Based on my experience in the power industry and our work on power plants, I am inclined to respectfully disagree with Ms. Amell. As I understand it, an individual has already entered a confined space (per 29 CFR 1910.146(b)) and then is exposed to a fall hazard greater than 6'. I don't believe the LOI is applicable in this case. This is similar to the hot deck on a precipitator in a power plant. In that situation, I believe that the space would be a PRCS per 1910.146(b). Obviously, an assessment should be performed prior to the execution of any work in the space. I would also have to (again, repectfully!)disagree with Dr. McClellan regarding common sense. In the early 20th century, it was common sense to test for voltage on a conductor by touching the conductor with the thumb and forefinger. Obviously this is not a good idea. Common sense is merely a collective belief in some process or procedure, and that that belief is right or correct. I would put forth that every task in the workplace be planned and that plan then executed. If during the execution of the task, a situation arises that was not planned for, then we step back and re-assess our plan and address the new issue rather than "shooting from the hip" or just plowing through. My opinions are based on years of experience in the electrical construction industry and the industrial hygiene field. Mark R. Ellison Corporate Safety Director Sachs Electric Company Telephone: 636.532.2000, ext. 270 Facsimile: 636.532.8980 "Plan Safety - Work Safely" -----Original Message----- From: DCHAS-L Discussion List [mailto:DCHAS-L**At_Symbol_Here**LIST.UVM.EDU] On Behalf Of Diane Amell Sent: Monday, December 03, 2007 4:47 PM To: DCHAS-L**At_Symbol_Here**LIST.UVM.EDU Subject: Re: [DCHAS-L] Confined Space question 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 This e-mail and any attachments are confidential and may be privileged information. If you are not the intended recipient, or the person responsible for delivering it to the intended recipient, please notify the sender immediately by replying to this message and destroy all copies of this message and the attachments. Unless otherwise noted, the opinion expressed above is provided by a staff member of the Minnesota Occupational Safety and Health Compliance Division. This response is not binding. You may request a formal opinion from the Minnesota Occupational Safety and Health Compliance Division. For details, visit our website at www.doli.state.mn.us/mnosha.html and click on "How to request a formal opinion". >>>
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=INTERPRETA TIONS&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) This e-mail transmission, and any of its attachments, may contain information that is confidential and may be privileged. This e-mail is intended only for the addressee(s) named above. If you receive this e-mail in error, please do not read, copy or disseminate it in any manner. If you are not the intended recipient, any disclosure, copying, distribution or use of the contents of this information is prohibited and may be unlawful. If you have received this communication in error, please reply to the sender immediately by reply e-mail and/or by telephone, informing the sender that the message was misdirected. After replying, please erase it from your computer system. Thank you.
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