Electrical welding in a nonpermit confined space

May 12, 1997
[Name Withheld]
Dear [Name Withheld]:
Thank you for your letter dated April 11, addressed to the Directorate of Safety Standards, requesting an interpretation of the Occupational Safety and Health Administration (OSHA) Permit-Required Confined Spaces (PRCS) standard, 29 CFR 1910.146. Your letter was referred to this office for response.
With regard to your question whether the introduction of electrical welding equipment into a non-permit confined space automatically leads to a reclassification of the space to a PRCS, please be advised that as long as the protective measures of Subpart Q — Welding, Cutting and Brazing, prevent a hazard from developing, the use of electrical welding equipment would not cause a confined space to be classified as PRCS.
The protective measures of other standards would be applicable to the work in this space, specifically the following paragraphs of Subpart Q. [1910.252(a)(4)(i), 1910.252(b)(4)(i) to 1910.252(b)(4)(vii), 1910.252(c)(4), 1910.252(c)(9), and 1910.252(c)(10)] must be followed.
In addition, please be advised that the use of cord and plug electrical equipment in a non-permit confined space does not cause the non-permit space to become a PRCS.
We appreciate your interest in occupational safety and health. If we can be of further assistance, please call [(202) 693-1850].
Sincerely,
John B. Miles, Jr., Director
Directorate of Compliance Programs
[Corrected 4/14/2009]