Permit Required Confined Spaces

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…...

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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…...

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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…...

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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…...

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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...

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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…...

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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…...

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

The creation of a Confined Space… from construction to general industry

This week I came across a perfect example demonstrating how OSHA’s recent 1926 Subpart AA – Confined Spaces in Construction can impact BOTH construction sites AND workplaces normally covered by General Industry Standards (1910).  A lot of businesses who deal with tanker trucks will have a “scale” for weighing these trucks.  This week while working at a clients…...

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Permit-Required Confined Space Alert – Hopper (MSHA)

A miner entered a feed hopper to remove bolts on the skirt board. When he heard a bull dozer that typically pushes material into the hopper approaching, the miner tried to escape through the opening at the bottom of the hopper. The bull dozer pushed material into the hopper, unaware that the miner was inside, burying him up to his…...

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OSHA’s First Year Enforcement Activities for Confined Spaces in Construction

On May 4, 2015, OSHA issued a new standard for CONSTRUCTION WORK IN CONFINED SPACES, which became effective August 3, 2015. This is a summary of OSHA activity for this new standard during the period October 2015 through September 2016. Penalties shown reflect current rather than initial amounts. For more information, see definitions. 1926.1203 – General…...

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Contractor doing a PRCS Rescue Evaluation (1910.146(k) & 1926.1211)

PLEASE NOTE: This article may contain grammar errors, as this is my response to the more than 60 messages I received in the past seven days regarding last week’s article, When contractors enter a host’s PRCSs (1910.146(c)(8)(iii).   I have put this together tonight so as to not keep any of those who contacted me…...

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BSEE Safety Bulletin No. 003 – Mud/Gas Separator Cleaning Results in PRCS Death

A fatal incident occurred when an Assistant Driller (AD) placed his head and an arm into a platform drilling rig’s vertical Mud/Gas Separator (MGS) through its inspection hatch, while performing the assigned, but non-routine task of removing built up and hardened material from inside the MGS.  A BSEE Panel investigation identified a number of established Safe Work Practices (SWPs)…...

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