Date: Mon, 3 Dec 2007 14:57:46 -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: "Gary M. Kehoe"
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
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
as the one Irwin posted on the AIHA list earlier today but he is a hard
to follow.

We have a situation where the top of coal silos need to be accessed
silos are not entered) on a routine basis to vacuum accumulated coal
The silos are not entered at any time during this activity.   The top
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
space below this room that is essentially wide open.  Due to the
of structural steel in the area above these silos, they cannot be
any other way and movement between the silos is not possible.  The
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
see the top of the silos from adjacent walkways in the boiler room
And you can usually see into the boiler room from the top of the silo
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
reside and there are no atmospheric hazards present.  Just to be
clear, the air in this area is the same atmosphere as in the entire
room and routine work being done in the area would not generate a

Strictly speaking the area has limited access, is not intended for
continuous occupancy, and can be entered to perform work so it meets
definition of a confined space.  There is a fall hazard in that a
could fall off one of the silo tops but there is no atmospheric
Where I am having a little heartburn is trying to explain to the
that this meets the criteria of a confined space.  Their analogy is
accessing a tank top outside via climbing down a ladder from a
Would that be treated a confined space?  Not in my book although it
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
312-925-1813 (C)
312-788-5533 (F)

Previous post   |  Top of Page   |   Next post

The content of this page reflects the personal opinion(s) of the author(s) only, not the American Chemical Society, ILPI, Safety Emporium, or any other party. Use of any information on this page is at the reader's own risk. Unauthorized reproduction of these materials is prohibited. Send questions/comments about the archive to
The maintenance and hosting of the DCHAS-L archive is provided through the generous support of Safety Emporium.