Permit Required Confined Spaces

PRCS fatality due to LOTO failures (Concrete Mixer(s))

We hear it often… “Who would turn the machine on while I’m working on it?”  It happens more often than most think.   Employee # 1 and Coworker #1, Coworker #2, and Coworker #3 were cleaning two (2) concrete mixers. Employee #1 was paired with Coworker #1 to clean out a mixer. Employee #1 entered…...

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OSHA cited the company for 2 willful and 24 serious PRCS violations (1 H2S death & $171,680)

Federal investigators determined a truck washing company failed to protect workers from hydrogen sulfide gas as they entered over-the-road tanker trailers to clean them out, causing one worker’s fatal injuries and hospitalizing two co-workers. OSHA responded to a report of the Sept. 1, 2023, incident and found the business failed to evaluate the tanker trailers for hazardous…...

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Episode 122 – Bryan Haywood – Permit and Non-Permit Required Confined Spaces

This was a brief 30-minute chat with my friend and longtime supporter @ SAFTENG on the topic of Permit-Required Confined Spaces.  This first episode was just the basics, but I explain how a confined space is DEFINED and how that confined space becomes a Permit-Required Confined Space (PRCS).  We then discuss the three (3) entry…...

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PRCS fatality – Tanker Truck (oxygen-deficiency during cleaning)

For those who believe entering a PRCS would not happen when the Oxygen level is measured at 19.5% (IDLH for O2 Deficiency)… November 22, 2022, @ 1:00 p.m., an employee from a local chemical company was cleaning the inside of a tanker trailer. The employee was required to enter the tank and wash out the…...

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Your life saving safety tip… atmospheric hazards (1% = 10,000 ppm)

I am no longer surprised when I teach a PRCS or an Emergency Response course and the students who have been doing entries into PRCSs and responding to emergencies but are unaware of primary atmospheric conditions.  This is how I explain it… We have 100% volume of air in the space. That 100% volume is…...

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PRCS fatality – welding in ship under construction (oxygen-deficiency during welding)

On August 28, 2023, at 7:30 a.m., a worker was welding in a confined space on a ship under construction. The victim was found unresponsive inside of the confined space. Per the medical examiner’s report, the employee was killed as a result of suffocation in an oxygen-deficient environment. NOTE: this is likely due to a…...

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FATAL entry into LPG Storage Tank (O2 Deficiency)

August 18, 2022, at 3:00 p.m., an employee entered an empty liquid propane gas (LPG) tank for servicing at an industrial equipment wholesaler facility. Earlier in the day, the employee approached a supervisor and said he wanted to enter the tank to spray Torq CB III penetrating oil product on an internal valve to loosen…...

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OSHA answers the question… Would it be compliant if an employer reviews a representative sample of the entry permits during the one-year review?

1910.146(d)(14) does not specify how many or what percentage of entry permits must be reviewed annually. Would it be compliant if an employer reviews a representative sample of the entry permits during the one-year review?   The easy answer is NO, ALL CANCELED ENTRY PERMITS AND NOT A REPRESENTATIVE SAMPLE OF THE ENTRY PERMITS must…...

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OSHA answers the question regarding – Retention of atmospheric monitoring records for a permit-required confined space

Although this question has been discussed before, OSHA issued a new Letter of Interpretation (LOI) late in 2023 (posted in 2024), answering the following question and has ARCHIVED their previous LOI from November 26, 1996. Does OSHA consider the initial monitoring data and subsequent re-testing data to constitute employee exposure records subject to the record…...

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2 entrants and 2 would-be-rescuers (VFD) in residential well

This is another example of entrants not recognizing the space they are entering is a CONFINED SPACE and the actions/work they did turned the confined space into a PERMIT-REQUIRED CONFINED SPACE.  Both entrants died and two (2) volunteer FF’s were injured in their attempts to perform rescues at this residential incident. On May 26, 2010,…...

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OSHA issues PRCS citations @ environmental and emergency services company (O2 Deficiency & $118K)

OR-OSHA has fined a Portland environmental and emergency services company $118,800 for violating job safety standards designed to protect workers from the potentially deadly hazards of confined spaces. The division cited the employer following an inspection of an incident reported by Portland Fire & Rescue. Oregon OSHA’s July 14, 2023 incident inspection found that two…...

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Fatal entry into Open-Top Frac Tank (PRCS & H2S)

At 8:00 a.m. on June 26, 2022, two (2) employees emptied and cleaned an open-topped frack tank (Tank #4) at an oil and gas services site. There were no eyewitnesses, and the employees were working at a remote site alone, so few details are known about what occurred. At the time of the investigation, hydrogen…...

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