Safety Tidbit 2.37 – PRCS Reclassification

Safety Tidbit 2.37 – PRCS Reclassification

Reference:       OSHA Permit-required Confined Spaces

So, this question from a client is a couple of weeks old now. I asked if they had any permit-required confined spaces (PRCS) at their facility. The client said no. However, as I conducted my walk-through I noticed an entry door to their ventilation system with a padlock on it. I inquired if anyone is required to go into the space to clean it out or do any maintenance? The client said yes maybe once or twice a year they go inside to visually inspect the walls and completely clean it out with vacuum cleaners. His follow-on comment was interesting: But we always lock it out and empty the hopper before we go into the space. Let’s start from the beginning:

What is a confined space? - "Confined space" means a space that:

·      Is large enough and so configured that an employee can bodily enter and perform assigned work; and

·      Has limited or restricted means for entry or exit (for example, tanks, vessels, silos, storage bins, hoppers, vaults, and pits are spaces that may have limited means of entry.); and

·      Is not designed for continuous employee occupancy.

Check – I think the ventilation space meets this requirement.

What is a permit-required confined space? "Permit-required confined space (permit space)" means a confined space that has 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 entrant;

·      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; or

·      Contains any other recognized serious safety or health hazard.

Check - during normal operations.

However according to 1910.146(c)(7), A space classified by the employer as a permit-required confined space may be reclassified as a non-permit confined space under the following procedures:

·      If the permit space poses no actual or potential atmospheric hazards and if all hazards within the space are eliminated without entry into the space, the permit space may be reclassified as a non-permit confined space for as long as the non-atmospheric hazards remain eliminated.

·      If it is necessary to enter the permit space to eliminate hazards, such entry shall be performed under paragraphs (d) through (k) of this section. If testing and inspection during that entry demonstrate that the hazards within the permit space have been eliminated, the permit space may be reclassified as a non-permit confined space for as long as the hazards remain eliminated.

·      NOTE: Control of atmospheric hazards through forced air ventilation does not constitute elimination of the hazards. Paragraph (c)(5) covers permit space entry where the employer can demonstrate that forced air ventilation alone will control all hazards in the space.

·      The employer shall document the basis for determining that all hazards in a permit space have been eliminated, through a certification that contains the date, the location of the space, and the signature of the person making the determination. The certification shall be made available to each employee entering the space or to that employee's authorized representative.

·      If hazards arise within a permit space that has been declassified to a non-permit space under paragraph (c)(7) of this section, each employee in the space shall exit the space. The employer shall then reevaluate the space and determine whether it must be reclassified as a permit space, in accordance with other applicable provisions of this section.

The operative statement is in the first bullet in 146(c)(7) just above – “…the permit space may be reclassified as a non-permit confined space for as long as the non-atmospheric hazards remain eliminated.” In other words, the space is permit-required confined space until the LOTO procedure has been executed and verified. As soon at the space is put back into service the “non-atmospheric hazards” are no longer controlled.

Hope this was helpful and thanks for reading my Safety Tidbits and as always if you have a burning safety or health question please let me know. ~ Bryan