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This guide is intended to help small businesses comply with the Confined Spaces standard. It addresses the most common compliance issues that employers will face and provides sufficient detail to serve as a useful compliance guide.  It does not, however, describe all provisions of the standard or alter the compliance responsibilities set forth in the standard, which is published at 29 CFR §§ 1926.1200-1213.  The reader must refer to the standard itself, which is available on OSHA’s website and in the Code of Federal Regulations, to determine all of the steps that must be taken to comply with the standard. 

Lets walk through a process in which we will isolate a PRCS using either the blinding/blanking or disconnect and misalignment provisions.  The vessel we will be entering is a PSM/RMP covered piece of equipment.  Here’s how I was taught the process works…

Since this is a PSM/RMP covered process we will be impacted by three key OSHA standards:
1910.147 - The control of hazardous energy (lockout/tagout)
1910.146 - Permit-required confined spaces
1910.119 - Process safety management of highly hazardous chemicals (specifically (f)(4)… opening process equipment or piping)

UPDATED 10/5/15, see bottom of page

Another common debate we like to have among our profession… When is entry rescue required and when is non-entry rescue required for entries into Permit-Required Confined Spaces?  Ask 10 safety professionals who are really into PRCS safety and I will bet you a burger and a beer that we will not get 100% agreement.  1910.146 language does not make this a cut & dried debate, so there is a lot of judgement to be made.  But here is my case that BOTH rescue means are REQUIRED with only an exception for non-entry rescue provisions… (NOTE:  the updates include language from OSHA's Confined Space Standard for Construction and its Preamble)

How many Confined Spaces do you see?

How many Confined Spaces signs would you use?

otm iv 5 II 14

You and your team are preparing to enter a PRCS and as the entry supervisor begins to review the permit, he/she explains the space is isolated and you notice the permit states "LOTO- N/A".  You inquire about this and ask about the isolation method(s) used for the entry.  The supervisor offers to show you the isolation  for the vertical 100,000 gallon storage tank and to walk-down the isolation with you.  The first pipe/line you come to is a 6” fuel discharge pipe and it is isolated using a disconnect and misalignment arrangement that rolled a 3’ spool piece down.  The next pipe you come is a 6” fuel inlet pipe and it is isolated using a disconnect and misalignment arrangement that rolled a 3’ spool piece down.  The third and last pipe is a 1” nitrogen pipe and it too is isolated using a disconnect and misalignment arrangement that rolled a 1’ spool piece down.  You notice that NONE of the three disconnect and misalignment arrangements were locked or tagged in their safe position.  When you ask about LOTO and where you and your team need to apply your LOTO lock(s), the entry supervisor says no locks needed.  Would you enter this tank?

SAFTENG members can CLICK HERE to download the WORD doc.


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