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

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

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

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

  5. 2016 OSHA PRCS activity by Industry Sectors

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

  7. Confined Space Fatality Alert - Unloading rail car

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

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

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

  11. Permit-Required Confined Spaces and Exposure Records Retention

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

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

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

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

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

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

  18. OSHA cites contractor under new Construction Confined Space Standard

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

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

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

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

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

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

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

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

  28. 2016 Ohio BWC PRCS Rescue Presentation (1910.146(k)

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

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

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

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

  33. Temporary Enforcement Policy for Residential Construction Work in Confined Spaces (1/2016)
  34. Real Life Accident: Chief Mate Dies From Asphyxiation
  35. Tough start for PRCS Fatalities into OSHA's 2016
  36. Confined Space Standards Side-by-Side Comparison Chart (OSHA Directorate of Construction)
  37. 2015 OSHA PRCS activity by Industry Sectors
  38. Employee Is Killed When Asphyxiated In Oil Storage Tank (PRCS - Issues with five minute escape pack)
  39. Scaffolder falls from height in a process vessel at a refinery - fatal
  40. NFPA 350, Table A.10.9.1 may be the MOST IMPORTANT Confined Space document published in 2015
  41. NFPA 350: Best Practices Guide for Safe Confined Space Entry and Work (Effective 12/4/15)
  42. Why OSHA states "entry" has taken place as soon as ANY PART of your body breaks the plane
  43. PRCS "program reviews" under 1910.146(13) & (14) (OSHRC decision)
  44. OSHRC decision on PRCS Tanker Truck Willfuls 
  45. IN-OSHA PRCS citations @ Power Plant inside pulverizer (Combustible Dusts $20K)

  46. MSHA's special initiative on Confined Spaces

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

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

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

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

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

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

No fewer than 60 fatal and non-fatal cases were documented in 2016. Of these, 30 (50%) were fatal and 29 (48%) of those cases were directly related to grain entrapments. In addition to the cases documented in 2016, cases that occurred in previous years continue to be added to the database due to ongoing discovery efforts. The total number of cases documented between 1962 and 2016 and entered in the PACSID is 1,935. Of those, 1,187 cases (61%) were reported as fatal and 1,432 (74%) involved grain storage and handling facilities. As noted in past summaries, the data presented do not account for all incidents involving agricultural confined spaces. There is no accumulative public record of these incidents due to the fact that there is no comprehensive or mandatory incident/injury reporting systems for most of agriculture; in addition, there has been reluctance on the part of some victims and employers to report non-fatal incidents, especially at farms, feedlots and seed processing operations. It is estimated that approximately 30% of cases go unreported.  CLICK HERE for the 2016 Report

The IRSST (Canada) just published a new research report to contribute to confined space accident prevention by helping companies apply existing regulations. Researchers wanted to gain a better understanding of confined space risk management and identify issues based on the literature and field observations, and develop a confined space risk analysis and work categorization tool that meets the needs defined in the first stage of the project.  This study provides support for designers, safety officers and rescuers in their respective efforts to improve the health and safe working conditions of people who must enter confined spaces. The tool can be used to design a confined space or to assess an existing one.

So what exactly does OSHA mean when they say...

Develop and implement the means, procedures, and practices necessary for safe permit space entry operations, including, but not limited to, the following:
1910.146(d)(3)(iii) Isolating the permit space

It is not uncommon to find spaces entered with NO isolation of the space and there tends to still be some "behind scene" arguements/debates as to just how does a PRCS have to be "isolated".  Here is what OSHA stated back in 1993 (emphasis added by me)

The term "isolation" means:

the process by which a permit space is removed from service AND completely protected against the release of energy and material into the space by such means as: blanking or blinding; misaligning or removing sections of lines, pipes, or ducts; a double block and bleed system; lockout or tagout of all sources of energy; or blocking or disconnecting all mechanical linkages.

The permit space MUST be ISOLATED from serious hazards. For example, if ENERGIZED PARTS OF ELECTRIC EQUIPMENT ARE EXPOSED, the circuit parts must be deenergized and locked out in accordance with section 1910.333(b). MECHANICAL EQUIPMENT posing a hazard within the space must be locked out or tagged in accordance with section 1910.147 or guarded in accordance with Subpart O of the General Industry Standards.



Source:  OSHA PRCS Preamble


PLEASE see my other articles on PRCS Energy Isolation





Back when OSHA was writing their Permit-Required Confined Space standard (1910.146) their review of accident data indicated that most confined space deaths and injuries were caused by atmospheric hazards.  And yet, still today, we see entrant, attendants, and entry supervisors; and even safety personnel, not understanding the atmospheric hazards associated with PRCSs.  I hope to shed some light on these hazards and the rationale OSHA used when writing the standard with regards to the hazards found in PRCSs.  

Here is a look at OSHA's Permit-Required Confined Space (PRCS) compliance activity in 2016 (October 2015 - September 2016). As you can see, OSHA did 192 PRCS inspections (↓) and issued 435 citations (↓) for a total of $1,285,302 in fines (↓). 2015 numbers were 206 inspections; 545 citations; and $1,435,301.  This is the SETTLED amount and NOT the initial citations. Here is a quick breakdown of activity:

  • NAICS Code: 311 / Food Manufacturing was #1 in # of citations with 44
  • NAICS Code: 562 / Waste Management and Remediation Services was #1 in $'s with $253,149
  • NAICS Code: 311 / Food Manufacturing was #1 in # of inspections with 22

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