Who Needs the PRCS Program?
I have a customer that has made the business decision to "farm-out" the task of routine cleaning of a dust collector to contractors. In my opinion it appears to be a Permit Required Confined Space. I endorse the decision.
Before they just wash their hands of the job I have advised them:
#1 Still their job to ensure the contractor is following OSHA and protecting their employees. Since their property they have a civil liability. They cannot just "farm that out"!
#2 Make known to the contractor all known hazards including items like SDS on chemicals present in the dust collector.
#3 Along with #2 post the proper the warning signage on the space as they themselves consider it a Permit Required Space.
#4 Although not required by OSHA since they do not have their employees enter the space, still consider a PRCS of their own. First, in case they do have to enter for repair or some other unforeseen task. Second, to understand the requirements and have them documented.
#5 Understand the recue techniques and methods of the contractor. Know the contractor's rescue plan!
What have I missed? Have I gone overboard? Thanks!
Comments (11)
Dust collection systems can be some dangerous confined spaces. I actually just did some confined space training last week at a facility in Tennessee who had a combustible dust explosion inside one of their baghouses a few years back - and they're still not back up and operating due to the damage.
In addition to the combustible dust hazard, you may have the potential for an inert space. Some facilities will purge dust collection systems and baghouses with an inert gas (e.g., nitrogen) to reduce the flammability hazard. However, in doing that, you create an IDLH atmosphere since it's close to 0% oxygen. Not sure if they do that at your site, but I'd ask just to be certain.
I'd imagine the host facility other confined spaces on their property, so if they do have PRCSs that they enter, then they'll have their own PRCS written program that they need to follow (in addition to the OSHA regs) and communicate to the contractor. The contractor will need to have their own PRCS written program, as well, so the contractor would need to follow whoever's program is more stringent.
Ultimately, even if the host facility doesn't enter any PRCSs whatsoever, they will still need to follow all of the requirements of 1910.146(c)(8), especially the post-entry debriefing.
Even if the host facility doesn't enter this PRCS, they still have OSHA requirements they have to meet - not just the civil liability part.
That space will most likely require an "entry-style" rescue (requiring a rescuer to enter the space to rescue them because non-entry rescue isn't feasible), so I'd highly recommend that they have someone trained in confined space rescue available on standby (NOT the fire department) to make a rescue.
Just found 1910.146(c)(8) and (c)(9) that helps too!!!
Definitely a permit required confined space. Farming out the work would still require review of their steps. Who is responsible or the contact person for rescue? Is it site provided or local fire department? Whats the phone #, have they called prior to entry to establish how much time they expect to be in there? Who will call them after the entry is complete?
Farming it out may solve part of the task, but you still have responsibilities to ensure it is being done to regulatory standards or better.