Confined Space Requirements

May 15, 2000

In order to better align our process with the OSHA requirements for confined space entry, Xerox is amending its confined space procedure.

According to 1910.146, the host employer (Xerox) is responsible for:

Informing the contractor that the workplace contains permit spaces and that permit space entry is allowed only through compliance with a permit space program meeting the requirements of this section;

Apprising the contractor of the elements, including the hazards identified and the host employer's experience with the space, that make the space in question a permit space;

Apprising the contractor of any precautions or procedures that the host employer has implemented for the protection of employees in or near permit spaces where contractor personnel will be working;

Coordinating entry operations with the contractor, when both host employer personnel and contractor personnel will be working in or near permit spaces, as required by paragraph (d)(11) of this section; and

Debriefing the contractor at the conclusion of the entry operations regarding the permit space program followed and regarding any hazards confronted or created in permit spaces during entry operations.

The contractor is responsible for having their own permit system compliant with the OSHA standard, and provide equipment necessary for performing the confined space tasks, including retrieval equipment and meters for atmospheric verification.

Therefore, effective August 14^th, 2000, Xerox personnel will no longer issue confined space permits to contractors or verify the atmospheric conditions of the space to be entered. The contractor will have sole responsibility for this. We will also no longer be able to provide an entry attendant to contractors.

It will remain a requirement that contractors needing to enter a confined space, contact the Xerox safety representative in advance. The Xerox representative will be required to review with you the potential hazards of the space, our experience with the space, precautions taken, and conduct a debriefing at the conclusion of work in the space.

Contractors will be required to provide Xerox with a copy of their confined space permit used for the space.

If necessary, you should update your company written safety program to reflect these changes.

Please feel free to contact Xerox Workplace / Contractor Safety (585-231-8482) with any questions or comments.

Thank you.