If I understand correctly what the scenario is, it is not a
permit-required confined space per the federal OSHA memo of
interpretation found at 
http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=INTERPRETATIONS&p_id=22697.
This is, of course, if the before-mentioned dust explosion hazard does
not exist.
 
- Diane Amell, MNOSHA
 

>>> "Gary M. Kehoe"  11/28/2007 5:28 PM >>>

First I apologize for the cross posting.  This issue is not as
interesting
as the one Irwin posted on the AIHA list earlier today but he is a hard
act
to follow.

We have a situation where the top of coal silos need to be accessed
(the
silos are not entered) on a routine basis to vacuum accumulated coal
dust.
The silos are not entered at any time during this activity.   The top
of
the silos are accessed via a hatch in the floor of a room above and an
attached ladder.  The space between the floor above and the top of the
silos is approximately 4-5 feet.  The silos themselves reside in the
open
space below this room that is essentially wide open.  Due to the
location
of structural steel in the area above these silos, they cannot be
accessed
any other way and movement between the silos is not possible.  The
space
between the top of the silos and the floor above is not sealed but the
structural steel blocks access and limits movement.  In some cases you
can
see the top of the silos from adjacent walkways in the boiler room
though.
And you can usually see into the boiler room from the top of the silo
but
what you see is limited by the structural steel in the area.

The atmosphere in this area is the same as the room in which the
bunkers
reside and there are no atmospheric hazards present.  Just to be
completely
clear, the air in this area is the same atmosphere as in the entire
boiler
room and routine work being done in the area would not generate a
hazardous
atmosphere.

Strictly speaking the area has limited access, is not intended for
continuous occupancy, and can be entered to perform work so it meets
the
definition of a confined space.  There is a fall hazard in that a
worker
could fall off one of the silo tops but there is no atmospheric
hazard.
Where I am having a little heartburn is trying to explain to the
station
that this meets the criteria of a confined space.  Their analogy is
accessing a tank top outside via climbing down a ladder from a
platform.
Would that be treated a confined space?  Not in my book although it
meets
the criteria, it is not "confined".   What is your opinion on how this
space should be classified and treated?

Thanks for your input.

Gary M. Kehoe, CIH
Senior Industrial Hygienist
Midwest Generation EMG
773-650-5732
312-925-1813 (C)
312-788-5533 (F)

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