Isolating a Permit-Required Confined Space is a requirement regardless of your entry option used

Citation 1 Item 3

Type of Violation: Serious; $10,728

29 CFR 1910.146(c)(7)(i): A space classified by the employer as a permit-required confined space may be reclassified as a non-permit confined space under the following procedures:

1910.146(c)(7)(i) If the permit space poses no actual or potential atmospheric hazards and if all hazards within the space are eliminated without entry into the space, the permit space may be reclassified as a non-permit confined space for as long as the non-atmospheric hazards remain eliminated.

a) From October 8, 2020, to January 4, 2021, the employer had reclassified and entered the powder coat process line, a permit-required confined space, on 13 occasions without ensuring the space posed no actual or potential atmospheric hazards in order for maintenance employees to perform repairs and preventive maintenance.

On the cure oven, the natural gas was not always gas locked out until November of 2020, the preheat oven and cure oven were not isolated from the natural gas lines as the ISOLATION PROCEDURE WAS NOT CORRECTLY PERFORMED BY ALL EMPLOYEES…

Citation 1 Item 4a

Type of Violation: Serious; $10,728

29 CFR 1910.146(d)(3)(i): Develop and implement the means, procedures, and practices necessary for safe permit space entry operations, including, but not limited to, the following:

Specifying acceptable entry conditions.

a) From October 8, 2020, to January 4, 2021, the employer reclassified and entered the powder coat process line, a permit-required confined space, on 13 occasions without implementing the means, procedure, and practices specifying safe entry conditions in order for maintenance employees to perform repairs and preventive maintenance.

The cure oven did not have the natural gas locked out until November of 2020, the PREHEAT OVEN AND CURE OVEN WERE NOT ISOLATED FROM THE NATURAL GAS USING A DOUBLE BLOCK AND BLEED…

Citation 1 Item 5a

Type of Violation: Serious; $10,728

29 CFR 1910.146(g)(3): The training shall establish employee proficiency in the duties required by this section and shall introduce new or revised procedures, as necessary, for compliance with this section.

a) On or about October 8, 2020, the employer did not provide training when a procedure was changed in that that employees were not trained on locking out the natural gas on the cure oven for the powder coat line, AN ENTRY SUPERVISOR AND EMPLOYEES WERE NOT TRAINED ON HOW TO ISOLATE THE NATURAL GAS LINES ON THE CURE OVEN AND PREHEAT THE OVEN…

Citation 1 Item 2

Type of Violation: Serious; $13,653

29 CFR 1910.147(c)(4)(ii): The procedures shall clearly and specifically outline the scope, purpose, authorization, rules, and techniques to be utilized for the control of hazardous energy, and the means to enforce compliance including, but not limited to, the following: B)Specific procedural steps for shutting down, isolating, blocking and securing machines or equipment to control hazardous energy;

a) On or about 10/30/2020 the energy control procedure for the Powder Coat Cure Oven was inadequate in that it did not include specific procedural steps for safely shutting down and isolating the natural gas lines. THE PROCEDURE DID NOT IDENTIFY THE MEANS OF BLEEDING OFF THE EXCESS NATURAL GAS, THEREBY EXPOSING EMPLOYEES TO THE HAZARDS ASSOCIATED WITH NATURAL GAS…

Relationship between the Control of hazardous energy (LOTO) standard and the Permit-required confined spaces (PRCS), 29 CFR §1910.146, standard.

The PRCS and the LOTO standards are generic and interrelated standards, and both standards may, depending upon the circumstances, apply to the isolation of hazardous energy for a PRCS. The application of the LOTO standard, with respect to PRCS, is governed by §1910.147(a)(3)(ii), which provides that, when other standards require LOTO, the procedural and training provisions of the LOTO standard shall be used and supplemented to effectively control hazardous energy. Therefore, for any particular PRCS, the question will be whether the 1910.146 standard requires LOTO to isolate hazardous energy.

The answer to this question depends on the type(s) of hazardous energy that must be isolated, whether LOTO provides isolation (offering complete employee protection), and whether the §1910.146 requires the use of LOTO. Pursuant to the §1910.146 standard (including its final rule preamble), electro-mechanical types of hazards, associated with a PRCS, must be isolated in accordance with the LOTO standard (or guarded in accordance with Machine guarding, Subpart O, requirements). Failure to follow the procedural and training requirements of the LOTO standard should be cited as §1910.147 violations related to the isolation of electro-mechanical hazards.

The PRCS standard does not, however, allow LOTO for flowable material isolation. This is because compliance with §1910.147 does not, in all cases, adequately isolate hazards created by materials such as steam, flammable gases, flammable and combustible liquids. In a permit-required confined space, hazards associated with flowable materials will be considered isolated only by the use of the following techniques: blanking or blinding; misaligning or removing sections of lines, pipes or duct; and use of a double block and bleed system. A double block and bleed isolation system, for example, usually utilizes the closure of two valves, the opening of a bleeder valve, and the application of LOTO devices (offering complete employee protection); whereas an employer can comply with §§ 1910.147(d)(3) and 1910.147(d)(4) of the LOTO standard by simply closing and LOTO of a single valve (which could create atmospheric hazards due to the leakage of a single valve).