Has OSHA’s Permit-Required Confined Space standard met its goal?

With year 2020 already claiming 7 lives inside PRCSs within the USA, I have to ask the question:  Has OSHA’s Permit-Required Confined Space standard meet its goal?  In OSHA’s Preamble for 1910.146, published in 1993, OSHA stated:

OSHA has determined that permit spaces pose significant risks to employees (62 fatalities and 12,643 injuries and illnesses annually) and estimates that compliance with the Permit-Required Confined Space standard will reduce the risk of permit space hazards by 85 percent (preventing 53 fatalities and 10,746 injuries and illnesses annually). This constitutes a substantial reduction of significant risk of material harm.

I must add that most of the 2020 deaths inside confined spaces happened in the farming industry and may or may not have been outside of OSHA’s scope of enforcement.  But in 1993, OSHA was hoping that 1910.146 would reduce PRCS fatalities to just nine (9) per year.  I do not know the exact numbers for General Industry workplaces, but I think we could come up with more than nine (9) PRCS fatalities each year since 1993.  Some days I dream of working for OSHA and my role would be limited to inspections/investigations related to PRCS, LOTO, HAZWOPER, and PSM.  But I am abruptly awakened to reality!

The 2017 Census of Fatal Occupational Injuries showed us that we were seeing an INCREASE in PRCS related deaths; we had 166 PRCS deaths in 2017 and that is up from the 144 PRCS Deaths in 2016.

In 2017, 41 U.S. workers died on the job after a single episode of inhaling chemicals and chemical products – 7 more fatal injuries than in 2016. This number ranged between 33 and 55 fatal injuries each year from 2011 to 2017, with a total of 297 fatalities across the 7-year span.  87 deaths occurred inside PRCSs.