Noise is a recognized hazard, but noise is NOT a hazard that makes a CS become a PRCS

Why is this article posted in the Permit-Required Confined Space section of the website?  Because there seem to be a large number of safety professionals that are under the impression that ANY occupational hazard can turn a confined space into a Permit-Required Confined Space.  Noise is a recognized occupational hazard – I think we can all agree on this; however, noise is NOT a hazard that would turn a confined space into a Permit-Required Confined Space (PRCS).  As I have pointed out before, BOTH the GI and Construction standards on Confined Spaces have a “disclaimer” regarding atmospheric concentrations of any substance for which a dose or a PEL is published. 

BEFORE you send me hate mail and claim I do not care about workers, let me once again make this clear – NOISE IS A HAZARD which we MUST protect our employees from.  But this hazard is managed via our Hearing Conservation Program REGARDLESS of where the exposure occurs.  So just because we need hearing protection because of the grinding inside the space is causing our exposure to exceed 90 dBA, this hazard would NOT make the space a Permit-Required Confined Space.  We MUST manage this exposure in the same way we would manage it if we were grinding in a small workspace and our exposure would exceed the 90 dBA

In no way did OSHA ever intend that ANY, or ALL, OCCUPATIONAL HAZARDS would make a CS a PRCS and they have said this over and over for decades.  Both standards make it clear that for a “hazard” to be one that would make a CS a PRCS, that hazard MUST impact the entrant in such a way that the hazard would cause death, incapacitation, impairment of ability to self-rescue, injury, or acute illness due to its health effects, of which NOISE does not meet these criteria.  And yes, I am aware of the police and military weaponizing noise frequencies – but seriously folks, that is NOT an occupational exposure that 99.99% of workers are being exposed to in the workplace.  So here is what OSHA has said about noise and PRCSs…

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