An attorney asked OSHA whether an employer could satisfy the permit-required confined space program review requirement by examining 'a representative sample of the entry permits during the one-year review' rather than every permit.
OSHA responded negatively. The regulation requires employers to 'Review the permit space program, using the canceled permits retained under paragraph (e)(6) of this section within 1 year after each entry' — and OSHA emphasized the word 'each' (29 CFR 1910.146(d), 1910.146(e)(6)).
The agency also pointed to the note to 29 CFR 1910.146(d)(4), which clarifies that 'Employers may perform a single annual review covering all entries performed during a 12-month period.' The flexibility offered by the standard is in timing — per-entry reviews or one comprehensive annual review — not in how many permits get reviewed. Every canceled permit must be included.