Over the years, I have encountered some great learning opportunities, many occurring during my VPP assessments. In one such evaluation in Alabama, the CSHO pointed out that our PRCS Labels were on the actual coverings over the entry portals (e.g., manways). As he explained, in that set-up, OSHA would not require the space to be labeled; however, as soon as the manway comes off the vessel, then there is NOTHING prohibiting entry into the area, and thus THEN A LABEL WOULD BE REQUIRED… the problem being is the label was on the manway which is off and leaning against the dike wall.
The bottom line is that a sealed-up vessel is not required (by OSHA) to be labeled, but as soon as space is open and someone can enter it, space MUST BE LABELED. So, when we label our PRCSs, it’s best NOT to put the DANGER sign on the entry portal cover(s).
