Permit Required Confined Spaces

An “energy isolation” failure on a PRCS results in a fatality (NH3 Dryer @ Fertilizer Plant)

As many continue the debate around energy isolation methods associated with entry into a Permit-Required Confined Space, I offer another example of why getting the energy isolation plan RIGHT is SO IMPORTANT.  I know there are safety professionals out there who feel strongly that single valve isolation or the use of an “automated valve” being…...

Membership Required

You must be a member to access this content.

View Membership Levels

Already a member? Log in here

An “energy isolation” failure on a PRCS results in a fatality (NH3 Dryer @ Fertilizer Plant) Read More »

OSHRC gets it wrong on 1910.1469(k) Rescue Plans

This case involved an industrial laundry company which uses continuous batch washers (CBW) which were correctly defined as a Permit-Required Confined Space (PRCS). During an OSHA inspection, the Compliance Officer (CO) took issue with the facility’s rescue plan from a CBW. After reading this case, I too took issue with their rescue plan; however, since…...

Membership Required

You must be a member to access this content.

View Membership Levels

Already a member? Log in here

OSHRC gets it wrong on 1910.1469(k) Rescue Plans Read More »

OSHRC confirms that EXPIRED “calibration gas” for calibrating atmospheric testing equipment is a violation

This OSHRC case involved laundry company who uses industrial sized washing machines which are correctly classified as a Permit-Required Confined Space (PRCS).  OSHA inspected the facility, and the CSHO discovered that the calibration gas used to calibrate the direct reading meter that would be used for testing the atmosphere inside the continuous batch washers (CBW) has expired 18…...

Membership Required

You must be a member to access this content.

View Membership Levels

Already a member? Log in here

OSHRC confirms that EXPIRED “calibration gas” for calibrating atmospheric testing equipment is a violation Read More »

Did the OSHRC just say that blanking/blinding, disconnect/misalignment, or a DB&B is not required for PRCS isolation?

I often review the OSHRC decisions to learn better the “legal” side of OSHA compliance and most of the time I find that the Review Commission is pretty much a straight shooter when it comes to applying OSHA standards. But there are times when I close my computer as if I just saw a ghost…...

Membership Required

You must be a member to access this content.

View Membership Levels

Already a member? Log in here

Did the OSHRC just say that blanking/blinding, disconnect/misalignment, or a DB&B is not required for PRCS isolation? Read More »

“Dock Levelers” and Permit-Required Confined Spaces

March 2018 UPDATE – OSHA has cited an egg processing facility for multiple safety violations after an employee suffered fatal injuries when he was struck by a dock leveler. A dock leveler is a device used to allow a forklift to travel between a loading dock and a trailer.  One of the employer’s dock levelers…...

Membership Required

You must be a member to access this content.

View Membership Levels

Already a member? Log in here

“Dock Levelers” and Permit-Required Confined Spaces Read More »

Failure of the Entry Supervisor to “verify rescue services are available” leads to an OSHA Willful Citation of $126,749 (Railcar & $204K)

I have written repeatedly about Confined Space rescue requirements and the problems with using off-site rescue teams, specifically referencing the requirement of 1910.146(j)(4)…  Duties of entry supervisors. The employer shall ensure that each entry supervisor: … 1910.146(j)(4) Verifies that rescue services are available and that the means for summoning them are operable; Now it seems that…...

Membership Required

You must be a member to access this content.

View Membership Levels

Already a member? Log in here

Failure of the Entry Supervisor to “verify rescue services are available” leads to an OSHA Willful Citation of $126,749 (Railcar & $204K) Read More »

Changing the configuration of a space may also require a different energy isolation plan

In many industries where the heating or cooling process comes into play, the process will probably have some type of heat exchanger or condenser. In large-volume processes, these units can be enormous; easily large enough to bodily enter and do assigned work. But many of these units may not get identified as a Permit-Required Confined…...

Membership Required

You must be a member to access this content.

View Membership Levels

Already a member? Log in here

Changing the configuration of a space may also require a different energy isolation plan Read More »

This “man-sized” door does NOT eliminate “limited means of egress”

As the debate continues in the refrigeration industry regarding the classification of evaporative condensers, I had someone send me a picture from one of the main manufacturers of evaporative condensers showing me an example of an evaporative condenser that no longer has “limited means of egress.” Therefore it is no longer a Confined Space and…...

Membership Required

You must be a member to access this content.

View Membership Levels

Already a member? Log in here

This “man-sized” door does NOT eliminate “limited means of egress” Read More »

Clarifying the “continuous employee occupancy” confined space definition

In both their General Industry and Construction Confined Space Standards, one of OSHA’s criteria for a “Confined Space” is that the space is “not designed for continuous employee occupancy.” These six (6) words seem to cause much confusion on both ends of the CS debate. I have seen it misused to claim a space is…...

Membership Required

You must be a member to access this content.

View Membership Levels

Already a member? Log in here

Clarifying the “continuous employee occupancy” confined space definition Read More »

OSHA issues PRCS and LOTO citations @ paper mill ($101K)

OSHA opened an inspection of the mill on Dec. 27, 2016, in response to a complaint alleging unsafe working conditions. Inspectors discovered employees exposed to serious safety hazards, including permit-required confined space hazards and LOTO failures, which I have summarized below:… Membership Required You must be a member to access this content.View Membership LevelsAlready a...

Membership Required

You must be a member to access this content.

View Membership Levels

Already a member? Log in here

OSHA issues PRCS and LOTO citations @ paper mill ($101K) Read More »

Why cooling towers should be considered PRCS’s

In my experience, I have found most older built cooling towers to be Permit-Required Confined Spaces (PRCS); however, some of the newer designs have addressed the hazards which make these units PRCS (e.g., guarding the fan and shaft within the unit) or these spaces may be eligible for reclassification using 1910.146(c)(7).  But this OSHA fatality inspection…...

Membership Required

You must be a member to access this content.

View Membership Levels

Already a member? Log in here

Why cooling towers should be considered PRCS’s Read More »

OSHA issues Construction PRCS citations @ FL manhole triple fatalities (H2S & $119K)

OSHA cited a South Florida utility company and related contracting company after the agency’s investigation into the deaths of three workers who succumbed to toxic gases in a manhole on Jan. 16, 2017.  A 34-year-old pipe layer entered the manhole – a confined space – and quickly became unresponsive. A 49-year-old laborer entered the hole…...

Membership Required

You must be a member to access this content.

View Membership Levels

Already a member? Log in here

OSHA issues Construction PRCS citations @ FL manhole triple fatalities (H2S & $119K) Read More »

Scroll to Top