As the popularity of “reclassifying PRCSs” continues to grow, so do the myths and lies about how this entry method applies and how it gets implemented. OSHA did provide some more clarification in their newest PRCS Standard for Construction, which I will use to explain the process of “reclassifying a PRCS to a non-Permit confined space.”
A space classified by an employer as a permit-required confined space (PRCS) may ONLY be reclassified as a non-permit confined space when a COMPETENT PERSON determines that all of the applicable requirements stated below have been met:
- If the PRCS poses NO actual OR potential atmospheric hazards AND if ALL the hazards within the space that made the area a PRCS are ELIMINATED OR ISOLATED WITHOUT entry into the PRCS (unless the employer can demonstrate that doing so without entry is infeasible), the PRCS may be “reclassified” as a non-permit confined space FOR AS LONG AS THE NON-ATMOSPHERIC HAZARDS REMAIN ELIMINATED OR ISOLATED;
then…
- The entry employer MUST ELIMINATE OR ISOLATE THE HAZARDS WITHOUT ENTERING THE SPACE (i.e., breaking the plane of the space) unless it can demonstrate that this is infeasible. If it is necessary to enter the PRCS to eliminate or isolate hazards, such entry MUST be performed as a FULL PERMITTED ENTRY. If testing AND inspection during that FULL PERMITTED ENTRY demonstrate that the risks within the permit space have been eliminated or isolated, the PRCS may be reclassified as a non-permit confined space for as long as the hazards remain excluded or isolated;
Note: CONTROL of atmospheric hazards through forced air ventilation does NOT constitute elimination or isolation of the hazards. 1926.1203(e) covers entry into a PRCS where the employer can demonstrate that forced air ventilation ALONE (i.e., no LOTO necessary) will control ALL PRCS hazards in the PRCS.
then…
- The entry employer MUST document the basis for determining that ALL PRCS hazards have been eliminated or isolated, through a certification that contains
- the date,
- the location of the space, and
- the signature of the person making the determination.
The certification MUST be made available to each employee entering the space or to that employee’s authorized representative
then…
- If PRCS hazards arise within a permit space that has been reclassified as a non-permit space, each employee in the area must exit the space IMMEDIATELY. A competent person must then reevaluate the space and reclassify it as a permit space as appropriate under all other applicable provisions of this standard.
