Personnel Safety

Q&A: Confined Space Reclassification

Recently, a customer asked the following question:

Through the course of a particular maintenance activity, some components of a generator are removed. The removal of this equipment opens up an area that was classified as a confined space such that the means of entry and exit are no longer restricted. The space itself has been reconfigured so that it is no longer a confined space. In which case, it would no longer be subject to the OSHA requirements of confined space entry. Is this a correct assessment of confined space classification? What is a best practice for documenting this kind of activity as we transition from confined space to not a confined space?

This is how we responded:

Use the following criteria to confirm your assessment of the confined space classification and document your process for doing so.

A confined space classified as a permit space may be reclassified as a nonpermit space if:

  • The permit space poses no actual or potential atmospheric hazards and if all hazards are eliminated without entering the space.
  • Testing and inspection demonstrate that the hazards have been eliminated.
  • It has been documented that the basis for determining that all hazards have been eliminated is through a certification that contains the date, location of the space, and the signature of the person making the determination.
  • It is necessary to enter the permit space to eliminate hazards, such entry must be performed under the requirements of the permit space program.
  • When hazards arise within a permit-required space that has been declassified to a nonpermit space, anyone in the space must exit; under such conditions, the employer must reevaluate the space and determine if it will be reclassified as a permit space.