Please address the situation when entering new construction underground
manholes and structures, that are not connected to existing service lines, that
there is no need to consider this a confined space. Employees are routinely
entering these types of structures and a contractor would have to hire personnel
solely to monitor this type of entry. Language should address this situation that in
order to be considered an active confined space, the entered area must be
connected to active lines. This would be alot of unecessary paperwork to be filled
out and records kept. This could be logged per jobsite per day or something along
those lines.
Edgar P. Martin, C.E. Williams Sons, Inc.
Comment Submitted by: Edgar P. Martin for C. E. Williams Sons, Inc.
This is comment on Proposed Rule
Confined Spaces in Construction
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