As we know, 1910.146 gives employers three (3) methods to enter Permit-Required Confined Spaces:

1) Full permitted entry following (d)-(k),

2) alternative entry methods prescribed in (c)(5), and

3) reclassification of the PRCS to a non-permit space by following (c)(7).

However, in the past year or so, we have come across another method… using BOTH (c)(5) AND (c)(7) in the same space at the same time. Questions:

1) Is this compliant with 1910.146?

2) Is this safe?

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