Right after doing our site Confined Space assessment, OSHA says that we must identify spaces deemed to be Permit-Required Confined Spaces. Many facilities order hundreds of signs to put on their spaces at a pretty penny… in other words; it ain’t cheap to label these spaces! So one would think that the labeling/marking would be done properly. Take the image to the left… anyone see anything wrong with this picture?
Think in a futuristic way… As shown in the photo, most PRCSs are labeled with a sign on the entry portal cover. We tend to put the DANGER sign directly on the accessway cover/door for everything from a hatch door, manway, hatchway, etc. As it sits, as shown in the photo, we have no issue, but what happens when the tank is prepped for entry and the manway cover is opened/removed?
Now we have an OPEN PRCS without any identification as such, a serious unsafe condition, as well as a failure in compliance. Let’s take a look at what OSHA’s 1910.146 says about identifying PRCSs and preventing unauthorized entry into PRCSs.