Are Semi-Trailers Permit-Required Confined Spaces

Permit-required confined spaces aren’t just sewer pipes. Semi-trailers can be hazardous too. Hear about hazards in three trailer types, empty and loaded.

In this 3½ minute podcast, Dan Clark describes OSHA’s standard on PRCS (permit-required confined spaces) for big-rigs.

Dan also defines confined spaces (CS), and offers tips on CS and PRCS programs for safety managers.


TRANSCRIPT:

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intro music and effects

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Dan Clark: When you think of confined spaces in the workplace, a truck probably isn’t the first space that comes to mind. Semi-trailers, though, can be confined spaces in certain situations. In some cases they can even be permit-required confined spaces. We’ll stare down the throat of this not-so-obvious safety issue next.

Hello I’m Dan Clark with The Safety Brief. We go toe-to-toe with health and safety hazards in today’s unpredictable industrial and construction worksites brought to you by creativesafetysupply.com. Hey, slice 10 percent off your web order with coupon code BIG10.

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OSHA’s picky about tanks, storage bins, tunnels, sewers, silos, closets and cubbyholes. They’re confined spaces. Semi-trailers can be just as dangerous to workers. They can be considered confined spaces or permit-required confined spaces.

THE OSHA STANDARD. Well, lets see. What’s up with these two designations?

CONFINED SPACE, or CS:

• It’s a space large enough for a person to enter and perform work;
• Has limited or restricted entry and exit; and
• Isn’t meant for continuous occupancy

(1:17)
PERMIT-REQUIRED CONFINED SPACE, or PRCS. Has all of the above, plus:

• A hazard. Examples:

○ A hazardous atmosphere;
○ The chance of material engulfing a worker;
○ Walls or floors that slope inward and could trap someone;
○ Risk of electrocution;
○ Unguarded machinery; and more.

TYPES OF SEMI-TRAILERS AND THEIR RISKS. Let’s look at the three types and how they rank when they’re empty and loaded.

1. Open top semi-trailers.

• When empty, they are confined spaces if there’s no open exit door or other means of getting out of there.
• When carrying a load such, as soil, sand or wood chips they are permit-required confined spaces. The hazard is present. The contents could engulf a person.

Are_Semi-Trailers_Permit-Required_Confined_Spaces-Creative_Safety_Supply-250x375(2:04)
2. Semi-trailers with a normal configuration of doors at the back.

• When empty, they are not confined spaces if the doors are secured open. If the doors are closed they are confined spaces.
• When carrying a load, it depends on the contents. If what’s inside presents a hazard in any way, the semi trailer could be considered PRCS.

3. Tank trailers. Let me poke my head in one here.

• When empty, they are confined spaces. Always. At a minimum. Yes, there is a hatch here but it’s no quick means of exit.
• When carrying a load, they could be PRCS if the contents could create a hazard. Hazards include someone being engulfed, a hazardous atmosphere, and more.

(2:51)
SO, WHAT’S A MANAGER TO DO?

Have a confined spaces and permit-required confined spaces program. This should include:

• Identifying and labeling semi-trailers as CS or PRCS;
• Having rules for going into these spaces; and
• Doing confined space training with the workers.

For more detailed info about PRCSs, listen to our podcast titled “Permit-Required Confined Spaces” at thesafetybrief.com. It’s linked in the transcript of this episode.

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That’s a wrap on this podcast, Are Semi-Trailers Permit-Required Confined Spaces? Come back to stay safe and safety compliant in today’s turbulent world of safety requirements. I’m Dan Clark of The Safety Brief, a presentation of Creative Safety Supply. Shave 10% off your entire order at creativesafetysupply.com with bonus coupon BIG10.

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END

Semi-trailers and agents images 2010 by U.S. Customs Border Protection / Donna Burton; Tank trailer 2010 by U.S. Dept. Of Energy

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