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This is sort of a slippery slope for both us and OSHA to walk.  It is clearly a requirement when contractors enter our Permit Required Confined Spaces (PRCS), but how do we demonstrate that we are indeed “debriefing” these contractors as required by 1910.146(c)(8)(v)?  What do we have on hand that can show all entries involving contractors involved a “debrief” at the conclusion of entry operations.  Several years ago I explained the reason why OSHA requires this debrief and the responses were all over the place; from I was crazy and OSHA never requires such a thing to “Wow, I guess we are not so thorough as I thought”.  This article is about how we can easily DOCUMENT our “debriefs” after each entry…

Employees risked potentially lethal suffocation caused by dangerous fumes as the company did not test the atmosphere and properly ventilate the air in food transport tankers before allowing workers to enter. After receiving an employee complaint, OSHA initiated an investigation on Aug. 6, 2014, at the tank-cleaning facility. The agency issued two willful and six serious safety violations involving permit-required confined spaces and fall hazards. The agency proposed fines of $179,000.  OSHA's investigation found that the facility did not ventilate the tankers to eliminate and control atmospheric hazards and failed to test and monitor the atmospheric conditions in the tankers before allowing workers to enter and clean them. Employees were also exposed to fall hazards of nearly 11 feet while cleaning the tankers, resulting in the issuance of the two willful violations. OSHA regulations require that the atmosphere in a confined space must be tested for oxygen, combustible gases, toxic gases and vapors. A confined space is one large enough for workers to enter and perform certain jobs, such as cleaning a food transport tanker, but it has limited or restricted means for entry or exit and is not designed for continuous occupancy.  The agency determined that the facility failed to develop a confined space entry permit program to include training workers on hazards, procedures for summoning emergency services and providing monitors when an employee entered a confined space. Electrical safety violations were also noted. A total of six serious citations were issued for these violations.  Here is a breakdown of the citations:

This fatal Hotwork Incident is a reminder of the dangers of welding inside Confined Spaces, ESPECIALLY those that contained a flammable liquid or gas!  The USCG did an excellent job with this investigation and report, laying out the timeline and facts leading up to this incident that caused this incident to occur.  It is a MUST read for those who permit HW activities within confined spaces.

2013.11.04 - Enclosed Space Flash Explosion Onboard Offshore Platform - Investigation Report Figure 6This incident information refers to an accident that occurred onboard an offshore platform in the Gulf of Mexico during maintenance and repair operations to clean several production vessels, including a high-pressure separator, the floatation cell, the wet-oil tank, and two stacked low-pressure separators, upper and lower. A flash fire ignited within one of the vessel’s causing injuries to four crew members.

Confined space warning 01Right after doing our site assessment, OSHA says that we must identify those spaces that are deemed to be Permit Required Confined Spaces.  Many facilities order hundreds of signs to put on their spaces at a pretty penny… in other words it ain’t cheap to label these spaces!  So one would think that the labeling/marking would be done properly.  Take the image to the left… anyone see anything wrong with this picture?  Think in a futuristic way…   As shown in the photo, most PRCSs are labeled with a sign on the access way covering.  Everything from a hatch door, manway lid, etc. we tend to put the DNAGER sign directly on the access way cover.  As it sits as shown in the photo we have no issue, but what happens when the tank is prepped for entry and the access way covering is opened/removed?  Now we have an OPEN PRCS without any identification as such; a serious unsafe condition, as well as a failure in compliance.

Lets take a look at what OSHA’s 1910.146 says about identifying PRCSs and preventing unauthorized entry into PRCSs.

Two workers were killed while cleaning rail cars and were exposed to a dangerous amount of hydrogen sulfide gas.  The primary cause of death of both employees was closed space asphyxiation and hydrogen sulfide intoxication, a byproduct of the residual organic waste contained in the tank. OSHA determined that neither victim was equipped with an emergency retrieval system before they entered the car. As a result, the liquid animal feed manufacturer has been placed in OSHA’s Severe Violator Enforcement Program.  

Facility also failed to:

  • complete a permit-required confined spaces entry permit
  • use testing and monitoring equipment to evaluate the permit space condition prior to entry; and
  • require employees to use rescue and emergency equipment.

OSHA also found the company failed to:

  • designate trained rescue employees
  • use a retrieval system attached to the worker to aid in rescue
  • train workers and place warning signs about hazards that may be encountered in confined spaces; and
  • ensure rail tank cars had been ventilated prior to entry

OSHA has proposed fines totaling $266,000.  Here is a breakdown of the citations:

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