Though the ruling will still become effective Aug. 3, OSHA will not issue citations to an employer that is making good-faith efforts to fulfill training requirements and comply with the standard. The agency will consider the following factors when evaluating these efforts:
- Has the employer trained its employees as required under the new standard, or at least scheduled such training?
- Does the employer have the equipment necessary for compliance, including personal protective equipment?
- Has the employer ordered or arranged to obtain the equipment required for compliance, or taking alternative measures to protect employees from confined space hazards?
- Has the employer engaged in additional efforts to educate and protect workers when it comes to confined space hazards?
- Evaluate the jobsite to identify confined spaces
- Develop a written program and permitting system for permit-required confined spaces
- Control physical hazards and conduct monitoring for atmospheric hazards in confined spaces that are permit required
- Provide training for confined space entrants, attendants, supervisors and emergency duties.