Experience Everything Compliance Network Has to Offer
Start Customizing Your Profile for Free!
Update to Professional Trial!
Already have an account?
YOU'RE ALL SET!
Enjoy your limited-time access to the Compliance Network Professional Trial!
A confirmation welcome email has been sent to your email address from ComplianceNetwork@t.jjkellercompliancenetwork.com. Please check your spam/junk folder if you can't find it in your inbox.
YOU'RE ALL SET!
Thank you for your interest in EnvironmentalHazmat related content.
You've reached your limit of free access, if you'd like more info, please contact us at 800-327-6868.
Copyright 2022 J. J. Keller & Associate, Inc. For re-use options please contact email@example.com or call 800-558-5011.
RegSenseConfined SpacesSafety & HealthConfined Space HazardsConfined SpacesGeneral Industry SafetyOccupational Safety and Health Administration (OSHA), DOLCompliance DocsStandard InterpretationEnglishFocus AreaUSA
The meaning of the word ''entrapment'' as in the Permit Required Confined Space (PRCS) standard.
Standard Number: 1910.146
October 8, 1993
Michael J. Shanshala
United Refining Company
Warren, Pennsylvania 16365
Dear Mr. Shanshala:
This is in response to your letter to John Stranahan, Area Director of the Erie Area Office. The letter was forwarded to us for response. In the letter you inquired whether an employee is considered "entrapped", as the word is used in the Permit Required Confined Space (PRCS) standard, if there is not an actual or potential asphyxiation hazard. The basis for the question is the wording in Footnote 7 in the Federal Register (Page 4476) in which the PRCS final rule was published. The Footnote could be read as inferring that "entrapment" occurs only when there is an actual or potential asphyxiation hazard.
OSHA considers "entrapment" to occur in any space that "has an internal configuration such that an entrant could be trapped or asphyxiated by inwardly converging walls or by a floor which slopes downward and tapers to a smaller cross section". The key word in the previous sentence is "or". Use of the word "or" makes it clear that the intent of the standard is that "entrapment" can occur with or without an asphyxiation hazard.
Employees "entrapped" in spaces that do not pose an actual or potential asphyxiation hazard are still subject to injury or death. An employee "entrapped" in a permit required confined space could become dehydrated or if they suffered a cut while becoming "entrapped", they could bleed to death.
Standards published as final rules are reviewed much more closely than preambles. Therefore, when there is a conflict between the preamble to a standard and the standard itself the standard normally takes precedence. That is the case in this situation.
If you require any additional information regarding this matter, please contact John McFee of my staff at (215) 596-1201.
LINDA R. ANKU
READ MORESHOW LESS
['Confined Space Hazards', 'Confined Spaces']
J. J. Keller is the trusted source for DOT / Transportation, OSHA / Workplace Safety, Human Resources, Construction Safety and Hazmat / Hazardous Materials regulation compliance products and services. J. J. Keller helps you increase safety awareness, reduce risk, follow best practices, improve safety training, and stay current with changing regulations.