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Date: Mon, 3 Dec 2007 16:46:36 -0600
Reply-To: Diane Amell <Diane.Amell**At_Symbol_Here**STATE.MN.US>
Sender: DCHAS-L Discussion List <DCHAS-L**At_Symbol_Here**LIST.UVM.EDU>
From: Diane Amell <Diane.Amell**At_Symbol_Here**STATE.MN.US>
Subject: Re: Confined Space question
Comments: To: roger.o.mcclellan**At_Symbol_Here**att.net
Hello everyone!
I'm sorry, but what I can address are the regulations and their
interpretations; i.e., the legal OSHA requirements. In this case,
rightly or wrongly, I interpreted his question as trying to classify the
space as defined under 1910.146. We certainly encourage employers to go
over and above the standard requirements, especially given that some of
them are 30+ years old.
(Actually I held off answering this earlier, in hopes that someone else
would, but alas and alack, only Pat Thomas did.)
- Diane Amell, MNOSHA
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>>> 12/3/2007 3:15 PM >>>
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)
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