OSHA’s “Limited or Restricted Entry & Exit” Confined Space Definition

Michelle Graveen, ASP, SMS, editor, J. J. Keller & Associates

As a business or group leader, it’s important to understand what is considered limited or restricted means of entry and exit, and how it affects your employees’ safety. The Occupational Safety and Health Administration’s General Industry standard at 29 CFR 1910.146 defines a confined space as meeting all of the following criteria:

1. Is large enough for an employee to bodily enter and work; and
2. Has limited or restricted means of entry and exit; and
3. Is not designed for continuous occupancy.

If the entrants may freely step into and out of the space, without having to step over a raised threshold or stoop under the door opening; and if equipment in the space or the travelling distance to the exit could not interfere with the entrants’ ability to escape in an emergency, then there would be no limited means of entry or exit. If this is the case, then the space does not meet the definition of “confined space.”

OSHA’s compliance directive, CPL 2.100—Application of the Permit-Required Confined Spaces (PRCS) Standards, includes the following guidance in Section (b) of Appendix E:

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.

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.

What about small openings in a confined space?

A space may be large enough inside for an employee to enter and work, but the portal to the space may be very small. A confined space (and a permit-required confined space) must have an entry port that is large enough to allow full-body entry. If the entrance is too small for a worker to completely enter, or if the space itself is too small for a worker to completely enter, then OSHA’s confined spaces standard does not apply. However, that does not mean that the space cannot be hazardous or that other OSHA standards do not apply. WMHS

About the author:
Michelle Graveen is certified as an Associate Safety Professional and a Safety Management Specialist and is an Editor at J. J. Keller & Associates, a nationally recognized compliance resource company that offers products and services to address the range of responsibilities held by business professionals. Graveen has 15 years of experience in industrial and occupational safety, having worked in a variety of industries, including heavy manufacturing, chemical manufacturing, warehousing and insurance. She is the editor of J. J. Keller’s Workplace Safety Manual for California Business and specializes in federal and California workplace safety topics—covering safety training, welding, permit-required confined space, lockout/tagout, powered industrial vehicles and other critical safety issues. For more information, visit www.jjkeller.com/osha and www.jjkellerlibrary.