Safety Knights

Surely there are some instances where a service pit is considered a confined space. However, if I had to guess, they’re eliminating one of the three criteria to be a confined space. Perhaps they have lighting, ventilation, etc and are claiming that it is designed for continuous human occupancy. Perhaps they have a configuration that allowed for unrestricted means of access and egress. While many pits do indeed meet the definition of a confined space, not all do. We would need to know more about the configuration of this space to make that determination.

To your point on CO, just because it’s not a confined space doesn’t mean that CO can’t build up in there. Many service areas have large garage doors that stay open with plenty of natural ventilation. I’ve also seen many service bays implement local exhaust ventilation for the exhaust to prevent CO buildup. Hopefully, they’re also limiting the amount of time the engine is running to reduce CO.

As far as reclassification goes, if the only hazard, or potential hazard, is atmospheric in nature, and they can prove that they have taken effective measures to eliminate that hazard through ventilation alone, they may use the alternate entry procedure which foregoes a lot of the requirements of the PRCS standard. Check out 1910.146(c)(5) for that process.

Hopefully that answers some of your questions?

As Chris mentioned, it typically doesn't meet all 3 requirements of a confined space. It typically doesn't have limited or restricted means of entry or exit because most have standard stairs to get in and out that is positioned away from the service pit (typically between vehicle bays).

In the case of places like Valvoline Instant Oil Changes and similar places, the pits are designed for continuous employee occupancy. As Chris said, it has lighting, proper ventilation, etc. and they designed it for a person to be down there most of the day.

With that being said, if it's a service pit at a maintenance shop where they're not down there all of the time and the stairs that exit directly underneath the vehicle where they COULD (but not always) have a limited means of entry/exit, it is more likely to meet the requirement of a confined space, but it still may not be a PRCS. CO is lighter than air, so it typically wouldn't accumulate in below-ground pits. Most maintenance shops either turn the vehicles off before getting down in the pit, or attach a ventilation system pipe to the exhaust tip on the vehicle to suck out the exhaust fumes, therefore eliminating the potential for a hazardous atmosphere. As a former auto/diesel technician, there's not many reasons to be in a service pit with the engine running.

In my opinion I could not explain it any better than Chris and Drew have!

Great job guys!

Fitz

We have a service pit at one of our locations. And like Drew and Chris stated in their responses, we have the stairs that lead out of the pit. We also have a system in our shop that monitors the CO levels and ventilates it outside. This is primarily due to we service refrigeration units on trailers. So to help keep much of the CO outside when working on them we have vent tubes as well, that connect to the exhaust.

Most of the time, our tech does not use the pit much.