Jonathan Zimmerman and I received some less than flattering feedback when I stated in our 2019 ASSP presentation that there are NO exemptions for NOT having a rescue plan for ENTRY RESCUE when the entry method is via a “permit” (1910.146 (d)-(k). This single topic garnered more discussion after our session than any other – it seemed to catch a lot of folks off guard. Of course, this is exactly why it made our Top 10 List. I even know that some attendees actually called OSHA as we received feedback from our friends at OSHA that they received a number of calls asking about this. But here is a Serious Citation from the double Tank Truck fatality case issued this week. If you were ever wondering if “entry style rescue” is REQUIRED on every “permitted-entry” into a PRCS, wonder no more!
NOTE: I encourage SAFTENG members to study these citations as they are “textbook” citations! You can also see our Safety2019 Presentation
On or about February 20, 2020, in the hazardous materials bay (#8), the employer did not ensure that a complete set of rescue procedures, beyond non-entry rescue, were developed and implemented prior to allowing entries into chemical trailer tanks for cleaning activities. An entry rescue team had not been designated by the employer (either an internally trained rescue team or an outside rescue team) in the event that non-entry rescue procedures were to fail. Documented rescue procedures were limited to reliance on non-entry rescue and calling 911 once the employee(s) had been retrieved from the space. In addition, there were no procedures in place for
preventing unauthorized personnel from attempting a rescue.
CLICK HERE for the official citation document
CLICK HERE for the Citations on line
