September 30, 1996

Dave Black
Timber Operators Council
895 Country Club Rd.
Suite “A-160”
Eugene OR 97401

Dear Mr Black:

This is in response to your August 9, 1996 letter in which you ask if it is necessary for an employer to do atmospheric testing as part of a permit space entry, when the only atmospheric hazard is welding and the welder is using either SCBA or air supplied respiratory protection.

1. To be a permit required confined space there must be a hazard within the space at the time of entry. In your case the hazard is generated by the welding process after entry into the space. The space is considered a confined space and not a permit required confined space.

In the case of welding within a confined space a person must follow the confined space welding requirements in 1910.252(a)(4), (b)(4), (c), (4), (7), (9) and (10). Section (b)(4) sets up the requirements for ventilation within confined spaces when welding.

2. If welding is conducted in a confined space pursuant to 1910.252 must I follow the permit required confined space requirements in 1910.146.?

You would be required to follow the requirements in the welding standards in 1910.252 rather than 1910.146 when doing welding in a confined space.

You ask if your paper on welding within confined spaces is accurate. The answer is yes. If we can be of further assistance to you please call Jerry Hoard at (503) 378-3272.

Sincerely,

Marilyn K. Schuster, ManagerStandards & Technical Resources SectionOregon Occupational Safety & Health DivisionS:\SHARE\TEC_TEMP\LTRSINTE\BLACK2.WPD