Permit Required Confined Spaces

OSHA has cited a railcar service provider for confined space hazards after an employee fatality in Pennsylvania and faces $551,226 in proposed penalties.  An employee asphyxiated in May 2019, while servicing a rail car containing crude oil sludge. OSHA cited the company for four (4) willful and three (3) serious violations for failing to protect…...

OSHA has cited two companies following an employee’s death at a refining facility.  The contractor and the facility collectively face over $106,000 in penalties after the contractor’s employee suffocated to death when he lost his air supply while on the job in a confined space at the facility. OSHA cited the industrial contractor for failing to…...

As our debate/discussion continues regarding falls within or into a Confined Space and if that fall hazard is one that makes the CS a PRCS and if a PRCS can be reclassified when there is a fall hazard present.  I keep sharing OSHA language and it keeps being diced up and rephrased to meet personal…...

At 11:45 a.m. on August 28, 2012, an employee was finishing a painting assignment to coat pipes in six confined spaces at a lift station site. The employee was cleaning the pipes using a Methyl Ethyl Ketone (MEK) solvent prior to applying a two-part epoxy paint that contained Xylene, Methyl Isobutyl Ketone (MIBK), and Ethyl…...

I am sure the thought has crossed everyone’s mind who has issued an entry permit for a HAZ ATM entry… “should the attendant be in breathing air as well?”.  Is there an exposure potential for the attendant to the HAZ ATM from within the PRCS?  Most attendants are stationed right outside the entry portal, add…...

One of the biggest mistakes I see in my auditing and the biggest frustration I have when facilities state they treat all of their confined spaces as PRCS is that most have not recognized the fact that a roll-off trash compactor and/or large palletizers are actually Permit-Required Confined Spaces.  For example, we have a large…...

Our behind the scenes debate continues and now a number of clients have joined in with their take on the matter. The fundamental part of our debate has come down to two (2) positions: does a fall inside or into a Confined Space make that CS a Permit-Required Confined Space? if you said yes to…...

Several years ago I wrote an article about how a space goes through its transitions to become a non-permit required confined space.  A space is not identified as a non-permit required confined space during its first evaluation; it becomes one after it has been “reclassified” using either (c)(7) or 1926.1203(g).  That article caused quite a…...

A company was fined $220,000 by the State Courts today under section 12(1) of the Workplace Safety and Health Act (“WSHA”) for failing to take adequate safety measures for its work in an underground storage tank.  On 25 July 2016, four workers were instructed by their supervisor to clean an underground storage tank, a permit-required confined space 3.2m…...

Another example of not understanding the chemical hazards in your CS/PRCS… This OSHA case shows us that “pits”, even those that would are not identified as a PRCS in a site evaluation can be deadly from the work we do inside them! When using a chemical that has a Vapor Density 3X’s that of air (1)…...

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…...