As our debate/discussion continues regarding falls within or into a Confined Space and if that fall hazard is one that makes the CS a PRCS and if a PRCS can be reclassified when there is a fall hazard present. I keep sharing OSHA language and it keeps being diced up and rephrased to meet personal agendas. Look, if anyone wants to manage the fall hazards via their entry permit system, I am in NO WAY saying you can not do it. What I am saying is that we need to stop laying claim that OSHA requires it. Granted, OSHA is the bottom of the proverbial safety barrel and as I have written many times, we MUST do better in safety than just meeting OSHA minimums. I have received countless e-mails and about 50% say a PRCS that contains a “fall hazard” can NOT be reclassified and surprisingly the other 50% danced around the idea that if the entrants were wearing personal fall arrest system (PFAS) that this would allow for the space to be reclassified. I still can not believe these arguments so many passionately defend, but to establish the fact that wearing a PFAS does NOT ELIMINATE the hazard, but merely controls the hazard. Thus if we treat a fall hazard as a “recognized serious safety and health hazard” that would prevent a PRCS from being reclassified to a non-PRCS; merely requiring the entrants (and/or attendants) to wear PFAS does NOT eliminate the hazard – which 1910.146(c)(7) requires ELIMINATION of the “hazards” which made the space a PRCS. Here is what OSHA had to say about “controlling” a hazard and “eliminating” a hazard as it relates to confined spaces…
(emphasis by me)
Q 1. Are attendants always required anytime employees enter a permit-required confined space (PRCS)?
R. The PRCS Standard allows entry into a PRCS without an attendant being present in two situations. They are:
1. when as per paragraph (c)(7) of 29 CFR 1910.146 all the hazards in the permit required confined space (PRCS) are eliminated, or
2. when as per paragraph (c)(5) of 29 CFR 1910.146 the only hazard in the PRCS is an actual or potential atmospheric hazard that can be controlled by continuous ventilation.
It is important that there be a understanding of what is meant by control of a hazard and elimination of a hazard. For purposes of the PRCS Standard, a hazard is considered to be CONTROLLED WHEN THE CONDITIONS WHICH CAUSED THE HAZARD STILL EXIST in the PRCS but they are being continuously managed so that the hazard cannot reoccur. ELIMINATION MEANS THE CONDITIONS WHICH CAUSED THE HAZARD TO BE CREATED NO LONGER EXIST IN THE PRCS. The most common example of control of a hazard is use of continuous ventilation to prevent a hazardous atmosphere from being created. An example of elimination of a hazard is use of one of the techniques described in the definition of the term “isolation”, which is defined in paragraph (b) of 29 CFR 1910.146. Generally speaking hazards are controlled or eliminated only for the duration of the entry into the PRCS.
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