Several years ago I wrote an article about how a space goes through its transitions to become a non-permit required confined space. A space is not identified as a non-permit required confined space during its first evaluation; it becomes one after it has been “reclassified” using either (c)(7) or 1926.1203(g). That article caused quite a stir with my readers, but most were convinced of the rationale. But now, OSHA has a different “definition” for a “non-permit required confined space” in 1926.1202 than from how they defined in 1910.146(b) way back in the 1990’s. Coupling this article with the one I posted back in June (Does OSHA’s new PRCS in Construction allow the use of Alternative Entry and Reclassification on the same PRCS?) I tend to think OSHA knew exactly what they were doing and here’s why…
