It is not hard to find people who complain about government regulations, but the regulations often exist because people do not take optimal precautions on a voluntary basis. This case illustrates that problem. Honorable Diane P. Wood, Chief Judge This case arose after toxic fumes in a large container (i.e. tanker truck) knocked out…...
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…...
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…...
OSHRC gets it wrong on 1910.1469(k) Rescue Plans Read More »
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…...
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…...
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…...
“Dock Levelers” and Permit-Required Confined Spaces Read More »
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…...
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…...
Changing the configuration of a space may also require a different energy isolation plan Read More »
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…...
This “man-sized” door does NOT eliminate “limited means of egress” Read More »
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…...
Clarifying the “continuous employee occupancy” confined space definition Read More »
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...
OSHA issues PRCS and LOTO citations @ paper mill ($101K) Read More »
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…...
Why cooling towers should be considered PRCS’s Read More »
