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?

Many of you that followed my incident alerts may remember the transformer manufacturer that had a fatal PRCS accident that killed two workers and left a third injured back at the end of 2015. The three people were working on a transformer in the plant and were found unresponsive. Unofficial sources said the transformer was an 8×12 unit. The Sheriff's office investigating said the first person was working inside the transformer and became unresponsive. The second and third workers entered the transformer to help the first worker and then became unresponsive. Two of the workers were pronounced dead. The third worker was taken to the hospital. OSHA has now issued their seven (7) serious citations ALL related to 1910.146...

The state of Washington's OSHA has published their DRAFT standard on Confined Spaces.  The standard pretty closely mirrors federal OSHA's 1926.1201-.1213; however, the OSHA standards in WA must be written in a much more simplified manner, thus we end up with a standard that is easier to read and WA-OSHA does an EXCELLENT job explaining the requirements with their "Summary" in each section and the special NOTES they post through out the standard.  They have also made some things more clear... for example, in their definition of a confined space they use the phrase "Not primarily designed for human occupancy" vs. "Is not designed for continuous employee occupancy" as found in Federal OSHA's definition.  For those in facilities that really want a well explained standard, this is a MUST READ.  CLICK HERE

An elevator superintendent, 41, suffocated when his lifeline tangled in an unguarded and rotating auger. OSHA investigators determined three workers, including the elevator superintendent, had been standing over the unguarded auger using a pole in an attempt to dislodge soybean debris in a grain bin that contained more than 50,000 bushels of soybeans sloped 12 to 20 feet up its walls.  A federal investigation into the worker's death found multiple violations of federal safety standards for grain handling at the facility.  On Sept. 9, 2016, OSHA issued three (3) egregious willful and three (3) serious violations following its investigation of the March 16, 2016, death. From 2011 to 2015, federal inspectors cited the Nebraska farmer-owned cooperative and joint venture six times for violating grain-handling safety standards.  The agency has placed the company in its Severe Violator Enforcement Program.  OSHA has proposed penalties of $411,540. View current citations below...

The company specializes in the cleaning of gasoline and gasoline tanks for gasoline retailers. On December 30 and 31, 2014, OSHA’s Compliance Officer (CSHO) conducted an inspection following a fatal accident at that worksite. An employee died after being found unresponsive at the bottom of a well containing a submersible turbine pump (STP) at a retail store under construction. Based upon the CSHO’s inspection, the Secretary of Labor, on May 14, 2015, issued a Citation and Notification of Penalty with three items (with subparts) alleging serious violations of 29 C.F.R. § 1910.23(a)(6) for failure to guard an open manhole; various subparts of § 1910.134 for deficiencies in its respirator program; and various subparts of § 1910.146 for failure to protect its employees from hazards associated with confined spaces. The Secretary proposed a total penalty of $13,600.00 for the Citation. Company timely contested the Citation. All of the violations are at issue.

Back in March of this year a major manufacturer of nitrogen and anhydrous ammonia had its second PRCS fatality in a four (4) month span.  Both of these incidents, as reported in the Incident Alerts, were construction-related permit-required confined space incidents.  NOTE: the first accident happened at their LA facility in December 2015 and resulted in two (2) serious citations for $14,000 and both have been contested.  OSHA just now closed out their investigation/inspection on this second fatality (in IA) and initially cited the contractor $203,000 under the relatively new Confined Spaces for Construction; the contractor had seven (7) citations deleted/vacated at their informal meeting so the case stands at 21 citations and $185,000.  I am not quite sure why this case did not warrant a press release or why this contractor has not been placed in the SVEP, but none the less here are the citations as they stand today...

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