This week I was at one of my food clients who use anhydrous ammonia as their refrigerant. This client replaced two old condensers with one bigger condenser. This new condenser came with some interesting labels, which to safety professionals, made our “assessment” of this piece of equipment relatively easy… it is a Permit-Required Confined Space. …...
Since our presentation at ASSP Safety2019! I have been getting the strangest request for clarification on how OSHA views “limited means of egress” and for the life of me, I just can’t understand why. Yes, the GI standard for PRCS’s (1910.146) does not define the phrase; however, since 2015 OSHA’s Construction Standard for PRCS has…...
Confined Spaces and Limited or restricted means for entry or exit Read More »
Since our presentation at ASSP Safety2019! I have been getting the strangest request for clarification on how OSHA views “limited means of egress” and for the life of me, I just can’t understand why. Yes, the GI standard for PRCS’s (1910.146) does not define the phrase; however, since 2015 OSHA’s Construction Standard for PRCS has…...
Confined Spaces and Limited or restricted means for entry or exit Read More »
At 10 p.m. on 3/19/18, an employee and coworker were performing preventative maintenance on a chlorine gas system used in a water filtration process. The employee and coworker were removing and reinstalling, a flange with a black Teflon rubber gasket. They were working in a 48-foot long, 24-foot wide, and 6-foot tall crawl space under…...
At 10 p.m. on 3/19/18, an employee and coworker were performing preventative maintenance on a chlorine gas system used in a water filtration process. The employee and coworker were removing and reinstalling, a flange with a black Teflon rubber gasket. They were working in a 48-foot long, 24-foot wide, and 6-foot tall crawl space under…...
A 47-year-old male employee was fatally injured when he became engulfed by sawdust after entering a dust collection silo. The company is a hardwood flooring manufacturer. On the day of the incident, the victim was cleaning the inside of a dust collection silo containing wood dust. The fire department had been called on to extinguish…...
PRCS Fatality – Engulfment inside wood dust silo Read More »
A 47-year-old male employee was fatally injured when he became engulfed by sawdust after entering a dust collection silo. The company is a hardwood flooring manufacturer. On the day of the incident, the victim was cleaning the inside of a dust collection silo containing wood dust. The fire department had been called on to extinguish…...
PRCS Fatality – Engulfment inside wood dust silo Read More »
I have an on going debate with a new food client on their “spiral freezers” being a Permit-Required Confined Space(s). In my professional opinion, a spiral freezer, at least all the ones I have been around, are without a doubt a PRCS. This company, including their brand manufacturer, are claiming they are not – based…...
Don’t confuse continuous employee occupancy with maintenance access Read More »
I have written about the differences between a CS vs. PRCS many times, but one situation that we must NEVER loose sight of is that many PRCS today are caused by the work taking place within them and NOT the normal PRCS hazards. What do I mean by this? The entry supervisor checks the atmosphere…...
When we make a confined space a Permit-Required Confined Space Read More »
JZ and I got our ASSP Safety2019! reviews today, as well as the recorded sessions were made available last night. Some of those who sent me a not so nicely worded e-mail after the conference have since relistened to the session and a couple of them actually apologized. Although not all have decided I am…...
Firday follies – Confined Spaces Read More »
One of the weakness of OSHA’s PRCS standard(s) (1910.146 and 1926.1200) is that when the space is evaluated and it is determined to only be a Confined Space (CS). Too often we let down our guard and assumed the space will pose no hazards to the workers entering the space. Recently I was made aware…...
We debated this topic a couple of years back and although I am not sure we came to an agreement, I was, still am, set on the idea that 1910.146(c)(5) and (c)(7) can NOT be used simultaneously on the same PRCS. In other words, the PRCS either qualifies for (c)(5) entry or (c)(7) entry; or…...
