We have all done it… used the words “confined space” when we were actually discussing a Permit-Required Confined Space. But in the year 2021, I hope we have come to realize the huge difference between the two types of spaces. Just merely speaking in terms of OSHA compliance, there is a good reason why 1910.146 is titled “Permit-required confined spaces” and not just confined spaces. Did you know that OSHA’s 1910.146 ONLY covers…
spaces that meet the criteria of a permit-required confined space (PRCS). The standard does NOT in any way cover those spaces which are only a confined space. Of course, we have to evaluate the space to determine its characteristics and whether the space contains any of the PRCS hazards, or has the potential to contain a HAZ ATM. But once we have established that the space is only a confined space and does NOT rise to the level of being a PRCS, then OSHA’s coverage of 1910.146 ends.
So words really do mean something, especially when we are having a technical discussion.
So why then did OSHA title their newer construction standard on confined spaces: “Confined Spaces in Construction” and not Permit-Required Confined Spaces in Construction?
Heck if I know, maybe the lawyers had more input than the OSH professionals; but just like 1910.146 does not cover “confined spaces” the same goes with the 1926 version – it too ONLY covers spaces that rise to the level of being a PRCS. Maybe we could get OSHA to recognize the difference between the two types of spaces!
