Confined Spaces

Plant Managers – Friday Plant Walks– Confined Spaces

Do you have Confined Spaces in your plant? I’m talking about the OSHA definition of confined spaces, not cramped closets.

You thought of silos, didn’t you? (Ace of Clubs.)

I mean confined spaces like silos, mixing vessels, reactors, material receivers, packout bins, day bins, pellet traps, cooling towers, water tanks, etc.

CONFINED SPACE – This is a brief and PARTIAL summary, but OSHA defines a confined space as a space that:

1. Is large enough and configured so an employee can bodily enter it;

2. Is difficult to get into or out of; and

3. Is not designed for continuous occupancy.

That small closet meets 1 and 3, but not 2 – there’s a door.

Inside the silo? That’s 1, 2, and 3. I’m talking about the business part of the silo where material is stored – not the walk-in part at ground level, at the cone.

(I just had a flashback to 12-year-old William inside a silo, leveling corn with a shovel as trucks were being unloaded via the auger up top. It’s crazy what you’ll do when you don’t know any better.)

PERMIT-REQUIRED CONFINED SPACE is a subset of the above, but the space:

1. May contain a hazardous atmosphere;
2. Contains material that could engulf someone in the space;
3. Is configured so someone could be trapped or asphyxiated;
4. Any other serious safety hazard.

Say you have a reactor or mixer where you compound or mix liquids – round at the top with a sloped bottom section. Say your folks go inside to clean it between products.

Referencing the above items, even if it’s empty:

• Hazardous atmosphere – are the pipes that bring material to the vessel isolated? Could a pump turn on and supply liquids or gases to the vessel?
• Engulfment – those pipes again. Or a dumper that feeds the space.
• Trapped – that sloped bottom.
• Any other hazard – an agitator that’s not locked out; steam lines.

All those potential hazards must be addressed, including testing the atmosphere with an air monitor, retrieval plan, and rescue plans. Some spaces can be reclassified as a non-permit confined space under certain conditions.

There is a lot more to confined spaces that can be covered in a LinkedIn post, but here’s what you can check in an afternoon:

• Do you (or HSE) have a list of the confined spaces at your plant? Does that list designate which of those are Permit-Required? Hazards of the space? Retrieval and rescue methods?
• Walking your plant, are there “DANGER – PERMIT-REQUIRED CONFINED SPACE – DO NOT ENTER signs on vessels and silos?
• Do your folks understand confined spaces?
• As you’re walking, look at tanks and vessels and consider whether your folks or contractors ever go inside them. How are they doing it safely? If they’re cleaning those vessels at night or on the weekends, how are they doing it?

If you want to understand more about this topic, see the OSHA link in the first comment.

Have a good weekend.

1910.146 – Permit-required confined spaces | Occupational Safety and Health Administration (osha.gov)