One of OSHA's criteria, in both their General Industry and Construction Confined Space Standards, for a "Confined Space" is that the space that is "not designed for continuous employee occupancy". It seems that these six (6) words cause much confusion on both ends of the CS debate. I have seen it mis-used in order to claim a space is a CS and I have seen it mis-used to claim a space is not a CS and therefore it was not a Permit-Required Confined Space (PRCS). My hope is to convince you that "not designed for continuous employee occupancy" really does mean what it says!

OSHA opened an inspection of the mill on Dec. 27, 2016, in response to a complaint alleging unsafe working conditions. Inspectors discovered employees exposed to serious safety hazards, including permit-required confined space hazards and LOTO failures, which I have summarized below:

  1. Why cooling towers should be considered PRCS's

  2. OSHA issues Construction PRCS citations @ FL manhole triple fatalities (H2S & $119K)

  3. The creation of a Confined Space... from construction to general industry

  4. Permit-Required Confined Space Alert - Hopper (MSHA)

  5. OSHA's First Year Enforcement Activities for Confined Spaces in Construction

  6. Contractor doing a PRCS Rescue Evaluation (1910.146(k) & 1926.1211)

  7. BSEE Safety Bulletin No. 003 - Mud/Gas Separator Cleaning Results in PRCS Death

  8. When contractors enter a host's PRCSs (1910.146(c)(8)(iii)

  9. Construction Companies learning that PRCS Rescue is not a walk in the park (1926.1211)

  10. Purdue University releases their 2016 Ag Confined Space Fatality Report

  11. Development of a Confined Space Risk Analysis and Work Categorization Tool (IRSST - Canadian)

  12. Isolating a Permit-Required Confined Space (1910.146(d)(3)(iii)

  13. OSHA's take on Atmospheric Hazards inside Permit-Required Confined Spaces

  14. 2016 OSHA PRCS activity by Industry Sectors

  15. Technological advances in Process Safety and Permit-Required Confined Space Entries

  16. Confined Space Fatality Alert - Unloading rail car

  17. Confined Space Alert - Collapse of floating roof in storage tank (WorkSafe Victoria)

  18. Tampa Bay FD reviews their CS Rescue protocols after Key Largo TRIPLE fatality incident

  19. OSHA issues Construction PRCS citations (Sewer Entry & $152K)

  20. Permit-Required Confined Spaces and Exposure Records Retention

  21. OSHA issues PRCS citations @ transformer manufacturer ($43K; 2 fatalities - 1 entrant and 2 "would be rescuers")

  22. WA-OSHA has published their DRAFT - Confined Spaces in Construction and it is AWESOME

  23. OSHA issues grain bin entry and LOTO Citations @ farmer-owned cooperative ($411K, Egregious Willful)

  24. General Industry vs. Construction on Permit-Required Confined Space Citations (OSHRC)

  25. OSHA cites a contractor $203K for a PRCS fatality and it flies under the radar

  26. Cal/OSHA has cited a metal processing company $73,105 for serious PRCS violations

  27. OSHA cites contractor under new Construction Confined Space Standard

  28. OSHA PRCS Citations on Reclassification with Combustible Coal Dust ($20K)

  29. USGC Marine Safety Information Bulletin - Enclosed Space Entry and Rescue Drills

  30. PRCS Entry Supervisor and Rescue verification has changed with 1926.1210

  31. OSHA's new Fact Sheet on PRCS Rescue - Is 911 your Confined Space Rescue Plan?

  32. Does “emergency services” mean “rescue service” in OSHA’s new PRCS standard for Construction?

  33. OSHA issues PRCS Citations @ food cannery($143K, Willful, Repeats)

  34. OSHA issues PRCS (Construction) Citations @ WWTP (PRCS, Pressure Testing & $85K)

  35. OSHA PRCS citations @ railcar cleaning facility (O2 Deficiency & $226K)
  36. OSHA PRCS Citations @ food plant (Acetic Acid/Vinegar & $79K)

  37. 2016 Ohio BWC PRCS Rescue Presentation (1910.146(k)

  38. OSHA PRCS citations @ Concrete Plant ($140,000)

  39. Does 1910.146 allow (c)(5) AND (c)(7) to be used on the same PRCS at the same time? (Part 2)

  40. OSHA S&H Bulletin - Hazards when Purging Hydrogen Gas-Cooled Electric Generators (SHIB 01-22-2016)

  41. Does 1910.146 allow (c)(5) AND (c)(7) to be used on the same PRCS at the same time?

  42. Temporary Enforcement Policy for Residential Construction Work in Confined Spaces (1/2016)
  43. Real Life Accident: Chief Mate Dies From Asphyxiation
  44. Tough start for PRCS Fatalities into OSHA's 2016
  45. Confined Space Standards Side-by-Side Comparison Chart (OSHA Directorate of Construction)
  46. 2015 OSHA PRCS activity by Industry Sectors
  47. Employee Is Killed When Asphyxiated In Oil Storage Tank (PRCS - Issues with five minute escape pack)
  48. Scaffolder falls from height in a process vessel at a refinery - fatal
  49. NFPA 350, Table A.10.9.1 may be the MOST IMPORTANT Confined Space document published in 2015
  50. NFPA 350: Best Practices Guide for Safe Confined Space Entry and Work (Effective 12/4/15)
  51. Why OSHA states "entry" has taken place as soon as ANY PART of your body breaks the plane
  52. PRCS "program reviews" under 1910.146(13) & (14) (OSHRC decision)
  53. OSHRC decision on PRCS Tanker Truck Willfuls 
  54. IN-OSHA PRCS citations @ Power Plant inside pulverizer (Combustible Dusts $20K)

  55. MSHA's special initiative on Confined Spaces

  56. Temporary Enforcement Policy for Residential Construction Work in Confined Spaces

  57. Is "competence" for doing a CS evaluation = to "competence" for doing a RECLASSIFICATION
  58. Confined Space Evaluations and a "competent person"
  59. OSHA PRCS citations @ Railcar Cleaning business (Flammable Atmosphere & $963,000)
  60. The five (5) KEY differences between PRCSs in GI and Construction and the added provisions that CLARIFY 1910.146 requirements (OSHA)
  61. OSHA publishes Confined Spaces: Protecting Construction Workers in Confined Spaces - Small Entity Compliance Guide (OSHA 3825)
  62. The process of isolating a PRCS
  63. When is entry rescue required and when is non-entry rescue required for entries into Permit-Required Confined Spaces
  64. How many confined spaces do you see?
  65. Would you be an entrant? (PRCS isolation)
  66. Side-by-Side comparison of OSHA's PRCS Standards
  67. PRCS energy isolation methods and locking/tagging
  68. Questions for those in General Industry work places about when the new Construction Confined Space standard would apply
  69. OSHA issues temporary enforcement policy for confined spaces in construction (OSHA)

  70. Comparing OSHA’s Confined Spaces in Construction standard (1926.1201-.1212) to the General Industry Standard (1910.146)

  71. Can you name ALL the "documentation" one would need to demonstrate FULL compliance with 1910.146?

  72. NFPA 350 Guide to Confined Space Entry and Work coming in November (NFPA)

  73. Why is 1910.146(j)(4) INVISIBLE in most every PRCS Entry Program/Procedure?
  74. On-Duty Firefighter Fatalities Involving Confined Spaces, 2003 – 2012 (NFPA Fire Analysis and Research Division)
  75. How do you comply with debriefing contractors after they exit your PRCS?
  76. OSHA issues PRCS Citations @ food tanker cleaning facility ($179K)
  77. Fatal Hotwork Explosion on Barge (USCG)
  78. Investigation of PRCS Flash Explosion and Injuries (BSEE)
  79. Labeling Permit Required Confined Spaces may not be as simple as some would believe
  80. OSHA issues PRCS citations after two workers died in Railcar with H2S
  81. WA-OSHA citations after worker, 19, dies inside "bark blower" truck
  82. UK’S HSE updates their “Safe work in confined spaces” Guidance
  83. OSHA PRCS citations involving Tanker Truck @ a producer and distributor of food products ($30K)
  84. OSHA PRCS citations involving Rail Car cleanout ($188K)
  85. OSHRC affirms PRCS citations (Preventing Unauthorized entry and Rescue)
  86. How can one argue that a large roll-off trash compactor is not a PRCS?
  87. Getting in is ALWAYS easier than getting out! (Video)
  88. OSHA cites a Grain Elevator for 1 willful, 2 repeat, 8 serious violations ($120,120)
  89. Safety Bulletin - Entry of a confined space on board a cargo ship resulting in three fatalities (Marine Accident Investigation Branch (MAIB)
  90. Oregon OSHA – Proposed Changes to Confined Spaces Standard for General Industry and Construction
  91. Volunteer Fire Fighter Dies During Attempted Rescue of Utility Worker From a Confined Space (NIOSH FACE)
  92. Confined Space Flash Fire (Tank NOT connected!)
  93. Cal/OSHA Cites an industrial service provider $82,090 for Accident in Confined Space that Seriously Injured Worker
  94. Off-Gassing Hazard from Wood Pellets and Chips (The Annals of Occupational Hygiene)
  95. OR-OSHA HAZARD ALERT: Confined Spaces – Winery Vessels
  96. OSHA cites concrete company after temporary worker fatality inside PRCS (Failure to LOTO and $303,900)
  97. ASU’s (Air Separation Units) Nitrogen Fatality
  98. Calibrating and Testing Direct-Reading Portable Gas Monitors (OSHA Bulletin)
  99. OSHA cites concrete company for 10 violations after worker fatally engulfed in fly-ash silo
  100. Confined Space Rescue GUIDANCE that should be taken to heart (WorkSafe BC)
  101. Confined Space Isolation GUIDANCE that should be taken to heart (WorkSafe BC)
  102. OSHRC rules on "off-site" PRCS Rescue Services
  103. Trucking company cited by OSHA for asphyxiation hazards following worker fatality (PRCS and $113K)
  104. NFPA 350 - Preliminary Draft of Guide for Safe Confined Space Entry and Work is Open for Public Input
  105. OR-OSHA Alert: Confined Spaces – Winery Vessels
  106. OSHRC on Permit Required Confined Spaces
  107. Paint Maker Dies from Exposure to Methylene Chloride While Cleaning a Paint Tank (California FACE Report #11CA009)
  108. OR-OSHA Delays Construction CS Standards
  109. Not designed to be occupied (Oregon OSHA’s guide to confined space safety)
  110. Cal/OSHA Cites Employers for Worker’s Death in Confined Space
  111. Confined Space Barriers (video product demo)
  112. FREE PRCS video from NY Dept of Labor
  113. Worker & FF die in sewer manhole (NY-FACE)
  114. Large rolloff type TRASH COMPACTORS are PRCS's
  115. OSHA cites industrial cleaning contractor after worker dies while cleaning storage tank at a chemical manufacturer
  116. OSHA issues PRCS citations to Brewery ($88,000)
  117. Drowning in PRCS (TN-OSHA #24-2008)
  118. PRCS Fatality - acute heptane and toluene toxicity (TN-OSHA Fatality II #4 2010)
  119. Verifying rescue services are "available" BEFORE entry
  120. MSHA HAZARD ALERT - Working in Confined Spaces
  121. NIOSH investigation of Dairy Plant Inspectors and Permit Required Confined Space's
  122. 11 Serious and 2 willful violations regarding confined spaces
  123. The infamous Phoenix FD Toluene Tank PRCS Rescue Fatality
  124. Oregon OSHA - Adopted Changes for the Confined Space Standard
  125. Grain Bin Accidents Still a Major Problem, Says Safety Specialist
  126. How fast does my PRCS Rescue Service have to respond?
  127. Monitoring PRCS Atmospheres and Entrants Rights
  128. Discussing the three (3) criteria that makes a space a Confined Space
  129. PRCS Reclassification Flow Chart  Edit     CAUGHT IN THE GRAIN!
  130. February 6th, 2012 PRCS Fatality in 30" Pipe
  131. Confined Space Emergency Response: Assessing Employer and Fire Department Practices (Cal-Berkley)
  132. Is a Roll-Off Trash Compactor a PRCS?
  133. Important Confined Space Atmospheric Hazards Study
  134. Entering a Cone of Safety (PRCS Safety Tips)
  135. CS Ventilation Straight Edge Tool
  136. WorkSafeBC has amended their PRCS Std... all agencies need to do this
  137. Using 1910.146(c)(7) as your entry method into a Permit-Required Confined Space
  138. Using 1910.146(c)(5) as your entry method into a Permit-Required Confined Space
  139. OSHA explains their expectations for RESCUE from permit-required confined spaces (1910.146(k)
  140. CS Rescue... Tripods and Winches and a false sense of security
  141. Creating a Permit-Required Confined Space
  142. Would your rescue plans pass an OSHA Inspection?
  143. PRCS Fatality News Account
  144. PRCS Multiple Fatality Incident
  145. PLEASE EVALUATE your CS Rescue Service!
  147. Sweating the SMALL stuff in CS Entry can make a BIG difference
  148. CONFINED SPACE FATALITY – Oxygen Deficiency from Nitrogen Purge
  149. PRCS Multiple Fatality Incident - 1 entrant and 3 "would be rescuers"
  150. Why does Confined Space and High Angle Rescue go hand in hand?
  151. The MUST SEE confined space video - REAL LIFE TRAGEDY
  152. Testing a PRCS atmosphere VIDEO
  153. Confined Spaces: Test to Live
  154. No Escape: Dangers of Confined Spaces
  155. Retaining CS Entry Permits
  156. One MAJOR flaw in the use of Combustible Gas meters that ALL users should know
  157. Confined Space Non-Entry Rescue
  158. OSHA cites 5 companies for PRCS violations that lead to a dust flash fire and H2S exposures
  159. Using my local FD as my PRCS Rescue Team
  160. Entry vs. Non-Entry Rescue
  161. Important Confined Space Atmospheric Hazards - Study Do you think wood chips and logs in a ship container hold could produce an IDLH atmosphere?
  162. Does exceeding the PEL make the atm a hazardous atm?
  163. Reclassifying a permit required confined space
  164. Evaluating a Confined Space
  165. Confined Space Hazards that are to be considered
  166. Isolation for Reclassification of PRCSs
  167. Evaluating Confined Spaces
  168. Making sense of entry options under OSHA's PRCS Entry Std. 1910.146
  169. A Purdue University report showed 51 grain bin accidents last year

In my experience, I have found most older built cooling towers to be Permit-Required Confined Spaces (PRCS); however, some of the newer designs have addressed the hazards which make these units PRCS (e.g. guarding the fan and shaft within the unit) or these spaces may be eligible for reclassification using 1910.146(c)(7).  But this OSHA fatality inspection shows us that there are serious hazards within these units that MUST BE managed before entry...

OSHA cited a South Florida utility company and related contracting company after the agency’s investigation into the deaths of three workers who succumbed to toxic gases in a manhole on Jan. 16, 2017.  A 34-year-old pipe layer entered the manhole – a confined space – and quickly became unresponsive. A 49-year-old laborer entered the hole and attempted to rescue the first employee. After the second employee also became unresponsive, a 24-year-old equipment operator followed to help his fallen coworkers. All three men died. Post-incident atmospheric testing in the manhole revealed lethal levels of hydrogen sulfide and carbon monoxide. Two other employees and a volunteer firefighter were also exposed to the toxic gases in the manhole during rescue attempts but survived.

Here are the citations...

scale3This week I came across a perfect example to demonstrate how OSHA's recent 1926 Subpart AA - Confined Spaces in Construction can impact BOTH construction sites AND workplaces normally covered by General Industry Standards (1910).  A lot of businesses who deal with tanker trucks will have a "scale" for weighing these trucks.  This week while working at a clients facility I came upon a job where their scale was being replaced.  As shown below, the installation of this scale required workers to enter what is clearly a Confined Space; however, due to the nature of their work and the condition in the scale pit this space did not rise to the level of it being a Permit-Required Confined Space (PRCS). Thus most of 1926.1201-.1213 or 1910.146 did NOT actually apply in this situation; however, there is one requirement that did apply under BOTH standards...

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