Permit Required Confined Spaces

Work dies and “would-be rescuer” severely injured in Tank Truck incident

On January 18, 2024, at 9:15 a.m., Employee #1, 37, was working inside a 7,000-gallon tanker trailer. Employee #1 was tasked with inspecting the damage to the interior of the tanker. Employee #1 was in the early stages of the tank inspection when he lost consciousness. A coworker noticed Employee #1 lost consciousness, and s/he…...

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Chain hoist used inside PRCS results in fatality

On April 3, 2024, at 9:00 a.m., an employee, 44, working as a plant operator for a building materials manufacturer was reinstalling mixer blades onto the shaft inside a Vince Hagan HM-10 Horizontal Concrete Mixer. The employee had been on a crew between January 2024 and April 2024 engaged in the shaft and blade replacement…...

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How deep does a space need to be before we consider it a “confined space”?

This can be related to process vessels, hoppers, pits, etc.- just about any “open-topped” space. Now, when it comes to hoppers, these will fall into the PRCS category based solely on their design with “inwardly converging walls or by a floor which slopes downward and tapers to a smaller cross-section.” But even then, a very…...

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Roles and Responsibilities in Safe Work Practices (PRCS)

As I have mentioned a few times, there is a substantial difference between a Safe Work Practice design to make OSHA happy and one that functions as a “management system” for the risk the “program” is trying to control.  Far too many “safety programs” are simply regurgitating the OSHA standards they intend to comply with…....

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PRCS program tips for Ventilation

The following are my tips to ensure PRCS are properly ventilated when necessary.  Far too often, ventilation is nothing more than a “nice effort,” which can lead to disastrous results.  So, in my time in safety at petrochemical and semiconductor facilities, the safety team managed the ventilation equipment (blowers and flexible ductwork). Still, the entry…...

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PRCS program tips for Space Isolation & Air Monitoring

I was working on another PRCS Entry program this week and thought I would offer some tidbits I include in my programs regarding: My programs are lengthy and are intended to include every aspect of managing the risks associated with working around and inside PRCSs. SPACE ISOLATION ALL connections to a confined space that can…...

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“Heat Gun” is a form of Hot Work in HAZLOCs (PRCS Fatality)

In an ordinary setting (i.e., one without flammable gases or vapors), its use is typically not considered Hot Work by many.  We always managed the hazards/risks when their use was not part of a formal hazard assessment for production/shipping.  But when a heat gun was used as part of maintenance activities in an area where…...

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OSHA clarifies that ONLY ACUTE atmospheric hazards apply to PRCS entries – NOT chronic hazards

I have this debate several times a year and always go to the “note” in 1910.146 related to the definition of “atmospheric hazards”.  And that is never enough to convince people that 1910.146 deals ONLY with ACUTE responses to atmospheric hazards – NOT chronic responses.  Now let’s be clear that chronic hazard MUST be addressed/managed,…...

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Breaking the plane of a PRCS (Flammable atm) w/Video

It is a common question… why does OSHA define entry as… Entry means the action by which a person passes through an opening into a permit-required confined space. Entry includes ensuing work activities in that space and is considered to have occurred as soon as any part of the entrant’s body breaks the plane of…...

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Scrubber under N2 blanket kills entrant

On February 19, 2015, employees were to perform a preventive maintenance inspection inside of a scrubber, which is maintained free of oxygen using a nitrogen blanket. When the designated attendant could not find the entrant employee, other employees searched for him. The entrant employee was found inside the scrubber (a metal tube) where he had…...

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OSHA issues PRCS Citations @ Trucking company ($621K)

The Minnesota Department of Labor and Industry’s (DLI’s) Minnesota OSHA (MNOSHA) Compliance has issued a $621,600 penalty to a trucking company primarily for lack of confined-space safety requirements at its facility in Virginia, Minnesota, following a worker fatality in a tanker in March 2024. In July 2024, MNOSHA Compliance issued 10 serious citations for violations…...

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PRCS Fatality – Engulfment (Water valve pit)

On February 23, 2023, at 11:45 a.m., an employee working for a city water department was repairing a leaking 12-inch PVC waterline main valve. The valve was located in a utility vault approximately 5 feet deep. The employee turned off the water to the west of the valve by opening multiple fire hydrants. He and…...

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