Since our presentation at ASSP Safety2019! I have been getting the strangest request for clarification on how OSHA views “limited means of egress” and for the life of me, I just can’t understand why. Yes, the GI standard for PRCS’s (1910.146) does not define the phrase; however, since 2015 OSHA’s Construction Standard for PRCS has actually defined the phrase quite clearly in the definitions section of the standard (1926.1202). And for those who wish to claim… “I am in General Industry so that definition does not apply to me”… well, then I can not help you. OSHA has made it clear that the newer Confined Spaces in Construction (1926.1201-.1213) is their standard of choice and it most certainly can apply to General Industry workplaces – it ALL depends on the type of work taking place inside the space as to which standard they will enforce. So what did OSHA say was “Limited or restricted means for entry or exit”… (and yes a ladder is without a doubt a restriction for entry and exit)
Limited or restricted means for entry or exit means a condition that has a potential to impede an employee’s movement into or out of a confined space. Such conditions include, but are not limited to, trip hazards, poor illumination, slippery floors, inclining surfaces and ladders.
This is key for us to understand, as this is one of the three (3) KEY criteria for a space to become a “confined space”, how this definition is to be applied in our CS evaluation.
Confined space means a space that:
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- Is large enough and so configured that an employee can bodily enter it;
- Has limited or restricted means for entry and exit; and
- Is not designed for continuous employee occupancy.
So when we look at a space to determine if the space will be a CS, we have to consider trip hazards, poor illumination, slippery floors, inclining surfaces and LADDERS.
Yes, I intentionally highlighted “ladders” with all capital letters as this one seems to hang a lot of folks up. If your ONLY means to enter and exit the space is by a ladder (fixed, step, or rope) and you have to climb more than 4 rungs (e.g. 4′) then the space has Limited or restricted means for entry or exit.
Be VERY CAREFUL playing the “Safety Reciprocal Game” in thinking that if I have stairs instead of a ladder then “all is OK”! This may be the case, but even when we have stairs provided as our means of entry/exit directly out of the space, it is what is inside the space that may “Limit or restrict our means for entry or exit”. In other words, what might we have to climb over, duck/crawl under, etc. to get to the stairs? These obstacles, merely getting to the stairs, will also Limit or restrict our means for entry or exit.
