As we know, 1910.146 gives employers three (3) methods to enter Permit-Required Confined Spaces:

1) Full permitted entry following (d)-(k),

2) alternative entry methods prescribed in (c)(5), and

3) reclassification of the PRCS to a non-permit space by following (c)(7).

However, in the past year or so we have come across another method… using BOTH (c)(5) AND (c)(7) on the same space at the same time. Questions:

1) Is this compliant with 1910.146?

2) Is this safe?

  1. Temporary Enforcement Policy for Residential Construction Work in Confined Spaces (1/2016)
  2. Real Life Accident: Chief Mate Dies From Asphyxiation
  3. Tough start for PRCS Fatalities into OSHA's 2016
  4. Confined Space Standards Side-by-Side Comparison Chart (OSHA Directorate of Construction)
  5. 2015 OSHA PRCS activity by Industry Sectors
  6. Employee Is Killed When Asphyxiated In Oil Storage Tank (PRCS - Issues with five minute escape pack)
  7. Scaffolder falls from height in a process vessel at a refinery - fatal
  8. NFPA 350, Table A.10.9.1 may be the MOST IMPORTANT Confined Space document published in 2015
  9. NFPA 350: Best Practices Guide for Safe Confined Space Entry and Work (Effective 12/4/15)
  10. Why OSHA states "entry" has taken place as soon as ANY PART of your body breaks the plane
  11. PRCS "program reviews" under 1910.146(13) & (14) (OSHRC decision)
  12. OSHRC decision on PRCS Tanker Truck Willfuls 
  13. IN-OSHA PRCS citations @ Power Plant inside pulverizer (Combustible Dusts $20K)

  14. MSHA's special initiative on Confined Spaces

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

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

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

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

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

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

dol logo

U.S. Department of Labor       

Occupational Safety and Health Administration

Washington, D.C. 20210


Reply to the attention of:

Jan 06 2016


THROUGH:   DOROTHY DOUGHERTY, Deputy Assistant Secretary

From: DEAN MCKENZIE, Acting Director Directorate of Construction

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

from official report from the Dutch Safety Board, May 2015

CLICK HERE (pdf) for full report in English

Two days before arriving in port, the Master received cargo documents from the shipper, which included an 11-page material safety data sheet (MSDS) on zinc concentrate. On receipt of the documents a safety meeting was held with the crew to discuss the cargo risks.  During the meeting, particular attention was paid to the use of personal protective equipment (full-vision goggles and respiratory particle filters) to protect against exposure to dust during loading. Although oxidation of the zinc concentrate, and thus its ability to reduce the oxygen content of a confined space, was indicated as a risk on the MSDS documentation, this risk was apparently not discussed during the safety meeting.  Loading commenced on arrival. The dust created during loading covered the ship’s deck and also found its way into the accommodation. A number of crew members experienced irritated airways and burning eyes as a result. The loading took less than a day and once completed the accommodation was cleaned of dust and the vessel left port.

Date of Incident  Employer/Address of Incident  Hazard Description  Inspection # 
12/4/15 Sulzer Chemtech USA Inc., 39018 Hwy 3089, Donaldsonville, LA  70346 Worker died from exposure to argon while retrieving tool from tank. 1110099
12/1/15 Alexander Petroleum, 612 County Rd.  326, West Jourdanton, TX  78026 Worker asphyxiated while cleaning tank that previously held Petroleum Distillate. 1109329
11/30/15 SPX Transformer Solutions Inc., Goldsboro, NC 27530 Two workers died from exposure to hazardous atmosphere inside transformer tank. 100368927
10/31/15 W.E. Soil Enhancement, Clyde, OH 43410

Worker asphyxiated by gases while pumping manure into tanker.

NOT 100% sure this was a CS accident

10/8/15 Dedicated Trailer Cleaning Services LLC, New Orleans, LA 70126 Worker died after cleaning interior of a rail car that had contained latex. 1098071



View 's profile on LinkedIn

  LinkedIn Group Button


 seminar logo white

I am doing my 1-Day

Process Safety Course

at ASSE's 2016 Seminar Fest

February 16, 2016


msc logo

I am presenting at the

2016 MI Safety Conference

"OSHA's Permit-Required Confined

Space Rescue  Requirements"

Tuesday, April 19, 2016

3:15 pm

DeVos Place
Grand Rapids, MI


OBWCtwitter Logo 400x400

I am presenting at the

2016 OH BWC Conference

"OSHA's Permit-Required Confined


Thursday, March 10, 2016
2:30 PM - 3:30 PM


ASSE 2016

I am presenting at the

2016 ASSE National Conference

Line Break and Process Opening

Best Practices

Session 720 on 6/29/16

7:45 - 9:00 a.m.



an unpaid endorsement


an unpaid endorsement


kemkey logo

an unpaid endorsement


 organdonor website reputation