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Confined Space Entry Program - How to control entry points when no permits used?

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  • Confined Space Entry Program - How to control entry points when no permits used?

    I did a few searches for this info prior to starting this thread. If its already addressed somewhere else, kindly point me to it and accept my apologies.

    I am working on our Confined Space Entry Program. I have all of our PRCS (Permit Required Confined Space) properly labeled.

    Per OSHA, if we want to allow entry (provide permit), we need a written program with testing, PPE, buddy-systems, extraction plans, and a whole lot more of headache.

    If we do NOT allow access, meaning NOBODY WILL EVER BE PERMITTED TO ENTER THE PRCS, I have to somehow control access points to prevent entry.

    The access points are manways on our Stout and Premier tanks. We also have serving tanks with a top lid that is bolted. I have no idea how to "control access" with these, and I really do not want to bolt/drill/weld/mount a bunch of hardware on manyway hatches.

    Has anyone already dealt with this? Got any simple fixes? Thanks!

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  • #2
    I had friends in the oil and gas industry and I asked to borrow there confined program manual. I had the girls up front re type it using our name instead of theres and all was well. I was on line to get a 10k fine but he said I will give you 24* to come up with the paper work so I made it in time. One thing you can also tell them is I dont go in there and theres nothing he can do about that. Did you know that even just sticking your hand in there means you have entered the vessel. I might suggest this to all reading this I learned allot about OSHA and their safety programs. I later had them come in so we could get certified in driving a fork lift (yes you need the class to be a legal driver) and began chatting with him, he told me the best thing to do is to call and ask for inspection. Now my owner about shit when I told him I did this but what is nice is that they cannot fine you for any violations on the voluntary Inspections I wrote down everything that he told me about and tried my best to get them all done. I now have a great working relationship with him and in fact he calls me when he has a trainee with him to come and "inspect" us. So long story short will they find something well probably but it will be pretty minor and he loves our beer so I catch him in here and we share a coldie.
    Mike Eme
    Brewmaster

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    • #3
      Thanks but...

      Originally posted by beerguy1 View Post
      I had friends in the oil and gas industry and I asked to borrow there confined program manual. I had the girls up front re type it using our name instead of theres and all was well. I was on line to get a 10k fine but he said I will give you 24* to come up with the paper work so I made it in time. One thing you can also tell them is I dont go in there and theres nothing he can do about that. Did you know that even just sticking your hand in there means you have entered the vessel. I might suggest this to all reading this I learned allot about OSHA and their safety programs. I later had them come in so we could get certified in driving a fork lift (yes you need the class to be a legal driver) and began chatting with him, he told me the best thing to do is to call and ask for inspection. Now my owner about shit when I told him I did this but what is nice is that they cannot fine you for any violations on the voluntary Inspections I wrote down everything that he told me about and tried my best to get them all done. I now have a great working relationship with him and in fact he calls me when he has a trainee with him to come and "inspect" us. So long story short will they find something well probably but it will be pretty minor and he loves our beer so I catch him in here and we share a coldie.
      That which you mention above constitutes a written confined space entry program. I do not want this. I am well aware of what constitutes "entry" per OSHA's definitions, and as far as they are concerned, WE DO NOT ENTER our PRCS. Because of this, I dont need a written confined space entry program, but I do need to somehow "control access" to prevent anyone from unauthorized entry.

      I'm looking for an way to lock the manyway doors, to avoid permits/measurements/etc that would again require the written program.

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      • #4
        Well done Mike , that's the right way to handle it. Nice Job, Up Front & Professional..

        Much better to make friends then enemies !!

        Gregg

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        • #5
          [QUOTE=jscottAT4;207060]That which you mention above constitutes a written confined space entry program. I do not want this. I am well aware of what constitutes "entry" per OSHA's definitions, and as far as they are concerned, WE DO NOT ENTER our PRCS. Because of this, I dont need a written confined space entry program, but I do need to somehow "control access" to prevent anyone from unauthorized entry.

          I'm looking for an way to lock the manyway doors, to avoid permits/measurements/etc that would again require the written program.[/QUOTE

          Damn I didnt want to piss you off
          Mike Eme
          Brewmaster

          Comment


          • #6
            Not pissed off, just looking for an answer to a question I cant seem to find an answer for.

            I'm trying to avoid having an **inspectable** written confined space entry program that requires testing, permits, and lots of stupid paperwork we wont need/use because ultimately we will not be entering confined spaces. This is just a bunch of paperwork and admin time, plus another thing to be discrepant on during an OSHA inspection.

            If I say "no access allowed", I only need to prevent access to the PRCS, and don't need all this paperwork.

            If I say "permitted access allowed", well now I have opened a very big and ugly can of worms that requires the written program, and all the ugly involved.

            Does this make sense?
            Last edited by jscottAT4; 07-12-2017, 11:59 AM.

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            • #7
              I have not had to jump down this rabbit hole so I dont know what all constitutes controlling access, but could it be as simple as having a chain across the manway with a sign that says "Confined space, no entry allowed"? Or maybe a lockout tag on the manway saying the same thing?
              Brandon Besser, P.E.
              "He that breaks a thing to find out what it is has left the path of wisdom" - Gandalf

              Comment


              • #8
                Originally posted by bbesser View Post
                I have not had to jump down this rabbit hole so I dont know what all constitutes controlling access, but could it be as simple as having a chain across the manway with a sign that says "Confined space, no entry allowed"? Or maybe a lockout tag on the manway saying the same thing?
                I like where your head is at, simple and effective.

                Thanks all for the input.

                If and when I ever get this figured out (waiting to hear back from an industrial hygienist who does OSHA compliance), I'll throw the details up here.

                PS - For what its worth, breweries in the area have received notice from OSHA stating intent for a Local Emphasis Program where they will start targeting craft breweries for compliance inspections. Confined Space Entry Program = PITA if you have not dealt with it before, or have not already started to.

                EDIT: Here is the response from industrial hygienist

                Hello J***,

                You are correct, if you do not allow employees to enter the spaces, then you are not required to maintain a written program. Placing signs and training employees not to enter the spaces satisfies the OSHA standard. The only other requirement is to ensure that if you hire contractors to perform work onsite, they are to be made aware of the spaces. If those contractors are to be working in the spaces, then you are responsible to ensure that they have an appropriate confined space program and do not endanger their employees or your employees.

                Nice work! Making sense of OSHA regulations is an accomplishment!

                Please feel free to ask any additional questions.

                So it looks like just telling employee's "don't go in there, dummy" in a nicer way satisfies OSHA standards. You don't need a Confined Space Entry Program if you are not ever going to allow or permit entry into the confined spaces. But, as pointed out by Mike above, the second ANY part of your body breaks that invisible plane, you have just "entered" a confined space. We have brushes, CIP systems, lights and mirros for inspection, so all work is designed to be performed outside of the space.

                Fun bit of trivia: Who is the man-way for in the first place? (Hint: Why is it there?)
                Last edited by jscottAT4; 07-12-2017, 02:29 PM.

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