Permit - required confined spaces
1910.146 (B 5)
"Non- permit confined space" means a confined space that does not contain or, with respect to atmospheric hazards, have the potential to contain any hazard capable of causing serious physiacal harm.
if I read it right "WITH RESPECT TO ATMOSPERIC HAZARDS"
would mean an atmosphere with less than 19.5% oxygen by volume (in this case)
Permit-required confined space (permit space)"
means a confined space that has one or more of the following characteristics;
(1) Contains or has the potential to contain a hazardous atmosphere
(2) Contains a material that has the potential for engulfing an entrant
(3) Has an internal configuration such that an entrant could be trapped or asphyxiated by inwardly converging walls or by a floor which slopes downward and tappers to a smaller cross section
(4) Containing any other recognized serious saftey or health hazard
the only thing here I believe could come into argument would be (4) and in that casse i believe a body harness attached to the ladder with a fall arrest lanyard would probally suffice
If air movment is an issue a small fan could be used to move the air (c)(5)(i)(b), (c)(5)(ii), (E)(3)
I would most definatley post an Attendant
(i)(4), (i)(5), (i)(6), (d)(6)
this is just my opinion, dont get me wrong i'm not saying throw caution to the wind or to take a devil may care attitude, be safe and take precautions,I do agree that it would be a confine space but I dont think it would be a "permit reqiured" confined space but at times osha can make it almost impossible at times to meet the guidelines