You and your team are preparing to enter a PRCS, and as the entry supervisor begins to review the permit, he/she explains the space is isolated, and you notice the permit states “LOTO- N/A.” You inquire about this and ask about the isolation method(s) used for the entry. The supervisor offers to show you the isolation for the vertical 100,000-gallon storage tank and to walk down the isolation with you. The first pipe/line you come to is a 6” fuel discharge pipe. It is isolated using a disconnect and misalignment arrangement that rolled a 3’ spool piece down. The next pipe you come to is a 6” fuel inlet pipe. It is isolated using a disconnect and misalignment arrangement that rolls down a 3’ spool piece. The third and last pipe is a 1” nitrogen pipe, and it, too is isolated using a disconnect and misalignment arrangement that rolled a 1’ spool piece down. You notice that NONE of the three disconnect and misalignment arrangements were locked or tagged in their safe position. When you ask about LOTO and where you and your team need to apply your LOTO lock(s), the entry supervisor says no locks are needed. Would you enter this tank?
This type of scenario is one that I have come across three times this year, and these are the first occasions where I have ever seen this type of practice in my 20+ years involved in PRCS safety. In all occasions, the facilities make it very clear that they use LOTO on their double block and bleed arrangements, but they do not lock or tag their disconnect and misalignment arrangements or their blinds/blanks. Let’s break this down from strictly a compliance perspective…
PRCS requirements:
“Isolation” means the process by which a permit space is removed from service and completely protected against the release of energy and material into the space by such means as: blanking or blinding; misaligning or removing sections of lines, pipes, or ducts; a double block and bleed system; lockout or tagout of all sources of energy; or blocking or disconnecting all mechanical linkages.
1910.146(d)(3) Develop and implement the means, procedures, and practices necessary for safe permit space entry operations, including, but not limited to, the following:
…
1910.146(d)(3)(iii) Isolating the permit space;
1910.146(f) Entry permit. The entry permit that documents compliance with this section and authorizes entry to a permit space shall identify:
…
1910.146(f)(8) The measures used to isolate the permit space and to eliminate or control permit space hazards before entry;
LOTO Info
Lockout is defined as The placement of a lockout device on an energy isolating device, in accordance with an established procedure, ensuring that the energy isolating device and the equipment being controlled cannot be operated until the lockout device is removed.
Lockout device is defined as A device that utilizes a positive means such as a lock, either key or combination type, to hold an energy isolating device in the safe position and prevent the energizing of a machine or equipment. Included are blank flanges and bolted slip blinds.
Take notice that OSHA included blank flanges and bolted slip blinds in their definition of a “lockout device”, something that I TOTALLY DISAGREE with, but it is how OSHA views their use.
So between 1910.146 isolation requirements and 1910.147 definitions, I am at a total loss as to how any facility would permit an entry supervisor to issue an entry permit without any LOTO in place on the isolation devices/arrangements. I have come to realize that 1910.146 does not specifically require locks to be applied to the disconnect/misalignment arrangement and that OSHA claims blank flanges and bolted slip blinds are actually “lockout devices,” so in their eyes, these isolations need not have a lock or tag applied. Only the double block and bleed arrangement does OSHA specifically call out the use of locks and tags.
I am sorry, but entering a PRCS where I do not have EXCLUSIVE CONTROL over the isolation devices/methods used to protect me is just downright foolish. I am not even sure how OSHA would view the scenario above… entering a PRCS without any LOTO applied to the “isolation of the space.” Applying a lock to a rolled spool piece is so easy, and tagging (or even locking) blank flanges and bolted slip blinds is so easy I do not understand why anyone would not take these actions or even how one comes to the conclusion that locking or tagging ALL isolation devices/methods is not part of entering a PRCS (and even a Non-PRCS).
Would you enter that storage tank?
