Permit Required Confined Spaces

Reclassifying a permit required confined space

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…...

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Evaluating a Confined Space

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…...

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Confined Space Hazards that are to be considered

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...

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Isolation for Reclassification of Permit-Required Confined Spaces

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…....

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Evaluating Confined Spaces (1910.146(c))

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…… Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in...

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Making sense of entry options under OSHA’s PRCS Entry Std. 1910.146

One of the most frequently asked about standards is OSHA’s Permit-Required Confined Space (PRCS) standard. The standard can be challenging 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…...

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A Purdue University report showed 51 grain bin accidents last year

A Purdue University report showed 51 grain bin accidents last year, up from 38 in 2009 and the most since tracking began in 1978. Twenty-five people died, and five of them were children under the age of 16. The previous record for grain bin accidents was 42 in 1993. The accidents prompted the OSHA to…...

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Overview of the Permit-Required Confined Spaces Standard

The Final Rule for Permit-Required Confined Spaces was published in the Federal Register on January 14, 1993, and became effective on April 15, 1993. The standard is based on years of gathering information on confined space fatalities and on testimony about the hazards of confined spaces from all sectors of industry and labor. Because it…...

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Entry into PRCS’s protected by a fixed fire protection system

I could have sworn I had already written about this hazard, but I’m guessing it was inside one of my social media groups.  So BUCKLE UP, Buttercup, as this is going to make a lot of folks unhappy.  Question:  Do I have to isolate my fixed fire suppression system protecting my PRCS?… Membership Required You...

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Why does OSHA’s 1910.146 require O2 to be sampled first?

Before an employee enters the space, the internal atmosphere shall be tested, with a calibrated direct-reading instrument, for oxygen content, for flammable gases and vapors, and for potential toxic air contaminants, in that order. We test for oxygen before testing for flammability (LEL) for two (2) critical reasons: Here is the breakdown of why this…...

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PRCS Fatality (Tanker Truck); 1 entrant and 2 would be rescuers

Employee #1 entered a semi-trailer truck to wash out the inside, which had contained a fatty acid (linseed oil). A short time later, he was found lying at the bottom under the hatch opening. Employees #2 and #3 jumped in to rescue him and were nearly overcome. Employee #1 died, and blood tests conducted two…...

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