It appears we may be blending 1910.146(c)(5) and (c)(7) in our attempt to reclassify a PRCS to a non-permit status. We must follow (c)(7) in our reclassification efforts. It does sound as if our PRCS may be able to be reclassified; however, I am not familiar with the type of space or specific situation.
OSHA states in (c)(7) that a PRCS can be reclassified if it has NO known OR potential hazardous atm. It also says in the CPL and preamble that ALL other hazards MUST BE “ELIMINATED.” Using the term “eliminated” is key; as in (c)(5), OSHA allows the hazardous atm to be “controlled” using the force air ventilation. But when reclassifying a PRCS, ALL hazards MUST BE “ELIMINATED.”
