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
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>>> 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)
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