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OSHA 1926.1205

Entry permit procedures

1926 Subpart AA

20 Questions & Answers
10 Interpretations

Questions & Answers

Under 1926.1205(a), what must the entry employer do before authorizing entry into a permit-required confined space?

The entry employer must document that the measures required by 1926.1204(c) are completed by preparing an entry permit before entry is authorized.

  • The permit is the written record that shows the pre-entry steps (such as testing, isolation, and ventilation) called for in 1926.1204(c) were taken.
  • Keep the permit available during the entry so entrants can verify the required measures were completed.

Under 1926.1205(b), who must sign the entry permit and when?

The entry supervisor identified on the permit must sign the entry permit to authorize entry before entry begins, as required by 1926.1205(b).

  • Do not allow authorized entrants into the space until the entry supervisor has signed the permit.

Under 1926.1205(c), how must the completed entry permit be made available to entrants and their representatives?

The completed permit must be made available at the time of entry to all authorized entrants or their authorized representatives by posting it at the entry portal or by any other equally effective means so entrants can confirm pre-entry preparations, as required by 1926.1205(c).

  • Examples of "equally effective means" include handing a copy to the attendant, placing it in a binder at the worksite, or using an electronic system that entrants can access at the portal.

Under 1926.1205(d), how long can an entry permit remain valid?

The duration of the permit may not exceed the time required to complete the assigned task or job identified on the permit, in accordance with 1926.1206(b).

  • Set the permit duration to match the realistic time for the specific job; do not issue open-ended permits that exceed task completion time.

Under 1926.1205(e)(1), when must the entry supervisor cancel the entry permit?

The entry supervisor must cancel the entry permit when the entry operations covered by the entry permit have been completed, per 1926.1205(e)(1).

  • Canceling documents that the job is finished and starts the required record-retention period.

Under 1926.1205(e)(2), what must the entry supervisor do if a temporary condition not allowed under the permit arises near or in the permit space?

The entry supervisor must suspend or cancel the entry permit and fully reassess the space before allowing reentry when a temporary condition not allowed under the permit arises in or near the permit space and it does not change the space's configuration or create new hazards, as explained in 1926.1205(e)(2).

  • After suspension, perform hazard evaluation and corrective measures, document findings, and issue a new or revalidated permit before reentry.

Under 1926.1205(e)(3), what action is required when a condition not allowed under the permit arises and is not covered by paragraph (e)(2)?

The entry supervisor must cancel the entry permit when a condition that is not allowed under the entry permit arises in or near the permit space and that condition is not covered by 1926.1205(e)(2).

  • Cancellation signals that the permit's assumptions are no longer valid and reentry requires a full reassessment and a new permit.

Under 1926.1205(f), how long must canceled entry permits be retained and why?

The entry employer must retain each canceled entry permit for at least 1 year to facilitate the review of the permit-required confined space program required by 1926.1204(n), as required by 1926.1205(f).

  • Note any problems encountered during the entry on the permit so the permit-required confined space program can be updated based on real incidents and near misses.

Under 1926.1205(f), what must be noted on the permit if problems occur during entry operations?

Any problems encountered during an entry operation must be noted on the pertinent permit so that appropriate revisions to the permit space program can be made, as required by 1926.1205(f).

  • Document equipment failures, unexpected atmospheric readings, near misses, and any procedural gaps observed so you can revise procedures, training, or equipment lists.

Under 1926.1205(c), can an entry employer use an electronic copy of the permit instead of posting a paper permit at the entry portal?

Yes; an electronic copy can be used if it is an "equally effective means" to make the completed permit available to entrants or their authorized representatives at the time of entry, per 1926.1205(c).

  • Ensure electronic access is reliable at the entry portal and that entrants can view the permit before entering.

Under 1926.1205(a) and 1926.1204(c), what kinds of measures must be completed and documented on the entry permit before entry?

The entry permit must document completion of the pre-entry measures required by 1926.1204(c), such as testing the atmosphere, isolating energy sources, ventilating, and verifying that hazards are controlled.

  • Typical items to document include atmospheric test results, lockout/tagout steps, physical barriers installed, ventilation provided, and required PPE or rescue arrangements, consistent with 1926.1204(c).

Under 1926.1205, who should be able to confirm that pre-entry preparations are completed and how?

Authorized entrants and their authorized representatives must be able to confirm that pre-entry preparations are completed by accessing the completed permit at the entry portal or by an equally effective method, as required by 1926.1205(c).

  • Make sure entrants know where to find the permit and understand the key items it documents (e.g., atmospheric readings, isolation, and rescue arrangements).

Under 1926.1205(d) and 1926.1206(b), how should a supervisor decide the permit's end time for a multi-step job?

The supervisor should set the permit duration to cover only the time required to complete the specific assigned task or job on the permit, consistent with 1926.1205(d) and the task-based timing in 1926.1206(b).

  • For multi-step jobs, either issue separate permits for distinct tasks with different hazards or issue a single permit with clear start/stop times tied to the specific scope and duration in 1926.1206(b).

Under 1926.1205(e)(2), if a temporary condition is fixed, can the original permit be resumed or must a new permit be issued?

If the temporary condition is addressed and the space is fully reassessed and found safe under the original permit's conditions, the supervisor may reauthorize entry after documentation; however, 1926.1205(e)(2) requires suspension or cancellation and a full reassessment before reentry.

  • Practically, document the reassessment and either reinstate the original permit (if allowed by your program) or issue a new permit reflecting any updated controls.

Under 1926.1205(f), how does retaining canceled permits help improve the confined space program under 1926.1204(n)?

Retaining canceled permits for at least 1 year provides records of past entries, problems, and corrective actions so the employer can review and revise the permit-required confined space program as required by 1926.1204(n) and 1926.1205(f).

  • Use canceled permits to identify recurring hazards, training gaps, equipment failures, or procedural weaknesses and update policies, training, and permits accordingly.

Under 1926.1205(a) and 1926.1204(c), can another employer prepare the entry permit for a subcontractor's workers?

An entry employer must document completion of the measures in 1926.1204(c) by preparing the entry permit, so whoever is the entry employer (the one responsible for the entrants) must ensure the permit is prepared and signed as required by 1926.1205(a).

  • If a subcontractor is the entry employer for its workers, that subcontractor must either prepare its own permit or ensure that a host or controlling employer prepares a permit that documents the required measures and identifies the entry supervisor.

Under 1926.1205(b), can an entry supervisor delegate the signature authority to someone else?

The permit must be signed by the entry supervisor identified on the permit to authorize entry, per 1926.1205(b), so the supervisor named on the permit needs to sign it; if another person will act as the entry supervisor, they must be identified on and sign the permit.

  • If you change who is supervising the entry, update the permit to name the new entry supervisor and obtain their signature before allowing entry.

Under 1926.1205(c), can authorized representatives from outside the company (like a union rep) review the entry permit?

Yes; the completed permit must be made available at the time of entry to authorized entrants or their authorized representatives, which can include union representatives, by posting at the entry portal or using an equally effective means as required by 1926.1205(c).

  • Ensure access procedures allow legitimate authorized representatives to view the permit without delaying work.

Under 1926.1205, what must be done if entry operations are interrupted overnight and work resumes the next day?

If the permit duration would exceed the time required to complete the assigned task, the employer must ensure the permit remains valid only for the permitted duration; if conditions changed or the permit expired, the entry supervisor must suspend or cancel the permit and fully reassess the space before reentry, consistent with 1926.1205(d) and 1926.1205(e).

  • When in doubt, perform fresh checks (atmospheric testing, isolation verification) and either extend the permit properly or issue a new permit before work resumes.

Under 1926.1205(f), what kind of entries or problems should be specifically documented on the canceled permit for later program review?

You should note on the canceled permit any equipment failures, unexpected atmospheric readings, near misses, injuries, deviations from procedures, or failures of PPE or rescue arrangements, because 1926.1205(f) requires documenting problems to support program revisions under 1926.1204(n).

  • Use these notes to update training, rescue plans, equipment lists, and permit checklists.