2023 Jul-Aug RETA Breeze

CONFINED SPACE? Have you ever seen a bucket classified as a confined space? Why not? There’s only one way in and out, so it has limited means of access and egress. The answer is simple. There’s no way you can enter it bodily. What about the oil separators on your screw compressors—are they designated as Confined Spaces? I have been in many plants where all the compressor oil separators were classified as Confined Spaces. In my opinion, this is a result of confusion about OSHA’s Permit-Required Confined Spaces Standard, 29 CFR 1910.146. The confusion arises when the definition of a Confined Space becomes conflated with the definition of a Confined Space Entry. Most people in industry are familiar with the definition of a Confined Space entry. This is the definition, straight from the OSHA standard: Entry means the action by which a person passes through an opening into a permit-required confined space. Entry includes ensuing work activities in that space and is considered to have occurred as soon as any part of the entrant’s body breaks the plane of an opening into the space.

Let’s look at another definition, straight from the OSHA standard--the definition of a Permit-Required Confined Space (PRCS). A PRCS is a space that meets the OSHA definition of a Confined Space, and: • Contains or has the potential to contain a hazardous atmosphere • Possesses an engulfment potential to someone who enters the space • Has an internal configuration that could cause an entrant to be trapped or asphyxiated • Contains any other recognized serious safety or health hazards Please note that a PRCS must first be a Confined Space. If the space in question does not meet the definition of a Confined Space, then it cannot be a Permit Required Confined Space. So, let’s look at the

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