Permit Required Confined Spaces

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…...

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…...

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…...

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…...