August 6, 1996

Robert Lishey
Risk Specialist
City of Portland Environmental Services
5001 N. Columbia Blvd
Portland, OR 97203-2409

Dear Mr. Lishey,

This is in response to your letter requesting clarifications on 1910.146, “Permit Required Confined Spaces.”

1910.146(k)(3) requires that retrieval systems be used except when the retrieval equipment would increase the risk to an entrant or would not contribute to the rescue of an entrant. When a retrieval system is not used, alternate methods of retrieval must be developed, and rescue personnel must be trained in retrieving the entrant in the event of an emergency.

The code does not prohibit a confined space being reconfigured to facilitate non-entry removal of an entrant.We hope this answers your question regarding confined spaces. If you have any questions or if we can be of further assistance, please contact David McLaughlin at (503) 378-3272.

Sincerely,

Marilyn K. Schuster, Manager
Standards and Technical Resources Section
Oregon Occupational Safety and Health Division