I suggest that at the first step one should ask if it makes COMMON SENSE to treat it as a confined space without any consideration of the regulations. A part of the COMMON SENSE approach is to ask if you were personally involved as a worker how would you like to see it handled. If the answer is you would like it treated as a confined space than ask the Plant Manager if he wants to substitute and be the first worker who proceeds if it is not treated as a confined space. COMMON SENSE and Professional Judgement should always be used before addressing  regulations and definitions.
    Roger

Roger O. McClellan, DVM, MMS, DSc(Honorary), Dipl-ABVT, Dipl-ABT, Fellow-ATS
Advisor, Toxicology and Human Health Risk Analysis 
13701 Quaking Aspen Place NE 
Albuquerque, NM 87111 
Tel: 505-296-7083 
Fax: 505-296-9573 
E-mail: roger.o.mcclellan**At_Symbol_Here**att.net 


-------------- Original message from Diane Amell : -------------- 

> 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) 

Previous post   |  Top of Page   |   Next post