Scenario: The client invites the manufacturer of a piece of equipment that we evaluated and determined the space to be a PRCS.
The client used the popular argument of “no one else treats these as a PRCS.” And the manufacturer rep explains how this latest model is made specifically for entry.
So, therefore, in their eyes, their equipment is not a PRCS.
This equipment is a small version of a rotary kiln. It is about 40′ long and rotates on its horizontal axis and at the bottom is a catch basic with an open auger. The means to enter is two (2) 36″ manways on the ends of the cylinder.
So “Big D” and I look at each other and smile; he gives me the wink and nod, and in perfect unison, we say, “Well, climb in there then.”
The manufacturer rep pulls out his lock and heads toward the electrical disconnect, at which time Big D and I inquire as to what he is planning to do.
His response was, “I’m going to lock it out”. And the proverbial safety discussion door was opened…
The simple fact that he felt the need (and rightfully so) to take action to make the space SAFE before his entry proves our point. In fact, after a five-minute discussion of the actions he was going to take, it turns out his intended actions were addressing the same hazards we identified in our evaluations which made the space a PRCS.
We evaluate the space as it is USED – NOT after we have taken the necessary steps to ELIMINATE the hazards. Taking those steps is part of reclassifying the PRCS to a NON-PRCS status. But as the space sits 99% of the time, it is a PRCS, and the standard requires some means to prevent unauthorized entry (including even breaking the plane with their pinky finger). Most facilities will utilize a DANGER sign at the entry portals.
This experience left the manufacturer rep scratching his head, asking how they could have missed this fundamental premise of PRCS safety. I am not sure if the company will reach out and correct their error to other customers; however, our client walked away fully convinced and will be issuing “Safety Alert” in the coming days.
