Permit Required Confined Space

What are Confined Spaces? TAS can assist with Confined Space Entry (CSE) and Confined Space Rescue (CSR).

Confined Spaces Dallas-Fort Worth Texas

Many workplaces have areas that meet OSHA’s definition of “confined spaces” – although certain confined areas are not necessarily designed for people, they are large enough for workers to enter and perform certain jobs. A confined space also has limited means for entry or exit. These spaces include areas such as tanks, vessels, vaults, silos, storage bins, silos, hoppers, silos, manholes, pits, tunnels, equipment housings, ductwork and pipelines. There may be other examples in your workplace.

When there are additional hazards present, OSHA elevates them to a category of a “permit-required confined space” (permit space). This standard is used to describe a confined space that has other hazards which can have some of the following characteristics: containing or can have or potentially have a hazardous atmosphere. The space can also contain material that may be able to engulf an entrant; has inwardly converging walls or floors that have a downward slope and tapers into a smaller area that may trap or asphyxiate an entrant, an example of this is a silo with a cone bottom (sand, grain, etc..). Other recognized hazards can include exposed live wires, piping into the space that may have liquid or a gas, unguarded machinery or additional machinery that has a hazard requiring locking out of potential energy sources (LOTO).

Confined Space Entry & Rescue

Environmental hazards can also be a factor. Heat stress of the area due to the type of space entered. Boilers, ovens, kilns or areas that lack air flow can contribute to heat stress. The environmental hazard coupled with the need to wear proper PPE all contribute to the added hazard of heat stress for the worker.

Confined Space Safety

Another environmental hazard is the weather. Rain and lightning are examples that may trigger the removal of all entrants from the confined space or the cancellation of a permit. Working in a space that is prone to filling with storm water may be a hazard from rain events several miles upstream. Lightning is a real hazard. For example, working an entry in a tank that previously contained a flammable substance creates an additional hazard that would prohibit entry during a forecasted lightning event.

Stand by Rescue

Off-site rescue service or EMS responders may satisfy the regulatory requirement for rescues but often present significant disadvantages of unrealistic response times. The response time is a collection of factors. Drive time alone is not a reliable, primary factor in determining timing for rescue respondents. The other factors include the attendant recognizing that there is an issue, equipment or gear loading and availability. The initial call out to the rescue team, calling medical teams, initial evaluation, planning the rescue, utilizing PPE and the rescue attempt itself will also factor into response times. Reducing any of these variables can improve the chances of a successful rescue. The collective of these steps can often make calculating a response time very difficult task and essentially an unreliable determination. An on-site, well-trained TAS stand by rescue team will help to eliminate many unknown variables. On-site, prepared and undistracted standby teams minimize response time failure and ensure timely action. TAS Environmental Services, L.P. employs highly skilled EH&S Staff to monitor Confined Space Rescue (CSR) training and on-going education. Our teams are trained on both CSR and CSE. We also train staff on CPR and First Aid in addition to 40 Hour hazwoper training. We can mobilize 24/7/365 to help minimize risk and maximize safety QC when Confined Space Entry (CSE) is necessary. Call us at 888.654.0111 for assistance.

TAS Environmental Services offers the best confined space entry services in Dallas-Fort Worth, Texas.

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TAS Environmental Services Acquires Delmar Disposal

TAS Environmental Services Acquires Delmar Disposal for Its Second Acquisition in 2017

Dallas-Fort Worth, TX-based TAS Environmental Services acquires Delmar Disposal strengthening its Industrial Division across 4 DFW locations

FORT WORTH, Texas, Nov. 28, 2017 /PRNewswire/ — TAS Environmental Services, L.P. (“TAS”), a Fort Worth-based environmental services provider and portfolio company of TEAM Partners, LLC, a Dallas, Texas-based private equity firm, announced the acquisition of Delmar Disposal Co. (“Delmar Disposal”), a Dallas-based industrial waste services provider. Delmar is TAS’ second add-on acquisition in 2017 and follows the acquisition of Water Kleen Services in May. Financial terms of the transaction were not disclosed.

TAS provides a comprehensive suite of environmental services including, among others, industrial services, emergency response, remediation, transportation, pipeline and terminal services. TAS operates in Texas, Louisiana and Arkansas.

Delmar Disposal, founded in 1988, provides environmental and industrial services including wastewater disposal, tank cleaning, grease trap cleaning and related services. Delmar operates a wastewater treatment and recycling facility and was recently recognized by the City of Dallas as a Blue Thumb Award recipient for its contribution in improving the water quality of the Trinity River.

“TAS is pleased to join forces with Delmar Disposal to deepen our commitment to the DFW environmental services market,” said Ed Genovese, TAS President and CEO. “This transaction strengthens our industrial services offering and adds an in-demand, internal recycling asset for TAS. We have tremendous respect for the operation that Delmar has built over the last 30 years and are honored to work with Delmar’s customers and employees going forward. TAS now operates DFW’s largest 24/7 industrial vacuum fleet with over 25 local units and is uniquely positioned to serve the demands of our growing customer base.”

Buddy Ham, owner of Delmar commented, “I am excited to watch Delmar’s next phase of growth under TAS. TAS is a natural home for Delmar as they adhere to our same philosophy of providing exceptional customer service and treating employees well. In addition, TAS will also bring additional resources and services to the customer base.”

David Mann, managing partner of TEAM Partners added, “We are thrilled to welcome Delmar to the TAS platform. This has been an active year for TAS as we have closed two add-on acquisitions in the past six months and opened a new greenfield location in Midland, Texas. Our appetite for future growth remains strong and we will continue to seek additional strategic acquisitions.”

About TAS Environmental Services, L.P.

TAS is a leading regional environmental services company based in Fort Worth, Texas. TAS offers a comprehensive service offering in Texas, Louisiana and Arkansas including emergency response, remediation, industrial services, transportation, waste management, pipeline and terminal services. For additional information about TAS and its capabilities, please visit

About TEAM Partners, LLC

TEAM is a Dallas-based private investment firm that invests in profitable, family owned and owner-operator businesses generally with up to $100 million in revenue. We focus on opportunities in which we can add value from our strategic, operational and financial resources. Since 2002, our principals have acquired 26 companies across numerous industries including industrial, business services and consumer products. For additional information, please visit


For TAS Environmental Services
Ed Genovese, CEO
Phone: (817) 535-7222

For TEAM Partners, LLC
David Mann
Phone: 214-621-0192

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EPA Sustainable Materials Management

Multiple Waste Management Streams Are Needed To Ensure Proper Disposal

TAS Environmental Services has become a leader in waste management solutions and as a result, we regularly update our practices to ensure our company is compliant based on EPA sustainable materials management guidelines.

The EPA works with public and private organizations to deliver the best data and non-hazardous materials and waste management hierarchy which highlights multiple approaches to waste management.

To learn more about what the United States Environmental Protection Agency considered the best process for materials management click here.

TAS Project Managers can be used as valuable resources that can help manage potential waste for recycling or reuse. Please contact us at for more information.


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RCRA / DOT Hazardous Waste Management Standards

TAS Training

TAS Environmental has expanded its training program by offering classes at your location or at the facility of your choice. For groups of 15 or more, we can even develop customized instruction so you get the greatest value for your training dollar.

Our RCRA/DOT Hazardous Waste Management Standards workshop improves worker safety while protecting the environment. Our workshops also satisfy the training requirements as defined in 40 CFR 262.34(a) and 265.16. In addition to satisfying federal requirements, our workshops also address state requirements as defined by the Texas Commission for Environmental Quality.

Our workshops are developed to satisfy a number requirements including initial training and annual refresher workshops. We will even develop customized workshops for you should your training needs extend beyond the standard courses. Our workshops also satisfy regulatory requirements according to generator status, including:
Large quantity generators per 30 TAC 335.69(a)(4)(A) and 40 CFR 262.34(a)/40 CFR 265.16 and for small quantity generators managing universal waste streams.

Our Next RCRA / DOT Hazardous Waste Management Standards Workshop will be held April 14th, from 8:00 am to 5:00 pm, at:

Hyatt Place
5900 Cityview Blvd
Fort Worth, TX 76132

$249 per person. $199 per person for multiple attendees
from the same company. To register, please complete the
registration form on the next page and forward it to your
TAS Environmental representative.

Click here to learn more.

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OSHA’s New Confined Space Standard

Re-Posted from Occupational Health & Safety
By Chris Irwin, Jessica Smith

Since it was issued in 1993, OSHA’s confined space regulation, 29 CFR 1910.146, has been geared toward general industry workers, with very little applying directly to the construction industry. Employers in the industry have tended to default to general industry standards but have not had a substantial regulation of their own to fall back on. On Aug. 3, 2015, however, the OSHA confined spaces in construction standard, 29 CFR Subpart AA 1926.1200, joined the existing general industry confined space standard and clearly defined rules for confined spaces in construction. It is estimated that this move can prevent roughly 780 serious injuries and five deaths each year.1

At a confined spaces press conference on May 1, 2015, Dr. David Michaels, assistant secretary of Labor for OSHA, stated, “This rule will save lives of construction workers. Unlike most general industry work sites, construction sites are continually evolving, with the number and characteristics of confined spaces changing as work progresses.”2 He added that “all workers have the right to a safe and healthy workplace, and it only makes sense that all workers have similar protections when working around the same hazards.”3

Confined Space vs. PRCS
First, let’s define a confined space. A confined space is a space large enough for a worker to enter, is not designed for “continuous employee occupancy,” and has limited means for entry and exit.4 A permit-required confined space (PRCS) is a confined space with one or more of the following characteristics:

  • Contains or has a potential to contain a hazardous atmosphere
  • Contains a material that has the potential for engulfing an entering employee
  • Has an internal configuration such that an employee could be trapped or asphyxiated by inwardly converging walls or by a downward-sloping floor
  • Contains any other recognized serious safety or health hazard5

Common Hazards
The new rules aim to reduce the risks presented by hazards common to confined spaces in the construction industry, such as oxygen deficiency and the presence of explosive or toxic gases, vapors, or fumes. Examples of confined spaces include condenser pits, manholes, ventilation ducts, tanks, sumps, and containment cavities, among many others.6 Hazards can be controlled by locking out moving parts, de-energizing electrical parts or wiring, blocking steam pipes and product in-feeding pipes, draining or pumping out liquid contents, or air monitoring and ventilating.7

Similarities and Differences in the Standards

How does 29 CFR 1926.1200 differ from general industry standards? It is generally agreed that this new standard was written to mirror many facets of its general industry counterpart. Construction entities that currently implement and comply with the general industry standard will have a strong basis for compliance to the new standard. That stated, there are several differences from the general industry standards that are discussed below.

The updated confined spaces rules include more specific provisions for requiring coordinated activities when multiple employers are on the same work site. These provisions are intended to ensure that hazards are not introduced into a confined space by an employee working on a different project or task nearby. The general industry standard required communication and coordinated activities, but the nature of a construction site with its larger number of contractors makes the dynamic of that coordination somewhat different.

At a construction site, a host employer (the owner of the site) is added to the mix of parties in communication. Prior to entry operations, the host employer must provide information to the controlling contractor on the location and potential hazards of any known confined spaces, as well as any precautions implemented for employee safety. The controlling contractor must then share that information with each entity entering the space or that could potentially introduce a hazard into the space. Each entry employer (subcontractor) should then inform the controlling contractor of the permit space program it plans to follow and any hazards likely to be confronted. The controlling contractor is then responsible for coordinating the activities of entry employers when multiple entities are either in the same space or their activities might conflict and introduce a hazard. After entry operations, the controlling contractor must debrief each entity that entered the permit space regarding the program followed and any hazards encountered. The controlling contractor must then provide the information gathered to the host employer.8

The new standard also includes a “competent person” clause. The general industry rule required that the employer evaluate the work site and identify confined spaces. The new construction standard instead requires evaluation by a “competent person,” perhaps a supervisor, and potentially multiple persons.9

Additionally, the new regulation allows for the mere suspension of a permit rather than a mandated cancellation if a condition not allowed under the entry permit arises with the permit space, so long as the condition is temporary in nature, does not change the configuration of the space, or create any new hazards within it.10

The Part 1926 standard also encourages continuous atmospheric monitoring where possible. The general industry standard required only periodic monitoring and never attached a timing requirement. It is noted that if the employer can demonstrate that periodic monitoring is sufficient, OSHA does not require continuous monitoring.11 However, continuous monitoring is always best practice.

In the new standard, OSHA requires that employers implement an early-warning system that continuously monitors for non-isolated engulfment hazards, such as flash flooding.12

Finally, employers are required to provide safety training in a language and vocabulary that workers understand.

Does This Affect You?
The new confined spaces standard applies to anyone doing construction with the exception of excavations, underground construction, caissons, cofferdams, compressed air, and diving, as specified in the law. If a company is engaging in both construction and industrial work and meets the criteria of 29 CFR 1926.1200—Confined Spaces in Construction, the employer should be in compliance.13

Employers’ Action Steps
Faced with new OSHA regulation, an employer’s action steps should begin with a determination of whether the regulation is relevant, i.e. whether there is a confined space at a work site. If there are one or more confined spaces that include existing or potential hazards, the employer must classify the space accordingly.

In conclusion, the new OSHA confined spaces in construction standard will have wide-reaching effects on the construction industry and the safety of its workers. Dr. Michaels stated that the rule “emphasizes training, continuous work site evaluation and communication requirements to further protect workers’ safety and health.”

Organizations planning to take on a construction project need to be well informed about the impacts of the new regulation and how to adjust their processes in order to remain in compliance. This article serves as a summary of the new standard. Further details on the standard in its entirety, compliance assistance documents, and other resources to help employers and workers understand the rule can be found on OSHA’s Confined Spaces page:


1. United States Department of Labor, Press Teleconference on Confined Spaces: Remarks Prepared for Delivery by Dr. David Michaels, (May 28, 2015)
2. United States Department of Labor, OSHA Confined Spaces Frequently Asked Questions, (May 28, 2015).
5. OSHA Confined Spaces in Construction standard, 29 CFR Subpart AA 1926.1200, p. 6,
6. Jeffrey Dalto, Update from OSHA Spokesperson on Publication of Upcoming Confined Spaces in Construction Standard (1926.1200), Convergence Training Blog, (May 29, 2015).
7. Occupational Safety and Health Division of North Carolina, Confined Spaces Training, (June 6, 2015).
8. Ibid pp. 12-14
9. Ibid p. 8
10. Ibid p. 19
11. Ibid p. 10
12. Ibid p. 16

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GE, Accenture release intelligent pipeline solutions

Re-Posted from The Bakken Magazine
By Ann Bailey | January 06, 2016

GE Accenture Blog Post PicGeneral Electric and Accenture have announced that Columbia Pipeline Group is using its Intelligent Pipeline Solution, a software that assists pipeline operators in making informed decisions about pipeline safety and integrity.

Columbia Pipeline Group now has a real-time view of more than 15,000 miles of interstate pipelines. The ability to monitor pipeline threats with pipeline solution software improves the risk management and produces situational awareness, according to GE.

Columbia Pipeline Group is located within the Marcellus and Utica shale areas of Ohio, West Virginia, Pennsylvania and New York and operates 15,000 miles of interstate natural gas pipelines.

The United States has more than 190,000 miles of liquid petroleum pipelines and 2.4 million miles of natural gas pipelines, according to the American Petroleum Institute. Meanwhile, the Dakota Access, a proposed pipeline would cross 1,134 miles in North Dakota, South Dakota, Iowa and Illinois and the Sacagawea Pipeline Company is developing a 76-mile pipeline to deliver crude oil from areas south of the river in McKenzie and Dunn Counties in North Dakota to areas north of Lake Sacagawea.

The global pipeline industry spends more than $40 billion annually to expand and maintain its access network, said Peggy Kostial, senior managing director for Accenture’s North American resources operating group. Sixty percent of the pipelines were installed before 1970 so safety increasingly is a driving factor for operators such as CPG to achieve real time and remote monitoring of their thousands of miles of pipeline, Kostial said.

Intelligent Pipeline Solution is designed to help pipeline operators to rank where resources are best applied so they can reduce the potential for unforeseen events. The software provides an integrated geospatial view of Columbia Pipeline Group’s assets aligned with critical factors related to pipeline integrity, Shawn Patterson, Columbia Pipeline Group CEO said.

The solution integrates data from several sources, including geographic information systems, work management systems and control systems. It also integrates external sources such as the National Aeronautics and Atmospheric Administration and the United States Geological Survey. Intelligent Pipeline Solution also integrates data such as pipeline attributes, risk scores and precipitation and fault lines. Users can use a set of filters and layers to examine data in different ways to quickly locate areas of interest.

Intelligent Pipeline Solution answers the call from transportation pipeline customers to address increased compliance regulations, safety concerns and maintenance and integrity management of their pipelines’ networks, said Brian Palmer, GE Measurement and Control president and CEO.

For more on the Bakken, follow us on Twitter @TheBakkenMag

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Science of Oil Spills Training Now Accepting Applications for Spring 2016

Re-Posted from the Office of Response and Restoration | NOAA


NOAA‘s Office of Response and Restoration, a leader in providing scientific information in response to marine pollution, has scheduled Science of Oil Spills (SOS) classes in two locations in spring 2016:

  • Mobile, Alabama the week of March 28, 2016
  • Ann Arbor, Michigan the week of May 16, 2016

We will accept applications for these classes as follows:

For the Mobile class, the application period will be open until Friday, January 22. We will notify accepted participants by email no later than Friday, February 5.

For the Ann Arbor class, the application period will be open until Friday, March 11. We will notify accepted participants by email no later than Friday, March 25.

SOS classes help spill responders increase their understanding of oil spill science when analyzing spills and making risk-based decisions. They are designed for new and mid-level spill responders.

These trainings cover:

  • Fate and behavior of oil spilled in the environment.
  • An introduction to oil chemistry and toxicity.
  • A review of basic spill response options for open water and shorelines.
  • Spill case studies.
  • Principles of ecological risk assessment.
  • A field trip.
  • An introduction to damage assessment techniques.
  • Determining cleanup endpoints.

To view the topics for the next SOS class, download a sample agenda [PDF, 170 KB].

Please understand that classes are not filled on a first-come, first-served basis. We try to diversify the participant composition to ensure a variety of perspectives and experiences, to enrich the workshop for the benefit of all participants. Classes are generally limited to 40 participants.

For more information, and to learn how to apply for the class, visit the SOS Classes page.


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Making Hazardous Waste Regulations Work for Today’s Marketplace

Re-Posted from EPA Connect | Story by Mathy Stanislaus 

The pace of technology and change in the modern world can be dizzying. As new medicines and treatments are developed, new types of waste emerge. However, our hazardous waste generator regulations were written in the 1980s and haven’t changed much over the years.
Well, today we’re taking steps toward changing that. I’m excited to announce that we are proposing two rules to provide businesses with the certainty and flexibility they need to successfully operate in today’s marketplace.

Over the last 35 years, we’ve heard from states and the regulated community that our hazardous waste generator regulations, which were designed for manufacturing, don’t fit all sectors and especially not the healthcare sector. We’ve listened and these two proposals make a number of updates and improvements to the existing regulations. We have proposed over 60 changes to the regulations to improve the effectiveness of and compliance with the hazardous waste generator program. This includes rearranging some of the generator regulations that had outgrown their original numbering system so it will be easier for facilities of all sizes that generate hazardous waste to find everything they need to know in one place.

The second rule will make it easier for healthcare providers to comply with hazardous waste rules while protecting the nation’s water. We’re proposing to remove the traditional manufacturing-based hazardous waste generator requirements and instead provide a new set of regulations designed to be workable in a healthcare setting while ensuring safe management and disposal of hazardous waste pharmaceuticals. The primary focus for nurses, doctors and pharmacists is providing healthcare – they are not experts in hazardous waste identification and management. This rule seeks to reduce the burden and increase compliance by proposing a more flexible, common sense approach for healthcare providers and the elimination of unnecessary management practices.

Pharmaceuticals entering the environment, through flushing or other means, are having a negative effect on aquatic ecosystems and on fish and animal populations. Our proposal is keeping pace with today’s environmental issues by banning the sewering, or flushing down the toilet or sink, of hazardous waste pharmaceuticals from healthcare facilities. It is projected to prevent the flushing of more than 6,400 tons of hazardous waste pharmaceuticals annually making our drinking water safer.

In order to keep our world safe and healthy, regulations should not only effectively manage sources of environmental harm, but also be flexible and clear enough for newcomers to understand. The updates and tailoring of the hazardous waste generator regulations by these two proposed rules increases compliance, which then increases environmental benefit. The new rules respond to the needs of both the environment and businesses, benefitting both sides.

Our proposals will be available for public comment online in the coming weeks once they are published in the Federal Register. We’d love to hear your thoughts. To review these proposed rules now, visit:

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