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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