The Entry Supervisor is an ABSOLUTE CRITICAL PATH in safely performing entries into PRCSs. With that said, if entry supervisors simply attend the same training that everyone else attends, we have FAILED them. We were asked to assist with a 2012 PRCS fatality incident where the abject failure of the facility to train its entry supervisors was undoubtedly the root cause of the tragedy. Yet the business wanted to lay the blame for two deaths at the feet of the attendant, rather than the entry supervisor and the management team’s failures. Although the management team could provide us “sign-in sheets” for their entry supervisors showing they had attended “PRCS training”, that training (an online video from a large online trainer) simply read the “roles and responsibilities” of the entry supervisor word for word from 1910.146(j). When we sat down with each entry supervisor (13 in all), we found that not a single entry supervisor was capable of explaining:
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Why Oxygen Concentration must be measured FIRST (then LEL and then Toxicity)
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The Correction Correlation with the LEL readings
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Why OSHA defined the LEL of 10% as a Hazardous Atm
- What it means to verify rescue services are available and the means to summon them are operational BEFORE signing the permit and authorizing entry
- The means and measures to reclassify a PRCS to a non-PRCS status
I do NOT blame the Entry Supervisors for their lack of knowledge – I blame management for doing as little as possible for such a CRITICAL PATH to safety.
