Permit Required Confined Spaces

We continue to find businesses misunderstanding the need and requirement for “non-entry rescue” requirements found in 1910.146(k)(3). Even when a business has its own in-house CS rescue team, the rule is that for EVERY entry into a Permit-Required Confined Space, non-entry rescue capabilities found in 1910.146(k)(3)(i) & 1910.146(k)(3)(ii). There are ONLY two exceptions to this…...

Workers were injured while vacuuming explosive dust inside a PRCS to clean out a natural gas processing unit…. Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...

First, let me say this upfront if your facility has not evaluated your local fire department’s rescue capabilities in the past 2-3 years, I STRONGLY ENCOURAGE it to do so ASAP.  With the drastic swing in the economy and many cities on the brink of bankruptcy, I know of at least 50 FDs that have…...

When do I have to have a Confined Space rescue team? I get this question almost monthly, and it worries me that so many facilities struggle with such a critical analysis. It is not easy, but it could be a matter of life or death and deserves some explanation. In this post, I will walk…...

Several recent accidents with fatal outcomes occurring during the discharge of logs and wood chips from ships in Swedish ports indicate the need to understand better the atmospheric conditions in holds and connecting stairways. The principal aim of the present study was to assess the air levels of oxygen and toxic gases in confined spaces…...

A post I made on another board regarding a discussion about what makes an atm a hazardous atm… just exceeding a PEL does not make the atm hazardous under the PRCS std.  You are correct that OSHA has stated an atmosphere that contains a substance at a concentration exceeding a permissible exposure limit intended solely…...

It appears we may be blending 1910.146(c)(5) and (c)(7) in our attempt to reclassify a PRCS to a non-permit status.  We must follow (c)(7) in our reclassification efforts.  It does sound as if our PRCS may be able to be reclassified; however, I am not familiar with the type of space or specific situation.  OSHA…...

A space is a CONFINED SPACE when ALL THREE (3) of the following characteristics are true about the space: Is large enough and so configured that an employee can bodily enter and perform assigned work; AND it has limited or restricted means for entry or exit; AND it is not designed for continuous employee occupancy…...

A post I made in regards to “Fall hazards being part of a hazard making a space a PRCS” Falls are NOT considered to be a hazard for consideration in evaluating a “confined space” for hazards that would make it a Permit-Required Confined Space. See the MEMORANDUM FOR:… Membership Required You must be a member...

There is a lot of confusion on reclassifying Permit-Required Confined Spaces to Non-Permit Spaces, which is allowed on spaces with NO KNOWN or POTENTIAL hazardous atmospheres. 1910.146(c)(7) covers this practice. The key DIFFERENCE between “reclassifying” a space using section (c)(7) and using “alternative entry methods,” which is covered under section (c)(5) is ELIMINATION vs. CONTROL…....

So, who has to do Confined Space Evaluations, and when must this evaluation be done? The short answers are ALL General Industry (1910) employers and at the time the standard was promulgated and before each entry. Let me explain…… Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log...

One of the most asked-about standards is OSHA’s Permit-Required Confined Space (PRCS) standard. The standard can be difficult to decipher, so this post attempts to break down an employer’s entry options. We should view the standard as offering three (3) entry options. Each option has its own set of rules and pros and cons. Once…...