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I am not sure what transpired with this inspection, but the power plant was also cited for these same violations, but all their citations were DELETED and the penalty reduced to $0.00.  The citations below were to the contractor who was actually doing the work inside the space.  I am not sure, but I would find it hard to imagine that any contractor would have the skills or ability to "reclassify" a PRCS at any workplace.  But it appears the host employer somehow got out of all these citations and the contractor did not; at least that is what it looks like from the citations.

To: Metal and Nonmetal Mining Alliance Partners and Stakeholders

From: Neal H. Merrifield, Administrator for Metal and Nonmetal Mine Safety and Health Mine Safety and Health Administration

Re: Confined Space Entry Alert Unsafe work in confined spaces has led to miner deaths and injuries in the metal and nonmetal mining industry.

Recent tragic incidents include: a fatality while cleaning the inside of a tanker railcar and a miner being severely burned during maintenance inside a baghouse screw conveyor hopper. To address these regrettable occurrences and help prevent similar instances in the future, MSHA will be placing special emphasis on enforcing its standards related to entering bins, hoppers, silos, tanks, and surge piles. MSHA and the Industrial Minerals Association-North America (IMA-NA) have engaged the issue of confined spaces as a project within the Alliance between the two organizations. We recommend conducting a hazard assessment and implementing a permitting system as part of a safe entry standard operating procedure (SOP).

  1. MSHA's special initiative on Confined Spaces 
  2. Temporary Enforcement Policy for Residential Construction Work in Confined Spaces

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

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

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

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

  19. Why is 1910.146(j)(4) INVISIBLE in most every PRCS Entry Program/Procedure?
  20. On-Duty Firefighter Fatalities Involving Confined Spaces, 2003 – 2012 (NFPA Fire Analysis and Research Division)
  21. How do you comply with debriefing contractors after they exit your PRCS?
  22. OSHA issues PRCS Citations @ food tanker cleaning facility ($179K)
  23. Fatal Hotwork Explosion on Barge (USCG)
  24. Investigation of PRCS Flash Explosion and Injuries (BSEE)
  25. Labeling Permit Required Confined Spaces may not be as simple as some would believe
  26. OSHA issues PRCS citations after two workers died in Railcar with H2S
  27. WA-OSHA citations after worker, 19, dies inside "bark blower" truck
  28. UK’S HSE updates their “Safe work in confined spaces” Guidance
  29. OSHA PRCS citations involving Tanker Truck @ a producer and distributor of food products ($30K)
  30. OSHA PRCS citations involving Rail Car cleanout ($188K)
  31. OSHRC affirms PRCS citations (Preventing Unauthorized entry and Rescue)
  32. How can one argue that a large roll-off trash compactor is not a PRCS?
  33. Getting in is ALWAYS easier than getting out! (Video)
  34. OSHA cites a Grain Elevator for 1 willful, 2 repeat, 8 serious violations ($120,120)
  35. Safety Bulletin - Entry of a confined space on board a cargo ship resulting in three fatalities (Marine Accident Investigation Branch (MAIB)
  36. Oregon OSHA – Proposed Changes to Confined Spaces Standard for General Industry and Construction
  37. Volunteer Fire Fighter Dies During Attempted Rescue of Utility Worker From a Confined Space (NIOSH FACE)
  38. Confined Space Flash Fire (Tank NOT connected!)
  39. Cal/OSHA Cites an industrial service provider $82,090 for Accident in Confined Space that Seriously Injured Worker
  40. Off-Gassing Hazard from Wood Pellets and Chips (The Annals of Occupational Hygiene)
  41. OR-OSHA HAZARD ALERT: Confined Spaces – Winery Vessels
  42. OSHA cites concrete company after temporary worker fatality inside PRCS (Failure to LOTO and $303,900)
  43. ASU’s (Air Separation Units) Nitrogen Fatality
  44. Calibrating and Testing Direct-Reading Portable Gas Monitors (OSHA Bulletin)
  45. OSHA cites concrete company for 10 violations after worker fatally engulfed in fly-ash silo
  46. Confined Space Rescue GUIDANCE that should be taken to heart (WorkSafe BC)
  47. Confined Space Isolation GUIDANCE that should be taken to heart (WorkSafe BC)
  48. OSHRC rules on "off-site" PRCS Rescue Services
  49. Trucking company cited by OSHA for asphyxiation hazards following worker fatality (PRCS and $113K)
  50. NFPA 350 - Preliminary Draft of Guide for Safe Confined Space Entry and Work is Open for Public Input
  51. OR-OSHA Alert: Confined Spaces – Winery Vessels
  52. OSHRC on Permit Required Confined Spaces
  53. Paint Maker Dies from Exposure to Methylene Chloride While Cleaning a Paint Tank (California FACE Report #11CA009)
  54. OR-OSHA Delays Construction CS Standards
  55. Not designed to be occupied (Oregon OSHA’s guide to confined space safety)
  56. Cal/OSHA Cites Employers for Worker’s Death in Confined Space
  57. Confined Space Barriers (video product demo)
  58. FREE PRCS video from NY Dept of Labor
  59. Worker & FF die in sewer manhole (NY-FACE)
  60. Large rolloff type TRASH COMPACTORS are PRCS's
  61. OSHA cites industrial cleaning contractor after worker dies while cleaning storage tank at a chemical manufacturer
  62. OSHA issues PRCS citations to Brewery ($88,000)
  63. Drowning in PRCS (TN-OSHA #24-2008)
  64. PRCS Fatality - acute heptane and toluene toxicity (TN-OSHA Fatality II #4 2010)
  65. Verifying rescue services are "available" BEFORE entry
  66. MSHA HAZARD ALERT - Working in Confined Spaces
  67. NIOSH investigation of Dairy Plant Inspectors and Permit Required Confined Space's
  68. 11 Serious and 2 willful violations regarding confined spaces
  69. The infamous Phoenix FD Toluene Tank PRCS Rescue Fatality
  70. Oregon OSHA - Adopted Changes for the Confined Space Standard
  71. Grain Bin Accidents Still a Major Problem, Says Safety Specialist
  72. How fast does my PRCS Rescue Service have to respond?
  73. Monitoring PRCS Atmospheres and Entrants Rights
  74. Discussing the three (3) criteria that makes a space a Confined Space
  75. PRCS Reclassification Flow Chart  Edit     CAUGHT IN THE GRAIN!
  76. February 6th, 2012 PRCS Fatality in 30" Pipe
  77. Confined Space Emergency Response: Assessing Employer and Fire Department Practices (Cal-Berkley)
  78. Is a Roll-Off Trash Compactor a PRCS?
  79. Important Confined Space Atmospheric Hazards Study
  80. Entering a Cone of Safety (PRCS Safety Tips)
  81. CS Ventilation Straight Edge Tool
  82. WorkSafeBC has amended their PRCS Std... all agencies need to do this
  83. CS Rescue... Tripods and Winches and a false sense of security
  84. Creating a Permit-Required Confined Space
  85. Would your rescue plans pass an OSHA Inspection?
  86. PRCS Fatality News Account
  87. PRCS Multiple Fatality Incident
  88. PLEASE EVALUATE your CS Rescue Service!
  90. Sweating the SMALL stuff in CS Entry can make a BIG difference
  91. CONFINED SPACE FATALITY – Oxygen Deficiency from Nitrogen Purge
  92. PRCS Multiple Fatality Incident - 1 entrant and 3 "would be rescuers"
  93. Why does Confined Space and High Angle Rescue go hand in hand?
  94. The MUST SEE confined space video - REAL LIFE TRAGEDY
  95. Testing a PRCS atmosphere VIDEO
  96. Confined Spaces: Test to Live
  97. No Escape: Dangers of Confined Spaces
  98. Retaining CS Entry Permits
  99. One MAJOR flaw in the use of Combustible Gas meters that ALL users should know
  100. Confined Space Non-Entry Rescue
  101. OSHA cites 5 companies for PRCS violations that lead to a dust flash fire and H2S exposures
  102. Using my local FD as my PRCS Rescue Team
  103. Entry vs. Non-Entry Rescue
  104. Important Confined Space Atmospheric Hazards - Study Do you think wood chips and logs in a ship container hold could produce an IDLH atmosphere?
  105. Does exceeding the PEL make the atm a hazardous atm?
  106. Reclassifying a permit required confined space
  107. Evaluating a Confined Space
  108. Confined Space Hazards that are to be considered
  109. Isolation for Reclassification of PRCSs
  110. Evaluating Confined Spaces
  111. Making sense of entry options under OSHA's PRCS Entry Std. 1910.146
  112. A Purdue University report showed 51 grain bin accidents last year


THROUGH:  DOROTHY DOUGHERTY, Deputy Assistant Secretary

From:   JAMES G. MADDUX, Director, Directorate of Construction

Subject:  Temporary Enforcement Policy for Residential Construction Work in Confined Spaces

OSHA’s new Confined Space standard for Construction requires a “competent person” in two CRITICAL functions; I should also point out these two functions are also CRITICAL within the General Industry functions as well.  These include EVALUATING spaces and RECLASSIFYING a PRCS to a non-PRCS.

Evaluation of Spaces

1926.1203(a) Before it begins work at a worksite, each employer must ensure that a competent person identifies all confined spaces in which one or more of the employees it directs may work, and identifies each space that is a permit space, through consideration and evaluation of the elements of that space, including testing as necessary.  


1926.1203(f) When there are changes in the use or configuration of a non-permit confined space that might increase the hazards to entrants, or some indication that the initial evaluation of the space may not have been adequate, each entry employer must have a competent person reevaluate that space and, if necessary, reclassify it as a permit-required confined space.

Reclassification of a PRCS

1926.1203(g) A space classified by an employer as a permit-required confined space may only be reclassified as a non-permit confined space when a competent person determines that all of the applicable requirements in paragraphs (g)(1) through (4) of this section have been met:…

But does this mean that the same “competent person” who did the CS Evaluation(s) is also a “competent person” in the requirements to RECLASSIFY a PRCS to a non-Permit Space?

And it has begun... With OSHA's new Confined Space construction standard they stated in 1926.1203(a) that...

Before it begins work at a worksite, each employer must ensure that a competent person identifies all confined spaces in which one or more of the employees it directs may work, and identifies each space that is a permit space, through consideration and evaluation of the elements of that space, including testing as necessary.

OSHA was even kind enough to define the term "Competent Person". It means

one who is capable of identifying existing and predictable hazards in the surroundings or working conditions which are unsanitary, hazardous, or dangerous to employees, and who has the authorization to take prompt corrective measures to eliminate them.

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