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:
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.
CHEMICAL or GAS LINES that are OPEN within the permit space MUST be isolated by such means as BLANKING OR BLINDING, MISALIGNING OR REMOVING SECTION OF LINES, PIPES, OR DUCTS, or a DOUBLE BLOCK AND BLEED SYSTEM.
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:
This is an AWESOME example how technology is IMPROVING process safety and personnel safety! Many thanks to KR for sharing this with us.
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.
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.