JZ and I got our ASSP Safety2019! reviews today, as well as the recorded sessions were made available last night. Some of those who sent me a not so nicely worded e-mail after the conference have since relistened to the session and a couple of them actually apologized. Although not all have decided I am not a dumb-_ss. For the life of me, I can not understand why so many safety professionals want OSHA’s PRCS standards to be their answer to every hazard known to man! The standard was written/promulgated to address those hazards inside CS that make the CS a PRCS and yet some want to actually argue that the space shown below is a CS under 1910.146 and/or 1926.1200…
Now think about it; does this pick-up bed with a shell over it not meet the definition of a CS? Based on OSHA’s definition(s), it…
-
Is large enough and so configured that an employee can bodily enter and perform assigned work; and
-
Has limited or restricted means for entry or exit; and
-
Is not designed for continuous employee occupancy
But I so hope one day we can all agree that when OSHA promulgated 1910.146 in the 1990s and 1926.1200 in 2015 this type of space was NOT what OSHA was trying to protect workers from. But one of those attendees took serious issue with my explaining what a CS and PRCS were and proceeded to share with me an incident where one of his/her workers crawled into the back of a covered pick-up (like the one shown above) and was overcome by a leaking gas cylinder. Had other workers not been around, “he could have died“. I understand his passion and fear and desperation to find some rule or standard that he/she can turn to so as to prevent this type of incident again. I was in shock listening to this and as I could hear his/her passion and disbelief as I continued to challenge their premise that a pick-up truck bed with a shell was a PRCS. So I had to ask… “Is your company actually issuing an entry permit when an employee opens the hatch window and reaches in? Is there a rescue team and non-entry rescue equipment available before they reach in?
Tragic as it could have been, OSHA would have used the exposure standards or maybe even the GDC to cite, but they would NOT have used the PRCS standards.
Do we have to control ALL recognized hazards? ABSOLUTELY we do, but that is why there are a multitude of OSHA standards and consensus standards that we rely on to establish baseline risks to these hazards. As much as I love 1910.146, it is NOT the answer to all my unsafe work conditions or unsafe work practices – it applies ONLY to those spaces that are actually a PRCS!
