All too often, when doing a CS entry or rescue course, we are surprised by the number of entry supervisors who do not understand the major limitation of a combustible gas meter… the LEL Correction Factor. EVERY meter in use today will have this limitation! This is how it works…
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.
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 need 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 us through
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 about a discussion on what makes an ATM hazardous…
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: Once you have determined the space is a CONFINED SPACE, the next step is to determine if your CONFINED SPACE has at least ONE (1) of the following hazards that would elevate it to the status
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:
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 is responsible for Confined Space Evaluations, and when must they be conducted? The short answers are ALL General Industry (1910) employers, and at the time the standard was promulgated, and before each entry. Let me explain…
