PRCS require continuous monitoring (as PRCS), nevertheless, the
    distinction is made that these confined spaces have an enhanced risk
    relative to the PRCS. Requirements for continuous monitoring are
    stricter on CS-PRCS. The burden of proof is on the employer to
    demonstrate that periodic monitoring would be sufficient to ensure
    that atmospheric hazards are not a threat to employees working in
    the CS-PRCS.*

-   *Early warning system is required for non-isolated engulfment
    hazards in CS-PRCS*.

-   [A Controlled Atmosphere Confined Spaces (CACS) classification was
    added to the construction std.]{.underline} **(The difference
    between CACS and IHCS is not clear in this section. The standard
    seems to make no distinction between the two in this section. --
    Need clarification).**

-   When employers can isolate the physical hazards and control
    atmospheric hazards (by forced ventilation), without entering the
    space, they would not "be required to comply with the PRCS
    requirements during identification/implementation process.

-   Forced ventilation will be used to control the atmospheric hazards
    in a CACS and the effectiveness of the forced ventilation will be
    determined by monitoring.

-   It is interesting to note that in a CACS, if ventilation fails, the
    atmosphere will remain at safe levels. When monitoring determines
    that atmospheric hazard levels are rising, entrants can safely exit
    the space until ventilation is restored. (This makes it "unnecessary
    for employer to arrange for a rescue service as required for PRCSs).

-   *The rule also makes emphasis on the fact that if the atmospheric
    hazards rise rapidly to unsafe levels, (in the event that mechanical
    ventilation fails), then the confined space shall be classified as
    PRCS and only mechanical ventilation may be an "inappropriate
    method" for controlling the atmospheric hazard.*

-   *Isolation of physical hazards and controlled atmospheric hazards
    with forced ventilation in CACS has to be documented by WRITING*.
    (1926.1216 paragraph (d) (4) lists the specific contents that the
    written verification must include.)

-   Under the training requirements, of 1926.1216 (CACS) paragraph
    (b)(2)(ii), the employer is required to train employees who are NOT
    authorized to perform entry rescues about the dangers of such
    rescues[.]{.underline} (This requirement is not listed on the
    general industry standard).

-   Paragraph (b) (2) (iii) (C) requires employers to ensure that
    employees exit a CACS when a hazard in the space arises for which
    the employees have not received training. (Another requirement not
    listed on the general industry standard).

-   **???? 1926.1217 states that "When an employer isolates or
    eliminates all atmospheric and physical hazards in a space, the
    space would qualify for the IHCS classification.** **(Still a little
    unclear about the difference between a CACS and an IHCS).**

> **\*\*\**(****Personal interpretation: In a CACS the atmospheric
> hazard still exists is just kept 'under control' while in an IHCS
> hazards, both atmospheric and physical are eliminated or isolated in a
> way that the hazard will not affect the confined space. This makes the
> IHCS classification less hazardous since there are no hazards
> affecting the confined space.)\*\*\**

-   Different from the training requirements for PRCSs, CS-PRCSs, and
    CACSs, documentation of training is NOT required for IHCSs.

Table **A1** -- Comparison between 1926 and 1910 rules \*\*:

+-----------------------------------+-----------------------------------+
| **1926 Proposed rules sections**  | **1910 rules sections**           |
+-----------------------------------+-----------------------------------+
| **Section                         | **1910.146** (a) Scope            |
| 1926.1201**---Introduction        |                                   |
|                                   | **1910.146** (b) Definitions      |
| **Section 1926.1202** -- Scope    |                                   |
|                                   | **1910.146** (c) General          |
| **Section 1926.1203** --          | Requirements                      |
| Definitions                       |                                   |
|                                   | **1910.146** (d) Permit-required  |
| **Section 1926.1204** -- Worksite | confined space program.           |
| evaluation, Information exchange  |                                   |
| and coordination.                 | **1910.146** (e) Permit system    |
|                                   |                                   |
| **Section 1926.1205** --          | **1910.146** (f) Entry permit     |
| Atmospheric Testing and           |                                   |
| Monitoring                        | **1910.146** (g) Training         |
|                                   |                                   |
| **Section 1926.1206** --          | **1910.146** (h) Duties of        |
| Classification and Precautions    | authorized entrants.              |
|                                   |                                   |
| **Section 1926.1207** --          | **1910.146** (i) Duties of        |
| Reassessment                      | attendants                        |
|                                   |                                   |
| **Section 1926.1208** --          | **1910.146** (j) Duties of        |
| Permit-Required Confined Spaces   | supervisors                       |
| (**PRCS)**                        |                                   |
|                                   | **1910.146** (K) Rescue and       |
| **Section 1926.1209** -- PRCS --  | emergency services                |
| Initial Tasks                     |                                   |
|                                   | **1910.146** (l) Employee         |
| **Section 1926.1210** -- PRCS --  | participation                     |
| Preparing for entry               |                                   |
|                                   |                                   |
| **Section 1926.1211** -- PRCS --  |                                   |
| During entry                      |                                   |
|                                   |                                   |
| **Section 1926.1212** -- PRCS --  |                                   |
| Terminating Entry                 |                                   |
|                                   |                                   |
| **Section 1926.1213** -- PRCS --  |                                   |
| Rescue Criteria                   |                                   |
|                                   |                                   |
| **Section 1926.1214** -- PRCS --  |                                   |
| Entry permits                     |                                   |
|                                   |                                   |
| **Section 1926.1215** --          |                                   |
| Continuous System -- PRCS         |                                   |
| (**CS-PRCS)**                     |                                   |
|                                   |                                   |
| **Section 1926.1216** --          |                                   |
| Controlled Atmosphere Confined    |                                   |
| Spaces -- **(CACS)** Requirements |                                   |
| for Classification and Accident   |                                   |
| Prevention Protection.            |                                   |
|                                   |                                   |
| **Section 1926.1217** -- Isolated |                                   |
| -- Hazard Confined Spaces         |                                   |
| **(IHCS)** -- Requirements for    |                                   |
| Classification and Accident       |                                   |
| Prevention and Protection.        |                                   |
|                                   |                                   |
| **Section 1926.1218** --          |                                   |
| Equipment                         |                                   |
|                                   |                                   |
| **Section 1926.1219** -- Records  |                                   |
+-----------------------------------+-----------------------------------+

> \*\* Note that the General Industry Standard only classifies confined
> spaces as permit required or not. The proposed rule for construction
> allows the employer to classify the confined spaces found on site with
> different classifications, depending on the hazards found and how will
> they be controlled.\*\*

Table **A2- Summary:**

+-----------------+--------------------+-----------------+------------+
| **[Observed     | **[Observed        | **[Interesting  | **         |
| Strengths       | weaknes            | observations    | [Questions |
| ]{.underline}** | ses]{.underline}** | and             | or         |
|                 |                    | comparisons     | com        |
|                 |                    | ]{.underline}** | ments]{.un |
|                 |                    |                 | derline}** |
+-----------------+--------------------+-----------------+------------+
| New and more    |                    |                 | How will   |
| detailed        |                    |                 | this       |
| definitions for |                    |                 | standard   |
| confined spaces |                    |                 | affect     |
| -- Allow        |                    |                 | trenching  |
| employer to     |                    |                 | and        |
| become more     |                    |                 | exc        |
| involved in     |                    |                 | avations?? |
| eliminating     |                    |                 | Can        |
| and/or          |                    |                 | citations  |
| isolating       |                    |                 | be issued  |
| hazards.        |                    |                 | using this |
|                 |                    |                 | standard   |
|                 |                    |                 | in         |
|                 |                    |                 | c          |
|                 |                    |                 | onjunction |
|                 |                    |                 | with the   |
|                 |                    |                 | trenching  |
|                 |                    |                 | and        |
|                 |                    |                 | excavation |
|                 |                    |                 | co         |
|                 |                    |                 | nstruction |
|                 |                    |                 | std.??     |
+-----------------+--------------------+-----------------+------------+
| Supportive      |                    | No written      |            |
| documentation   |                    | program vs.     |            |
| is required for |                    | written program |            |
| hazard          |                    | required for    |            |
| assessments,    |                    | 1910.           |            |
| monitoring,     |                    |                 |            |
| training and    |                    |                 |            |
| other           |                    |                 |            |
| determinations. |                    |                 |            |
+-----------------+--------------------+-----------------+------------+
| Contractors are | No clear           |                 |            |
| held            | difference between |                 |            |
| responsible for | host employer and  |                 |            |
| sharing         | controlling        |                 |            |
| confined space  | contractor.        |                 |            |
| information     |                    |                 |            |
| with the host   |                    |                 |            |
| employer or the |                    |                 |            |
| general         |                    |                 |            |
| contractor.     |                    |                 |            |
+-----------------+--------------------+-----------------+------------+
|                 | A knowledgeable or |                 | The        |
|                 | competent person's |                 | contractor |
|                 | role in            |                 | is assumed |
|                 | identification and |                 | to be a    |
|                 | classification of  |                 | competent  |
|                 | the confined space |                 | or         |
|                 | IS NOT addressed.  |                 | knowl      |
|                 |                    |                 | edgeable?? |
+-----------------+--------------------+-----------------+------------+
| **[Observed     | **[Observed        | **[Interesting  | **         |
| Strengths       | weaknesses         | observations    | [Questions |
| (cont.)         | (con               | and comparisons | or         |
| ]{.underline}** | t.)]{.underline}** | (cont.)         | comments   |
|                 |                    | ]{.underline}** | (c         |
|                 |                    |                 | ont.)]{.un |
|                 |                    |                 | derline}** |
+-----------------+--------------------+-----------------+------------+
| The employer is | Gray area over who | The proposed    | Gray area  |
| required to     | will be ultimately | rule gives      | over who   |
| provide medical | responsible for    | special         | will be    |
| facilities to   | this; (host        | emphasis to the | ultimately |
| treat employees | em                 | difference      | r          |
| affected by     | ployer/controlling | between general | esponsible |
| atmospheric     | contractor or      | industry and    | for this;  |
| hazards in the  | contractors??)     | construction    | (host      |
| confined space. |                    | monitoring      | employer/c |
|                 |                    | requirements,   | ontrolling |
|                 |                    | since in a      | contractor |
|                 |                    | construction    | or         |
|                 |                    | setting it is   | cont       |
|                 |                    | more difficult  | ractors??) |
|                 |                    | to predict      |            |
|                 |                    | hazardous       |            |
|                 |                    | levels of       |            |
|                 |                    | contaminants in |            |
|                 |                    | the atmosphere. |            |
+-----------------+--------------------+-----------------+------------+
| More detailed   | *'Movable          | The proposed    |            |
| description of  | equipment'*        | rule makes the  |            |
| the types of    | present at the job | distinction     |            |
| equipment that  | site may be used   | that a CS-PRCS  |            |
| is **not**      | as an anchor point | or a PRCS can   |            |
| allowed or      | for an employee    | be documented   |            |
| suitable for    | life line, if      | as CACS or IHCS |            |
| PRCS retrieval. | heavy enough to    | ONLY if         |            |
|                 | serve as an anchor | physical and    |            |
|                 | point and only if  | atmospheric     |            |
|                 | effectively locked | hazards are     |            |
|                 | out and tagged     | eliminated or   |            |
|                 | out.               | isolated. This  |            |
|                 |                    | does not        |            |
|                 |                    | restrict the    |            |
|                 |                    | employer to     |            |
|                 |                    | classify a      |            |
|                 |                    | lower hazard    |            |
|                 |                    | level confined  |            |
|                 |                    | space (CACS) as |            |
|                 |                    | a higher hazard |            |
|                 |                    | level confined  |            |
|                 |                    | space (PRCS).   |            |
+-----------------+--------------------+-----------------+------------+
| **[Observed     | **[Observed        | **[Interesting  | **         |
| Strengths       | weaknesses         | observations    | [Questions |
| (cont.)         | (con               | and comparisons | or         |
| ]{.underline}** | t.)]{.underline}** | (cont.)         | comments   |
|                 |                    | ]{.underline}** | (c         |
|                 |                    |                 | ont.)]{.un |
|                 |                    |                 | derline}** |
+-----------------+--------------------+-----------------+------------+
| A hazard        |                    | A hazard        |            |
| assessment will |                    | assessment will |            |
| be required     |                    | be required     |            |
| before "any     |                    | before "any     |            |
| cover is        |                    | cover is        |            |
| removed"        |                    | removed".       |            |
|                 |                    | (1910.146       |            |
|                 |                    | states that     |            |
|                 |                    | "Any conditions |            |
|                 |                    | making it       |            |
|                 |                    | unsafe to       |            |
|                 |                    | remove an       |            |
|                 |                    | entrance cover  |            |
|                 |                    | shall be        |            |
|                 |                    | eliminated      |            |
|                 |                    | before the      |            |
|                 |                    | cover is        |            |
|                 |                    | removed" --     |            |
|                 |                    | Involves hazard |            |
|                 |                    | assessment, but |            |
|                 |                    | is not as       |            |
|                 |                    | specific as the |            |
|                 |                    | construction    |            |
|                 |                    | standard)       |            |
+-----------------+--------------------+-----------------+------------+
| The standard    |                    | 1926 rule       |            |
| specifies that  |                    | specifies that  |            |
| employers have  |                    | if a hoisting   |            |
| to ensure that  |                    | system is used  |            |
| "rescue service |                    | for personnel   |            |
| employees       |                    | rescue, it will |            |
| practice the    |                    | have to be      |            |
| removal of      |                    | designed and    |            |
| dummies,        |                    | manufactured    |            |
| mannequins, or  |                    | for personnel   |            |
| people from a   |                    | lifting. (This  |            |
| PRCS or from a  |                    | rule also gives |            |
| simulated PRCS. |                    | the employer    |            |
|                 |                    | the flexibility |            |
|                 |                    | of allowing a   |            |
|                 |                    | professional    |            |
|                 |                    | engineer to     |            |
|                 |                    | approve a       |            |
|                 |                    | job-made        |            |
|                 |                    | system).        |            |
+-----------------+--------------------+-----------------+------------+
| **[Observed     | **[Observed        | **[Interesting  | **         |
| Strengths       | weaknesses         | observations    | [Questions |
| (cont.)         | (con               | and comparisons | or         |
| ]{.underline}** | t.)]{.underline}** | (cont.)         | comments   |
|                 |                    | ]{.underline}** | (c         |
|                 |                    |                 | ont.)]{.un |
|                 |                    |                 | derline}** |
+-----------------+--------------------+-----------------+------------+
| CS-PRCS require |                    | An early        |            |
| continuous      |                    | warning system  |            |
| monitoring (as  |                    | is required for |            |
| PRCS),          |                    | non-isolated    |            |
| nevertheless,   |                    | engulfment      |            |
| the distinction |                    | hazards in      |            |
| is made that    |                    | CS-PRCS.        |            |
| these confined  |                    |                 |            |
| spaces have an  |                    |                 |            |
| enhanced risk   |                    |                 |            |
| relative to the |                    |                 |            |
| PRCS.           |                    |                 |            |
| Requirements    |                    |                 |            |
| for continuous  |                    |                 |            |
| monitoring are  |                    |                 |            |
| stricter on     |                    |                 |            |
| CS-PRCS.        |                    |                 |            |
+-----------------+--------------------+-----------------+------------+
|                 | The difference     | Under the       | *          |
|                 | between CACS and   | training        | \*\*\*CSHO |
|                 | IHCS is not clear  | requirements,   | und        |
|                 | in this section.   | of 1926.1216    | erstanding |
|                 | The standard seems | (CACS)          | of this    |
|                 | to make no         | paragraph       | defferenc  |
|                 | distinction        | (b)(2)(ii), the | e:\*\*\**: |
|                 | between the two in | employer is     |            |
|                 | this section. --   | required to     | In a CACS  |
|                 | Need clarification | train employees | the        |
|                 |                    | who are NOT     | a          |
|                 |                    | authorized to   | tmospheric |
|                 |                    | perform entry   | hazard     |
|                 |                    | rescues about   | still      |
|                 |                    | the dangers of  | exists is  |
|                 |                    | such rescues.   | just kept  |
|                 |                    | (This           | 'under     |
|                 |                    | requirement is  | control'   |
|                 |                    | not listed on   | while in   |
|                 |                    | the general     | an IHCS    |
|                 |                    | industry        | hazards,   |
|                 |                    | standard).      | both       |
|                 |                    |                 | a          |
|                 |                    |                 | tmospheric |
|                 |                    |                 | and        |
|                 |                    |                 | physical   |
|                 |                    |                 | are        |
|                 |                    |                 | eliminated |
|                 |                    |                 | or         |
|                 |                    |                 | isolated   |
|                 |                    |                 | in a way   |
|                 |                    |                 | that the   |
|                 |                    |                 | hazard     |
|                 |                    |                 | will not   |
|                 |                    |                 | affect the |
|                 |                    |                 | confined   |
|                 |                    |                 | space.     |
+-----------------+--------------------+-----------------+------------+
| **[Observed     | **[Observed        | **[Interesting  | **         |
| Strengths       | weaknesses         | observations    | [Questions |
| (cont.)         | (con               | and comparisons | or         |
| ]{.underline}** | t.)]{.underline}** | (cont.)         | comments   |
|                 |                    | ]{.underline}** | (c         |
|                 |                    |                 | ont.)]{.un |
|                 |                    |                 | derline}** |
+-----------------+--------------------+-----------------+------------+
| The rule also   |                    | Paragraph (b)   | It is      |
| makes emphasis  |                    | (2) (iii) (C)   | i          |
| on the fact     |                    | requires        | nteresting |
| that if the     |                    | employers to    | to note    |
| atmospheric     |                    | ensure that     | that in a  |
| hazards rise    |                    | employees exit  | CACS, if   |
| rapidly to      |                    | a CACS when a   | v          |
| unsafe levels,  |                    | hazard in the   | entilation |
| (in the event   |                    | space arises    | fails, the |
| that mechanical |                    | for which the   | atmosphere |
| ventilation     |                    | employees have  | will       |
| fails), then    |                    | not received    | remain at  |
| the confined    |                    | training.       | safe       |
| space shall be  |                    | (Requirement    | levels.    |
| classified as   |                    | not listed on   | When       |
| PRCS and only   |                    | the general     | monitoring |
| mechanical      |                    | industry        | determines |
| ventilation may |                    | standard).      | that       |
| be an           |                    |                 | a          |
| "inappropriate  |                    |                 | tmospheric |
| method" for     |                    |                 | hazard     |
| controlling the |                    |                 | levels are |
| atmospheric     |                    |                 | rising,    |
| hazard.         |                    |                 | entrants   |
|                 |                    |                 | can safely |
|                 |                    |                 | exit the   |
|                 |                    |                 | space      |
|                 |                    |                 | until      |
|                 |                    |                 | v          |
|                 |                    |                 | entilation |
|                 |                    |                 | is         |
|                 |                    |                 | restored.  |
|                 |                    |                 | (This      |
|                 |                    |                 | makes it   |
|                 |                    |                 | "u         |
|                 |                    |                 | nnecessary |
|                 |                    |                 | for        |
|                 |                    |                 | employer   |
|                 |                    |                 | to arrange |
|                 |                    |                 | for a      |
|                 |                    |                 | rescue     |
|                 |                    |                 | service as |
|                 |                    |                 | required   |
|                 |                    |                 | for        |
|                 |                    |                 | PRCSs).    |
+-----------------+--------------------+-----------------+------------+
| Isolation of    |                    |                 |            |
| physical        |                    |                 |            |
| hazards and     |                    |                 |            |
| controlled      |                    |                 |            |
| atmospheric     |                    |                 |            |
| hazards with    |                    |                 |            |
| forced          |                    |                 |            |
| ventilation in  |                    |                 |            |
| CACS has to be  |                    |                 |            |
| documented by   |                    |                 |            |
| WRITING.        |                    |                 |            |
+-----------------+--------------------+-----------------+------------+