Screen Shot 2017 05 31 at 10.41.14 PMA miner entered a feed hopper to remove bolts on the skirt board. When he heard a bull dozer that typically pushes material into the hopper approaching, the miner tried to escape through the opening at the bottom of the hopper. The bull dozer pushed material into the hopper, unaware that the miner was inside, burying him up to his chest. It took emergency services approximately two hours to extricate the miner.  The accident occurred in March 2017.

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

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

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

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

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

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

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

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

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

  10. 2016 OSHA PRCS activity by Industry Sectors

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

  12. Confined Space Fatality Alert - Unloading rail car

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

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

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

  16. Permit-Required Confined Spaces and Exposure Records Retention

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

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

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

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

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

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

  23. OSHA cites contractor under new Construction Confined Space Standard

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

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

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

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

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

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

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

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

  33. 2016 Ohio BWC PRCS Rescue Presentation (1910.146(k)

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

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

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

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

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

  51. MSHA's special initiative on Confined Spaces

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

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

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

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

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

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

On May 4, 2015, OSHA issued a new standard for CONSTRUCTION WORK IN CONFINED SPACES, which became effective August 3, 2015. This is a summary of OSHA activity for this new standard during the period October 2015 through September 2016. Penalties shown reflect current rather than initial amounts. For more information, see definitions.

1926.1203 - General requirements

PLEASE NOTE: This article may contain grammar errors, as this is my response to the more than 60 messages I received in the past seven days regarding last week's article When contractors enter a host's PRCSs (1910.146(c)(8)(iii).   I have put this together tonight so as to not keep any of those who contacted me waiting any longer. If you find an error, please be a friend and point it out to me and I will correct ASAP.  As I told many of you who contacted me, that article was not about any one particular facility; and based on the number of you who thought I was using your case as an example shows how widespread the issue/concern just is.  This article is intended to answer a lot of the questions/challenges I received regarding a contractor being responsible for the rescue aspect of their entry into a Host's PRCS.

Screen Shot 2017 05 13 at 10.01.40 PM

A fatal incident occurred when an Assistant Driller (AD) placed his head and an arm into a platform drilling rig’s vertical Mud/Gas Separator (MGS) through its inspection hatch, while performing the assigned, but non-routine task of removing built up and hardened material from inside the MGS.  A BSEE Panel investigation identified a number of established Safe Work Practices (SWPs) that, if followed, should have prevented the task from proceeding in the manner in which it occurred. The contaminating material, believed to be cement, had already begun to cure and harden inside the MGS when it was discovered. The decision was made to attempt to remove the material, and supervisors authorized the task without understanding of the extent of the buildup.

What obligations does the host employer have when they hire a contractor to work within one of their Permit-Required Confined Spaces (PRCS)? The answer seems to be all over the map, depending on the industry where the space is located, the size of the company, the company’s written program, etc. This article is intended to help make sense of what should be happening when a contractor is hired to enter a PRCS on a host employer’s site. I am using 1910.146 and 1926.1201-.1213, as well as 1910.147, as my basis for my discussion.

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