I have written over 180 articles on the topic of Permit-Required Confined Spaces. We can agree there is a lot to write and talk about on this topic. In our travels, we do a lot of work with clients around their PRCS management; most of the time, this work is more “technical.” In this article, I want to explain how we should manage our PRCS Entry programs as a mini “safety management system.” Please remember that much of what I will discuss is NOT an OSHA requirement. However, I will use 1910.146 as the framework for the article.
Any PRCS entry management system begins with the written program. And as I wrote about last week, Is shorter better? (Part II – PRCS Program) the written program is the core of the management system. Every item I will discuss in this article MUST be explained, in detail, how each piece of this pie works together to manage the incredible risks associated with PRCS entry.
After our program is in place, with management approval and support, the next step may be the most critical. Evaluating our facility for Confined Spaces and those that rise to the level of a Permit-Required Confined Space. The evaluation step can be extensive; as I said, it may be the most critical step in the management system. Of course, the permitting and atmospheric sampling are the critical paths in the entry operations.
