Don’t confuse continuous employee occupancy with maintenance access

I have an on going debate with a new food client on their “spiral freezers” being a Permit-Required Confined Space(s).  In my professional opinion, a spiral freezer, at least all the ones I have been around, are without a doubt a PRCS.  This company, including their brand manufacturer, are claiming they are not – based on the fact that the manufacturer claims they have “designed” their spiral freezer to be occupied.  This is INSANE to even be having this discussion, but to be still having it in 2019 is just sad and folks these people, especially the manufacturer, who apparently has been telling all of their customers their freezers are not a CS (or PRCS), are mad as hell, but I am not budging.  In this article, I will explain how/why a spiral freezer is without a doubt a PRCS.  I have found a lot of images and videos of spiral freezers and these images and videos are NOT of the brand this “former client” is using, but their design(s) that make these spaces a PRCS are almost identical.  So let’s jump right in (all pun intended)…

Here is a nice video showing all sides of a spiral freezer which does a nice job showing its size, entry portals, etc.  This is NOT the brand the client had, just a nice video that shows a spiral freezer very similar to the size and design of the clients.

So the argument is that the inside of this spiral freezer is designed for “continuous employee occupancy”.  OSHA’s definition of a CS is: (emphasis by me)

“Confined space” means a space that:

1. 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.