Limited or Restricted Egress
Criteria and Interpretations
A space is considered to have limited or restricted means of entry or exit if an entrant's ability to escape in an emergency situation would be hindered.
Doors and Portals
The dimensions of a door and its location should be considered when evaluating a space and determining if it poses a limited or restricted means of entry or exit. However, the presence of a door does not in and of itself mean that the space is not a confined space.
- 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 entrant 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 entrant has to crawl to gain access to the intended work location.
- An access door or portal which is too small to allow an entrant to walk upright and unimpeded through it will be considered to be restrictive.
- A door configuration which requires a person to step over a raised threshold would be considered to be restrictive.
- Doors that can be secured in an open position, or where the doors can be opened from inside the space, such as truck trailers, ovens, or freezers, are not considered to be restrictive.
Ladders and Stairs
Ladders and temporary, movable, spiral, or articulated stairs are usually considered to be a limited or restricted means of egress. Fixed industrial stairs, in compliance with OSHA standards, generally indicate the space is designed for human occupancy and would only make a space "confined" if they would interfere with the entrant's ability to exit or be rescued in a hazardous situation.
Tunnels and Culverts
The distance and/or time that it would take an entrant to travel in a space to reach a point of safety is another determinant for restricted exit. Although OSHA provides no definitive criteria for the time or distance traveled to limit or restrict egress, Virginia Tech uses a rule of thumb of 50 feet from an unrestricted door.
Open-Topped Spaces
Open-topped spaces, such as pits (including elevator pits), dikes, dump truck beds, roll-off dumpsters, tanks, excavations, etc., would be considered to have limited or restricted means of egress if they are greater than four feet deep (i.e. where a ladder would be necessary for safe egress). Where doors are provided and secured in an open position, such as in dump truck beds and roll-off containers, the space would not be considered to have limited or restricted means of egress. In addition, for roll-off containers that do not have doors, the use of a temporary stair meeting the specifications for a fixed industrial stair, securely installed, would provide an unrestricted means of egress.
Attics, Crawl Spaces, and Drop Ceilings
These spaces often meet the criteria for having a limited or restricted means of egress due to the size of the door, portal, or access way and would be considered to be confined spaces. However, OSHA does recognize the fact that they often have adequate natural or mechanical ventilation and typically do not contain other serious hazards, and therefore are generally considered to be non-permit spaces based upon the presence or absence of other serious hazards.