Reclassifying “Permit Required Confined Spaces”

I had the opportunity to view one of the best presentations on permit required confined spaces that I have ever seen.  Tom Burgess, MS, CSP, CIH covered 32 slides in 35 minutes before addressing a host of questions.  Mr. Burgess identified an often overlooked opportunity for temporary reclassification of an existing permit required confined space.

When you can eliminate all hazards before entry, it is possible and acceptable to temporarily reclassify the space as a non-permit required entry.  In this case, you need to document the hazards and how you eliminated them.  A full entry permit is then no longer necessary.  The Preamble to 29 CFR 1910.146 is instructive…

For the purpose of reclassifying a permit-required confined space that has potential energy sources in it, the methods the employer must use depend on the types of energies requiring elimination or isolation. OSHA’s lockout/tagout requirements address electro-mechanical hazards, but lockout/tagout will not eliminate hazards associated with flowable materials such as steam, natural gas, and other substances that can cause hazardous atmospheres or engulfment hazards in a confined space.

A good example is elevator repairmen who must enter the lower level of an elevator to perform service and maintenance.  Under typical conditions, there are no hazards other than the electrical energy source and elevator car movement.  If the system was merely turned off, the potential for unexpected / unintended motion would still exist.  That action is not sufficient to reclassify the space and does not meet OSHA’s Lockout/Tagout standard.  On the other hand, if the primary electrical energy is isolated and the system is locked before entry, the space is no longer a permit required confined space.

We recommend that our clients take an hour to review the presentation. It’s worth the time.  If you have questions, call us. We can help…