For those who have been adamant and faithful followers of 1910.146, know that the standard requires the Entry Supervisor to verify rescue services are available and that the means for summoning them are operable BEFORE he/she signs the entry permit and allows entry to begin.  Although we get a lot of push back on this, as many people do not believe this is actually required for EACH ENTRY, here is the actual wording...

Permit-required confined spaces can present conditions that are immediately dangerous to workers’ lives or health if not properly identified, evaluated, tested and controlled. OSHA has developed a standard for Confined Spaces in Construction (29 CFR 1926 Subpart AA) for any space that meets all of the following criteria:

  • Is large enough for a worker to enter;
  • Has limited means of entry or exit; and
  • Is not designed for continuous occupancy.

One provision of the standard requires employers to develop and implement procedures for summoning rescue or emergency services in permit-required confined spaces. An employer who relies on local emergency services for assistance is required to meet the requirements of §1926.1211- Rescue and emergency services. OSHA recognizes that not all rescue services or emergency responders are trained and equipped to conduct confined space rescues. When employers identify an off-site rescue service, it is critical that the rescuers can protect their employees. The emergency services should be familiar with the exact site location, types of permit-required confined spaces and the necessary rescue equipment.

I have written several times now about OSHA’s new Construction Standard for Permit-Required Confined Spaces and how this new standard clarifies several aspects regarding the General Industry Standard 1910.146. But one requirement I continue to get push back on is the fact that ENTRY-STYLE Rescue is REQUIRED for ALL “permitted entires” in both Construction and General Industry. It seems that 1926.1204(i) is the requirement so many want to slice and dice to meet their needs against my better judgement…

A food cannery faces $143,550 in federal penalties after a worker, 35, fell more than 17 feet into an empty sauerkraut vat and broke multiple bones. The inspection that followed was the fourth time since 2011 that OSHA has cited the company for failing to protect workers from fall and machine hazards. On April 13, OSHA issued one willful, two repeat, five serious and one-other-than serious safety violations after the Oct. 27, 2015 injury inspection. The agency found similar violations at the facility in 2013 and 2015. Here is a breakdown of the PRCS citations (as well as the others):

These citations are the FIRST OSHA citations using 1926.1201-1213, OSHA’s confined space in constructionOSHA’s confined space in construction standard.  It is IMPORTANT to point out these citations involved work at a waste-water treatment plant (WWTP) which is normally a workplace that would fall under OSHA's GENERAL INDUSTRY standards; however, the work being done INSIDE the 54" pipe was CONSTRUCTION WORK.  This case also involved sub-contractors who were also cited for PRCS issues.  This inspection came about because a worker, 42, was leak testing joints inside a 54-inch round pipe and suffered fatal blunt force injuries in October 2015, when an inflatable “bladder” ruptured.  Here is a breakdown of the 1926.1201-1213, OSHA’s confined space in construction standard citations:

PLEASE pay particular attention to the citations regarding RESCUE from this 54" pipe!

  1. OSHA PRCS citations @ railcar cleaning facility (O2 Deficiency & $226K)

  2. OSHA PRCS Citations @ food plant (Acetic Acid/Vinegar & $79K)

  3. 2016 Ohio BWC PRCS Rescue Presentation (1910.146(k)

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

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

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

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

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

  21. MSHA's special initiative on Confined Spaces

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

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

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

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

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

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