Audit of PBS’s Management of Permit-Required Confined Space

Why We Performed This Audit

We performed an audit of the GSA Public Buildings Service’s (PBS’s) management of its permit- required confined space. This audit was included in the GSA Office of Inspector General’s Fiscal Year 2025 Audit Plan. We planned and performed this audit after an assessment of a hotline complaint found widespread concerns over PBS’s oversight of contractors’ compliance with permit-required confined space requirements.

Confined spaces are work areas that are enclosed or partially enclosed, presenting unique health and safety risks to workers who must enter, work in, or exit from them. Without proper safety measures, work in confined spaces can present significant health and life safety risks. According to a July 2020 report issued by the U.S. Bureau of Labor Statistics, more than 1,000 workers were fatally injured in confined spaces from 2011 to 2018.

Some confined spaces require a permit for entry because they present additional health or safety hazards, such as entrapment, engulfment, or hazardous atmospheric conditions. A permit is a written or printed document provided by an employer that allows and controls entry into a hazardous confined space. The Occupational Safety and Health Administration (OSHA) refers to these spaces as permit-required confined spaces (permit spaces). Examples of permit spaces include tanks, sump pump pits, traps, manholes, crawl spaces, and elevator pits.>

To protect employees and contractors from these risks, PBS must comply with applicable OSHA requirements governing permit spaces. Accordingly, our audit objective was to determine whether PBS is adequately identifying, assessing the safety of, and mitigating the hazards found in permit spaces as required by OSHA Standard 1910.146, Permit-required confined spaces (29 C.F.R. 1910.146).  

What We Found

PBS is not effectively managing permit space, and as a result, it is not complying with OSHA requirements, potentially exposing GSA employees and contractors to health and life safety risks. Specifically, PBS did not ensure operations and maintenance (O&M) contractors consistently complied with PBS’s permit space requirements. PBS also did not consistently implement timely and complete abatement plans for open confined and permit space risk conditions. Finally, PBS did not consistently evaluate elevator pits to determine whether they were permit spaces

What We Recommend

We recommend that the Acting PBS Commissioner improve PBS’s management of permit- required confined space by:

1. Ensuring that PBS contracting officers’ representatives (CORs):
   1. Verify that all O&M contractors:
      1. Maintain complete building operating plans, including a confined and permit space inventory.
      2. Ensure all building operating plans are uploaded into the National Computerized Maintenance Management System and verify that the plans include a fully populated, current permit space inventory.  
      3. Develop building-specific permit space entry programs.  
      4. Assess permit spaces and ensure they are accurately classified and labeled in accordance with OSHA requirements.
   2. Maintain complete and accurate contract files, including all permit space deliverables.
2. Establishing a formal COR handover checklist that requires outgoing CORs to digitally certify the transfer of all permit space inventories and permit systems to their successor(s) before offboarding.
3. Developing and implementing comprehensive training for CORs concerning:
   1. O&M contract requirements, including those governing permit and confined spaces.  
   2. Appropriate oversight to ensure that permit space deliverables meet OSHA and PBS policy requirements.
4. Ensuring that current bridge contracts and all future O&M solicitations incorporate the updated language and requirements of the current PBS National O&M Specification.
5. Developing and implementing a formal quality assurance review process within the Inventory Reporting Information System to verify that abatement plans for open confined and permit space risk conditions contain a justification for delay, a completion timetable, and interim protective measures.
6.  Developing standardized guidance for evaluating elevator pits to determine if they meet OSHA and PBS permit space requirements.

The Acting PBS Commissioner agreed with the report recommendations. GSA’s written comments are included in their entirety in Appendix E.