What do you get when you have no “qualified/competent” person on site who fully understands the implementation of a Confined Space program AND OSHA’s eTool Industry page is being read literally by the unqualified worker? The answer: SERIOUS PRCS PROBLEMS! I had a smile on my face the entire time I was thinking about how to write this article in the hopes that industry could recognize the insanity of its argument. I have tried to get OSHA to revise their page, but due to limited resources, they have not gotten around to it. My smile on my face is because one of the professionals I have been debating this topic with is one of the many who claim I am too literal in my reading of the codes and standards, but now he is angry when he shows me an OSHA webpage that he reads in “literal terms” and I am telling him its wrong. I do fully understand his frustrations, but there is a good reason why NASA does not allow me to pilot their next mission – I HAVE NO CLUE HOW TO FLY A ROCKET and in the world of S&H, persons who are not “qualified” or “competent” in matters related to Permit-Required Confined Spaces really should not be making decisions based on their lack of knowledge, training, and/or experience as this leads to a really bad place!
For those of you who follow my ramblings, you may have recalled a 2019 article titled “Don’t confuse continuous employee occupancy with maintenance access” where I attempted to make the case that a Spiral Freezer is a without question a Permit-Required Confined Space. This debate came after another facility within the same organization suggested that a spiral freezer is not even a Confined Space and therefore could never rise to be a PRCS. Their position was that a “spiral freezer” was DESIGNED FOR CONTINUOUS EMPLOYEE OCCUPANCY; regardless of the fact that inside the freezer is intended to be -50F. But this latest facility visit identified their spiral freezer as a Confined Space but not a PRCS. The spiral freezers at this location were refrigerated with Anhydrous Ammonia – not with Nitrogen (N2) or Carbon Dioxide (CO2) and this was the basis for their classification as a Confined Space and not a PRCS. You may be asking yourself, why did it matter what the refrigerant was?
Pay close attention to the highlighted portion of OSHA’s Poultry Processing Industry eTool and confined spaces below and we can see how a less than knowledgable person regarding matters of Confined Space could come to the conclusion that if a freezer is chilled with Anhydrous Ammonia (NH3) it is different than those that are chilled with Nitrogen or Nitrogen (N2) or Carbon Dioxide (CO2). When in fact, NH3 is just as bad when inside a Confined Space. But to the refrigeration manager who was tasked with deciding whether their spiral freezer was a PRCS, he turned to OSHA’s guidance specific to his industry and found his answer:
PLEASE NOTE: the VAST MAJORITY of all spiral freezers are a PRCS, but as I made my argument, part of the reasons for this is the UNGUARDED equipment within the freezer and NOT solely based on the potential hazardous atmoipshere due to the refrigerant being used.
