Gary,
I think one thing that needs to be looked at is the potential for a coal 
dust explosion.  Are precautions being taken, what type of vacuum is 
being used, what is the potential for static buildup, does the vacuum 
have a potential for spark generation, what are the accumulations, what 
is the humidity of the space, is it a possibility?  If any of this 
applies then in fact you do have a hazardous atmosphere because if there 
is an explosion inside of the silos then the people doing the vacuuming 
are goners just as if they were in an inert environment.  
Pat Thomas
  ----- Original Message ----- 
  From: Gary M. Kehoe 
  To: DCHAS-L**At_Symbol_Here**LIST.UVM.EDU ; safety**At_Symbol_Here**ls.eei.org ; ih**At_Symbol_Here**ls.eei.org ; 
aihaih-list**At_Symbol_Here**YahooGroups.com 
  Cc: John Mulroy 
  Sent: Wednesday, November 28, 2007 5:28 PM
  Subject: [aihaih-list] Confined Space question


  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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