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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