The word “potential” is defined by Merriam-Webster as: existing in possibility : capable of development into actuality In OSHA’s PRCS standards (both 1910 and 1926 versions) it uses the word “potential” when talking about atmospheric hazards; especially when we are talking about RECLASSIFYING a PRCS to a NON-PRCS using 1910.146(c)(7) or 1926.1203(g) 1926.1203(g)(1) If the permit […]
So OSHA made some serious improvements in their latest Construction Standard, 1926.1201-.1213, for confined spaces. But there is another option to “upgrade” our efforts for entry safety practices and that is NFPA 326 – Standard for the Safeguarding of Tanks and Containers for Entry, Cleaning, or Repair.
The short and simple answer is YES. It is, without a doubt, a PRCS. This debate is much like the “Is an Evaporative Condenser a PRCS” discussion. This week, I was presenting at the 2020 Refrigerating Engineers & Technicians Association (RETA) virtual conference, and my presentation was “Evaluating Your Ammonia Refrigeration System to determine if
At 9:50 a.m. on June 5, 2018, Employee #1 was in an 8 foot by 8-foot pit that was approximately 10 feet deep, cleaning out built-up sediment using a brush and 5-gallon bucket. Employee #1 was being helped by Employee #2, who was dumping the waste outside of the building that the pit was in.
Does your entry procedures/practices allow for “misaligning or removing sections of lines, pipes, or ducts” as a means to isolate a PRCS? If yes, do your procedures/practices specify the length of “sections of lines, pipes, or ducts” that have to be removed in order to meet the intent of “isolation”? I can not recall where
NOTE: this incident happened long BEFORE OSHA had 1910.146 in place… At about 3:30 p.m. on October 10, 1986, Employee #1, a self contractor, arrived to inspect the sawmill’s fire protection sprinkler system backflow valve located in an underground vault 8 ft deep by 6 ft wide by 12 ft long with a 31 in.
At 10:45 a.m. on January 11, 2020, Employee #1, employed by an oil and gas operation company, was overseeing a heater treater welding repair. Employee #2 emptied the remaining fluids in the heater treater. Employee #1 power washed the heater treater to remove any remaining flammable materials and ensure that it was safe for welding.
CAUTION: This interim order is specific to the facility requesting it. Do NOT use these measures at your facility!!! If I had a nickel for every time I have heard the excuse… “its more dangerous to do these isolations than it is to do the entry with lesser isolations,” I would not be writing this
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.
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
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
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 –
