Does an PRCS attendant need respiratory protection?

I am sure the thought has crossed everyone’s mind who has issued an entry permit for a HAZ ATM entry… “should the attendant be in breathing air as well?”.  Is there an exposure potential for the attendant to the HAZ ATM from within the PRCS?  Most attendants are stationed right outside the entry portal, add to the scenario forced fresh-air ventilation into the space and we have an exposure event.  However, it is not uncommon to find an attendant who is not even in a respiratory protection program nor equipped with proper respiratory protection should an event occur where they would need to perform NON-ENTRY rescue procedures.  Here is a 2018 OSHA case, also see the CSB Valero PRCS video, where the person OUTSIDE the space was killed by the HAZ ATM within the space at a poultry plant.  The employee died from exposure to ammonia and hydrogen sulfide vapors associated with poultry blood.

NOTE: this fatality was NOT associated with a PRCS entry, I am just using this case to show how an exposure OUTSIDE the space can happen.

At 5:00 a.m. on September 27, 2018, the employee was unloading and washing a truck tanker with water that had contained poultry blood. The employee was found unresponsive on top of the tanker with his head over the tanker opening. The employee was killed from exposure to ammonia and hydrogen sulfide vapors from the tanker truck.

Violation Summary
  Serious Willful Repeat Other Total
Initial Violations 1       1
Current Violations 1       1
Initial Penalty $13,260 $0 $0 $0 $13,260
Current Penalty $10,608 $0 $0 $0 $10,608

 

Violation Items
# ID Type Standard Issuance Abate Curr$ Init$
1. 01001A Serious 19101000 B02 03/25/2019   $10,608 $13,260
2. 01001B Serious 19101000 E 03/25/2019   $0 $0
3. 01001C Serious 19100134 D01 I 03/25/2019   $0 $0

 

Case File

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