Host/Contractor Relationship | Permit-Required Confined Spaces

OSHA addresses the host/contractor relationship for permit-required confined space entries in §1910.146(c)(8) by requiring the parties to share information and coordinate entry procedures. If an outside contractor is hired to perform work in a confined space, it is the host employer’s responsibility to ensure that the contractor uses a written confined space program. The host employer must verify that the contractor’s workers are adequately trained in permit-required confined space entry and that they are informed of the hazards in the host’s facility as it relates to their work.

Host employers must provide information to contractors on:

§  Their permit spaces,

§  The permit space program,

§  Established procedures, and

§  Likely hazards that the contractor’s workers may encounter.

Once work has begun, the host should routinely check that the contractor is following the agreed upon procedures.

The contractor is responsible to ensure that all necessary information regarding the space, its hazards, and entry procedures are provided and that any additional hazards encountered during the work are reported to the host employer. Joint entries must be coordinated and the contractor debriefed at the conclusion of entry operations.

Coordination between the host and contractor should include a determination of which permit program is to be used by the contractor. The host employer is not prohibited from requiring a contractor to use the host’s permit program, nor is the contractor required to use it. But, the host employer may choose to condition its contract on the contractor’s compliance with the host’s program.

The host employer and the contractor need to cooperate and make arrangements to implement a permit program best suited for a particular situation. There are a wide variety of circumstances in which contractor personnel enter permit spaces. There are circumstances in which a contractor sets up a complete permit space program at the host employer’s workplace, and there are situations in which both contractor and host employer employees are working side-by-side in a permit space.