OK, PSM requires us to evaluate our “contractors” who will be working on, in or adjacent to a covered process. OSHA’s Permit Required Confined Space Standard also comes into play during a PSM audit (see .119(f)(4)). Under the PRCS std. OSHA requires us to “evaluate” our rescue services (.146(k)(1)(i)-(ii)) using something similar to Appendix F from .146.
Since I have yet to see a PSM covered process that does not have any PRCS’s, does this mean that the PRCS rescue service will go through TWO SEPARATE evaluations? Keep in mind the .119(h) evaluation is a COMPLETELY different focus than the .146(k) evaluation.
I for one feel they need BOTH evaluations if they will in deed will be expected to perform their duties in a PSM covered process area. Therefore, I would expect to see evidence (e.g. written documentation) of BOTH of these evaluations.
Often I will find the S&H manager will have done a Rescue Evaluation, but this company does not appear on the site’s PSM Approved Contractors and has not undergone any type of PSM evaluation. Recently I came across this in one my audits and to the facilities surprise, the PRCS rescue contractor would not have passed their PSM contractor evaluation!!!
Not sure how OSHA would view this, but there is NO DOUBT, both the PSM and Rescue reviews are entirely different and one can not replace the other; therefore by my simply analysis, both evaluations would be needed!?!?!?!
Your thoughts…