As I grow old I think I have mellowed out too much with “sutle” hints at hazards and how we “should consider” certain things. Well, its time to throw some cold water on the issue and WAKE THE HELL UP PEOPLE! We have done our last audit of 2019 and like many before them we found a serious issue regarding Permit-Required Confined Spaces (PRCS), or should I say Confined Spaces. You see, in the eyes of OSHA 1910.146 and 1926.1201-.1213 only apply when the space rises to the level of being a PRCS. And this application method means that if the hazard evaluation is done incorrectly, entrants could be exposed to serious dangers. But what about the space that really does not contain any PRCS at the time of the evaluation and thus is NOT identified as a PRCS. Often times these spaces are left out in left field and receive little to no safety efforts when workers enter them. Over the past six years, we have been looking for these types of arrangements during our work, especially during our audits, and it has been quite shocking how many spaces we find workers inside doing work that has a high potential to generate a hazardous atmosphere (HAZ ATM) with no safeguards and the reasoning is always… “it’s not a PRCS”… but the work taking place makes it one! Let me explain…
