Permit Required Confined Spaces

PRCS Entry Supervisor training

The Entry Supervisor is an ABSOLUTE CRITICAL PATH in safely performing entries into PRCSs.  With that said, if entry supervisors simply attend the same training that everyone else attends, we have FAILED them.  We were asked to assist with a 2012 PRCS fatality incident where the abject failure of the facility to train its entry…...

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PRCS fatality (HAZ ATM – asphyxiation)

At 3:00 p.m. on August 18, 2022, 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 stated that he wanted to enter the tank to spray a penetrating oil product on an internal valve to loosen…...

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Argon in 20″ pipe leads to welder asphyxiating

During construction work at an LNG plant, Argon was used in Corrosion Resistant Alloy (CRA) welding to remove oxygen from the molten weld. The Argon accumulated in the piping, and when the welder checked the weld from inside, he fainted and died.          … Membership Required You must be a member to...

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Heat Stroke during entry into PRCS (Baghouse)

At 12:45 p.m. on July 5, 2022, Employee #1, 46, and his coworker cleaned a baghouse on a roof. The employee was wearing a Tyvek suit, KN95 respirator, and a safety harness when he made an entry into a steel baghouse, which is a confined space. National Weather Service reported conditions of 93 degrees F,…...

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Argon used in welding asphyxiates welder in 24″ pipe

At 1:30 p.m. on April 19, 2022, an employee, 35, was back welding inside a spool vessel (titanium pipe) that was 24 inches in diameter. The employee was asphyxiated due to the displacement of oxygen by argon gas…. Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in...

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Two employees entered a 21″ sewer manhole that was oxygen deficient

At 4:15 p.m. on June 14, 2022, two employees entered a 21-inch sewer manhole to conduct vacuum testing, not knowing that it was oxygen deficient. Both employees were overcome and died…. Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...

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Emptying and Cleaning an open-topped frack tank results in two fatalities (H2S suspected)

At 8:00 a.m. on June 26, 2022, two employees, 45 and 46, were emptying and cleaning 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 by themselves, so few details are known about what occurred…. Membership Required You...

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Six words in 1910.146 that are almost never complied with and may be the greatest challenge for most facilities

Which six words am I talking about?  There are a lot of requirements in 1910.146 and 1926.1201-.1213 that get missed on entries.  Luckily, missing a few here and there USUALLY does not equate to a tragic accident.  However, the six words I speak of are a CRITICAL PATH in a “permitted entry” into a PRCS. …...

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Does this video show work inside a PRCS or an “industry practice”?

I have several clients who offload ships/containers in this manner. Whenever I see this, I immediately go to “that is a PRCS”. The ship/container is for sure a CS, and the fact that we have an engine putting off CO inside the ship/container makes the space a PRCS. I am fortunate enough to have great…...

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Grain Coop issued Willfuls after worker lost leg inside silo

SPECIAL NOTE: This appears to be the first case where OSHA has applied it’s new Instance-by-Instance Penalty for Willful Citations.  This case involved a leg amupation while working inside a sile with the paddle conveyor still running.  OSHA issued three (3) Willfuls using 1910.28(b)(6)(i) for each citation and all three (3) were willfuls. An grain…...

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Did OSHA miss the opportunity to improve safety around PRCSs?

In OSHA’s LOTO standard, they incorporated a requirement that required businesses to have forethought about the means used to isolate energy.  Specifically, the standard requires: 1910.147(c)(2)(iii) After January 2, 1990, whenever replacement or major repair, renovation or modification of a machine or equipment is performed, and whenever new machines or equipment are installed, energy isolating…...

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