Letter 1084

OSHA and pretreatment washer standards

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I would like to hear how others in the industry interpert the OSHA standards on pretreatment washers as to the confined space standard. It it classified as a permit required, or as a non permit required entry? What precautions are taken when you need to enter the washer systen during the course of the day. What documentation is required to satisfy OSHA?

Neal Pecha
Reltec Corp.

Unfortunately every inspector interprets the CFR "his/Her" way and there is not a whole lot of agreement. The safest thing that you can do is to follow the CFR on confined spaces to the complete total letter of the law, or you are at the mercy of the inspector's opinion. There is no logic to a lot of this, but the intent is employee safety. If there is any ultra remote way that an employee might possibly be injured by a sequence of nearly impossible happenings, you are still supposed to have forsaw that and provided training, warnings and Etc. Do not forget Lock Out / Tag Out in this training prior to entry.

Good Luck
Jim

James Watts - Fl

The biggest requirement is that the managers of the operation really believe that it is important to prepare for entry into confined spaces. Safety should be considered a cost of production and money should be budgeted to this area just like we budget money for pumps, cleaner chemicals, heat exchangers. If they believe this, they will make the time to schedule maintenance so that safety does not interfere with the production schedule. i.e., There will never be a time that someone feels forced to break safety rules to get a line back into production.

Tom Pullizzi Platronica.com Falls Township, PA

 

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