OSHA has addressed two (2) PRCS questions related to the Isolation of Piping that does NOT terminate within the space. This was a long time coming, as NFPA 350 and several trade groups have stated that piping that does NOT terminate within the PRCS need not be isolated. OSHA agreed, as long as six (6) criteria are met related to said piping…
NOTE: Please keep in mind, this LOI is focused on utility piping, specifically water and steam. Piping conveying a Highly Hazardous Chemical/Extremely Hazardous Substance is an entirely different risk assessment, as we would not need to “engulf the entrant” in order to create an IDLH atmopshere.
Whether there exists a “reasonable probability of a rupture or leak where the contents of the piping would cause a serious safety or health hazard” is a determination to be made by the employer. Factors to consider include, but are not limited to:
