Permit Required Confined Spaces

NFPA 350: Best Practices Guide for Safe Confined Space Entry and Work (Effective 12/4/15)

NFPA has published their much anticipated guide on Confined Spaces, NFPA 350: Best Practices Guide for Safe Confined Space Entry and Work, 2016 Edition. It became effective on December 4, 2015. This first edition of NFPA 350, Guide for Safe Confined Space Entry and Work, establishes best practices and “how to” for confined space entry…...

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Why OSHA states “entry” has taken place as soon as ANY PART of your body breaks the plane

1910.146 is pretty clear as to when “entry” has taken place, and 1926.1202 even expands the definition to make it clear that even UNINTENTIONAL breaking of the plane is an “entry.  But why did OSHA say “any part of the body” and not “the head” since the majority of accidents are atmospheric related?  I have…...

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PRCS “program reviews” under 1910.146(13) & (14) (OSHRC decision)

OSHA’s Permit Required Confined Space standard has been around since the mid 1990’s and the requirement(s) to perform “program reviews” has been part of the standard from its very beginning.  In a recent OSHRC case, both the Administrative Law Judge and the full commission took issue with a company’s efforts in how they did (or…...

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OSHRC decision on PRCS Tanker Truck Willfuls

This OSHRC decision reverses an ALJ decision which I posted in August 2013, but this case has some very interesting aspects that EVERYONE who manages a PRCS Entry program needs to read.  Most notably, this case involves:  gas meter maintenance,   program revision/employees not protected, “Conditions” Required for Alternate Entry, program revision/annual permit review, enforcement,…...

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IN-OSHA PRCS citations @ Power Plant inside pulverizer (Combustible Dusts $20K)

I am not sure what transpired with this inspection, but the power plant was also cited for these same violations, but all their citations were DELETED and the penalty reduced to $0.00.  The citations below were to the contractor who was actually doing the work inside the space.  I am not sure, but I would…...

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MSHA’s special initiative on Confined Spaces

To: Metal and Nonmetal Mining Alliance Partners and Stakeholders From: Neal H. Merrifield, Administrator for Metal and Nonmetal Mine Safety and Health Mine Safety and Health Administration Re: Confined Space Entry Alert Unsafe work in confined spaces has led to miner deaths and injuries in the metal and nonmetal mining industry. Recent tragic incidents include:…...

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Temporary Enforcement Policy for Residential Construction Work in Confined Spaces

Memorandum For: REGIONAL ADMINISTRATORS AND STATE PLAN DESIGNEES THROUGH:  DOROTHY DOUGHERTY, Deputy Assistant Secretary From:   JAMES G. MADDUX, Director, Directorate of Construction Subject:  Temporary Enforcement Policy for Residential Construction Work in Confined Spaces… Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...

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Is “competence” for doing a CS evaluation = to “competence” for doing a RECLASSIFICATION

OSHA’s new Confined Space standard for Construction requires a “competent person” in two CRITICAL functions; I should also point out these two functions are also CRITICAL within the General Industry functions as well.  These include EVALUATING spaces and RECLASSIFYING a PRCS to a non-PRCS. Evaluation of Spaces 1926.1203(a) Before it begins work at a worksite,…...

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Confined Space Evaluations and a “competent person”

And it has begun… With OSHA’s new Confined Space construction standard, they stated in 1926.1203(a) that… Before it begins work at a worksite, each employer must ensure that a competent person identifies all confined spaces in which one or more of the employees it directs may work, and identifies each space that is a permit…...

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OSHA PRCS citations @ Railcar Cleaning business (Flammable Atmosphere & $963,000)

Moments before a blast ripped through a railcar on April 14, 2015, a check of the air quality inside indicated a serious risk of an explosion. Despite the warning, the company sent two employees, aged 41 and 45, into the railcar to work without monitoring the air continuously for explosive hazards as required, nor providing…...

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The five (5) KEY differences between PRCSs in GI and Construction and the added provisions that CLARIFY 1910.146 requirements (OSHA)

There are five key differences from the construction rule and several areas where OSHA has clarified existing requirements. The five new requirements include:… Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...

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The five (5) KEY differences between PRCSs in GI and Construction and the added provisions that CLARIFY 1910.146 requirements (OSHA) Read More »

Does ammonia need to be removed from evaporative condenser coils for entry into these PRCSs??

7/7/2020 UPDATE: Found the OSHA Case where an evaporator fan motor bracket failed, causing the fan to fall onto the coil(s) and cause a NH3 release 6/30/2020 UPDATE:  See my video of an NH3 Condenser Tube/Coil failure (Hydraulic Expansion) on my YouTube Channel   In 2012 I attempted to convince you that ammonia evaporative condensers…...

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Does ammonia need to be removed from evaporative condenser coils for entry into these PRCSs?? Read More »

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