OSHA and NFPA have aligned on “the potential” for a HAZ ATM within a PRCS, but would you “reclassify” the space under their guidance?

Both OSHA and NFPA state that if the pipe does NOT terminate within the space, the pipe does NOT have to be evacuated to consider the contents of the pipe a “potential” to generate a HAZ ATM. In a recent OSHA LOI, OSHA used several thresholds that the employer should/must use in its evaluation of...