Permit Required Confined Spaces

FATAL PRCS accident; Explosion (Flammable atm & $44K)

On or about January 11, 2020, employees engaged in performing cleaning and maintenance on a heater treater system with a combustible engine power washer within range of flammable material stored within the heater treater were exposed to burn hazards…. Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log...

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FATAL PRCS accident; Explosion (Flammable atm & $44K) Read More »

PRCS Rescue and Emergency Services (1926.1211)

As the debate continues to rage regarding the types of PRCS rescue and when they are required, OSHA has seen fit to publish the following: (emphasis by me) Effective emergency planning is vital to ensure that any entrant who becomes sick or is injured in a permit space can be evacuated quickly and safely. The…...

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Alternate Procedures for Certain Permit Spaces — Section 1203(e)

This a followup to my earlier posting about OSHA LOI and using both Reclassifications and Alternate procedures on the same space at the same time.  I received a lot of questions from that post so I thought I would share the info I shared with those who contacted me.  This information is also directly from…...

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Entry into a space that is a PRCS REQUIRES a rescue plan and coordination with that team

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 –…...

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OSHA issues PRCS citations at tank cleaning business after double fatality (single entrant, one would-be rescuer, $1.5M)

UPDATE from OSHA case file:  At 12:30 p.m. on February 20, 2020, Employee #1, employed by a structural steel fabricator and erector company, was entering a tank to clean it. The tank had a combination of Ecocure II and methyl ethyl ketone (MEK) residues and had been purged with nitrogen. Employee #1 entered the permit-required…...

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OSHA issues PRCS citations at tank cleaning business after double fatality (single entrant, one would-be rescuer, $1.5M) Read More »

PRCS Attendants are a CRITICAL PATH for a safe entry – who are you allowing to fill your roles?

We have all seen it… the person assigned to be the PRCS Attendant (and Fire Watches suffer this infliction as well) are the youngest, weakest, least trained, least experienced, lowest paid, and most incapable person on the job/team. As I have written about before, one of my former employers actually but an age restriction on…...

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OSHA confirms in a LOI that we can ISOLATE, use FORCED AIR Ventilation, and CONTINUOUS atmospheric monitoring to enter a PRCS without an entry permit

OSHA published a Letter of Interpretation making it clear that we can use “alternative entry” methods such that when the physical hazard(s) can be ELIMINATED OR ISOLATED through engineering controls, AND any atmospheric hazards can be CONTROLLED through forced-air ventilation and continuous atmospheric monitoring, the space may be entered using the alternate procedures set forth…...

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OSHA confirms in a LOI that we can ISOLATE, use FORCED AIR Ventilation, and CONTINUOUS atmospheric monitoring to enter a PRCS without an entry permit Read More »

One Entrant and 3 would-be rescuers with 2 fatalities and 5 hospitalizations ($499K)

At 12:45 a.m. on December 28, 2019, Employee #1 entered a tanker truck that last held Vinyl Acetate Polymer Residue, a hazardous waste material, and became unresponsive while in the tanker. Employee #2 and Employee #3 entered the tank to rescue Employee #1 and also became unresponsive. Employee #4 entered the tank and was able…...

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NFPA 350, Guide for Safe Confined Space Entry and Work Updates/Revisions

Today, the NFPA adopted some interesting revisions to their NFPA 350, Guide for Safe Confined Space Entry and Work.  One item that many may find interesting is 8.6.5 Pipes and lines that run through a confined space… Here are the most notable updates/revisions: Non-Members can find the changes Here…. Membership Required You must be a...

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Fatal occupational injuries involving confined spaces (BLS July 2020)

From 2011 to 2018, 1,030 workers died from occupational injuries involving a confined space. The annual figures range from a low of 88 in 2012 to a high of 166 in 2017. Fatal occupational injuries involving confined spaces, 2011-2018 Year 2011 2012 2013 2014 2015 2016 2017 2018 Fatal work injuries 120 88 112 116…...

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OSHRC vacates fatal PRCS citations involving gasoline tank cleaning (OSHRC said it was “construction work”)

The company is a fuel filtration and tank cleaning company. In December 2014, an employee was found unresponsive and later died from gasoline inhalation while cleaning tanks at a construction site in Daytona Beach, Florida. Following the incident, OSHA conducted an inspection and issued an 11- item serious citation for violations of 29 C.F.R. §…...

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OSHRC vacates fatal PRCS citations involving gasoline tank cleaning (OSHRC said it was “construction work”) Read More »

PRCS fatality in Flour Tanker Truck (Nitrogen – O2 Deficiency)

On November 19, 2019, an employee was unloading his semi-truck tanker of flour and hooked up a blower hose that is powered from the truck’s transmission. The employee climbed to the top of the tanker while trying to get a better seal and opened the hatch before entering. Emergency Services was contacted and removed the…...

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