Safety Knights

Do you have a picture? Does it meet all the criteria of a non-permit space, including "not designed for continuous employee occupancy"? If it's designed for continuous employee occupancy, then it can't be a PRCS or even a non-permit space.

I would agree with Drew if you want to just follow OSHA! For OSHA it must meet the three criteria of a Confined Space, 1910.146(b) Definitions - Confined Space. I would like to see a picture for a definitive answer, better yet see it in person.

However, to me that question is sort of moot. Sounds to me this is the sort of thing I want to ensure everything is locked out before anyone enters and that process is documented! There is nothing that says I cannot just call it a PRCS. Possibly make it more safe than OSHA. If you want to error on the side of caution and make it a PRCS that requires Lockout do it! You are more than good! Nothing says you can not make things MORE safe than OSHA 1910.146.

Some argumentative Operations guy like me (with OSHA knowledge) might argue it is not a CS. But you being smarter, can say the employees must be protected by 1910.147, you just want it documented! I would probably grumble something about taking more downtime. But then you are going to say, "Really how much time does it require to complete a small form and ensure safety?"

PS Sometimes I think we get to hung up on what OSHA calls something. My experience over 50 years (from the earliest days of OSHA), is to use OSHA as the base, where we start to be safe. But if we really want to make things safe for our employees’ we go the extra mile! Generally. I have found if we make things really safe, practice what we preach, reduce human error as much as possible, and circle back an audit, OSHA compliance is a given! In Lean we call that Plan, Do, Check, Act, or PDCA!

I agree the first step is to determine if the space is a confined space (don’t worry about the permit piece yet).

OSHA states "Confined space means a space that: (1) Is large enough and so configured that an employee can bodily enter and perform assigned work; and (2) 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 (3) Is not designed for continuous employee occupancy."

Generally speaking, the fact that stairs are part of the design leads me to believe your scenario does not meet the 2nd requirement for confined space (limited or restricted means for entry or exit). Another words, it is generally difficult to argue the stairs cause “limited” or “restricted” means for entry or exit since stairs are (by design) fairly easy to navigate.

If the space meets the definition of confined space, then your scenario with mechanical hazards might be accurate. As others have suggested, it would be easier to comment if additional information was provided.

Addam,

I understand where you’re coming from, but let me clarify why this situation might not meet the criteria for a Permit-Required Confined Space (PRCS).

Yes, a saw booth with stairs leading down could technically meet some of the characteristics of a confined space, especially if there’s limited entry and exit. However, for it to be classified as permit-required, there needs to be more than just a mechanical hazard. OSHA’s definition of PRCS includes not only physical hazards but also atmospheric hazards or other recognized serious hazards that can restrict entry/exit or pose an immediate threat to the worker inside.

In your case, if the only issue is the saw or mechanical equipment, proper LOTO procedures can mitigate that hazard without necessarily making it a permit-required space. LOTO is often sufficient to eliminate the hazard from the equipment during maintenance or servicing.

That being said, if there are additional factors, such as the risk of engulfment or dangerous atmospheric conditions (e.g., poor ventilation, potential for toxic gases), those could push it into PRCS territory. But just having a mechanical hazard alone, with LOTO in place, doesn’t necessarily require PRCS classification.

Let me know if that clears things up or if there are more specifics we should look into. A picture would definitely be helpful.

Best,

Alfredo Guardado