How to Reclassify a Permit-Required Confined Space to a Non-Permit Confined Space

A permit-required confined space (PRCS) is defined by OSHA as a confined space that:

1. contains or has the potential to contain a hazardous atmosphere;
2. contains a material that has the potential for engulfing an entrant;
3. has an internal configuration such that an entrant could be trapped or asphyxiated by inwardly converging walls or by a floor which slopes downward and tapers to a smaller cross-section; or
4. contains any other recognized serious safety or health hazard.

Employers have the option to reclassify a PRCS to a non – permit confined space under paragraph (c)(7) of 29 CFR 1910.146. If the space under consideration has no atmospheric hazards, and has no potential for an atmospheric hazard to arise, a space may be able to be reclassified to a non – permit confined space. For a space to be reclassified, all hazards must be eliminated. Once all hazards have been eliminated, the space is temporarily reclassified as non – permit, and remains non – permit as long as the hazards are eliminated.

Employers must also document how they determined the hazards were eliminated. Having the option of reclassifying a permit space to a non – permit space gives the employer an alternative to a full permit entry, which is usually safer for employees and may be a less expensive option for employers.

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