RECORD ID D00-04-004

STANDARD NUMBER

INFORMATION DATE 04-17-2000

SUBJECT Confined Spaces; Limited Means Of Entry Or Egress.

QUESTION

In evaluating an air handler unit as a confined space, a controversial element is encountered. Generally, there is a 4" "lip" at the bottom of the opening; and the doorway opening is typically more narrow than a standard doorway. Does this configuration (somewhat narrow opening and a 4" lip) constitute a "limited means of entry or egress," and satisfy 1 of 3 criteria to establish a confined space? What constitutes "limited entry?" Is it contorting the body in any manner, such as turning your shoulders for entry? Is the "lip" considered a tripping hazard, and therefore inhibits unfettered egress?

REGULATORY REVIEW

This responds to your question concerning the classification of air handlers as confined spaces under 29 CFR 1910.146, Permit-Required Confined Spaces. Based on your submission and telephone discussions, it would appear the interior of air handlers in question would generally meet the three criteria for a confined space from the standard's definition section (see excerpts from 29 CFR 1910.146 (b) below). If serious hazards are either nonexistent or controlled, the space should be considered a "Non-permit" space. Spaces should be classified appropriately and not be over classified. Improperly classifying all confined spaces as permitted tends to dilute the importance of utilizing appropriate measures when serious hazards exist. Definitions utilized in this Interpretation from 29 CFR 1910.146 "Confined space" means a space that: (1) Is large enough and so configured that an employee can bodily enter and perform assigned work; and (2) Has limited or restricted means for entry or exit (for example, tanks, vessels, silos, storage bins, hoppers, vaults, and pits are spaces that may have limited means of entry.); and (3) Is not designed for continuous employee occupancy. "Non-permit confined space" means a confined space that does not contain or, with respect to atmospheric hazards, have the potential to contain any hazard capable of causing death or serious physical harm. "Permit-required confined space program (permit space program)" means the employer's overall program for controlling, and, where appropriate, for protecting employees from, permit space hazards and for regulating employee entry into permit spaces.