Date: Mon, 3 Dec 2007 21:15:16 +0000
Reply-To: roger.o.mcclellan**At_Symbol_Here**ATT.NET
Sender: DCHAS-L Discussion List <DCHAS-L**At_Symbol_Here**LIST.UVM.EDU>
From: roger.o.mcclellan**At_Symbol_Here**ATT.NET
Subject: Re: Confined Space question
Comments: To: Diane Amell

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** -------------- 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 > > 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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