As the debate continues in the refrigeration industry regarding the classification of evaporative condensers, I had someone send me a picture from one of the main manufacturers of evaporative condensers showing me an example of an evaporative condenser that no longer has “limited means of egress” and therefore it is no longer a Confined Space and therefore is not a Permit-Required Confined Space. The company is actually marketing the “man-sized” access door to improve access to the unit’s basin; however, they make no mention as to this “man-sized” access door having anything to do with revising a Confined Space assessment. Here is the “man-sized” access door, here is what OSHA says about limited egress, and what say you…

man sized door not

NOTE:  I have blanked out the name of the company and brand name - this is NOT about the company of this unit, but rather the poor judgement of some who claim this "man-sized" door changes the classification of this unit.

 

To provide some perspective on the size of this "man-sized" door, here is another pic from their brochure:

man sized door not2

 

OSHA has actually provided two (2) explanations as to what is considered “limited means of egress”. One is found in their relatively new Confined Spaces in Construction standard:

Limited or restricted means for entry or exit means a condition that has a potential to impede an employee's movement into or out of a confined space. Such conditions include, but are not limited to, trip hazards, poor illumination, slippery floors, inclining surfaces and ladders.

 

The other explanation is provided in their Compliance Directive CPL 02-00-100, Application of the Permit-Required Confined Spaces (PRCS) Standards, 29 CFR 1910.146. In this CPL OSHA states:

1. Under what circumstances will stairs or ladders constitute a limited or restricted means of egress under the standard?

Ladders, and temporary, movable, spiral, or articulated stairs will usually be considered a limited or restricted means of egress. Fixed industrial stairs that meet OSHA standards will be considered a limited or restricted means of egress when the conditions or physical characteristics of the space, in light of the hazards present in it, would interfere with the entrant's ability to exit or be rescued in a hazardous situation.

2. Does the fact that a space has a door mean that the space does not have limited or restricted means of entry or exit and, therefore, is not a "confined space"?

A space has limited or restricted means of entry or exit if an entrant's ability to escape in an emergency would be hindered. The dimensions of a door and its location are factors in determining whether an entrant can easily escape; however, the presence of a door does not in and of itself mean that the space is not a confined space. For example, a space such as a bag house or crawl space that has a door leading into it, but also has pipes, conduits, ducts, or equipment or materials that an employee would be required to crawl over or under or squeeze around in order to escape, has limited or restricted means of exit. A piece of equipment with an access door, such as a conveyor feed, a drying oven, or a paint spray enclosure, will also be considered to have restricted means of entry or exit if an employee has to crawl to gain access to his or her intended work location. Similarly, an access door or portal which is too small to allow an employee to walk upright and unimpeded through it will be considered to restrict an employee's ability to escape. OSHA published a technical amendment to the preamble in Federal Register / Vol. 59, No. 213 / Friday, November 4, 1994, page 55208.

Amendment to Preamble of 29 CFR 1910.146

In the Permit-Required Confined Spaces standard, on pages 4477 and 4478 of the January 14, 1993 Federal Register document preamble, OSHA made the following statement:

As indicated in the preamble to the proposal [54 FR 24089], OSHA notes that doorways and other portals through which a person can walk are not to be considered limited means for entry or exit.

This sentence was intended to limit the application of the definition of confined spaces to those areas where an employee would be forced to enter or exit in a posture that might slow self-rescue, or make rescue more difficult. These spaces warrant additional consideration as to whether they pose a hazard to entrants and would, therefore, be regulated as permit-required confined spaces (permit spaces). For example, even if the door or portal of a space is of sufficient size, obstructions could make entry into or exit from the space difficult. The Agency intended that spaces which otherwise meet the definition of confined spaces, and which have obstructed entry or exits even though the portal is a standard size doorway, be classified as confined spaces. OSHA acknowledges that the preamble to the final rule did not clearly express that intent.

Accordingly, OSHA is adding preamble language to follow the above- mentioned statement. This text will make OSHA's original intent clear, without changing the PRCS standard.

4. How will OSHA assess a space which is entirely open on one plane, such as a pit, in determining whether a space has limited or restricted means for entry or exit?

In determining whether a space has limited or restricted means for entry or exit, OSHA will evaluate its overall characteristics to determine if an entrant's ability to escape in an emergency would be hindered. Thus, a pit, shaft or tank that is entirely open on one plane can be considered a confined space if the means for entering the space (stairway, ladderway, etc.) are narrow or twisted, or otherwise configured in such a way as to hinder an entrant's ability to quickly escape
(See question No. 1 of this section). Similarly, the pit, shaft, or tank itself may be confining because of the presence of pipes, ducts, baffles, equipment or other factors which would hinder an entrant's ability to escape.

 

So with these data points directly from OSHA publications, how would one come to the conclusion that this “man-sized” door does not present limited means of egress? Yes the door is larger than a manway, but it is neither large enough or designed to eliminate “limited means of egress”. Just the design of the doorway which is too small to allow an employee to walk upright and unimpeded through it restricts an entrants ability to escape.

 
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