I am guessing that maybe we should have had the “Top 11 Myths” rather than the “Top 10 Myths” in our presentation at Safety2019! I continue to get emails from folks who want to convince me that “ventilation is required for all entries into PRCSs”. I have even had a face-to-face discussion with an OSHA CSHO from a State Plan who informed that it was required for “ALL entries”. And as we should all do, when someone tells us something is required and we have questions we should ask them to provide their source for this “requirement”. 100% of these folks, including the State OSHA CSHO have cited the following:
1910.146(c)(5)(i)(B) The employer can demonstrate that continuous forced air ventilation alone is sufficient to maintain that permit space safe for entry;
This is what drives me crazy about our profession… NOT understanding the most basic requirements AND their application to a hazardous situation! The statement/requirement stated above is a DIRECT copy and paste from 1910.146 and we can find the same exact language in 1926.1203, but OSHA did add an EXTRA requirement in their newer Construction standard by also requiring…
and that, in the event the ventilation system stops working, entrants can exit the space safely
But when does this ventilation requirement apply? Does it apply to ALL entries into ALL PRCS’s? Absolutely NOT and here are the facts…
SPECIAL NOTE: for those of you who take the approach that “what can it hurt?”, log in and read the posts I have made over the years where we took a hazard from OUTSIDE the space and introduced INTO the space by IMPROPER/POORLY SET UP ventilation and the vast majority of these incidents, the ventilation was NOT necessary, but the Entry Supervisor also thought that “ventilation was required on all entries”.
