[Is a harness required in the following situation, there is a 12-15' well in which a pump must be replaced on rare occasions. An employee must enter to undo the bolts. Air monitoring is performed and no air quality problems have been detected. A permit program is in place and the response team is notified prior to each entry.]

Review of Definition of Permit Required Confined Space D94-02-053

1910.146(k)(3) requires a full body or chest harness on each authorized entrant to a permit required confined space, unless the harness would increase the hazard of entry or would not contribute to the rescue of the entrant. Wristlets are permitted if a harness is infeasible or if the employer can demonstrate that wristlets are safer and more effective.

The definition of a permit confined space should be reviewed. From the caller's description, there is no hazardous atmosphere and the internal configuration is not inwardly converging. The potential for engulfment should be evaluated, according to the definition provided in the standard. If there is a potential for water to be present at the bottom sufficient to cause drowning of a possibly unconscious person, then there would be an engulfment hazard. Other recognized safety or health hazards must also be evaluated. The results of this evaluation may be used to determine that this confined space is not a permit required confined space and that consequently, the requirements of 1910.146 would not apply. OSHA and DOE would still require protection for the entrant, but 1910.146 would not specifically apply.

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Last modified: 04/18/96 08:50:32