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I do not work on construction sites so I have not been following the roll-out of OSHA Confined Space standard for the Construction Industry (1926.1200) all that closely.  But my phone has not stopped ringing with clients who have received a ton of advertising about how this “new OSHA rule will impact you”.  Some of this literature is just disgusting in how it misleads an unsuspecting manager who wants to do the right thing.  But as I began to research some of these claims I did take notice that this new CS standard for construction can be a glimpse into OSHA’s 2nd attempt at writing a CS standard and some of the new definitions and requirements should be included in our general industry program(s). 

Let’s look at some of these requirements:

OSHA has announced their Information Collection Activities; Submission for OMB Review; Comment Request; Permit-Required Confined Spaces in General Industry Standard.  Some of these announcements have some interesting tid-bits in them.  This PRCS announcement listed all the documentation one would need to fully comply with 1910.146.  Most of us could list many of these items, but some may not come to mind until you read them in OSHA's posting...

The Technical Committee has completed the second draft revisions and, absent any Notice of Intent to Make a Motion (NITMAMs), the new guide will be released this coming November!  This document explains  “how to” comply with provisions in the existing confined space regulations and standards by providing more detailed guidance on subjects such as

  • hazard identification,
  • air monitoring,
  • ventilation and
  • rescue.  

You can stay on top of what is happening with NFPA 350 by signing up for email alerts at www.nfpa.org/350.

Articles on Confined Space Entry and Rescue

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

As the debate rages on regarding rescue services, there is ONE LITTLE SIMPLE requirement that would STOP ALL entries before rescue services are VERIFIED to be “available”…

1910.146(j) Duties of entry supervisors. The employer shall ensure that each entry supervisor:

...

1910.146(j)(4) Verifies that rescue services are available and that the means for summoning them are operable;

This Entry Supervisor REQUIREMENT could not be any more clear… it is their JOB (and SOLELY their job) as Entry Supervisor to VERIFY that what ever rescue service they plan to use (on-site vs. offsite) the service/team is available and the means the attendant will use to summon them to the space is “operable”. 

What does this actually mean?

Seven (7)  incidents were found in a search for firefighter fatalities involving confined spaces.  Eight firefighters were killed in these seven incidents.  The victims were not necessarily in the confined spaces when fatally injured. Five of the seven incidents were investigated by the National Institute for Occupational Safety & Health (NIOSH). The investigation summaries and links to the complete investigation reports are shown here.

 
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