One of the weakness of OSHA’s PRCS standard(s) (1910.146 and 1926.1200) is that when the space is evaluated and it is determined to only be a Confined Space (CS). Too often we let down our guard and assumed the space will pose no hazards to the workers entering the space. Recently I was made aware of a serious incident inside some HVAC duct work. This duct work had been evaluated by the site safety team and like most evaluations of HVAC duct work, it was determined the space was indeed a Confined Space, but did not rise to the level of being a Permit-Required Confined Space. So when the facility had a forklift incident and damaged the HVAC, the facility decided to go ahead and make some “improvements” to the HVAC duct work at the recomendation of the HVAC contractor and this took a contractor inside the duct work. Since the space had been determined to be only a CS (NOT a PRCS) no special requirements or any type of hazard evaluation took place before the contractor entered the space and began his work. Then, this happened…
