OSHA Construction Standard For Confined Space Entry: Planning And Managing Industrial Painting Projects For Compliance

From JPCL, December 2015

By Alison B. Kaelin, CQA, ABKaelin, LLC, and Stanford T. Liang, CIH/CSP, AM Health and Safety

The authors will discuss the key details in OSHA’s recently issued Standard for Confined Spaces and describe ways in which contractors and owners can assure compliance and safety when working in confined spaces....

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Tagged categories: ABKaelin LLC; Certifications and standards; Compliance; Confined space; Health & Safety; Health and safety; OSHA; Regulations

Comment from B Brown, (1/27/2016, 7:18 PM)

My thank you to the authors. I knew the OSHA regulations had changed and have read 1910.146 hoping to learn what defines a Permit Required Confined Space (PCRS for those of you wondering what that undefined text logo might mean,) Can anyone explain that or do I have to contract Mr. Alison or Stanford to learn the answer that most basic question?????? Thank you all, BUBBA

Comment from B Brown, (1/27/2016, 8:25 PM)

My thanks to you the authors. I knew OSHA regulations had recently changed and I have read 1910.146 multiple times hoping to learn what defines a PCRS. (PCRS for those of you wondering what that undefined text/logo might mean) Maybe I should just relax. People have told me that before, "Just relax Bubba. We don't know either and if They come after us we will hire the cheapest attorney we can find, explain our problem and let them explain our confusion. Can anyone explain what now qualifies as a PCRS or do I have to contract Mr. Alison or Stanford to learn the answer to that most basic question?????? One more comment and this observation is not not explicit to this article. I have observed similar OSHA violations pictured in industry publications many times and sometimes on the cover of the publication! That fellow pictured crawling out of a manhole is probably exiting a 24" manhole. The size of the opening is OK but he is on a ladder that projects above the opening and blocks a portion of the hole with ladder rung restrictions. The problem is that the rules for ladder openings requires that there be 24" of clear space between the ladder and the entrant hand hold'rung/or opposite side of the opening in relation to the ladder rung. The ladder can not have more than 4" of obstruction between the centerline of any ladder rung and the obstruction on the rung below. Also, the top rung has to have a minimum of 2 1/2" clear space between that rung and the obstruction. These rules require that the distance between the ladder and any obstruction SHALL BE no less than 7" of toe space. That photo doesn't meet all of those rules. I am posting, hoping someone replies and hammers me for my ignorance. If not, please contact me at BUBBA@email.com. Maybe I have found a new consulting profession! Bubba/Confused/& Disappointed....

Comment from Alison Kaelin, (1/28/2016, 2:32 PM)

By definition, a confined space: Is large enough for an employee to enter fully and perform assigned work; Is not designed for continuous occupancy by the employee; and Has a limited or restricted means of entry or exit. These spaces may include underground vaults, tanks, storage bins, pits and diked areas, vessels, silos and other similar areas. By definition, a permit-required confined space has one or more of these characteristics: Contains or has the potential to contain a hazardous atmosphere; Contains a material with the potential to engulf someone who enters the space; Has an internal configuration that might cause an entrant to be trapped or asphyxiated by inwardly converging walls or by a floor that slopes downward and tapers to a smaller cross section; and/or Contains any other recognized serious safety or health hazards. Regarding the photos, these are stock photos selected by JPCL. They were not intended address ladders or other items. I appreciate your review and identification of the issues associated with the photo. This will hopefully help others avoid similar issues.

Comment from Thomas Van Hooser, (6/17/2016, 8:36 AM)

Very good explanations

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