Fatality Alert: Confined Spaces

Accident Type: Confined space

Type of Operations: Unloading rail car

Competent Safety Monitor on Site: No

Was the Worksite Inspected Regularly: No

Training and Education Provided: No

Employee Job Title: General Labor

Length of Employment: 4 months

Experience at this Type of Work: 15-20 times previously

Time on Task: 45 min

Environmental /Geographic Conditions: Confined Space

Screen Shot 2017 01 21 at 10.06.53 PM

Brief Description of Accident:

This Alert highlights the risks associated with maintenance work in a confined space, such as a storage tank that has an internal floating roof, and suggests control measures to address these risks.

Background

In a recent incident at a major hazard facility (MHF), the internal floating roof of a storage tank collapsed down to the support leg stop position while a maintenance task was being carried out. The support leg stop position is designed to support the internal floating roof at a predetermined rest height just above the storage tank floor.  

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

  2. Permit-Required Confined Spaces and Exposure Records Retention

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

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

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

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

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

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

  9. OSHA cites contractor under new Construction Confined Space Standard

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

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

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

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

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

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

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

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

  19. 2016 Ohio BWC PRCS Rescue Presentation (1910.146(k)

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

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

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

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

  24. Temporary Enforcement Policy for Residential Construction Work in Confined Spaces (1/2016)
  25. Real Life Accident: Chief Mate Dies From Asphyxiation
  26. Tough start for PRCS Fatalities into OSHA's 2016
  27. Confined Space Standards Side-by-Side Comparison Chart (OSHA Directorate of Construction)
  28. 2015 OSHA PRCS activity by Industry Sectors
  29. Employee Is Killed When Asphyxiated In Oil Storage Tank (PRCS - Issues with five minute escape pack)
  30. Scaffolder falls from height in a process vessel at a refinery - fatal
  31. NFPA 350, Table A.10.9.1 may be the MOST IMPORTANT Confined Space document published in 2015
  32. NFPA 350: Best Practices Guide for Safe Confined Space Entry and Work (Effective 12/4/15)
  33. Why OSHA states "entry" has taken place as soon as ANY PART of your body breaks the plane
  34. PRCS "program reviews" under 1910.146(13) & (14) (OSHRC decision)
  35. OSHRC decision on PRCS Tanker Truck Willfuls 
  36. IN-OSHA PRCS citations @ Power Plant inside pulverizer (Combustible Dusts $20K)

  37. MSHA's special initiative on Confined Spaces

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

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

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

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

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

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

OSHA responded to a report of unsafe working conditions May 17, 2016, after two employees lost consciousness and collapsed. The workers were exposed to hazardous gas while entering a sewer system. OSHA investigators found the company allowed the workers inside a confined space without having tested the space for hazards. OSHA issued citations for six serious violations and one willful violation. The agency also cited the company for failing to maintain gas testing meters and rescue equipment, and for not training all employees in confined space entry. OSHA proposed penalties of $152,147. Here is the breakdown of the citations:

OSHA has long stated that "entry permits" which contain exposure data MUST be maintained per 1910.1020.  However, this requirement seems to not be well understood.  It seems we find companies that prohibit entry into any hazardous atmosphere are keeping warehouses full of closed entry permits and those companies that are actually entering hazardous atmospheres are throwing out their permits after their annual review.  So what is the actual requirement?

 
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