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Interim confined space enforcement for utility underground work

Summary An internal OSHA memo addressed permit required confined space enforcement in utility manholes and vaults. It directed staff to consult a deputy director before citing these facilities while the agency prepared a clarification.
Document
Federal guidance
Agency
Occupational Safety and Health Administration (OSHA)
Document number
1993-04-15-0
Date issued
April 15, 1993
Status
Archived by the agency
OSHA labels this an archive document and warns that it may no longer represent current policy.
Status last verified October 9, 2026

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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

April 15, 1993

MEMORANDUM TO: REGIONAL ADMINISTRATORS

THROUGH: LEO CAREY
Director of Field Programs

FROM: ROGER A. CLARK
Director of Compliance Programs

SUBJECT: Applicability of Permit-Required Confined Space Standard
to Electrical Utility Underground Workplaces

The Edison Electric Institute (EEI) has asked Acting Assistant Secretary Zeigler to stay the confined space standard as applied to electric and steam utility underground workplaces such as manholes and vaults and to clarify OSHA's enforcement policy concerning the application of the confined space standard to these facilities. We have informed EEI that enforcement of the confined space standard in these facilities will be restricted, and a letter clarifying the agency's position is being prepared for issuance over the Assistant Secretary's signature. In the interim, please contact H. Berrien Zettler, the Deputy Director for Compliance Programs, prior to issuing any citations for confined space violations in these facilities. I will forward copies of Acting Assistant Secretary Zeigler's letter when it is issued.

Please distribute this memo to the appropriate state plan officials. If you have any questions, please contact Ray Donnelly or Art Buchanan of my staff at (202) 219-8041.

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