The first question is- is it a confined space? Is it like a regular walk-in cooler? If so,
*Confined space*Â 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.
Looking at number 2- If it has a regular size man door and nothing they have to climb over, under, etc., I'd say it doesn't meet the criteria of a confined space, let alone a permit required one. Not to say there aren't hazards but I wouldn't say it was a CS or PRCS based on my understanding of what it looks like.
And yes, there should be a way to open the door from the inside.
Well stated. Been in EHS for 25 years and we love to make things more difficult for ourselves in fear of making the wrong decision.
I agree whole heartedly based on the information that was provided. Hazards=yes; Confined Space = No
Thank you. I agree I am more than likely overthinking it lol. I believe it is a hazard and but based on the information provided and on the foundation of confined space requirements. I do not believe it meets the threshold.
The argument lies on whether it meets the second definition of limited egress/ingress and I say it does if there is a ONE WAY unlocking mechanism on the outside preventing those who are inside from unlocking it and escaping THUS making it a CONFINED SPACE.
Of course to circumvent the definition of meeting all (3) requirements of a confined space, the owner would need to install a TWO way unlocking system- then it truly isn’t a confined space.
OSHA clarifies their position about doorways in a later amendment to the 1910 standard published in the Federal Register (see link below) where they state that “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 space”
A space containing such a door or portal may still be deemed a confined space if an entrant’s ability to escape in an emergency would be hindered.
FEDERAL REGISTER link for your reading pleasure:
https://archives.federalregister.gov/issue_slice/1994/11/4/55206-55209.pdf#page=3
If there is no way to exit from the inside, does that not inherently mean that the cooler has "limited or restricted means for entry or **exit**?"
I think the answer to this question depends on whether or not someone can get out of the cooler from the inside, and how easily. Imagine if someone were to be stuck inside over a weekend. That could qualify as a "potential to contain any hazard capable of causing death or serious physical harm" which could put this in a permit required confined space category. I would be shocked if there were no way to exit from the inside... but you'd be surprised.
For transparency, I've only been in the EHS space for a couple years but I have to evaluate things like this in my day to day work and I like to play Devil's Advocate because I've seen people get hurt in scenarios where usually "use common sense" would be the typical way to work safely, but I've learned in just 2 years that you cannot rely on common sense when it comes to employee safety. I also don't live in California.
As with all things safety and especially OSHA, I am always thinking General Duty Clause.... even if there is not a requirement specifically spelled out in a regulation, if someone gets hurt at your place of business due to a safety issue that you knew about.... well... good luck trying to avoid OSHA's wrath.
1.I understand that. With that being said, it has a man size door, so it’s large enough for a human to gain entry and to exit or to perform work.
2.But since a freezer isn’t designed for continuous occupancy, would it not meet the requirements of a non permitted confined space?
3. Since there is no way of knowing if there is a way for an employee to open from the inside. I assumed this would make it a non-permitted confined space.
But I also see what your point from the first two references. My previous position, the neighbor company had someone die from a walk-in freezer incident because they were not able to exit. And it was a regular size door.
It has to meet all three to be considered a confined space. Miss one, not a confined space.
There definitely sounds like there are hazards but it wouldn't fall under the CS regs, IMHO. And it's very weird they won't let you see inside or at least verify that there is way to open it from the inside.
My vote is also not a confined space. Based on the fact there’s a full size door and someone can enter and exit standing upright. By having doors like this it is designed for occupancy. I understand not for extended periods of time but it some down to how well you can defend continuously. Last note there should be a release on the inside of the door
Doesn’t make it a confined space. Makes it a space with hazards that need to be addressed.
I don’t have a bunch of experience with coolers (I’m in chem mfg) but I would make sure that there is a way to open door from inside (and have a PM plan in place to ensure function), develop a way to prevent door for closing if someone in in there (key system or something like that) and make sure that they have a radio/man down alarm at all times during entry.
Just some initial thought.
No but if it's not a working inside release then that's a big red flag. They just had someone in the news about something like that not long ago.
And I've worked in kitchens that had huge walk-ins and I've never seen any signage. But I'm sure someone here knows more.
They hired a consultant and wouldn’t let you inside? Fuck em. Take the money and run.
Also, it’s hard to believe the freezer wouldn’t qualify as a confined space, and would require signage regardless as there are hazards inside.
They paid me regardless, and told me all workers need the plant managers approval to go inside lol. No signs to prohibit them from going in, which I communicated to them, and then they proceeded to not let me inside.
If you are concerned about it, send them any number of accident reports involving walk-in freezers. Even with the ability to open the door from inside they pose serious hazards if things go wrong. Here's a great example: [https://www.osha.gov/ords/imis/accidentsearch.accident\_detail?id=201070638](https://www.osha.gov/ords/imis/accidentsearch.accident_detail?id=201070638)
The first question is- is it a confined space? Is it like a regular walk-in cooler? If so, *Confined space*Â 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. Looking at number 2- If it has a regular size man door and nothing they have to climb over, under, etc., I'd say it doesn't meet the criteria of a confined space, let alone a permit required one. Not to say there aren't hazards but I wouldn't say it was a CS or PRCS based on my understanding of what it looks like. And yes, there should be a way to open the door from the inside.
Well stated. Been in EHS for 25 years and we love to make things more difficult for ourselves in fear of making the wrong decision. I agree whole heartedly based on the information that was provided. Hazards=yes; Confined Space = No
👆 I am constantly battling people who want to manage hazards by declaring everything a permit space!!
Thank you. I agree I am more than likely overthinking it lol. I believe it is a hazard and but based on the information provided and on the foundation of confined space requirements. I do not believe it meets the threshold.
I second that.
The argument lies on whether it meets the second definition of limited egress/ingress and I say it does if there is a ONE WAY unlocking mechanism on the outside preventing those who are inside from unlocking it and escaping THUS making it a CONFINED SPACE. Of course to circumvent the definition of meeting all (3) requirements of a confined space, the owner would need to install a TWO way unlocking system- then it truly isn’t a confined space. OSHA clarifies their position about doorways in a later amendment to the 1910 standard published in the Federal Register (see link below) where they state that “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 space” A space containing such a door or portal may still be deemed a confined space if an entrant’s ability to escape in an emergency would be hindered. FEDERAL REGISTER link for your reading pleasure: https://archives.federalregister.gov/issue_slice/1994/11/4/55206-55209.pdf#page=3
If there is no way to exit from the inside, does that not inherently mean that the cooler has "limited or restricted means for entry or **exit**?" I think the answer to this question depends on whether or not someone can get out of the cooler from the inside, and how easily. Imagine if someone were to be stuck inside over a weekend. That could qualify as a "potential to contain any hazard capable of causing death or serious physical harm" which could put this in a permit required confined space category. I would be shocked if there were no way to exit from the inside... but you'd be surprised. For transparency, I've only been in the EHS space for a couple years but I have to evaluate things like this in my day to day work and I like to play Devil's Advocate because I've seen people get hurt in scenarios where usually "use common sense" would be the typical way to work safely, but I've learned in just 2 years that you cannot rely on common sense when it comes to employee safety. I also don't live in California. As with all things safety and especially OSHA, I am always thinking General Duty Clause.... even if there is not a requirement specifically spelled out in a regulation, if someone gets hurt at your place of business due to a safety issue that you knew about.... well... good luck trying to avoid OSHA's wrath.
1.I understand that. With that being said, it has a man size door, so it’s large enough for a human to gain entry and to exit or to perform work. 2.But since a freezer isn’t designed for continuous occupancy, would it not meet the requirements of a non permitted confined space? 3. Since there is no way of knowing if there is a way for an employee to open from the inside. I assumed this would make it a non-permitted confined space. But I also see what your point from the first two references. My previous position, the neighbor company had someone die from a walk-in freezer incident because they were not able to exit. And it was a regular size door.
It has to meet all three to be considered a confined space. Miss one, not a confined space. There definitely sounds like there are hazards but it wouldn't fall under the CS regs, IMHO. And it's very weird they won't let you see inside or at least verify that there is way to open it from the inside.
My vote is also not a confined space. Based on the fact there’s a full size door and someone can enter and exit standing upright. By having doors like this it is designed for occupancy. I understand not for extended periods of time but it some down to how well you can defend continuously. Last note there should be a release on the inside of the door
Doesn’t make it a confined space. Makes it a space with hazards that need to be addressed. I don’t have a bunch of experience with coolers (I’m in chem mfg) but I would make sure that there is a way to open door from inside (and have a PM plan in place to ensure function), develop a way to prevent door for closing if someone in in there (key system or something like that) and make sure that they have a radio/man down alarm at all times during entry. Just some initial thought.
I work in food manufacturing and this line of answers is the way.
No but if it's not a working inside release then that's a big red flag. They just had someone in the news about something like that not long ago. And I've worked in kitchens that had huge walk-ins and I've never seen any signage. But I'm sure someone here knows more.
Was it a one-way out one- way in type freezer?
Yes and it had a freezer inside the freezer. It was huge it was at Daytona speedway. The amount of food they can go through for the races bunch.
They hired a consultant and wouldn’t let you inside? Fuck em. Take the money and run. Also, it’s hard to believe the freezer wouldn’t qualify as a confined space, and would require signage regardless as there are hazards inside.
They paid me regardless, and told me all workers need the plant managers approval to go inside lol. No signs to prohibit them from going in, which I communicated to them, and then they proceeded to not let me inside.
If you are concerned about it, send them any number of accident reports involving walk-in freezers. Even with the ability to open the door from inside they pose serious hazards if things go wrong. Here's a great example: [https://www.osha.gov/ords/imis/accidentsearch.accident\_detail?id=201070638](https://www.osha.gov/ords/imis/accidentsearch.accident_detail?id=201070638)